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

Comments on DG-5088 Jully 27, 2026 1a.Applicable regulation cited as 10 CFR 50.34(c), however that specific regulation only applies to “…production or utilization facility that will be subject to §§ 73.50 and 73.60 of this chapter must include a physical security plan.” Most NPUF’s are not subject to §§ 73.50 AND 73.60, I’m not sure if any licensee is subject to both regulations. Also, any NPUF that is less than 2 MW(t) is not subject to 73.60. 1b.Suggestion clarification that 10 CFR 50.34(c) be corrected to state §§ 73.50 OR 73.60 and drop the “and” in this sentence. 2a.Add to the related guidance section a reference to “DANU-ISG-2026-01” (SGI) 2b.DG-5088 seems to have a few differences from “DANU-ISG-2026-01”, need to clarify which guidance should be used by NPUF licensees. 3a.The original Table 1 from the 1983 RG is missing from the new version. 3b.Recommend updating Table 1 to include consideration of material attractiveness. Using a table makes applicability much easier to understand and was shared by the NRC at various public presentations in the past. 4a.page 10, performance Objectives - Establishing 2 hours as the definition of prompt for prompt detection will lead to inadequate protection. It will also lead to confusion for the protection at a NPUF, since those licensees were all issued post-9/11 additional security measure that require detection time be much sooner than 2 hours. New NPUF licensees are advised to align with guidance given to existing NPUF’s (reference DANU-ISG-2026-01 ML26140A323, non-public version found at ML25189A443) 4b.Did the NRC staff review the guidance from the NRC to NPUF’s to verify this guidance (DG-5088) aligns with DANU-ISG-2026-01? How can licensees determine which guidance should be applied?