The commenter argues that the Managing Fatigue rule (10 CFR 26 Subpart I) provides no measurable safety benefit and creates unnecessary complexity for nuclear licensees. They propose dissolving the rule, claiming that the current requirements are based on unproven theories and do not reflect actual safety risks in the nuclear industry.

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.