ML19305E213
| ML19305E213 | |
| Person / Time | |
|---|---|
| Issue date: | 04/04/1980 |
| From: | NRC OFFICE OF STANDARDS DEVELOPMENT |
| To: | |
| Shared Package | |
| ML19305E211 | List: |
| References | |
| SECY-80-177, NUDOCS 8004230126 | |
| Download: ML19305E213 (1) | |
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[7590-01]
D standards or to the establishing of requirements concerning how they are to be met.
The Commission is bound to implement these standards in its regulations, thus assuring that they will be met by activities authorized by the Commission's licensing decisions.
The Commission may not substitute its judgment for that of the EPA, but the Commission may, and must, deter-mine whether particular proposed disposal activities will conform to the EPA standard.
The EPA has published its generally applicable environmental standard for all of the fuel cycle except waste storage and disposal, 40 CFR 190, which expresses the limit in the form of a quantitative dose limit to the individual.
The EPA is in the process of developing its HLW standard.
The Commission expects this standard (40 CFR 191), to be similar in approach to that followed in 40 CFR 190.
(2) As noted above, although the Commission is bound to implement the EPA HLW standard, it has the authority and discretion to determine how that standard will be achieved.
In particular, the Commission must decide how it will develop its regulatory requirements, viz., the tech-l nical criteria of 10 CFR Part 60, and carry out its decision process to show that in each particular licensing case, the EPA standard will be met.
(3)
In order to establish the technical criteria for meeting the EPA standard and to make individual licensing decisions as to whether such criteria are met, the Commission needs to carry out conservative analyses because of the many uncertainties associated with HLW waste disposal in geologic repositories.
These uncertainties arise from the inability, given the present and expected state of science and technology, to determine precisely the degree to which wastes, under credible condi-tions for the time periods involved, will be contained and isolated.
I 1080OJ L2 30 Enclosure "A"