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 opposes the proposed change to the general performance objective of 73.55(b)(3), arguing that the 25 REM dose reference value is excessively high and lacks international standards. They contend that the new rule would allow sites to lack protection against deliberate events that exceed the severity of the Fukushima-Daiichi accident, potentially shattering public confidence in nuclear safety.