The commenter supports the proposed rule regarding reprocessing facilities but expresses concern that the current language could be interpreted to grant the NRC authority to license utilization facilities under 10 CFR Part 70. They propose specific amendments to 10 CFR 70.2 and 10 CFR 70.1(g) to clarify that Part 70 is not intended for the licensing of utilization facilities.

The commenter suggests clarifying the language in 10 CFR 70.25 to better define "unsealed special nuclear material" by using terminology consistent with 10 CFR 70.32(c)(1). They argue this change will ensure that microreactor factories using TRISO fuel compacts are properly required to provide adequate financial assurance for decommissioning.

The commenter proposes specific amendments to the definitions of "uranium enrichment facility" and "uranium enrichment equipment" in 10 CFR 70.4. They argue these changes are necessary to resolve regulatory conflicts regarding laboratory-scale facilities and to ensure that component vendors are not unnecessarily burdened by licensing requirements for special nuclear material they do not possess.

The commenter supports the proposed rule but argues that it needs to explicitly clarify that "at-risk construction" does not waive compliance with other federal environmental statutes, such as the Endangered Species Act (ESA) and the National Historic Preservation Act (NHPA). They suggest adding clarifying provisions or providing implementation guidance to ensure that early construction activities do not interfere with the NRC's ability to fulfill its environmental and historic preservation obligations.

A professional nuclear engineer submits comments opposing the proposed rule, arguing that it relies on an incomplete evidentiary record and fails to adequately evaluate the risk-side consequences of proposed regulatory relaxations. The commenter specifically criticizes the self-certification pathways for physical security exemptions, the extension of unreviewed reporting windows for special nuclear material, and the lack of a reprocessing-specific decommissioning funding standard.

Anna Rucz, representing TechKonsulting and Rucz Aviation Consulting Group, opposes the proposed rule because it lacks a quantified risk assessment to justify the removal of regulations. She argues that the rule prioritizes industry timelines over public safety and requests more rigorous safety reviews and community impact statements.

The Tennessee Department of Environment and Conservation (TDEC) supports the proposed amendments to clarify physical protection regulations regarding large components as radioactive waste. They specifically recommend expanding the exemption to include components from fusion machines, citing similar security risks to those already addressed in the rule.

The commenter supports the NRC's move to formalize exemptions for large components and robust structures into the rule language. However, they suggest refining the criteria to ensure that mobile reactors or components are not exempt, regardless of their weight.