NRC Mulls Changes to Radiation Safety Requirements

The Nuclear Regulatory Commission will publish a proposed rule reconsidering certain radiation safety requirements on April 30, agency representatives said at a public meeting last week. The meeting discussed 28 total rules that are being considered or implemented in response to an executive order last year on “reforming the NRC.” The proposed rules will be open for comments, and the final rules will come in November, according to speakers at the meeting.

The NRC’s expected rule changes come after the Department of Energy eliminated the “as low as reasonably achievable” (ALARA) requirements from its regulations, sparking mixed reactions among Congress and nuclear experts. DOE regulations apply to its own reactors, as well as those run by contractors outside the national lab system, including those in the DOE Reactor Pilot Program, while the NRC regulates commercial reactors more broadly.

The executive order directs the NRC to “reconsider reliance on the linear no-threshold (LNT) model for radiation exposure and the ‘as low as reasonably achievable’ standard, which is predicated on LNT.” Under the LNT scientific model, there is no safe threshold of radiation exposure, and harm, specifically increased cancer risk, is assumed to be directly proportional to the amount of exposure.

The order adds that these models “lack sound scientific basis and produce irrational results, such as requiring that nuclear plants protect against radiation below naturally occurring levels.” It directs the NRC to consider adopting determinate radiation limits instead and consult with DOE, the Environmental Protection Agency, and the Department of Defense.

The proposal to eliminate ALARA also appears in the conservative policy document Project 2025, which was widely considered a blueprint for President Donald Trump’s second term.

The order did not direct any such changes at DOE, but Energy Secretary Chris Wright issued a memorandum in January that removes the ALARA principle from all DOE directives and regulations. The memorandum cites a July 2025 report from Idaho National Lab that recommends eliminating all ALARA requirements and limits below the whole-body dose limit of 5,000 millirem per year for workers. ALARA requirements at the NRC, for instance, include worker training in ALARA principles, implementing systems for tracking individual and collective dose trends, radiation-safety committee oversight for complex operations, and optimizing facility layout and equipment design, the report states.

In response to a question about how the NRC’s changes would compare to DOE’s, NRC Associate Director for Operations David Curtis said at last week’s meeting that DOE’s review of its regulations was “pretty independent” of the NRC’s. “I often like to think about the interaction that we have with other federal agencies [as] less about doing things exactly the same way and more about being harmonious… so that there’s a consistency and a logic to it,” he added.

DOE began removing ALARA from regulations as early as last fall, but reportedly only shared the changes with nuclear companies rather than making them public. The agency has since published the orders online, though an agency spokesperson said DOE is “still evaluating what specific changes to these standards are needed.”

“Previous reporting has grossly mischaracterized the Department’s intent. The new Nuclear Energy (NE) orders remove unnecessary administrative burdens that are redundant to other requirements, such as items that are covered by the U.S. Environmental Protection Agency. They do not loosen environmental, safety, or security regulations,” the DOE spokesperson added.

Multiple attendees at the NRC meeting requested that the NRC extend the 30-day comment period for the new rules or hold the associated public meetings at earlier dates.

Response from societies and Congress

Some nuclear groups have argued that the use of the ALARA principle should change because it has become equivalent to “as low as possible,” which they say significantly raises costs in order to minimize radiation to levels lower than necessary to protect human health.

According to the American Nuclear Society, “the NRC and other federal agencies should focus on applying the ‘as low as reasonably achievable’ principle in the manner it was originally intended. … ALARA is intended to be an optimization process in which the costs associated with any potential dose reduction are balanced against the benefits in a risk-informed decision-making process considering all appropriate factors. Unfortunately, current implementation of ALARA often results in a practice of dose minimization rather than a risk-informed optimization, which can lead to more harm than benefit.”

Others have criticized the current administration for seeking changes to LNT and ALARA, saying the changes are not scientifically driven. Edwin Lyman, director of nuclear power safety for the Union of Concerned Scientists, said that all major radiation protection organizations, including the International Commission on Radiological Protection, have “reaffirmed that the linear no-threshold model is the most appropriate for radiation protection.”

Lyman also criticized the “significant procedural irregularities” of the NRC’s rulemakings related to the nuclear executive orders, including the lack of a technical basis document, also called a regulatory basis document, which is a study laying out the evidence and analysis behind the changes. “It’s a violation of scientific integrity, but also it’s going to make them vulnerable to lawsuits. If they don’t document their changes sufficiently, that could be cited for being arbitrary and capricious,” Lyman added.

Similar disagreements exist among congressional Democrats. Rep. Jake Auchincloss (D-MA), a member of the House Energy and Commerce Committee, has expressed interest in revisiting ALARA, including through a new ADVANCE Act. The original ADVANCE Act, which became law in 2024, aimed to support nuclear energy, including by accelerating licensing of advanced nuclear reactor technologies.

Other Democrats remain opposed to changing ALARA. “Eliminating the ALARA rule would be reckless,” Rep. Diana DeGette (D-CO), ranking member of the House Energy and Commerce Subcommittee on Health, said in a statement to FYI. “I strongly oppose any effort, whether at DOE or NRC, to weaken standards in the name of speed. Cutting corners on nuclear safety puts people at risk,” she added.

Linear no-threshold

At a public NRC meeting in July last year, some presenters said that LNT is an inappropriate model to estimate health effects from low-level radiation exposure, while others argued that recent science continues to support LNT.

Current standards are based on evidence from victims of very high radiation doses, such as atomic bomb survivors, said Craig Little, federal agency liaison for the Health Physics Society. “We know we have good data down to 10 rem. We have almost no data below that,” he added. The NRC’s annual limit for a member of the public is only 1% of that level, at 100 millirem.

“We don’t have all that information yet, and so we don’t have a good model to use as a replacement for the linear no-threshold,” Little said.

Little said HPS supports continued funding for the Million Person Study, which collects dosimetric information for over a million workers in various fields and compares that data to the workers’ eventual causes of death. “It’s a small program, and it just cannot get consistently funded. I think if it had $5 or $10 million, it would be complete,” Little said.

“To really make it ‘science-based,’ you’re gonna have to put a lot more money into research to define what the effects are at low levels. Otherwise, it’s just a policy decision,” Little added.

Kathryn Higley, president of the National Council on Radiation Protection and Measurements, one of the sponsor organizations for the Million Person Study, said funding is the main limitation on the study. “If somebody came in and said, ‘Here’s a big bucket of money. Can you speed it up?’ The answer is, yes, we can. That’s the challenge, because we’re largely a volunteer organization, but there’s certain costs that we have to get covered in order to advance this work,” Higley said.

The study has also been sponsored by NASA, the EPA, the Centers for Disease Control and Prevention, and DOE, including through the agency’s low-dose radiation research program. Though Trump’s order focused on the NRC’s use of ALARA, each of these agencies has its own regulations related to ALARA, whether related to protecting medical patients or astronauts.

HPS has also been in favor of increased funding for radiobiology studies to understand what level of radiation leads to a “systemic problem” in the human body, Little said.