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

The proposal to dissolve work hour controls raises a valid point that the fatigue rule could be simpler. However, simplifying the process should not mean eliminating the work-hour protections that have been the foundation of nuclear fatigue management for more than a decade. The argument is based largely on reducing administrative effort, software costs, and business processes rather than showing that the work-hour limits no longer improve safety. In a high-risk industry like nuclear power, the goal is to prevent mistakes before they happen, not wait until there is evidence of an accident. The fact that there are few or no major events caused solely by exceeding work-hour limits is not proof that the controls are unnecessary. It is more likely evidence that the preventive controls are doing exactly what they were designed to do. Over more than 20 years of supporting nuclear plant operations, I have repeatedly observed that fatigue remains a real operational risk, particularly during refueling outages when production demands are at their highest. Covered workers are often scheduled to the maximum work-hour limits allowed by the regulation, while workers performing non-covered duties are frequently scheduled for 18-hour days for more than 30 consecutive days without a day off for restorative sleep. Although these workers may not be subject to the same regulatory limits, they often perform safety-important work that directly supports plant operations. During these extended work periods, supervisors and managers routinely observe workers showing signs that are consistent with fatigue. These include reduced alertness, slower decision-making, difficulty processing information, delayed responses, and challenges communicating clearly. In many cases, workers push through these conditions because they are committed to completing the work safely and on schedule. These observations align with decades of scientific research demonstrating that fatigue affects cognitive performance well before an individual recognizes the impairment. Decades of scientific research consistently show that fatigue affects alertness, judgment, decision-making, reaction time, and the ability to recognize errors. These effects occur even when workers believe they are performing normally. Fatigue is caused not only by long shifts, but also by cumulative work hours, insufficient recovery time, and working against the body's natural circadian rhythm. These risks do not disappear simply because the calculations become difficult. Technical advancements have actually made these calculations simpler to manage. If the current rule is too complex, the solution is to simplify how compliance is managed, not eliminate the protections themselves. A simpler, science-based rule that maintains reasonable limits on daily hours, weekly hours, and recovery time would reduce administrative burden while continuing to protect workers, the public, and nuclear safety. Eliminating preventive work-hour controls because pf a perception that they are difficult to administer places operational efficiency above the preventive safety principles and defense-in-depth philosophy that have guided the nuclear industry for decades. The question should not be whether the rule can be simplified, it should be whether any proposed changes continue to provide an equivalent level of protection against the well-established risks of fatigue. If they do not, then simplification comes at the expense of safety rather than in support of it.