If she gets a faster reload, then it should be just enough to allow b33212 to get a safe reload against the entire cast and that's it. Anything more is unnecessary really.
So that can certainly be less than 60+, but 40 is more of a decrease than needed to achieve that goal.
b33212 already gives a safe reload against the vast majority of the cast, it's just that it's slightly less than enough to get a reload against certain characters like Scorpion. This wouldn't be too much of an issue, but when you take b33212 out of the picture, it's like she can't reload at all without getting punished. And b33212 is already a risky move to use, so it's not like it's a free, riskless refill. And she still doesn't get a refill off any of her overhead options, so she needs to work pretty hard to get the opponent to respect the overhead before opening them up with b33212.
But yeah. reload should be sliiiightly quicker. Just enough to make a reload after b33212 safe against the few character it already isn't safe against. Doesn't sound like too big an issue at first, but against those characters where she doesn't have that safe reload, it's "pick another variation or die" territory.
Then again, by virtue of the variation system, NRS may opt to let that continue to be the option for Sonya players.