New and serious safety and environmental concerns have arisen with regard to the operation of already-licensed nuclear plants. Measured by virtually any objective standard, the 2.206 device has not been an effective vehicle for public participation in the ongoing oversight of nuclear plants. The Nuclear Regulatory Commission's (NRC) cavalier approach to 2.206 petitions might not pose such a serious problem if the Atomic Energy Act, like most modern day environmental and public health statutes, contained a citizen suit provision. A citizen suit provision could greatly assist members of the public to ensure that the NRC carries out its non-discretionary responsibilities. One potential criticism of the approach in the nuclear power context is that many of the NRC's regulations and standards are highly complex and that courts may therefore misconstrue or misapply them in analyzing whether particular licensees are in "violation" of them.