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

NEI's proposal to eliminate cumulative work-hour controls should not be adopted. While retaining the 16-hour in 24-hour and 72-hour in 7-day limits addresses extreme short-term schedules, it does not prevent fatigue from building over days and weeks. Fatigue develops through repeated long hours, limited recovery, night work, and sustained schedules, not from a single long shift. That is why cumulative work-hour controls remain an essential preventive safety measure. The weakness in NEI's proposal is clear with simple math. A worker could work six 12-hour shifts every week (72 hours), receive only one day off, and repeat that schedule for weeks while remaining fully compliant. Although the weekly limit is never exceeded, fatigue and sleep debt continue to accumulate because the rule measures only weekly exposure, not cumulative fatigue. The proposed 60-hour average over eight weeks has the same flaw. A worker could work 72 hours per week for six consecutive weeks (432 hours), followed by 24 hours per week for two weeks (48 hours), totaling 480 hours and meeting the proposed average. However, six weeks of maximum schedules have already occurred before the reduced workload. Recovery after the fact does not prevent the fatigue risk that already existed. Cumulative controls must identify and limit fatigue as it develops rather than relying on future time off to improve an average. The regulation can be simplified without removing these protections by: Retaining the 16-hour rolling 24-hour limit. Retaining the 72-hour rolling 7-day limit. Eliminating the 26-hour in 48-hour limit while maintaining minimum break requirements. Using one simple rolling cumulative work-hour limit. Replacing multiple minimum-days-off calculations with one consistent restorative recovery requirement. Simplifying outage and waiver requirements. Requiring recovery before transitioning from extended non-covered work into covered duties. Retaining simple protections against circadian fatigue when rotating between day and night schedules. NEI also argues that cumulative calculations create unnecessary administrative burden. However, much of that burden comes from business processes, software configurations, approval workflows, and conservative licensee interpretations, not from the NRC regulation itself. Modern scheduling systems can easily calculate rolling hours and recovery periods. The solution is to simplify implementation, standardize guidance, and reduce unnecessary administrative processes, not eliminate objective fatigue protections. NEI further argues that cumulative calculations cannot determine whether a worker is actually fatigued. That is true, but it misses the purpose of the regulation. Cumulative work-hour limits are not designed to diagnose fatigue, they are preventive controls based on scientific evidence that certain work schedules significantly increase fatigue risk. Radiation dose limits do not predict exactly when harm will occur, yet they prevent excessive exposure. Speed limits do not predict crashes, yet they reduce risk. Cumulative work-hour limits serve the same preventive purpose. Objective scheduling limits should complement, not be replaced by, self-declarations, supervisor observations, and behavioral observation programs. Workers often underestimate their own fatigue, and supervisors may not recognize declining alertness, judgment, communication, or situational awareness until performance has already degraded. Experience has also shown weaknesses in behavioral observation programs, including instances where routine supervisor reviews for fatigue were completed for workers who had not even reported to those supervisors for more than 30 days. More than 20 years of operating experience across the nuclear industry demonstrates that fatigue remains a real operational risk, particularly during outages where personnel routinely work maximum allowable hours and non-covered workers often work 18-hour days for weeks without restorative days off. These conditions have resulted in reduced alertness, slower decision-making, and communication difficulties while workers remain focused on meeting production goals. The NRC can modernize Subpart I by simplifying calculations and reducing unnecessary administrative burden while preserving objective cumulative fatigue protections. Eliminating cumulative work-hour controls would remove one of the program's most important preventive safeguards without providing an equivalent level of protection. The solution is to simplify the rule, not weaken it. The purpose of the 14300 effort is to reduce prescriptive requirements without compromising safety. Removing work hour controls would compromise safety and change the focus to meeting production goals and business costs over the safety of personnel and the public.