Comment on FR Doc # 2026-12702, NRC-2025-1370-0001, from Anonymous

I appreciate the opportunity to comment on this draft rule proposal. Overall, it is good to see that the NRC is placing the long-needed exemptions for large components and robust structures into the rule language instead of continuing to rely on enforcement guidance and interim positions that were never meant to be in place long-term. However, with the development of the proposed Part 57 that recently completed the comment period, another potential regulatory gap became apparent with the 37.11 exemptions. Specifically, the justification for the expansion of large components and addition of robust structures to the list of exemptions in 37.11 is predicated on the time and equipment needed to access or move the radiological material. This is a valid assumption for components in fixed locations. However, the development of Part 57 postulates a class of reactor or component that is mobile by design or implementation invalidating this base assumption. Therefore, it is suggested that the exemption criteria in 37.11 be revised to clarify that reactors or components that are mobile are not subject to the 37.11 exemptions regardless of overall weight. An additional definition of mobile may also need to be added to 37.5 to clarify applicability (e.g., limited or restricted mobility due to implementation method would not count as mobile).