Comment on FR Doc # 2026-08550, NRC-2025-0379-0011, from Tam Fortis Solutions, Inc.
Tam Fortis Solutions, Inc.SupportBusiness
Summary: Tam Fortis Solutions, a nuclear energy company, expresses strong support for the proposed 10 CFR Part 57 rulemaking, noting that their helicopter-portable microreactor aligns with the rule's risk profile and safety philosophy. They recommend that the final rule prioritize a physics-grounded assurance framework for autonomous operations, adopt a risk-informed approach to failures, and ensure technology-neutral guidance for passive, non-water-cooled designs.
Tam Fortis Solutions submits the attached comment in strong support of proposed 10 CFR Part 57. Tam Fortis is developing the first truly helicopter-portable microreactor, a sealed, factory-fuelled, autonomously operated unit for austere, unattended deployment that embodies the risk profile, passive safety, transportable form factor, and autonomous operating model Part 57 was written to accommodate. Our central recommendation is that the final rule assure autonomous operation against validated physics rather than opaque machine-learned proxies: validated physics decides, learned models only rank and accelerate which validated computations to run, and every consequential action is checked against hard physical limits by an independent verifier before actuation. Neither a proxy that replaces validated physics nor a general-purpose large language model should be relied upon in a safety-significant decision role, consistent with the Commission's October 2024 AI gap assessment. On Federal Register Notice Question 10-1, Tam Fortis answers yes, the NRC should allow remote and autonomous operation of plants demonstrating low consequences, provided the autonomous operation is demonstrated to produce results equivalent to or more conservative than a localized licensed operator, including under an assumed loss of connectivity to any central controlling AI source. On Question 11-1, a robust risk-informed approach should replace the single-failure criterion. The full comment is provided in the attached PDF.