Proposed rules on ALARA, reactor licensing revamp introduced by NRC

Background on ALARA and LNT: Since its introduction in the 1970s, the ALARA principle has received both support and criticism within and outside the nuclear community. In 2017, the American Nuclear Society identified low-dose radiation regulation as an ANS Nuclear Grand Challenge. Recent and ongoing work in policy and research communities has sought to establish a scientific basis to resolve questions of low-dose radiation policy and regulation.

Executive Order 14300, “Ordering the Reform of the Nuclear Regulatory Commission,” was issued in May 2025 and called for the NRC to “reconsider reliance on the [LNT] model for radiation exposure and the “as low as reasonably achievable” standard, which is predicated on LNT.” Both LNT and ALARA were described in the EO as “flawed.”

A July 2025 report from Idaho National Laboratory made a case for eliminating ALARA and setting higher dose limits. Some experts asserted that the EO provided an opportunity to unify and clarify U.S. radiation regulations across agencies by establishing a scientifically justified “below regulatory concern” threshold. Others have cautioned against “loosening the protections” of the LNT model.

The proposed rule on ALARA: The proposed rule would replace the longstanding ALARA approach with requirements the NRC said are clearer, more objective, and more focused on compliance with regulatory precautions and established dose limits. According to the NRC’s announcement on the proposed rule, “The agency concluded that retaining ALARA as a separate regulatory expectation can lead to additional costs and complexity without a measurable safety benefit.”

NRC Chairman Ho Nieh described the replacement as "more predictable" than the previous framework.

Facilities that have established operational controls and procedures that incorporate ALARA procedures and that have been in place for years and in some cases decades—such as operating reactors, fuel cycle facilities, and hospitals—shouldn't expect major changes due to the proposed rule, Nieh said.

Where the changes may have more impact is at new facilities and reactors.

"These new reactor designers and new technology designers are trying to hit a moving target—how much shielding do you need to put in place to have an operational ALARA program?" Nieh said in a July 1 media call. "What's reasonable? What may be reasonable to you may be very different from a reasonableness perspective [for] me. What we're doing is putting in place structure that does not currently exist today."

According to the NRC’s proposed rule, the updates would accomplish the following:

• Adopt a graded approach to dose management based on risk and operational circumstances.
• Provide licensees with a greater flexibility to use modern methods for evaluating radiation doses.
• Expand options for managing occupational radiation exposure.
• Allow caregivers of patients receiving treatments involving radioactive materials to voluntarily receive higher doses, improving patient care while maintaining appropriate protections.

"This rulemaking is raising the bar on clarity in our regulations; it is not lowering the bar on our safety standards," Nieh said.

The NRC will open a 45-day period for public comments following the proposed rule's FR publication. The NRC plans to hold a public meeting during the comment period.

Nieh said they will take every public comment into consideration and make appropriate adjustments. "There has been a lot of buildup to this rule," he acknowledged.

"This is not erasing the entire rulebooks of radiation protection—in fact, we honestly did very little of that. When it comes to ALARA, we eliminated reference to that specific term in our regulations," said Nieh. "We want to get away from driving our licensees and our applicants toward an expectation that's open ended."

The licensing proposed rule: The NRC's reactor licensing proposed rule will impact practically all aspects of a facility's life cycle, from early design approvals to operations to decommissioning.

"It is informed by decades of operating experience, lessons learned from new reactor licensing, and the emergence of advanced reactor designs that challenge the boundaries of existing regulations," the NRC said in an announcement of the proposed rule.

Nieh said the rule will affect reactor construction, license renewals, life extensions, definitions of licensing basis events, advanced reactor fuels, and emergency preparedness programs.

"We're adding several safety-focused regulatory flexibilities aimed at accelerating deployment of new reactors, as well as expanding the capacity of existing reactors," he added.

When it comes to the early stages of nuclear construction, the proposed rule would have NRC oversight put a greater emphasis on safety-significant systems. Some early site activities would fall under a more general licensing process once an application has been docketed, according to the announcement. The proposed rule would also emphasize risk-informed, flexible options for regulatory activities, such as safety analyses and model updates.

The proposed rule also addresses modernizing emergency preparedness, updating quality-assurance standards, expanding licensing and siting flexibility, and supporting advanced fuels. Nieh said the proposed rule opens a pathway for 40-year license renewals and ultimately for 100 years of operation.

The goal is to not regulate by exemptions, added Mike Franovich, incoming director of the Office of Nuclear Reactor Research. While it is allowable under Part 50 requirements, regulating by exemptions is "inherently inefficient," he said.

So much has been learned over the past few decades in areas like fuels, that "we can move forward with instead of a 20-year renewal term go to a 40-year renewal term," said Franovich. "We're actually applying our knowledge here."

The NRC will accept comments on the proposed rule for 45 days following its FR posting.