Strange Mood Engineering, a vendor providing a collaborative design platform for the nuclear supply chain, supports the proposed modernization of electronic processing for Safeguards Information. They recommend moving toward a performance-based security standard rather than a topology-specific one and request clarifications on third-party managed services and the scope of AI-driven processing.

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 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 proposes several specific regulatory changes to fatigue management and outage criteria, including increasing work limits during sequestration events and removing redundant annual reporting requirements. They argue these changes would reduce administrative burdens for both licensees and the NRC while maintaining safety through existing oversight processes.

The commenter supports the NRC's initiative to modernize and review its regulations to improve efficiency and accommodate new technologies. They emphasize that while redundant requirements should be removed, the agency must maintain its commitment to rigorous, science-based safety and security standards.

The commenter opposes the proposed 73.55(a)(1)(i) and the performance objective of 73.55(b)(3) because they argue the 25-rem threshold is too high and could allow facilities to bypass physical security requirements for radiological sabotage. They request that the NRC require protection of engineered safety features and provide technical analyses justifying the shift in performance objectives.

The commenter advocates for the NRC to replace prescriptive testing periodicities with a risk-informed, performance-based approach. They argue that allowing licensees to establish testing frequencies based on equipment performance history and reliability data reduces administrative burden and improves security effectiveness.

The commenter argues that the NRC should remove prescriptive timeline calculations from regulations and instead rely on performance-based validation through force-on-force exercises and drills. They contend that mathematical models are merely predictions, whereas actual performance testing provides a more realistic and less redundant measure of security effectiveness.

The commenter argues that the NRC should eliminate prescriptive criteria for credited operator actions in DG-5093 because these factors are already evaluated through performance-based drills and exercises. They contend that the current requirements create unnecessary administrative burden and redundancy without providing additional security assurance.