More Radioactive Pollution is coming—Tell NRC: Protect BETTER

Radioactive Pollution will Increase if New Federal Rules are Adopted

YOUR COMMENTS NEEDED!

(08-08-2026) The US Nuclear Regulatory Commission (NRC) is planning changes to the national radiation rules, which will increase radioactive pollution, reducing protection for nuclear workers and for our public and environmental health. Research shows the need for tighter radiation regulation—not weaker.

Generational Radiation Impact Project (GRIP) has shown that the current regulations do not provide protection for those who need it most. [UNIDIR 2024]

Check out GRIP WEBSITE for lots more info on radiation impacts. Short talking points on this proposed rule change below.

Let’s oppose weakening and work together to strengthen radiation protection!

Comment period open now—closes August 31, 2026

A quick, clear and easy way to make a comment is on the Protect Better Campaign website. GRIP is one of the founding organizations of the COALITION TO STOP RADIOACTIVE POLLUTION. It has done a great job of simple, clear draft comments—and instructions how to submit.

Three ProtectBetter.org WEBINARS coming next three weeks:

Wednesday August 12, and 19, and 26 —

Speakers, Q+A, and support for putting iyour comments—NRC needs to know the WORLD IS WATCHING!

Webinar info will travel on email…or check www.protectbetter.org Soon!

See KEY POINTS below.

When you are ready, this link goes directly to where you can type in a comment, or upload documents if you want to participate at that level.

https://www.regulations.gov/commenton/NRC-2025-1140-0001

Note: the material you submit is all included in the public Docket. Do not include any information that you do not consider public.

There is no limit to the number of comments anyone can submit. Comments by groups, individuals, and ‘by anonymous’ are all accepted

We welcome and encourage techinical comments since they add to the resources in the Docket that future litigants can pull on to make a legal case to appeal the final rule. Nonetheless, general comments including your concerns about how nuclear industry already impacts your community, your family, you are vital.

THANK YOU FOR MAKING A LITTLE TIME TO ACT BEFORE THE DOCKET CLOSES ON AUGUST 31.

The final rule, which may be impacted by our comments is due at the end of December.

[Below Talking Points and further GRIP commentary]

Please ask others to participate—this rule change will impact everyone!

Visit the Protect Better Campaign site for a quick way to make your comment.

Key points:

The radiation limits for the public “look” the same, but NRC’s new rule would drop the provisions to reduce exposures “As Low As Reasonably Achievable” (ALARA) below the 100 millirem / year (air at fenceline) rule. Radioactive pollution will increase.
Every exposure to radiation is cumulative, and decades of research shows that every exposure is unsafe—with the potential for cancer or disruption of pregnancy.
NRC admits that without ALARA it is no longer regulating the low-end (below 100 millirems per year) of exposure;
There will be health impacts but NRC claims these are “unknown”—NRC is closing its eyes to studies of “legal” exposure levels that show increased illness in communities near NRC licensed nuclear operations, and similar sites worldwide.
For a discussion of why 100 millirems has NEVER been protective, see longer commentary below—NRC itself says that a 70 year lifetime exposure to 100 millirems results in 70 times higher cancer rates than the Superfund program under EPA.
AND NRC will allow any license holder to apply for an exemption from the annual limits for the public. The proposed rule gives no boundaries for amount of additional radiation or duration of the exemption.
Radioactive pollution allowed in liquid discharge to public waterways / aquatic environments will go from concentrations that NRC says will result in human exposures of 10 millirems a year to exposures of 25 millirems per year. These discharges include radioactivity that will persist in our environment for years to millennia.
Workers in a radioactive job licensed by the NRC (or a state surrogate agency) includie medical offices that use radioactive medication or sealed sources, purified uranium processing, nuclear power reactors, nuclear energy support services (laundries, repair shops, transport) are subject to exposure at work, and they are also members of the public and the points above apply to them.
At work, the annual exposure limit of 5 REMS (5,000 millirems) is no longer the maximum allowed. The discontinuation of the ALARA will allow the employer to expose workers up to the maximum radiation exposure limit each year, and if detectors show a workers’ exposure is below the maximum for the year, any remaining “unused” exposure can be added to future years—so its “Exposure with no remorse.”

Even though NRC is allowing licensed operations to their choice of dosimetry (model for radiation impact) NRC will continue to use Reference Man in application of its newly “modernized” rule. Use of Reference Man means that all children, and all women will be impacted more than how the various aspects of the rule assume.

THANK YOU FOR YOUR COMMITMENT TO BETTER PROTECTION!

Submit your comments here:

https://www.regulations.gov/commenton/NRC-2025-1140-0001

First there is a window where you can type directly for shorter comments. Below that is a way to upload comments in PDF. You can also attach supporting documents. We recommend actually adding documents where you can—links are not likely to be considered by NRC as part of your submission.

Questions? Feel free to reach out to Mary Olson [gripcom2025 @ gmail.com] or call 828-242-5621. Please no texts.

Following is material we sent out previously:

Comment period on the NRC proposed rule is open now—closing on August 31, 2026

Read on if you want the blow-by-blows of NRC proposed reduction in protection.

This link is where you can type in or upload your comments 24/7 here:

https://www.regulations.gov/commenton/NRC-2025-1140-0001

Reminder: There is no limit as to how many comments you / your organization can submit. You may also comment anonymously. If you prefer to comment anonymously, do not include any identification in the body of your comment and follow the instructions for anonymous submission on the first link below.

Simple comments are fine—and we also welcome and encourage anyone adding science to the docket. As the process goes forward, some organizations may take legal action to challenge the final rule. When that day comes EVERYTHING in the comment period docekt (no matter who put it there) is available for the litigants to build their case. THANK YOU!

If you want to dig in, the proposed rule is on this link:

https://www.govinfo.gov/content/pkg/FR-2026-07-15/pdf/2026-14208.pdf

In our view, you can comment without reading it. The proposed rule is long and it includes edits to the existing regulations, so it may be confusing. We offer an outline of the changes to the rule, and some talking points below, as well as links to short published summaries***.

Who is impacted by NRC’s proposed changes?

EVERYONE! The rule drops and bends other key radiation protections for:

The general public

Nuclear workers—at nuclear power reactors and all fuel cycle facilities
Nuclear medical workers*
Cancer patient caregivers and family members
Aquatic ecosystems and drinking water

Below are some points—please add your own, in your own voice!

We will be following up with a list of science citations—and you can check Cindy Folker’s from Beyond Nuclear here.

What are the key changes for public protection in the NRC proposal to change radiation regulations?

Although the NRC claims to retain the same levels of public protection—this is false because:

o While the NRC retains the Linear No Threshold (LNT) model to describe radiation impact which says: there is no “safe” level of exposure, there is the potential for harm from radiation all the way down to zero exposure—it also proposes to eliminate the “As Low as Reasonably Achievable” (ALARA) policy from its rules.

o ALARA was a directive to drive radiation exposures lower than the exposure limits in the regulations.

o ALARA was a way to move towards the “no safe exposure” part of the LNT Model, though the inclusion of “reasonable cost” undercut this to some degree.

@ This means that more radioactive pollution will be released into air, water, and ecosystems.

@ Tell the NRC that there is no safe level of exposure to radiation and no amount of radioactive pollution that is acceptable.

@ Protection of Public Health and Safety are NRC’s responsibility under the Atomic Energy Act—and they must uphold this responsibility.

The NRC retains the overall “fence line” exposure limit of 100 millirems (mrem) per year to the public, however:

o This 100 mrem/year routine level of radiation exposure, according to NRC itself, causes 3.5 fatal cancers per 1000** people exposed over a lifetime (which is the same as 1 in 286 people dying from NRC allowable levels of radiation exposure). **

o This 1 in 286 is hardly the 1 in a million promised by society when dangerous technologies were introduced.

o And NRC delivers much more disease and death than the worst Superfund sites regulated by the EPA where the risk of cancer is 1 in 10,000.

o In general, the EPA regulates toxic chemicals at 1 cancer per 100,000. Again, NRC existing regulations are not protective.

o 100 mrem per year is “perfect functioning,” meaning that there are no bad leaks, no accidents, and it is assessed on the Reference Man model, so it does not reflect the disproportionate harm to children or women.

o The 100 mrem is tied to each license, so, in fact, there is no total exposure limit—as we now know from the Chan School of Public Health, many people are exposed to and impacted by the emissions of more than one reactor.

@ TELL NRC NO “BAG-LIMIT!” A deathrate of 1 in 286 due to one nuclear industry license is a lie—it’s higher for females, higher for children, and many people get multiple exposures, and their risk is multiplied by multiple sources of exposure.

@ Let’s ask for a risk level of 1 in 100,000 cancer incidence—which would mean the nuclear industry could only cause an exposure well below 1 mrem per year. This is no less reasonable than asking us to accept a deathrate due to nuclear industry activities of 1 in 286.

The NRC more than doubles the allowable exposure from the discharge of radioactive effluents to water and sewage—from 10 mrem per year to 25 mrem per year.

@ Do not make all the waters near nuclear reactors and nuclear fuel cycle sites as dirty as the waters around Fukushima in Japan. A catastrophic meltdown of three reactors in Japan should not deliver a blank check for dirty discharges here.

The NRC is allowing unreported radioactive discharges. If the effluents from a nuclear facility will deliver exposures below 25 mrem / year, no public reporting is required.

@ Do not let data on radioactive water pollution become inaccessible to site neighbors and those downstream of nuclear sites. NRC should require sampling and data reporting for every license.

@ Today, the technology exists for real-time monitoring and reporting of radioactive discharges to both air and water. This real-time monitoring should be available to anyone, via the internet.

@ When it comes to loading our environment with persistent radioactive pollution that will linger in air, water and food production areas for generations, let’s not be skimpy with data collection. Tell NRC in addition to real-time monitoring, licensess should also report more precise information generated by laboratory analysis that is currently reported on a quarterly basis—and should continue.

Finally, the industry may be completely deregulated in some times and places since:

The new proposed rule invites any nuclear license holder to request an exemption from the 100 mrem / year public exposure limit allowing them to expose the public at an undesignated level higher than 100 mrem / year.

o The NRC says approval of exemptions are more likely for operations located in low-population areas. This makes sense, unless you live in a rural area—which are also food production areas.

o The NRC does not include an exposure cap on the exemption, or specify how long the exemption might last.

o The existing regulation limits any special exemption to no more than 500 mrem/ year total exposure to the public and requires a specified (short) period of time. The new proposal has no exemption cap or expression of a limit on time.

o There are no provisions for reporting exemptions to the public in NRC’s changes to the current regulations.

o The NRC is subject to The Hobbs act because its activities can result in “takings” from the public.

@ Under Hobbs, the public has a right to judicial review—let’s ask for a judge (not an NRC judge) to review any proposed exemption from the already unacceptable level of radiation induced infertility, illness, and death.

@ Tell the NRC that an unlimited exemption on exposure for an unlimited time is deregulation that gives a lie to the existence of the US NRC. Tell them that complete shutdown and cleanup of all licensed sites is the only way to hang up the job of a nuclear industry regulator.

NRC is gutting protection of nuclear workers

Nuclear workers include not only nuclear power reactor sites, but also in situ leach uranium mines, uranium processing, nuclear fuel production, any (future) reprocessing, nuclear support services including nuclear laundries, decontamination services, decommissioning, transport, waste handling, and waste disposal sites.

Medical workers are included in these regulations if they work at facilities that handle special nuclear material for diagnosis and treatment.

The NRC exposure limit for workers remains 5 Rems per year—however, as stated, NRC has deleted the As Low as Reasonably Achievable (ALARA) policy. For workers, ALARA was a set of practices, policies, and for most nuclear employers a commitment NOT to expose workers needlessly. Lowering on-site exposures often translated into lower exposures off-site as well.
And, at the same time, the NRC is instituting a new, complicated opportunity for employers to expose workers in excess of the annual limits through Planned occupational dose limit extensions under § 20.1205 [see page 39 of the proposed rule].
Planned occupational dose limit extension would allow the employer to assign tasks resulting in a dose limit as high as a total of 25 Rems (average) over a 5-year period—specified as the previous 4 years and the current year. This means that the NRC is now giving employers the opposite of ALARA—it is mandating “Expose to the Max.”

@ Thankfully, the NRC exempts declared pregnancy and minor children from this program.

@ GRIP friend Dr. David Richardson has calculated*** that this exposure rate will raise their lifetime cancer risk by 20 percent if workers actually received that dose annually, according to the linear model.

@ Tell the NRC this is an unacceptable outcome of employment—that they should be ashamed of participating in allowing industrial operations to take this level of human life.

Caregivers beware

For anyone who is giving care to a family member or client who is receiving medical care that includes administration of radioactive materials, the NRC has a new plan:

Family caregivers may be exposed to 5 times the annual public exposure limit (or 500 millirems) per administration regime. This is in addition to the 100 mrem a year from ongoing industry activities.

Caregivers in the healthcare system may be exposed to as much as 2 Rems per administration regimen, over and above the public limit of 100 mrem / year. No cap is given as to how many regimens may impact one individual in the course of a year.

o Tell the NRC to require medical facilities to provide caregivers with personal protective equipment and other means to reduce the radiation exposure from care for others.

o Tell the NRC to impose time limits and a total cap per year to reduce caregiver’s exposure.

o Mandate virtual visits for family members.

o Tell the NRC not to make cancer treatment a death sentence for other family members.

If you are ready to write your own more detailed comments, you can submit them here:

https://www.regulations.gov/commenton/NRC-2025-1140-0001

First there is a window where you can type directly, and below that is a place to upload longer comments in file form. You can also attach supporting documents.

The following is additional information—likely more than you need. Feel free to ignore, or graze…

From the text:

*NRC regulations apply to medical offices if they use, possess, or administer byproduct radioactive materials (e.g., for nuclear medicine, PET scans, or radiopharmaceutical therapies).

** In 1990 the NRC published its Expanded BRC Policy Statement for a program that would have deregulated about 1/3 of the low-level radioactive waste from NRC licensees. In the publication of this Policy Statement, NRC included a risk analysis of the harm from radiation (GRIP is not endorsing this risk analysis, merely reporting one of the few—perhaps the only time that NRC has admitted the level of harm radiation causes.)

The citation is: Federal Register, Vol 55, No 128, July 3, 1990. Notices: US Nuclear Regulatory Commission, Below Regulatory Concern Policy Statement, pages 27522—27537.

This link is where you can type in or upload your comments 24/7 here: https://www.regulations.gov/commenton/NRC-2025-1140-0001

Citations from the text:

*** See quote from Dr David Richardson in the Scientific American rundown on the new NRC radiation proposal: https://www.scientificamerican.com/article/how-could-laxer-radiation-exposure-rules-affect-public-health/;

Two relatively short articles on the NRC proposed changes:

https://www.scientificamerican.com/article/weaker-radiation-limits-will-not-help-nuclear-energy/; https://www.eenews.net/articles/nrc-considers-eliminating-half-century-old-radiation-standard/

And our Friends at Physicians for Social Responsibility offered this great Webinar

Watch a short Webinar from the new Coalition to Stop Radioactive Pollution.

If you want to chat about any of this, drop me a line.

Mary Olson, gripcom2025@gmail.com — we can set up a call, or exchange on email.

THANK YOU!