Alan R.P. Journet Ph.D.
Cofacilitator
Southern Oregon Climate Action Now
August 31st 2025
Reference Docket ID NRC-2025-1140, NRC Proposed Adjustments for standards Governing Ionizing Radiation Exposure
I write as cofacilitator of Southern Oregon Climate Action Now, the oldest grassroots climate organization in Southern Oregon representing some 2,000 Southern Oregonians who understand and accept the scientific consensus regarding climate change and are concerned about the climate crisis. We seek federal, state, and local action to address it and oppose proposed actions that contribute to the crisis. We are rural and coastal Southern Oregonians who live on the frontlines of the warming, reducing snowpack, heatwaves, drought, rising sea level, and the increasing wildfire risk that climate trends conspire to impose on us. Because of our concern, we pay close attention to actions nationally, statewide, and locally that influence our collective efforts to address the serious climate crisis. As our logo above indicates, the focus of SOCAN is to promote action through science while encouraging that action be undertaken through a social justice lens. Based on review of the proposal, we oppose relaxing radiation safety standards.
According to the U.S. Centers for Disease Control (CDC 2026a) “If there is no direct benefit from receiving a dose [of radiation], even a small one, it should be avoided.” The implication from this CDC statement has to be that there is no safe dose. The question we might ask, in relation to the current effort by the Nuclear Regulatory Commission to relax safety standards is suggested by Brumfiel (2026) in reporting that “The update is part of President Trump’s expansive changes to nuclear oversight, as his administration seeks to revive nuclear energy to power data centers for artificial intelligence.” The question raised: Is relaxing ionizing radiation standards a risk worth taking simply in order to support the nuclear industry?
In its request, the NRC proposes to abandon the ‘Linear No-Threshold’ (LNT) Model and the consequent ‘As Low As Reasonably Achievable’ (ALARA) standard for exposure in favor of a defined criterion for exposure below which ionizing radiation is designated as safe.
As Seel and Stein (2025) pointed out, the Linear No-Threshold (LNT) Model for determining radiation safety was established many decades ago as “a pragmatic, intentionally conservative policy choice” for determining the safe level of exposure to radiation. This model led to the basic guideline that radiation levels should be As Low As Reasonably Achievable (ALARA).
In discussing the concept of ‘as low as reasonably achievable’ as a standard for determining the safety level for ionizing radiation, the CDC (2026b) defines ALARA as “avoiding exposure to radiation that does not have a direct benefit to you, even if the dose is small. To do this, you can use three basic protective measures in radiation safety: time, distance, and shielding. In a Scientific American review of the NRC proposal, Pappas (2026) pointed out that the change recommended by the NRC “would do away with a principle called ALARA…., Under ALARA, there are maximum doses of radiation exposure that workers and the public must stay below. But beyond those thresholds, nuclear operators are also required to continuously try and push doses downward—to as low as is “reasonably” achievable.
Although the origin of the LNT model dates back to the early years of this century (e.g. Boice 2017), more recent studies have endorsed it. For example, only two years ago, Wojcik and Zölzer (2024) reported “…experimental approaches with both cell and animal models are unable to provide unequivocal evidence for the existence of a dose threshold below which radiation carries no risk to human health.” Indeed, in its proposal to adjust the standards, regarding the LNT model, the NRC itself states: “The NRC considers its current standards for protection against radiation to be science-based.” There appears no such claim regarding the proposed standards leaving the reader wondering why the NRC would reject science-based standards in favor of some other protocol.
In a Scientific American review of the NRC proposal, Pappas (2026) pointed out: “The LNT model holds that despite the difficulty of detecting whether a cancer has been caused by low-dose radiation amid the sea of cancer diagnoses, there is no threshold at which radiation is safe.”
According to the Federal Register (2026), the effort to weaken nuclear power plant rules is defined as Reforming and Modernizing the NRC’s Radiation Protection Framework.:NRC claims “The intent of these revisions is twofold and directed at enabling the safe use of nuclear technology while maintaining reasonable assurance of adequate protection from the health effects of radiation exposure….” The NRC explains its goals as follows: “Consequently, the NRC proposes to remove references to the ALARA principle, which rests on the LNT model’s assessment of risks from very low doses of radiation, from its regulations; instead, the NRC would apply a less-subjective, graded approach to managing doses below regulatory limits.
Seel and Stein (2025) pointed out that the pressure to adjust this standard is based not on updated medical analysis but on the “surge in electricity demand, driven by the rapid expansion of artificial intelligence, data centers, industrial growth, and widespread electrification.” The question we have to ask ourselves concerns the extent to which it is rational (or conservative from a human health perspective) to adjust a medical safety criterion in order to promote economic goals and that serve individuals who evidently care little about the health and wellbeing of the public.
This raises the important question of whether nuclear power generation is a sound route to increasing energy production. Journet (2025) provided a clear assessment of the lack of merit of this approach particularly in the context of addressing the climate crisis. The essence of that analysis is that proponents of nuclear generation offer three premises to justify their promotion of nuclear energy:
1) Clean renewable energy sources are inadequate to provide our energy needs.
2) Nuclear energy generation is free of greenhouse gas emissions.
3) Nuclear energy is safe.
Journet (2025) concluded that the literature clearly argues all three basic premises are false.
Ahmad (2025) among others, makes the case that “Across the United States, data center demand is climbing at a pace that traditional grid planning can’t match.” This author also notes: “Artificial intelligence and cloud computing are driving multi-gigawatt expansions in regions where interconnection queues are already stressed, leaving developers in search of reliable, round-the-clock, low-carbon power that doesn’t require hundreds of acres of land….” Ahmad (2025) also suggested “That search is bringing nuclear energy, specifically small modular reactors, back into engineering conversations.” Among the broad array of environmental problems that the push for ever more data centers imposes are substantial energy use, rising utility bills, massive water use, and the risk of increased air pollution (e.g., Walker & Goldsmith 2026). There seems ample evidence that the push for relaxing nuclear safety standards is driven by a desire to promote Small Modular Nuclear Reactors (SMNR) as a means of powering data centers. Lyman (2024) persuasively burst the SMNR bubble in discussing a series of issues and myths regarding these entities:
1. SMRs are not more economical than large reactors.
2. SMRs are not generally safer or more secure than large light-water reactors.
3. SMRs will not reduce the problem of what to do with radioactive waste.
4. SMNRs cannot be counted on to provide reliable and resilient off-the-grid power for facilities, such as data centers, bitcoin mining, hydrogen or petrochemical production.
S. SMNRs do not use fuel more efficiently than large reactors.
A critical question regarding this entire NRC effort is: ‘Does relaxing the standards for exposure to ionizing radiation serve the public good?’ There is probably little doubt that it serves the interests of:
- executives and shareholders in the nuclear industry,
- the manufacturers of Small Modular Nuclear Reactors, and
- those developing and deploying data centers and cryptocurrency ventures.
I close by asking: if new nuclear reactors are as safe as proponents claim why do we need to relax safety standards and why does the nuclear industry not demand Congress overturn the Price Anderson Act?
It is worth reminding ourselves of the United Nations’ Precautionary Principle (Pinto Bazurco 2026) and applying this principle to protecting human health.
“In order to protect the environment, the precautionary approach shall be widely applied by States according to their capabilities. Where there are threats of serious or irreversible damage, lack of full scientific certainty shall not be used as a reason for postponing cost-effective measures to prevent environmental degradation.”
It is very clear to us that relaxing the standards for safe levels of ionizing radiation exposure to serve the economic aspirations of a limited segment of the population does not serve the public interest and should be rejected.
Respectfully Submitted
Alan Journet Ph.D.
7113 Griffin Lane
Jacksonville
OR 97530-4182
alan@socan.eco
541-500-2331
541-301-4107
Literature Cited
Ahmad S. 2026 Demand for data centers soars; could small modular reactors meet the need? American Society for Civil Engineers https://www.asce.org/publications-and-news/civil-engineering-source/article/2025/12/17/demand-for-data-centers-soars-could-small-modular-reactors-meet-the-need
Boice J. 2017. The linear nonthreshold (LNT) model as used in radiation protection: an NCRP update. International Journal of radiation Biology 93 (10): 10790192. https://pubmed.ncbi.nlm.nih.gov/28532210/
Brumfiel G. 2026 Nuclear regulator prepares to abandon a decades-old radiation safety rule. National Public radio Morning Edition. https://www.npr.org/2026/08/27/nx-s1-5920368/nrc-nuclear-radiation-safety-rules-alara-update
CDC 2026a Radiation Safety. Centers for Disease Control https://www.cdc.gov/radiation-health/safety/index.html
CDC 2026b ALARA – As Low As Reasonably Achievable Recommendations. Centers for Disease Control https//www.cdc.gov/radiation-health/safety/alara.html
Federal Register 2026 Reforming and Modernizing the NRC’s Radiation Protection Framework: A Proposed Rule by the Nuclear Regulatory Commission on 07/15/2026. https://www Federal Register :: Reforming and Modernizing the NRC’s Radiation Protection Framework.
Journet A. 2025 Climate Action and the Nuclear Conundrum. Southern Oregon Climate Action Now https://socan.eco/climate-action-and-the-nuclear-conundrum/
Pappas S.(2026) How could loosened radiation exposure rules affect public health? Scientific American https://www.scientificamerican.com/article/how-could-laxer-radiation-exposure-rules-affect-public-health/
Pinto Bazurco J. 2026 The Precautionary Principle: Still Only One Earth: Lessons from 50 years of UN sustainable development policy. International Institute for Sustainable Development
Seel P & Stein A. 2025 Drawing the Line: The Linear No-Threshold Model, and When are Doses Too Small to Matter? Breakthrough Institute https://thebreakthrough.imgix.net/Drawing-the-Line-Radiation-Protection-White-Paper-BTI.pdf
Walker C & Goldsmith I. 2026 From Energy Use to Air Quality, the Many Ways Data Centers Affect US Communities. World Resources Institute. https://www.wri.org/insights/us-data-center-growth-impacts Wojcik A & Zölzer F. 2024 The scientific nature of the linear no-threshold (LNT) model used in the system of radiological protection. Radiation and Environmental Biophysics. 63(4):483–489 https://pmc.ncbi.nlm.nih.gov/articles/PMC11588861/
