The hypothesis of a lunar cataclysmic cratering episode between 3.8 and 3.9 Gyr ago lacks proof. Its strongest form proposes no cratering before about 4.0 Gyr, followed by catastrophic formation of most lunar craters and basins in <200 Myr. The premise that "zero impact melts implies zero impacts" is disproved by data from asteroids, on which early collisions clearly occurred, but from which early impact melts are scarce. Plausible cataclysm models imply that any cataclysm should have affected the whole inner solar system, but among available lunar and asteroid impact melt and impact age resetting data, a narrow, strong 3.8-3.9 Gyr spike in ages is seen only in the region sampled by Apollo/Luna. Reported lunar meteorite data do not show the spike. Asteroid data show a broader, milder peak, spreading from about 4.2 to 3.5 Gyr. These data suggest either that the spike in Apollo impact melt ages is associated with unique lunar front side events, or that the lunar meteorites data represent different kinds of events than the Apollo/Luna data. Here, we develop an alternate "megaregolith evolution" hypothesis to explain these data. In this hypothesis, early impact melts are absent not because there were no impacts, but because the high rate of early impacts led to their pulverization. The model estimates survival halflives of most lunar impact melts prior to 4.1 Gyr at <100 Myr. After a certain time, T_(critical)～4.0 Gyr, impact melts began to survive to the present. The age distribution differences among impact melts and plutonic rocks are controlled by, and hold clues to, the history of regolith evolution and the relative depths of sequenstration of impact melts versus plutonic rocks, both among lunar and asteroidal samples. Both the "zero cratering, then cataclysm" hypothesis and the "megaregolith evolution" hypothesis require further testing, especially with lunar meteorite impact melt studies.
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