NRC Proposes Overhaul of Radiation Protection Framework

The U.S. Nuclear Regulatory Commission (NRC) on July 15, 2026, published a proposed rule titled "Reforming and Modernizing the NRC's Radiation Protection Framework" that would comprehensively revise the NRC's radiation protection regulations. If finalized, the rule would represent the most significant revision to the NRC's radiation protection standards since its last major overhaul in 1991.

The proposed rule is a direct response to Executive Order (EO) 14300, "Ordering the Reform of the Nuclear Regulatory Commission," signed by President Donald Trump on May 23, 2025. Section 5(b) of EO 14300 requires the NRC to "reconsider reliance on the linear no-threshold (LNT) model for radiation exposure and the 'as low as reasonably achievable' standard, which is predicated on LNT" and states that "in reconsidering those limits, the NRC shall specifically consider adopting determinate radiation limits."

Public comments on the proposed rule must be submitted electronically via regulations.gov by 11:59 p.m. ET on August 31, 2026, referencing Docket ID NRC-2025-1140.

NRC's Position on the LNT Model

Despite the EO's directive to "specifically consider adopting determinate radiation limits," the NRC has concluded that establishing a determinate regulatory dose limit for stochastic health effects (i.e., a brightline threshold below which radiation is deemed categorically safe) is not currently supported by scientific evidence. The NRC considered shifting to a framework based entirely on determinate dose limits for both stochastic and non-stochastic effects – a "go/no-go" regulatory approach – but ultimately rejected that approach.

Instead, the NRC reaffirms that the linear dose-response model remains the most appropriate available consensus model for formulating radiation protection standards and planning radiation protection programs. The NRC's existing regulatory dose limits are considered sufficient to provide reasonable assurance of adequate protection of public health and safety. The decision to reaffirm the LNT model makes the proposed rule more legally durable in light of the comprehensive review undertaken by the NRC between 2015 and 2021 that reached the same conclusion as there has been little new scientific evidence presented since that review to revise NRC's analysis regarding LNT.

However, the NRC has determined that its current radiation protection standards allow for excessive subjectivity leading to overly conservative assessments, in tension with the NRC's "Efficiency," "Clarity" and "Reliability" Principles of Good Regulation. Accordingly, the NRC proposes to use the linear model as a partial basis for regulation while removing the excessive conservatisms and potential for disproportionate enforcement that resulted from LNT's emphasis on the lack of a threshold for stochastic effects. In short, the NRC retains LNT as a scientific model but fundamentally changes how that model is implemented in practice.

Retirement of ALARA and Adoption of a Graded Approach to Dose Management

Perhaps the most significant practical change in the proposed rule is the complete discontinuation of "as low as reasonably achievable" (ALARA) terminology from the NRC's regulations and guidance. The principal complaint regarding ALARA by industry stakeholders has been that "reasonable" is subjective and licensees have been subjected to unreasonable requirements that are not justified by the safety case. The NRC considered, and rejected, the idea of simply clarifying that ALARA demands only "reasonable" protection measures, finding that mere clarification would likely fail to achieve clarity and only result in an enduring irresolution of the issues associated with its current implementation of ALARA. Instead, the NRC proposes to remove the definition of ALARA entirely and replace it with a new defined term: "graded approach to dose management."

The proposed rule defines the graded approach as:

"[A]n approach whereby progressively increasing radiation protection measures are required as prospective, or actual, radiation doses exceed determinate dose thresholds to provide reasonable assurance that the applicable regulatory limit is not exceeded."

Under this framework, the graded approach relies on existing precautionary requirements (radiation worker training, radiological monitoring, signage and posting) to control doses below limits, with progressively more rigorous measures required as doses approach the regulatory limits.

Occupational Dose Thresholds

The proposed rule establishes the following determinate dose thresholds for occupational exposures, with specified actions required at each level. The two examples of graded requirements below the five rem/year occupational dose threshold cited in the proposed rule are existing regulatory requirements. Additional context for the graded approach is expected in forthcoming NRC guidance.

• Above 100 mrem/year (Expected Dose): Licensees must provide radiation worker training and instruction to workers pursuant to 10 C.F.R. 19.12.
• Above 500 mrem/year (10 Percent of the Applicable Limit): Licensees must monitor doses to individual workers pursuant to 10 C.F.R. 20.1502.
• Above Five rem/year (the Occupational Regulatory Dose Limit): Licensees may use the new planned occupational dose limit extension process (proposed Section 20.1205) or existing planned special exposure process (Section 20.1206), where higher doses are needed for specific tasks.

Public Dose Graded Approach

For public dose, the NRC states that two acceptable ways of managing public dose would be:

• not analyzing projected public doses below 25 percent of the public dose limit (i.e., below 25 mrem/year, given the 100 mrem/year public dose limit)
• performing a cost-benefit analysis (using the NUREG-1530 assumptions or equivalent) for projected doses at or above 25 mrem/year to determine whether additional protective measures are cost-justified

Forthcoming Implementing Guidance

The NRC is developing implementing guidance to further define and provide acceptable approaches for the graded approach to dose management. Three draft guidance documents (DG-8063, DG-8064 and DG-8067) are being issued for public comment concurrently with the proposed rule. Additional guidance documents are expected to be issued after the proposed rule is published on a separate timeline.

The guidance will explain that radiation protection measures under the graded approach can be justified using a cost-benefit comparison – specifically, the cost of a protective measure (e.g., shielding, additional workers, robotics) compared against a reasonably calculated cost of an averted person-rem. NUREG-1530 provides an example reasonable cost-basis, using a nominal cost of $5,200 per averted person-rem (in 2014 dollars). Additional guidance will likely provide more examples of acceptable steps to meet the intent of the graded approach. Interested parties should monitor guidance as it is released for potential changes to the methodology for determining when certain dose limits are likely to be exceeded.

Other Specific Proposed Changes

In addition to the changes discussed above, the proposed rule includes the following notable provisions:

• Planned Occupational Dose Limit Extension (Proposed Section 20.1205). Establishes a new process allowing individual workers to exceed certain annual occupational dose limits, provided doses remain within specified multiyear (five-year) limitations (up to twice the annual limit in a given year and five times the annual limit over the current year plus preceding four years), without the added administrative burden of the existing planned special exposure process.
• Alternative Dosimetry Systems (New Section 20.1010 and Appendix H). Allows licensees and applicants to voluntarily use specific, preapproved alternative dosimetry methods to demonstrate compliance with radiation protection standards without needing a separate case-by-case NRC exemption.
• Revised Reporting Thresholds (Section 20.2106). Introduces a reporting threshold allowing licensees to annotate that a dose was received but did not exceed 10 percent of the applicable monitoring criteria, rather than recording the numerical value.
• Five-Year Dose Assessment for Overexposure Reporting (Section 20.2203(a)(2)). Replaces current unplanned overexposure reporting criteria with a five-year dose assessment approach – e.g., reporting of an unplanned exceedance of the occupational total effective dose equivalent limit is required only if the total effective dose equivalent for the current year and preceding four years exceeds 25 rem; for public dose, only if the total exceeds 500 mrem over five years.
• Higher Public Dose Limits on Request. Allows applicants and licensees to apply for higher public dose limits on a case-by-case basis, both for members of the public in a facility's "controlled area" and in the unrestricted area (removing the current 500 mrem/year upper cap). Also deletes the short-term public dose rate limit of 0.002 rem in any hour as duplicative.
• Increased Effluent Emissions Constraint. Increases the radionuclide/effluent emissions constraint from 10 mrem/year to 25 mrem/year while requiring licensees exceeding that constraint to collect and report data annually and evaluate cost-justified corrective actions.
• New Caregiver Framework. Introduces a "caregiver" concept in 10 C.F.R. Parts 20 and 35, allowing a consenting caregiver of a patient administered radioactive material to receive doses up to the occupational dose limit (five rem) per patient administration regimen without requiring an individual NRC exemption (current exemption process allows up to two rem by default that can be increased in particular cases). Also shifts the medical patient-release dose basis from "per administration" to "per administration regimen."
• Restricted-Use License Termination Flexibility. Provides additional clarity and flexibility for license termination under restricted use (Sections 20.1403, 20.1404) by adding an explicit cost-benefit analysis option.

Next Steps

The proposed rule, if finalized, would represent a fundamental shift in how the NRC regulates radiation protection – one that replaces the subjective, open-ended ALARA framework with a structured, threshold-based approach more favorable to operational predictability for licensees.

Applicants and licensees should consider the following near-term actions:

• Monitor the rulemaking and review the three concurrent draft guidance documents (DG-8063, DG-8064 and DG-8067) for operational detail on how the NRC intends to implement the graded approach.
• Consider submitting comments by August 31, 2026, referencing Docket ID NRC-2025-1140.
• Monitor for additional guidance documents released after the rule that can materially impact the meaning of the rule and have operational impacts.
• Assess the implications of retiring ALARA for existing radiation protection programs, procedures and license conditions that currently reference ALARA or contain ALARA-based commitments.
• Evaluate whether the new alternative dosimetry systems listed in proposed Appendix H offer advantages for a facility's compliance program.
• Consult with counsel regarding how the transition from ALARA to the graded approach may affect pending or anticipated licensing actions, enforcement matters or decommissioning activities.

For additional information or questions, please contact the authors.

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