Comment on FR Doc # 2026-12702, NRC-2025-1370-0006, from Anna Rucz

Comment on Proposed Rule – Docket ID NRC-2025-1370 Re: Modernization of NRC Materials Licensing Requirements I am submitting this comment to raise concerns regarding the proposed rule’s framing and substantive content, specifically as it relates to the balance between regulatory efficiency and the NRC’s core safety mission. 1. Absence of quantified safety impact analysis The summary explicitly characterizes the proposed changes as “deregulatory in nature,” including elimination of “unnecessary regulations” and modification of reporting/recordkeeping requirements. However, the docket materials reviewed do not appear to include a quantified risk assessment demonstrating that each eliminated requirement is genuinely non-safety-significant, as opposed to administratively burdensome for industry. A determination that a regulation is “unnecessary” should rest on documented risk analysis, not solely on licensee timeline or cost considerations tied to Executive Orders 14154, 14192, and 14294. 2. Streamlined Spent Fuel Reprocessing and Fuel Cycle Facility Licensing (Sections D–F) These sections warrant particular scrutiny. Spent fuel reprocessing and fuel cycle facilities carry proliferation-sensitive and long-tail environmental risk profiles that differ materially from reactor construction timelines. The rule should clarify what independent technical review, if any, remains mandatory under the streamlined pathway, and whether “Pilot Fuel Lines” (Section C) will be subject to the same materials control and accounting standards as fully licensed facilities. 3. Beneficiary analysis is one-sided The stated rationale — enabling “existing and certain new applicants to bring power to the grid” — centers exclusively on licensee and developer benefit (faster, cheaper licensing). The docket does not present a corresponding analysis of impact on public and worker safety margins, nor does it address how affected communities near licensed facilities were consulted in scoping this rule, consistent with NRC’s mission to protect public health and safety independent of industry timeline pressure. 4. Recommendation I request that the NRC supplement this rulemaking with: (a) a facility-type-specific risk assessment for each streamlined category, (b) clarification of what safety review steps are eliminated versus merely expedited, and (c) an affected-community impact statement separate from the industry-facing cost/timeline analysis already provided. Respectfully submitted for the record under Docket ID NRC-2025-1370.