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.

The commenter opposes the proposed rule to automatically expand the list of eligible Substance Abuse Experts (SAEs) based on professional licensure. They argue that eligibility should instead be based on a competency-based framework that requires specialized education, training, and experience in substance use disorders and regulatory requirements.

An individual commenter opposes the proposed changes, arguing that they compromise public safety in favor of corporate profit. The commenter expresses concern that the changes violate safety culture mandates and could lead to industry destruction in the event of a reactor accident.

The commenter opposes the proposed changes to the access authorization program, specifically arguing against the removal of prescriptive identity verification requirements, the elimination of periodic credit history checks, and the extension of audit intervals. They argue that these changes weaken insider threat protections and reduce necessary oversight of nuclear power plant security.

The commenter opposes the proposal to eliminate cumulative work-hour controls, arguing that such controls are essential for preventing fatigue and ensuring worker safety. They suggest that the NRC should simplify the administrative burden of the regulations without removing objective protections that prevent excessive work schedules.

The commenter opposes the proposal to dissolve work hour controls, arguing that while the rule could be simplified, the protections are essential for nuclear safety. They highlight that fatigue remains a significant operational risk and that eliminating these controls prioritizes administrative efficiency over worker safety and the "defense-in-depth" philosophy.

The commenter supports the modernization of fitness-for-duty requirements but requests more rigorous, data-driven justifications for specific physical-security changes. They specifically ask for prior NRC approval for self-determined exemptions, published operating-experience data for reduced exercise frequencies, and a clearer account of how "reasonable assurance" will be audited.

The commenter opposes the proposed requirement to use NIST SP 800-171 as the cybersecurity baseline for Safeguards Information (SGI). They argue that SGI requires a risk-based approach commensurate with its high security impact, rather than a fixed minimum baseline designed for less sensitive Controlled Unclassified Information (CUI).