To:
Secretary, U.S. Nuclear Regulatory Commission (submit via www.regulations.gov, Docket ID NRC-2025-1140)
Subject: [YOUR NAME] Public Comment on NRC Proposed Radiation Protection Rule Changes (Docket NRC-2025-1140; RIN 3150-AL47)
As a resident living near the Seabrook Station nuclear reactor, I am a stakeholder with a vested interest in the Nuclear Regulatory Commission's (NRC) proposed rule, “Reforming and Modernizing the NRC's Radiation Protection Framework” (91 FR 43456), published July 15, 2026. I oppose this rule as currently proposed, because it would reduce assurance of safety for members of the public like me who live near a nuclear reactor.
The proposed rule would eliminate the term “ALARA” — As Low As Reasonably Achievable — from the NRC's regulations entirely. ALARA has long required licensees to keep radiation exposure as low as reasonably achievable, not just below a legal limit. In its place, the NRC would substitute a system of fixed numeric thresholds, largely left to future guidance and that only trigger additional protective measures after the public has been excessively exposed. This is a significant step back from a standard that pushes exposure down at every opportunity, to one that permits exposure to rise toward the maximum before more protection is required.
The proposed rule would also let workers exceed their normal annual radiation dose limit as long as exposure is averaged over multiple years. It would also reduce how often overexposures and monitoring results must be reported, and would give licensees more flexibility on radioactive effluent releases into the environment. Notably, the NRC's own analysis projects this rule would save industry and regulators millions of dollars per year — with no corresponding, quantified health and safety impact for people living near reactors.
Most concerning to me is a change to how overexposures to the public get reported. Today, if a licensee exceeds the public dose limit of 100 mrem in a year, that is required to be reported. Under this proposal, reporting would instead be based on a rolling 5-year average, meaning a report would only be required if the total dose over the current year and the prior four years exceeds 500 mrem. In practice, this means a single year in which the public dose limit is significantly exceeded may not have to be reported to the NRC at all, as long as it is offset by lower-dose years elsewhere in that five-year window. Neighbors of a nuclear plant deserve to know, in real time, when a legal dose limit protecting them has been exceeded — not years later, and not only if a multi-year average happens to stay under the line.
I understand the NRC reviewed and rejected a nearly identical set of changes in 2021, when it concluded that “the LNT model continues to provide a sound regulatory basis for minimizing the risk” of unnecessary radiation exposure (86 FR 45923, 2021). The current proposal does not identify any new science that overturns that finding. The Commission's own preamble to this rule acknowledges that no better model than LNT exists today.
Human health and safety must be the priority, ahead of corporate cost savings, political pressure, or other external factors seeking to distort known truths about radiation safety. I urge the NRC to withdraw or substantially revise this proposal and to retain ALARA as a binding, codified requirement rather than replacing it with guidance-level thresholds.
Thank you,
[NAME]
[CITY/TOWN, STATE]
To: Secretary, U.S. Nuclear Regulatory Commission (submit via www.regulations.gov, Docket ID NRC-2025-1140)
Subject: [YOUR NAME] Public Comment on NRC Proposed Radiation Protection Rule Changes (Docket NRC-2025-1140; RIN 3150-AL47)
As a resident living near the Seabrook Station nuclear reactor, I am a stakeholder with a vested interest in the Nuclear Regulatory Commission's (NRC) proposed rule, “Reforming and Modernizing the NRC's Radiation Protection Framework” (91 FR 43456), published July 15, 2026. I oppose this rule as currently proposed, because it would reduce assurance of safety for members of the public like me who live near a nuclear reactor.
The proposed rule would eliminate the term “ALARA” — As Low As Reasonably Achievable — from the NRC's regulations entirely. ALARA has long required licensees to keep radiation exposure as low as reasonably achievable, not just below a legal limit. In its place, the NRC would substitute a system of fixed numeric thresholds, largely left to future guidance and that only trigger additional protective measures after the public has been excessively exposed. This is a significant step back from a standard that pushes exposure down at every opportunity, to one that permits exposure to rise toward the maximum before more protection is required.
The proposed rule would also let workers exceed their normal annual radiation dose limit as long as exposure is averaged over multiple years. It would also reduce how often overexposures and monitoring results must be reported, and would give licensees more flexibility on radioactive effluent releases into the environment. Notably, the NRC's own analysis projects this rule would save industry and regulators millions of dollars per year — with no corresponding, quantified health and safety impact for people living near reactors.
Most concerning to me is a change to how overexposures to the public get reported. Today, if a licensee exceeds the public dose limit of 100 mrem in a year, that is required to be reported. Under this proposal, reporting would instead be based on a rolling 5-year average, meaning a report would only be required if the total dose over the current year and the prior four years exceeds 500 mrem. In practice, this means a single year in which the public dose limit is significantly exceeded may not have to be reported to the NRC at all, as long as it is offset by lower-dose years elsewhere in that five-year window. Neighbors of a nuclear plant deserve to know, in real time, when a legal dose limit protecting them has been exceeded — not years later, and not only if a multi-year average happens to stay under the line.
I understand the NRC reviewed and rejected a nearly identical set of changes in 2021, when it concluded that “the LNT model continues to provide a sound regulatory basis for minimizing the risk” of unnecessary radiation exposure (86 FR 45923, 2021). The current proposal does not identify any new science that overturns that finding. The Commission's own preamble to this rule acknowledges that no better model than LNT exists today.
Human health and safety must be the priority, ahead of corporate cost savings, political pressure, or other external factors seeking to distort known truths about radiation safety. I urge the NRC to withdraw or substantially revise this proposal and to retain ALARA as a binding, codified requirement rather than replacing it with guidance-level thresholds.
Thank you,
[NAME]
[CITY/TOWN, STATE]