Final group and AG Comments on Exemption from Rulemaking NRC-2025-1568
Dear All who signed on to the Comments on Exemptions from Licensing
THANK YOU
The final signed submission is attached. (Two more groups were added, one in my additional comments)
The final comments are slightly changed from what everyone signed because we found out at the last minute that the exemptions would be many times higher than we originally calculated (500 millirem/year not 10 millirem/year) so I made adjustments throughout the comments to correct this. Our position is still NO millirems per year exemptions at all—keep manmade radioactive materials regulated and licensed. But this increase PER exemption (with no limit on the number of exemptions) is 5 or more times higher than the legal dose from nuclear power and other licensed fuel chain facilities. The attached comments from state Attorneys General calculate some even-higher dose exemptions could result from this rule-change.
Please let me know – dianed@nirs.org or 202-841 8588-- if that means your group does not want to remain on the comments and I will remove the group.
THANK YOU AGAIN for staying with this very long and very winnable fight!!
If anyone knows of attorneys that might be up for legally challenging this rule change, please let me know ASAP. WE have until Dec 4 to appeal to the federal courts because it was published as a direct FINAL RULE Oct 5, 2026
Diane D’Arrigo
Nuclear Information and Resource Service
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