Comment on FR Doc # 2026-12989, NRC-2025-1303-0001, from Anonymous

Recommendation: Revise DG-5093 (RG 5.75 Rev 2) Section 5.6.2 NRC should eliminate the prescriptive criteria associated with credited operator actions because the effectiveness, feasibility, and reliability of those actions are already evaluated through performance-based drills, exercises, target set analyses, and inspection activities. Operator actions credited within a protective strategy are performed by trained and qualified operators operating under approved plant procedures. The current requirements in items (a) through (f) effectively duplicate evaluations that are already performed during target set development, validation exercises, force-on-force activities, operator training, licensed operator requalification, and emergency preparedness performance demonstrations. The additional administrative requirement to separately demonstrate that sufficient time exists, environmental conditions permit access, adversary interference is precluded, equipment is available, procedures are approved, and training is maintained does not provide meaningful additional assurance beyond what is already demonstrated through performance testing and operational oversight. A performance-based regulatory framework should focus on whether the operator actions can be successfully executed during realistic scenarios rather than requiring prescriptive documentation of each individual criterion. If an operator action is incorporated into the plant's defensive strategy and is successfully demonstrated during drills, exercises, or other validated performance activities, that should provide sufficient evidence that the action is credible and achievable. Furthermore, the current criteria may unnecessarily limit innovation and flexibility in protective strategy development. Licensees continually evaluate plant response capabilities, equipment availability, operator proficiency, and procedural effectiveness through established corrective action, training, and operational assessment programs. These programs identify and address deficiencies more effectively than static administrative checks. The proposed criteria also create redundancy because: •Time availability is evaluated during target set analysis, tactical assessments, and exercise performance. •Environmental accessibility is assessed as part of plant design, operating procedures, and scenario validation. •Adversary interference considerations are inherent in target set analysis and force-on-force evaluations. •Equipment availability is governed by maintenance, surveillance, operability, and configuration control programs. •Approved procedures are already required under plant operational controls. •Training and qualification requirements are maintained through licensed operator and accredited training programs. As a result, these criteria do not independently enhance security effectiveness but instead add administrative burden to requirements already evaluated through multiple existing performance and oversight programs. A more risk-informed and performance-based approach would allow credit for qualified operator actions that are incorporated into the approved protective strategy and successfully demonstrated through drills, exercises, or other validated performance evaluations. This approach would maintain security effectiveness while reducing unnecessary regulatory burden and better align with the objective of focusing on actual performance rather than prescriptive process verification.