NEWBURYPORT − The C-10 Research & Education Foundation, the nonprofit watchdog group that monitors radiological safety around Seabrook Station, has joined state attorney generals, including Massachusetts Assistant Atty. Gen. Amy Laura Cahn, in urging the federal Nuclear Regulatory Commission (NRC) to reject a proposed rule that would eliminate the agency’s longstanding radiation standard.
Driven by the White House, the initiative to change the As Low As Reasonably Achievable (ALARA) radiation protection standard would move nuclear power plants away from an obligation to minimize radiation doses
That would save money rather than public health, C-10’s executive director Sarah Abramson said.
The comment, filed last week in the Federal Register, is in response to the NRC’s proposed rule “Reforming and Modernizing the NRC’s Radiation Protection Framework” (Docket NRC-2025-1140).
C-10 argued that the proposal to replace ALARA is a move away from an affirmative, continuous obligation to minimize radiation dose towards a weaker, threshold-triggered system. That shift is being driven by cost savings to the industry rather than public health evidence.
“The NRC’s own preamble admits the underlying science hasn’t changed since the agency rejected this same argument in 2021,” Abramson wrote. “If the science hasn’t moved, then this isn’t a technical update — it’s a policy rollback dressed up as a clarification, and it would leave the nearly 180,000 people who live within 10 miles of Seabrook Station less protected, not more.”
The NRC’s regulatory analysis projects the industry will save $9.53 million annually with no quantified public health benefit.
Key concerns raised by C-10 and the state Attorney Generals are:
- A reversal without new evidence. In 2021, the NRC denied a petition to weaken radiation limits, finding no compelling evidence to support relaxing them. The new proposal does not cite new science to justify reversing that finding.
- Oversight moved out of public view. The rule would shift responsibility for setting dose thresholds from codified regulation to NRC guidance documents, which can be changed with far less public notice or comment.
- No accounting for cumulative exposure. The rule does not address cumulative radiation dose to communities near multiple nuclear sources — a particular concern for Seacoast New Hampshire, situated near both Seabrook Station and the Portsmouth Naval Shipyard.
- Vulnerable populations overlooked. The proposal does not explain how new dose thresholds would account for the most radiosensitive populations, including developing fetuses and children, rather than relying on adult-male reference data.
The Seabrook Station is licensed to operate until 2050, although its concrete structures are significantly weakened by alkali-silica reaction (ASR) wherein some of the materials inside the plant’s concrete mix are reacting with moisture.
C-10 maintained that the degradation, characterized by severe cracking and spalling, is widespread throughout the plant including its reactor containment enclosure building which protects the public from harmful radiation. The damage is severe enough that there are special license conditions and monitors in place to track this irreversible “concrete cancer” as it continues to get worse.
The watchdog group is a nonpartisan 501(c)(3) public advocacy organization serving communities within the 10-mile emergency planning zone of Seabrook Station in New Hampshire and Massachusetts. The organization operates three core programs: real-time radiological air monitoring under contract with the Massachusetts Department of Public Health; public outreach and education on radiological emergency preparedness, and research and advocacy on public health outcomes related to the Seabrook nuclear plant.
Learn more at www.c-10.org.






