Comment on FR Doc # 2026-09877, NRC-2025-1205-0001, from Anonymous

Issue 1: Definition of "Research" for NARM and Source Material Regulatory Framework: 10 CFR Part 30 (Byproduct Material), 10 CFR Part 40 (Source Material), and the Energy Policy Act of 2005 (EPAct) regarding Naturally Occurring and Accelerator-Produced Radioactive Material (NARM). The Problem: Current regulations trigger a requirement for a Specific License based solely on the intent to conduct research, regardless of whether the material exists in an otherwise legally exempt quantity or items (such as radium-containing antiques or trace mineral samples). The term "research" is applied so broadly that it fails to differentiate between industrial/academic laboratories and benign non-destructive analysis conducted by hobbyists, citizen scientists, or independent collectors. Example of Inconsistency: An intact, radium-painted antique watch is legally possessed without a specific license under general exemptions. However, if a collector places that exact same watch into a sealed container strictly to measure its radon emanation fraction via non-destructive gamma spectroscopy, the activity is legally reclassified as "research," triggering a complex and expensive specific licensing requirement. The physical risk profile of the item has not changed, yet the regulatory burden becomes prohibitive. Proposed Resolution: Amend the definitions within 10 CFR 30.4 and 10 CFR 40.4 to exclude non-destructive evaluation of legally possessed, exempt quantities or exempt items from the definition of "research" requiring a specific license. Issue 2: Ambiguity and Impracticality of Radon-222 Possession Limits Regulatory Framework: 10 CFR Part 30 Appendix B (byproduct material possession limits). The Problem: Because Radon-222 is often treated as a non-enumerated alpha-emitting radioisotope in general possession tables, its licensing thresholds default to sub-picocurie or low-nanocurie limits. These thresholds sometimes sit below practical ambient baselines and limits of detection. Context: A standard residential home may have a natural radon inventory exceeding 500,000 pCi while remaining well within EPA prescribed safe ambient limits. A temporary, localized isolation of 10 to 100 uCi by a researcher or hobbyist represents a negligible, short-term exposure vector. Treating transient samples in the same way as manufactured alpha sources is not necessary, as they do not easily lend themselves to creating significant health or safety risks. Proposed Resolution: Establish an explicit, realistic possession and emanation threshold for radon-222 gas derived from legally possessed items (such as unmodified mineral specimens or consumer antiques) under 10 CFR 30.14, etc. to avoid regulating amounts comparable to those easily obtained from the environment. Issue 3: Regulatory Chilling Effect on Indoor Radon Mitigation and Scrubbing Systems Regulatory Framework: 10 CFR Part 20 (Standards for Protection Against Radiation) and Lead-210 accumulation. The Problem: Consumers are looking beyond sub-slab depressurization toward active HVAC charcoal scrubbing systems. These systems concentrate radon, and long lived daughter isotopes in the filter media. The Conflict: High-efficiency residential and commercial HVAC filters already accumulate radon decay products (RDPs) and are disposed of in standard municipal waste. An efficient radon scrubber in a standard home system could easily trap 10 uCi of transient radon gas and a permanent residual footprint of roughly 20 nCi of Pb-210 annually, creating an unnecessary regulatory gray area regarding unlicensed possession of byproduct materials. Proposed Resolution: Provide clear, explicit exemptions in 10 CFR Part 30 for the possession, accumulation, and aging of filtration media utilized specifically for environmental radon remediation in public and private buildings. Issue 4: Chilling Effect on the Availability and Economics of Calibration Standards Regulatory Framework: 10 CFR 30.15 and 10 CFR 30.18 (Exempt quantities). The Problem: Due to the rigid regulatory climate surrounding Radium-222, low-activity gamma calibration standards—including NIST SRMs -- frequently require specific licensing even at benign levels of activity. Market Impact: This strict stance has led to artificial market scarcity. Low-level Radium standards routinely cost up to 30 times more than comparable isotopes (such as Cesium-137), hindering the ability of independent researchers, citizen scientists, and small laboratories to accurately calibrate radiation detection equipment for radon & radium. NIST itself no longer provides a radon gas SRM; flow through radon emission standard are foreign made, expensive, difficult to import, not NIST traceable, and also require a specific license. Proposed Resolution: Expand the exempt quantity provisions in 10 CFR 30.18 to explicitly include low-activity, sealed Ra-226 calibration standards when used exclusively for instrument calibration and verification.