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

In this rulemaking, the NRC does not adequately support the change of the general performance objective of 73.55(b)(3) form preventing significant core damage and spent fuel sabotage to preventing a radiological release in excess of the dose reference values of 25 REM in a 2 hour period. There is no national or international standard that states that 25 REM exposure to a member of the public is an acceptable dose consequence. In fact both the NRC and international standards set 0.1 REM in a full year as the acceptable dose consequence to the public. Additionally, the change to 73.55(a)(1)(i) to exempt most security requirements from licensees that can analyze a dose consequence from a design basis threat attack to less than 25 REM presents a situation where a site would not need to provide protection against a deliberate event that would exceed the Fukushima-Daiichi accident by 25 times. Specifically, per the Congressional Research Service report on the event, dose rates at the site boundary at Fukushima-Daiichi reached 1 REM despite the extensive and significant levels of offsite contamination. The acceptance of the 25 REM dose reference value as the security bounding condition establishes an NRC position that a deliberate event that exceeds the most significant radiological event outside of the Chernobyl accident would not need to be prevented. Public confidence in the NRC is critical to the acceptance of new nuclear construction and application as well as the continued utilization of existing nuclear assets. Public confidence will be shattered once the implications of this rule change are more broadly realized and the resultant impact on the nuclear industry will be devastating. As a believer in the utility of this technology, I implore you to establish a security bounding criteria that is based on solid logic, real world events, and actual onsite and offsite consequences.