The Nuclear Regulatory Commission (NRC) has proposed a sweeping rewrite of federal radiation-protection regulations. The proposal, titled “Reforming and Modernizing the NRC’s Radiation Protection Framework,” would eliminate the use of ALARA throughout NRC regulations and guidance.
The formal public-comment period closes on August 31, 2026. However, members of the public may still attempt to submit late comments. Late comments are not guaranteed consideration, so anyone wishing to comment should do so as soon as possible. You can also read Tri-Valley CAREs’ detailed organizational comment opposing the proposal here.
Tri-Valley CAREs and our colleagues at the Committee to Bridge the Gap also reached out to the California Attorney General’s Office requesting that they submit comments opposing the NRC rule change. We were then pleased to see that they joined with 10 other state Attorney General offices in submitting a joint comment in opposition.
ALARA means keeping radiation exposure “as low as reasonably achievable.” It recognizes that meeting a legal dose limit is not the same as preventing unnecessary exposure. Under ALARA, nuclear facilities must consider reasonable ways to reduce radiation through shielding, safer procedures, monitoring, worker training, equipment improvements and contamination controls.
What is the NRC proposing?
The NRC would replace ALARA with a “graded approach to dose management” focused primarily on ensuring that regulatory dose limits are not exceeded. Among other changes, the proposal would:
- Remove ALARA from NRC regulations and guidance.
- Allow workers, under certain conditions, to receive more than the annual occupational dose limit by using “unused” doses from the previous five years.
- Allow licensees to request higher radiation dose limits for members of the public, including in some areas outside facility boundaries.
- Eliminate the existing public protection of no more than two millirem in any one hour in an unrestricted area
- Allow cost benefit calculations to determine whether certain exposure-reduction or corrective measures are “justified”
The “graded approach” would work like a warning system with several levels. As a worker’s or community member’s expected radiation dose rises, a nuclear facility would have to take stronger safety steps, such as providing training or monitoring exposure. At lower dose levels, facilities could decide that additional protections are unnecessary or cost too much. Our concern is that this could turn the legal limit into a target instead of a last-resort.
The NRC itself acknowledges that there is no scientific consensus establishing a threshold below which radiation cannot cause cancer or other stochastic health effects. That uncertainty is a reason for precaution and not deregulation.
Why does this matter to Livermore?
Lawrence Livermore National Laboratory is regulated by the Department of Energy and National Nuclear Security Administration, not by NRC when it comes to radiation safety. This proposal would therefore not directly rewrite most of the Lab’s radiation-protection requirements.
But the NRC is not acting alone. In January 2026, Energy Secretary Chris Wright approved a plan to eliminate ALARA from DOE directives and regulations. The Defense Nuclear Facilities Safety Board has since described DOE’s action as involving “potential revisions” to 10 CFR Part 835, the federal regulation that protects DOE workers from radiation.
DOE has not yet finished removing ALARA from that regulation. DOE’s own website still says that under 10 CFR Part 835, radiation doses “are required to be ALARA” and must stay below the legal dose limits. DOE also says the requirements of Part 835 are matters of law.
This means two major federal agencies are now moving toward weaker use of ALARA: DOE, which oversees nuclear weapons sites like Livermore Lab, and the NRC, which regulates civilian nuclear facilities.
Livermore’s experience shows why these regulation changes are inadequate. In October 2024, a valve misalignment at LLNL’s Building 298 caused an unplanned release of 35.6 curies of tritium. Although the release was below EPA’s 100-curie reporting threshold, the Lab subsequently implemented new administrative and engineering controls. “Below the limit” should never end the inquiry. The question must also be: Could this exposure have been prevented? Read LLNL’s report on the release.
The financial savings from weaker protections would accrue to institutions, while the risks would be borne by workers, communities, vulnerable populations and future generations. Avoided exposure should not become a budget item that facilities can choose to spend at their discretion.
When are comments due?
Comments must be submitted by August 31, 2026, at 11:59 p.m. Eastern Time or 8:59 p.m. Pacific Time.
The docket number is NRC-2025-1140.
If the online form no longer accepts comments, contact the NRC staff member listed for this rulemaking: Caylee Kenny at Caylee.Kenny@nrc.gov or 301-415-7150, and ask how to submit a late comment for inclusion in the docket.
How you can comment
A good place to begin is by visiting Protect Better’s NRC comment page. Protect Better was created by advocates working to protect the ALARA standard and it provides a plain language explanation of the proposal, suggested talking points, comment-writing guidance and links to submit your comment.
Then:
- Open the NRC’s official public-comment form.
- Type your comment into the form or upload it as a document.
- Introduce yourself and explain why radiation protection matters to you. You do not need to be a scientist or technical expert to make public comments.
- Clearly state that you oppose proposed rule NRC-2025-1140.
- Ask the NRC to retain ALARA and reject provisions allowing higher worker and public exposures.
- Preview your comment, submit it and save the confirmation or tracking number.
Comments become public records and anonymous comments are permitted.
If the online form is closed, contact NRC staff member Caylee Kenny at Caylee.Kenny@nrc.gov or 301-415-7150 for alternate submission instructions.
A short, personal and specific comment can be effective. Explain how you, your family, your workplace or your community could be affected. Tri-Valley CAREs will also submit a detailed organizational comment opposing the rollback of ALARA and addressing its implications for workers, communities near nuclear facilities, Lawrence Livermore Lab and the wider nuclear weapons complex.
Resources
- Protect Better: explanation, talking points and commenting resources
- Submit your comment directly to the NRC
- View the docket and submitted comments
- Read the complete proposed rule
- Regulations.gov guidance for writing an effective comment
Please submit your comment before August 31 and tell the NRC: Keep radiation exposure as low as reasonably achievable.
Find our community presentation on the rule-making change at NRC here.
Tri-Valley CAREs has submitted a detailed organizational comment opposing the rollback of ALARA and addressing the consequences for nuclear workers, surrounding communities, vulnerable populations, Lawrence Livermore National Laboratory and the broader nuclear weapons complex. Read our complete comment here.
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