Comments filed by The Coalition to Stop Radioactive Pollution:

Beyond Nuclear
Committee to Bridge the Gap
Ecological Options Network
Fukushima Fallout Awareness Network
Generational Radiation Impact Project
HEAL Utah
San Luis Obispo Mothers for Peace
Nuclear Energy Information Service
Nuclear Information Resource Service
Oregon Conservancy Foundation
Physicians for Social Responsibility
Rocky Mountain Peace and Justice
Samuel Lawrence Foundation
Texas Nuclear Watchdogs

Opening summary:

30 August 2026
Attn: Nuclear Regulatory Commission
Washington, DC 20555-0001
Submitted electronically via regulations.gov

Re: Docket NRC-2025-1140 – Reforming and Modernizing the Radiation Protection Framework
On behalf of the Coalition to Stop Radioactive Pollution, we respectfully submit these comments
regarding Docket NRC-2025-1140, Reforming and Modernizing the Radiation Protection
Framework.

As a Coalition, and as individual organizations comprising the Coalition, we are compelled to
place on the record our fundamental opposition to the Nuclear Regulatory Commission’s (NRC)
proposed rulemaking. If adopted, this rulemaking would constitute a monumental shift in the
current radiation protection guidelines. The NRC’s continued reliance on the assertion that the
proposed revisions will “maintain reasonable assurance of adequate protection” constitutes an
egregious mischaracterization of the scope and significance of the proposed rulemaking. This
formulation minimizes the profound implications of the proposed changes by suggesting that the
existing levels of protection will be preserved, while the rulemaking would in fact eliminate or
substantially alter the fundamental principles and precautionary mechanisms that have
historically governed radiation protection standards in the United States. The proposed rule would
dramatically increase the legal radiation exposures to workers and the public, as well as releases
to air, water, and sewage, through surreptitious means.

This proposed rule change comes at a time when scientific knowledge has made clear
that the health risks of ionizing radiation are more significant than previously understood. It also
comes at a moment when the enduring health, economic, social, and environmental
consequences of past radiation exposures are still being experienced by communities affected by
the nuclear industry. These are not merely historical or individual harms: entire communities
continue to bear the cumulative and intergenerational consequences of radiation exposure and
contamination. With this knowledge, weakening the nation’s radiation protection framework
would move in precisely the wrong direction. What we need is a move toward stronger, science-
based protections and toward greater awareness of the real risks and health consequences that
will be borne by everyone living in the US. The risks should be clear to those who must bear them,
and radiation regulations should be required to be consistent with the United Nations Declaration
on the Rights of Indigenous Peoples, which requires consultation and freely given prior and
informed consent. This proposed rulemaking is a shameful attempt by the NRC to legally,
unjustifiably, and unnecessarily increase exposure rates to workers and the general public. The
proposed rule aims to significantly weaken US radiation protection standards which are already
insufficient.

Should this rulemaking move forward, we believe the outcomes will be catastrophic. We
maintain that adoption of the proposed rule, whether in its entirety or through any of its individual
provisions, would undermine essential protections for public health and for safety of atomic
workers and the public from radiological risks in the United States. The NRC’s proposed revisions
are not supported by the most up-to-date, peer-reviewed scientific evidence, nor do they reflect
the prevailing scientific understanding of the human health consequences of exposure to ionizing
radiation.

The proposed rulemaking lacks an adequate evidentiary and scientific basis and
represents a significant departure from the precautionary scientific evidence-based approach
that should govern the regulation of radioactive environmental pollution. This deficiency is
particularly evident in the NRC’s assertion that implementation of its proposed rule will result in
“increased public exposure to Ionizing Radiation…with potential stochastic health effects of
unknown magnitude… expected to be minimal” [see US Nuclear Regulatory Commission 2026a,
27, Table 4, emphasis added]. Such a conclusion is deeply concerning because it fails to identify
and appears to minimize the potential consequences of increased exposure while simultaneously
failing to demonstrate an adequate scientific basis for determining that the associated risks are
sufficiently small to warrant weakening existing protections. Dropping the regulation of stochastic
impacts is further confirmation that the NRC is abdicating its authority, and therefore its
responsibility, to protect all those living and working in the US from radiological harm. When
stochastic health effects are “out of scope” of the regulations, the level of deregulation no longer
demonstrates compliance with NRC’s statutory obligations.

Furthermore, the full scale revision of one hundred percent of the NRC’s Code of Federal
Regulations in one 18-month period precludes meaningful public engagement. The affected
public, individuals, organizations and state and local governments are flooded with enormously
important revisions comprised of more content and background material than can be taken in,
analyzed, and commented on in this timeframe. Moreover, many of the provisions in the revised
rule NRC 2025-1400 violate the APA, NEPA, the Atomic Energy Act, and the Nuclear Waste Policy
Act and its amendments.

We strongly encourage the Commission to give careful and full consideration to the
scientific evidence and analysis presented herein, which demonstrate the need for stronger, not
weaker, protections from the risks of ionizing radiation. The evidence makes clear that this is not
the time to diminish longstanding safeguards or relax the regulatory framework governing
radiological exposures. Rather, the NRC should strengthen its commitment to robust, evidence-
based protections for workers and the public.

We urge the NRC to abandon the proposed rulemaking in its entirety and work instead to
preserve and strengthen the protections necessary to safeguard public health and safety in
the United States. We recommend that the NRC bring civil nuclear regulations into line with
the Environmental Protection Agency’s (EPA) longstanding commitment to reducing
exposures to workers and the public and to regulate down to very low risk levels. Current
EPA protections provide seventy times more protection from radiation exposure to neighbors
living next door to Super Fund sites than does NRC to any member of the general public.
There is no justification for the NRC to allow additional harm.