Beyond ALARA: The Implications of the NRC’s Proposed Radiation Protection Framework

Key Takeaways

• The NRC has proposed a rulemaking that would eliminate the longstanding “As Low As Reasonably Achievable” (ALARA) requirement from its radiation protection regulations while retaining existing numerical dose limits for workers and the public.
• The proposal follows the Department of Energy's January 2026 decision to remove ALARA from DOE regulations and directives based on similar concerns regarding regulatory burden and may reflect a broader federal reassessment of radiation protection policy.
• Existing nuclear power plants may see limited immediate operational changes due to their mature radiation protection programs and deeply embedded ALARA practices.
• Advanced reactor developers and new fuel cycle projects could benefit from the proposed rules’ greater regulatory flexibility through reduced compliance burdens, simplified licensing reviews, and a more risk-informed approach to facility design and operation.
• The proposal raises potential legal and regulatory questions concerning changes to NRC inspection and enforcement practices, effects on future licensing reviews, possible impacts on radiation exposure litigation, and challenges associated with maintaining consistency with other domestic and international radiation protection frameworks that continue to incorporate ALARA principles.

On July 1, 2026, the U.S. Nuclear Regulatory Commission (NRC) provided notice of a proposed rulemaking that would substantially revise its radiation protection regulations by eliminating the longstanding requirement that radiation exposures be maintained "as low as reasonably achievable.” While the proposal retains existing numerical dose limits for workers and the public, it would replace ALARA with a regulatory framework focused on compliance with objective dose limits and risk-informed radiation protection measures. The NRC describes the proposal as a modernization effort intended to improve regulatory clarity and reduce unnecessary burden without compromising safety.

The NRC's proposal follows a similar policy shift at the U.S. Department of Energy (DOE) which, in January 2026, eliminated ALARA from its regulations after concluding that it imposed unnecessary operational and economic burdens while providing limited additional safety benefits beyond existing radiation dose limits. While DOE's decision applies only to DOE-owned facilities and activities, the NRC's proposal is potentially far more consequential because the NRC regulates not only commercial nuclear power plants, but also fuel cycle facilities, medical licensees, research institutions, and thousands of other users of radioactive materials across the United States. As a result, any change to the NRC's radiation protection framework could have implications across virtually the entire civilian nuclear sector. Taken together, DOE’s and NRC’s actions may provide an indication of the direction federal nuclear policy.

ALARA’s Origin and Requirements

The ALARA principle emerged after World War II as experts sought to manage uncertainties related to the potential health effects of low-dose radiation exposure. Regulators adopted a radiation protection approach based on the concept of a “tolerance dose,” the idea that there were exposure levels below which radiation posed little or no risk. As scientific understanding evolved, regulators embraced a more precautionary approach based on the Linear No-Threshold (LNT) model. The LNT model assumes that the risk of radiation-induced harm increases proportionally with radiation dose and that no dose of radiation, regardless of how small, is entirely without risk. Under LNT, ALARA became the guiding principle for radiation protection and requires licensees to maintain radiation exposures "as low as reasonably achievable" considering technological feasibility, economics, and societal considerations. Even if exposure levels are below regulatory limits, licensees must continually evaluate whether additional reasonable measures can be taken to further reduce exposure to workers and the public.

How ALARA Has Shaped the U.S. Nuclear Industry

For decades, ALARA has been deeply embedded in virtually every segment of the civilian nuclear industry. For example, at nuclear power plants, ALARA has influenced refueling outage and decommissioning planning, worker dose budgeting, shielding design, contamination control programs, radiation work permits, the use of remote tools and robotics. Over time, ALARA has become an integral component of operational decision-making and safety culture throughout the industry.

Supporters of ALARA view it as a critical driver of continuous improvement in radiation protection. Critics, however, contend that ALARA has evolved into an open-ended regulatory obligation that often requires significant expenditures to achieve increasingly small reductions in radiation dose, even where measurable health benefits are uncertain. While regulators, scientists, and stakeholders continue to debate the appropriateness of the LNT model, the significance of this debate is reflected in President Trump’s Executive Order 14300 which directed the NRC to reconsider its reliance on both the LNT model and ALARA. As such, the NRC's current proposal may be seen as the latest chapter in the decades-long evolution of radiation protection standards. For now, ALARA continues to be the radiation protection standard among many other organizations such as the International Commission on Radiological Protection.

What the NRC's Proposed Rule Would Change

The centerpiece of the NRC's proposal is the elimination of ALARA as a standalone regulatory requirement. While licensees would continue to be subject to established dose limits for workers and the public, they would no longer be required to demonstrate that exposures have been reduced as low as reasonably achievable. The NRC has emphasized that existing numerical dose limits would remain unchanged. The proposal would also adopt a more risk-informed and graded approach to radiation protection, provide greater flexibility to use modern dose assessment methodologies, expand options for managing occupational radiation exposures, and offer additional flexibility in certain medical-use applications. According to the NRC, these changes reflect decades of advances in science and accumulated operational experience, and would provide greater predictability, transparency, and regulatory certainty.

Practical Implications for the Nuclear Industry

From a practical standpoint, in the near term the proposed rules are unlikely to dramatically change day-to-day operations at existing nuclear power plants where mature radiation protection programs exist and deeply embedded ALARA practices have evolved over decades. Instead, the rules may yield various benefits over time starting with a reduction in the administrative burden associated with demonstrating ALARA compliance. Currently, licensees must show not only that radiation exposures remain below applicable limits, but also that reasonable steps have been taken to reduce those exposures even further. Eliminating ALARA as a separate regulatory obligation could simplify compliance programs and reduce documentation requirements.

The proposal may also affect NRC inspections and enforcement activities by shifting oversight toward compliance with objective dose limits and specified radiation protection requirements and could also alter future licensing reviews by reducing the emphasis on demonstrating ALARA compliance as part of facility design and operational planning. By eliminating the arguable subjectivity of what is “reasonably achievable” and focusing on objective dose limits and clearly defined regulatory requirements, the proposed framework may provide greater predictability and certainty for licensees. The proposed rule could also yield cost savings by allowing licensees to focus on activities that present greater safety significance while reducing costs associated with achieving marginal dose reductions. Finally, developers of advanced reactors and fuel cycle facilities may benefit the most from the proposed rules’ risk-informed and performance-based framework which could provide greater flexibility in reactor design, shielding requirements, facility layout, licensing strategies, and construction planning.

Potential Risks and Challenges

The proposed rules, however, are not without risks. The proposal may have implications for occupational and public exposure claims and related litigation. Although NRC compliance does not necessarily determine civil liability, ALARA has historically served as evidence that an employer pursued radiation protection measures beyond minimum regulatory requirements. If ALARA is removed from NRC regulations, future disputes could increasingly focus on whether compliance with applicable dose limits alone satisfies an employer's duty of care. Additionally, many domestic and international radiation protection frameworks continue to incorporate optimization principles similar to ALARA. Companies operating internationally or under multiple regulatory regimes may need to maintain ALARA-based programs regardless of whether the NRC ultimately adopts a different approach. Finally, if the proposed rules are perceived as adversely impacting the industry’s radiation protection standards and overall safety culture, workforce relations and public support for the resurgent domestic nuclear industry could be jeopardized.

Conclusion

The NRC's proposal to eliminate ALARA represents one of the most consequential changes to U.S. radiation protection policy in decades. When viewed alongside DOE’s decision to eliminate ALARA from its own regulations, the NRC's proposal suggests a broader federal reassessment of long-standing assumptions underlying radiation protection policy. Whether ultimately adopted or substantially modified, the rulemaking is likely to shape the regulatory environment for the next generation of nuclear power plants, fuel cycle facilities, and other nuclear technologies.

The NRC will accept public comments for 45 days following publication of the proposed rules in the Federal Register and plans to hold a public meeting on the proposed rules.