Comment on FR Doc # 2026-12989, NRC-2025-1303-0001, from PGE Trojan ISFSI
PGE Trojan ISFSISupportOther
Summary: Trojan identifies inconsistencies in the proposed rulemaking regarding standalone ISFSI facilities, noting that current regulations (10 CFR 73.51) lack the flexibility for modern security technologies found in reactor site regulations. They argue that the rule should be updated to allow for risk-informed, performance-based security strategies and to resolve discrepancies in alert reporting requirements.
Trojan ISFSI Comments
NUCLEAR REGULATORY COMMISSION
10 CFR Parts 26, 50, 52, 72, 73, and 95
[NRC-2025-1303; PRM-26-4; PRM-26-7; PRM-26-8; NRC-2012-0079]
RIN 3150-AL53
Modernizing Security Requirements
Trojan identifies potential inconsistency in the proposed changes as they relate to standalone ISFSI facilities.
Specific ISFSI facilities are regulated under 10 CFR 73.51 and continue to operate under established Interim Compensatory Measures (ICMs). These security requirements have remained largely unchanged for many years and do not currently provide the same flexibility for the use of modern security technologies that are available under 10 CFR 73.55 for operating reactor sites.
The proposed rulemaking appropriately recognizes technological advancements and risk-informed approaches for power reactor security programs. However, similar considerations do not appear to be reflected in 10 CFR 73.51. As a result, ISFSI sites may be limited in their ability to implement newer technologies, alternative security strategies, or performance-based approaches that could provide equivalent or enhanced security effectiveness while reducing unnecessary regulatory burden.
10 CFR Part 72.75(a) for an alert includes contingency events and reporting within 1-hour. In comparison to 73.1200 which includes potential hostile actions or acts of sabotage against a facility states alerts within 15-min. This discrepancy creates confusion and unnecessary burden on ISFSI’s that have minimal staffing.