Nuclear Waste: Change in Test Strategy Sound, but DOE Overstated Savings
(Letter Report, 12/27/94, GAO/RCED-95-44).

After pursuing for a decade a strategy for underground tests with
nuclear wastes in the Waste Isolation Pilot Plant--a proposed repository
for the disposal of transuranic wastes located near Carlsbad, New
Mexico--the Energy Department (DOE) announced in October 1993 that it
was abandoning these tests in favor of laboratory-based tests. DOE
claimed that this change would save about $139 million by January 2000
and would allow DOE to begin disposing of waste by 1998. The general
consensus among scientists, experts, and regulators is that DOE's
decision to discontinue its planned underground tests with transuranic
wastes is sound. However, GAO questions DOE's projected cost savings.
For instance, DOE lacks documentation for many elements of the estimated
cost savings. GAO also concludes that DOE will not be able to open the
plant by 1998 instead of 2000. Numerous unresolved issues could affect
when DOE can eventually begin disposing of wastes in the facility. For
example it is unclear whether DOE's schedule gives the Environmental
Protection Agency enough time to review DOE's procedures and decide if
DOE has complied with EPA's regulatory requirements for disposing of
transuranic wastes in a repository.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  RCED-95-44
     TITLE:  Nuclear Waste: Change in Test Strategy Sound, but DOE 
             Overstated Savings
      DATE:  12/27/94
   SUBJECT:  Nuclear waste management
             Nuclear waste disposal
             Radioactive wastes
             Nuclear facilities
             Test facilities
             Future budget projections
             Cost effectiveness analysis
             Atomic energy defense activities
             Environmental monitoring

             
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Cover
================================================================ COVER


Report to Congressional Requesters

December 1994

Change in Test Strategy Sound, but DOE Overstated Savings

GAO/RCED-95-44

WIPP Test Strategy


Abbreviations
=============================================================== ABBREV

  DOE - Department of Energy
  EPA - Environmental Protection Agency
  GAO - General Accounting Office
  RCRA - Resource Conservation and Recovery Act
  WIPP - Waste Isolation Pilot Plant

Letter
=============================================================== LETTER


B-257988

December 27, 1994

Congressional Requesters

After pursuing, for a decade, a strategy for underground tests with
nuclear wastes in the Waste Isolation Pilot Plant (WIPP)--a proposed
repository for the disposal of transuranic wastes located near
Carlsbad, New Mexico--the Department of Energy (DOE) announced in
October 1993 that it was abandoning these tests in favor of
laboratory-based tests.\1 By making this change, DOE claimed it would
save about $139 million by January 2000 and begin disposing of the
wastes 2 years earlier than that date.  Accordingly, you asked us to
determine (1) if DOE's decision was scientifically sound and (2) if
DOE's projected cost and time savings were realistic.  You also asked
us to assess the current outlook for DOE's satisfying all remaining
technical and regulatory requirements.  As agreed with your offices,
we addressed the first two issues in this report.  Because DOE had
not completed its analysis of WIPP's fiscal year 1995 budget at the
time of our review, we will address the third issue in a subsequent
report. 


--------------------
\1 Transuranic wastes are certain nuclear wastes from the nation's
nuclear defense program, such as tools, paper, and rags, that are
contaminated with long-lived, radioactive elements having atomic
numbers higher than uranium. 


   RESULTS IN BRIEF
------------------------------------------------------------ Letter :1

The general consensus among scientists, experts, regulators, and
others interested in WIPP is that DOE's decision to discontinue its
planned underground tests with transuranic wastes is sound.  In spite
of numerous revisions to the planned tests, key scientific,
regulatory, and oversight groups continued to identify technical and
operational concerns with the tests.  For example, the Environmental
Protection Agency (EPA) questioned whether the tests would yield
information that was directly relevant to demonstrating compliance
with the agency's disposal standards.  Furthermore, with no
regulatory, operational, or scientific imperative for conducting
underground tests, many scientists, experts, regulatory bodies, and
interested groups support replacing the tests with laboratory tests
that appear to be scientifically viable and can be more safely
controlled. 

Although DOE's decision to abandon the underground tests is
considered to be sound, the Department's projected cost savings are
not justified for two reasons.  First, DOE said it would save $88
million by deferring annual payments of impact assistance to New
Mexico from 1994, when DOE had planned to begin waste tests in WIPP,
to 1998, when DOE now plans to receive the first waste at the
facility.\2 Because DOE will eventually make these payments, the
actual savings would be limited to the gain to the government from
DOE's making the payments 4 years later than DOE otherwise would
have; we estimate that the savings would be between $27 million and
$32 million.  Second, DOE lacked adequate support for other elements
of the estimated cost savings.  Documentation for many cost elements
was either incomplete or inconsistent. 

Two other factors also raise questions about the savings DOE
projected from its decision to substitute laboratory-based tests for
underground tests.  First, DOE had already concluded that budget
constraints would probably preclude it from requesting additional
funds that it considered essential for improving the underground
tests.  Thus, it is questionable if DOE could "save" funds that it
did not expect to request and receive.  Second, DOE may incur new
costs for initiatives in the Carlsbad area related to the
Department's decision to cancel the underground tests. 

Finally, DOE will not achieve its new objective of opening WIPP by
January 1998 instead of January 2000.  In fact, before DOE's October
1993 announcement, a senior manager had informed the Secretary of
Energy that disposal operations could "possibly" begin in 1998 but,
assuming no litigation, would "likely" begin in 2000.  Moreover, 2
months after the announcement, DOE extended the schedule for opening
WIPP by 5 months--to June 1998--and reduced the scope of initially
planned disposal operations.  Although that schedule remains in
effect, numerous unresolved issues, both within and beyond DOE's
control, could affect when DOE can eventually begin disposing of
wastes in the facility.  For example, it is unclear whether DOE's
schedule allows EPA sufficient time to review DOE's procedures and
decide if DOE has complied with EPA's regulatory requirements for
disposing of transuranic wastes in a repository. 


--------------------
\2 Economic impact assistance payments are moneys that DOE is
authorized to pay New Mexico, beginning with the fiscal year in which
the transport of transuranic waste to WIPP is initiated, to help
offset any financial burdens due to the operation of this
first-of-a-kind research facility. 


   BACKGROUND
------------------------------------------------------------ Letter :2

Transuranic wastes have been accumulating at DOE's nuclear defense
facilities since the 1940s.  Most transuranic wastes are either
buried in shallow pits or stored above ground.  After 1970, DOE and
its predecessor agencies began packaging transuranic wastes in
containers that could be stored for 20 years or more, pending their
permanent disposal. 

In December 1979, the Congress authorized DOE to build and operate
WIPP expressly to demonstrate the safe disposal of radioactive wastes
resulting from U.S.  defense activities and programs.\3 WIPP is
located about 26 miles east of Carlsbad, New Mexico, and lies in a
salt formation about 2,150 feet below the surface.  Construction of
the primary WIPP facilities, including surface facilities for
handling waste, shafts from the surface to the repository area, and
one of eight planned disposal areas, was completed in 1988. 

The 1992 WIPP Land Withdrawal Act (P.L.  102-579) required that
before WIPP can become a permanent waste repository, the
Administrator of EPA must certify that WIPP complies with EPA's
disposal regulations for radioactive wastes.  These standards set
limits on releases of radioactive materials into the environment and
on annual doses of radiation to people for 10,000 years after
disposal.  In addition, DOE must meet the disposal requirements for
hazardous wastes defined under the Resource Conservation and Recovery
Act of 1976, as amended (RCRA).  RCRA's requirements apply to these
wastes because well over 50 percent of DOE's inventory of transuranic
wastes is also believed to contain hazardous waste components. 

DOE plans to demonstrate regulatory compliance at WIPP through
"performance assessment," an analytical method for predicting the
behavior of WIPP for thousands of years and for estimating releases
of radiation and hazardous chemicals to the general environment.  The
performance assessment method will use mathematical models developed
and validated by information that DOE and its contractors--in
particular, Sandia National Laboratories and Westinghouse Electric
Corporation--are collecting through research and experimental
programs.  Part of DOE's overall research effort included plans to
study, by means of tests in WIPP, the behavior of transuranic wastes
to help determine WIPP's suitability for the permanent disposal of
waste. 

As of August 25, 1994, DOE had spent about $1.5 billion on
construction, research, and other activities at WIPP, or about $1.8
billion in constant 1994 dollars.  Annual funding for WIPP has
averaged $190.4 million over the last 2 fiscal years.  This amount
included about $11 million per year for organizations that provide
ongoing technical reviews of WIPP or are affected by WIPP's
activities, such as New Mexico's Environmental Evaluation Group, the
National Academy of Sciences' WIPP Committee, the Western Governors
Association, and various Indian tribes.  Funds for activities devoted
to planned underground testing in fiscal year 1993--the final year in
which DOE supported underground waste tests--represented about 20
percent of the total WIPP funds to be spent that year. 


--------------------
\3 Department of Energy National Security and Military Applications
of Nuclear Energy Authorization Act of 1980 (P.L.  96-164). 


   DECISION TO CHANGE TEST
   STRATEGY WAS CONSIDERED TO BE
   SOUND
------------------------------------------------------------ Letter :3

Many scientists, experts, regulators, and other interested groups
found DOE's decision to replace underground waste tests with
laboratory tests to be sound.  While many of these officials
initially supported the concept of testing transuranic wastes in
WIPP, DOE experienced numerous technical and operational problems
with its planned tests.  Although DOE several times redefined and
scaled back its plans for testing wastes in WIPP, regulators,
scientists, and others became increasingly concerned about (1) the
usefulness of the data that the tests would produce, (2) DOE's
limited success in resolving technical and operational concerns
associated with the tests, and (3) DOE's large, continuing investment
in money and time spent on the tests at the expense of other research
in WIPP.  DOE's shift in policy to laboratory tests was welcomed by
many scientists, regulatory bodies, and other interest groups.  Their
general belief was that DOE's revised strategy was scientifically
viable and appeared to be a promising avenue by which DOE could make
an informed judgment on regulatory compliance at WIPP. 


      DESPITE REVISIONS TO
      UNDERGROUND TESTING,
      SCIENTISTS' CONCERNS
      PERSISTED
---------------------------------------------------------- Letter :3.1

Although initial acceptance existed for the concept of tests in WIPP,
concerns by scientists and experts outside WIPP continued to mount
over technical and operational issues despite DOE's numerous
revisions to the test plans.  As DOE's test program evolved, DOE
changed the stated purpose of its proposed underground tests with
transuranic wastes as well as the quantities of wastes needed to
support the tests.  Early in the program, DOE had emphasized the need
to store as many as 125,000 55-gallon drums of wastes in WIPP. 
According to DOE, this large quantity was necessary to demonstrate
safe and efficient waste-handling techniques and, to a lesser degree,
to conduct tests to help determine WIPP's suitability as a waste
repository. 

But following the discovery that brine (water saturated with salt)
was seeping into WIPP from the repository's walls, scientists outside
WIPP raised concerns about WIPP's suitability for the permanent
disposal of waste.  The concerns centered on whether the interaction
of the brine and the wastes would form gases that could drive
contaminated wastes out of the repository and into the environment. 
Given the serious nature of the concerns, groups such as the National
Academy of Sciences' WIPP Panel (the predecessor of the WIPP
Committee) urged DOE to study this issue more fully before storing
large quantities of wastes in WIPP. 

DOE responded, in April 1990, with a more modest test plan focused on
collecting primary gas generation data from two types of underground
tests.  First, DOE would measure gases from wastes put in specially
instrumented metal test containers, called bins.  Second, DOE would
measure gases from drums of wastes stored in smaller-scaled disposal
rooms, or alcoves, in WIPP. 

However, DOE again faced technical and operational difficulties.  DOE
could not develop and test an effective method for sealing the
alcoves and ensuring accurate gas measurements.  Also, DOE's planned
test for studying the behavior of waste in certain bins injected with
brine could not be performed without the risk of accidentally
contaminating the repository.  Furthermore, safety and operational
concerns were expressed by key scientific and oversight review
groups, such as the National Academy of Science's WIPP Panel and a
blue ribbon panel established by former Secretary of Energy James D. 
Watkins, who initially had agreed that DOE should conduct the tests. 
Therefore, by early 1993, DOE had again changed the emphasis of its
underground tests for assessing WIPP's performance.  The emphasis was
changed from obtaining primary data to obtaining supporting data that
would confirm other information collected from laboratory tests. 


      DOE ABANDONED UNDERGROUND
      TESTING
---------------------------------------------------------- Letter :3.2

After subsequent critical reviews from EPA, DOE's own review team,
the Academy's WIPP Panel, and others, DOE ultimately changed its test
strategy to eliminate underground testing with wastes and replaced it
with laboratory tests.  For example, EPA identified problems with the
plans for testing wastes underground that DOE had submitted to EPA
for review and approval.  Under the 1992 Land Withdrawal Act, such
underground tests had to provide data "directly relevant" to a
certification of compliance with EPA's radiation standards or to
compliance with RCRA.  Following DOE's submission of its plans to EPA
in March 1993, EPA reported that the test plans were incomplete
because they lacked technical details on certain design plans and
tests.  A key unresolved issue was whether the data that DOE would
collect from its underground tests would be directly relevant to
determining compliance with EPA's standards. 

In April 1993, at the request of DOE management, the WIPP program
initiated the Contingency Test Task Force to review potential
alternatives to the underground testing approach.  In mid-1993, while
still pursuing its plans for testing wastes underground, DOE
management also called for a comprehensive, independent review of the
testing approach.  The review team, consisting of a DOE team leader,
DOE contractor staff, and private consultants not involved with the
WIPP test program found significant technical shortcomings with the
waste tests.  It also found no regulatory, operational, or scientific
imperative for the tests to be conducted underground.  The team
anticipated that laboratory tests would be an effective substitute
and therefore recommended that DOE abandon the underground tests. 

During September 1993, DOE weighed improving the underground waste
tests against eliminating them altogether.  Faced with considerable
criticism of the underground testing strategy, including the results
of its own independent review, DOE announced in October 1993 that it
would eliminate these underground tests in favor of additional
laboratory tests using real and simulated transuranic wastes.  In the
long run, DOE said, the new approach would be cheaper and faster to
implement and would address criticisms made by the National Academy
of Sciences, other reviewers, and stakeholders about the underground
waste tests.  DOE's decision was consistent with positions we had
expressed in earlier testimony and reports.  (See app.  V for a list
of GAO products on this topic.)


      EXTERNAL PARTIES SUPPORTED
      DOE'S DECISION
---------------------------------------------------------- Letter :3.3

Scientific, technical, and regulatory experts as well as state and
local community groups agreed with DOE's decision to eliminate the
underground tests.  For example, EPA supported DOE's decision,
stating that performing laboratory tests was a more effective and
efficient means for DOE to reach a final decision on WIPP's
suitability as a repository.  Similarly, the National Academy of
Sciences' WIPP Committee stated that the new DOE strategy was a
significant step in the right direction and appeared to address
concerns that the former WIPP Panel had raised in a 1992 report.  In
that report, the Panel noted that DOE had not convincingly justified
its proposed tests and that DOE's concentration on these tests
diverted time and resources away from other critical research. 
Finally, New Mexico's Environmental Evaluation Group reiterated its
long-standing position that many of DOE's proposed underground waste
tests could have been done in the laboratory, which would have
allowed earlier collection of gas generation data.  (App.  I further
discusses the evolution of DOE's plans for testing wastes underground
and various perspectives on the changes.)


   DOE'S PROJECTED SAVINGS ARE NOT
   JUSTIFIED
------------------------------------------------------------ Letter :4

DOE has not justified most of the $139 million in savings that it
attributed to its decision to abandon the underground tests in favor
of laboratory-based tests.  The largest component of the estimated
savings ($88 million) related to the deferral of certain payments to
New Mexico that are to begin with the first shipment of transuranic
wastes to WIPP for testing or disposal.  Deferring these payments, as
DOE claimed, would reduce previously planned expenditures by $88
million by the beginning of 1998; however, the payments would still
be made in future years.  Therefore, the real savings are limited to
the difference in the present value of the payments that would be
made under the old and the new plans for completing waste tests in
WIPP and for beginning to dispose of waste at the facility. 
Moreover, the support that DOE provided us with for the remaining
elements of its projected savings was often incomplete, inconsistent,
or altogether lacking. 

Furthermore, documentation from DOE strongly indicated that budget
constraints would probably preclude DOE from requesting $66 million
in additional funds that it considered essential for improving the
underground tests.  Thus, deciding not to pursue the improved
underground test program did not "save" $66 million because DOE did
not expect that it would have included these additional funds in
future budget requests.  Finally, DOE may incur up to $10.6 million
in additional costs, such as increased funding commitments to the
local Carlsbad community, that related to DOE's decision to abandon
the waste tests. 


      DOE ESTIMATED $139 MILLION
      IN TOTAL SAVINGS
---------------------------------------------------------- Letter :4.1

DOE's projection of cost savings was based on a comparison of two
options.  Under option 1, the anticipated annual operating budgets
for WIPP would be increased to make improvements to the plans for
testing wastes underground.  Under option 2--laboratory testing--the
anticipated budgets would be reduced by replacing the underground
tests with a program of enhanced laboratory tests and other related
activities.  In calculating the estimated costs of the two options,
DOE began with its anticipated budgets for fiscal years 1994 through
2000.  These budgets included, among other things, the costs to
support ongoing and planned activities related to DOE's proposed
underground tests at WIPP.  For this 7-year period, DOE's total
anticipated budget was over $1.5 billion.  For option 1, DOE added to
the budgets the additional costs it believed were necessary to
improve the underground tests.  For option 2, DOE added to the
budgets the additional costs associated with the new test strategy
and subtracted the costs it believed it would avoid under the option. 
Table 1 shows DOE's calculation of the $139 million in costs savings
by choosing option 2 over option 1. 



                           Table 1
           
               DOE's October 1993 Comparison of
           Estimated Costs for Option 1 and Option
                       2 Test Programs

                    (Dollars in millions)

Cost element
-----------------------------  -----------------------------
Option 1
------------------------------------------------------------
Total anticipated WIPP
budget,                        $1,538
fiscal years 1994-2000

Additional cost of
modifications for
underground                    66
waste testing

============================================================
Total                          $1,604


Option 2
------------------------------------------------------------
Total anticipated WIPP
budget,                        $1,538
fiscal years 1994-2000

Additions to budget

Enhanced laboratory tests      18
Accelerated compliance         9
New work scope                 21
Staff retraining               3
Disposal phase readiness       8

============================================================
Subtotal                       $59

Deletions from budget

Radioactive wastes
operations and support
activities related to the
underground waste tests        (44)
New Mexico impact assistance   (88)

============================================================
Total                          $1,465

============================================================
Savings, option 2 over option  $139
1
------------------------------------------------------------
Source:  Briefing paper on alternative costs by DOE's Office of
Environmental Management, Sept.  26, 1993. 

As shown in table 1, the largest item in DOE's cost savings
projection was its deletion from the anticipated budget for WIPP of
$88 million in impact assistance payments to New Mexico.  The WIPP
Land Withdrawal Act authorized the Secretary of Energy to pay New
Mexico $20 million a year for 15 years, beginning with the fiscal
year in which the transport of radioactive wastes to WIPP is
initiated.\4 Prior to the act's passage, DOE had made commitments to
New Mexico under which DOE intended to annually request from the
Congress the authority and funding to make continual impact
assistance payments to the state.  Under option 1, DOE would have
made impact assistance payments to New Mexico beginning in fiscal
year 1994, when WIPP was scheduled to receive wastes for underground
tests.  Under option 2, the payments would not begin until fiscal
year 1998, when DOE expected to begin receiving transuranic wastes
for permanent disposal in WIPP. 

The remainder of DOE's estimated savings ($51 million) was based on
costs avoided by eliminating improvements to the underground tests
($66 million) and related operations and support costs ($44 million),
which were offset by the new scope of work for the laboratory-based
tests ($59 million). 


--------------------
\4 The act also authorized annual adjustments for inflation after the
first fiscal year, which DOE took into account when calculating the
total amount of impact assistance deferred.  Hence, the amount that
DOE subtracted is more than $80 million for the 4-year period from
1994 through 1997. 


      PROJECTED SAVINGS ARE NOT
      JUSTIFIED
---------------------------------------------------------- Letter :4.2

DOE's projected cost savings are not justified for two reasons. 
First, when DOE estimated that its new testing approach would result
in deferring $88 million in impact assistance payments, it claimed
that amount as the savings created over the course of the revised
test program, which is projected to end in 1997.  These payments,
however, would be made later.  Therefore, we believe that a more
appropriate method of estimating the savings resulting from deferring
the impact assistance payments is to limit the estimated amount to
savings that the government would receive if DOE made these payments
later than it otherwise would have.  A widely accepted method of
estimating this gain is to compare the present values of each stream
of payments.  Accordingly, we estimate that the 1994 present value of
the savings resulting from deferring impact assistance payments is
between $27 million and $32 million.\5 Although the payments would
begin 4 years later as a result of DOE's decision to change its test
program, a total of 15 annual payments would still be made to New
Mexico because DOE anticipates that disposal operations in WIPP will
last about 25 years. 

Second, DOE's documentation supporting the remaining items in its
projected cost savings (1) often did not match the figures that DOE
had used in its analysis, (2) was incomplete or absent, or (3) was
based on the professional judgment of DOE personnel.  For example,
there were inconsistencies in DOE's support for the $21 million cost
of the new scope of work supporting the enhanced laboratory program
under option 2.  Likewise, DOE produced several documents that
supported the cost of option 1.  These costs, however, varied widely
from the $66 million cost that DOE claimed was necessary to improve
testing under option 1.  (App.  II discusses DOE's limited support
for these and other cost items.)


--------------------
\5 In calculating the present values of future streams of payments,
we discounted the future impact assistance payments to their 1994
present values by applying a "real" discount rate to the anticipated
payments before they were adjusted for inflation.  Because the
payments were not adjusted for inflation, a real discount rate, which
adjusts only for the time value of money and not for inflation, is
appropriate.  We estimated the real discount rate by subtracting the
rate of expected inflation from the prevailing interest rate for
federal borrowing, a method which yielded a range of 3 to 4 percent. 


      OTHER FACTORS AFFECT DOE'S
      CLAIMED SAVINGS
---------------------------------------------------------- Letter :4.3

Two other factors also raise questions about the savings that DOE
projected from its decision to substitute laboratory-based tests for
underground tests.  First, DOE had not included in its anticipated
budgets the $66 million that it had estimated was needed to improve
the planned underground tests under option 1.  In fact, DOE's
documentation strongly suggested that budget constraints would
probably preclude DOE from requesting these additional funds. 
According to a May 1993 memorandum from the director of the WIPP
Project Integration Office, a careful analysis of WIPP's budget
showed that DOE had obtained its peak funding for the WIPP program
and that future budgets would continue at a level reflecting
increases for inflation only.  Thus, it is questionable whether DOE
could "save" funds that it did not expect to request and receive. 

DOE's Director of the WIPP Program disagreed with this position.  The
director stated that if DOE had selected option 1, its senior
management would have sought the additional budget requirements. 
However, other documents we obtained during our review tend to
confirm our analysis that it was unlikely that future budgets for
WIPP would have been increased to meet the funding requirements for
option 1. 

Second, DOE may incur more than $10 million in other costs related to
WIPP that are not directly associated with DOE's old or new test
strategy but would nevertheless result, at least in part, from the
change in strategy.  Since the change, for example, DOE has committed
over $9 million to enhance economic development in the Carlsbad area
because of citizens' concerns about the economic impact of
discontinuing the underground testing.  (App.  II discusses these
costs in more detail.)


   DOE WILL NOT MEET ITS OCTOBER
   1993 PROJECTED SCHEDULE
------------------------------------------------------------ Letter :5

Although DOE claimed in October 1993 that its change in test strategy
could accelerate, by 2 years, its proposed schedule for opening WIPP,
the prediction proved to be unrealistic and faces numerous
uncertainties.  The analysis supporting DOE's decision to change the
test strategy stated that DOE could begin disposal operations at WIPP
in January 1998 rather than January 2000.\6 DOE believed that it
could accelerate the schedule for two reasons.  First, DOE believed
it would be able to collect supporting experimental data faster under
the revised testing program.  And second, DOE believed that it would
no longer have to obtain EPA's advance approval of plans for the
underground testing and retrieval of transuranic wastes in WIPP.  DOE
had estimated that EPA's review and approval of these plans would
take about 10 months. 

DOE's accelerated schedule, however, was very optimistic.  Prior to
announcing the accelerated schedule, for example, DOE's Assistant
Secretary for Environmental Management stated, in a memorandum to the
Secretary of Energy, that it was "possible" to open WIPP 2 years
earlier under the new test strategy.  However, the Assistant
Secretary also predicted that waste operations would "likely" begin
in 2000, assuming that no lawsuits would further delay the
repository's opening.  Also, according to the former Planning and
Administrative Branch Chief of the WIPP Project Integration Office,
the 1998 date assumed the best possible circumstances leading to a
disposal decision and assumed that DOE would not encounter any
bottlenecks in dealing with regulators or other participating
organizations.  He said that DOE would have to be extremely fortunate
to arrive at a decision by 1998. 

Shortly after developing the schedule, DOE quickly realized that the
schedule was very optimistic.  In December 1993, DOE added 5 months
to the accelerated schedule and cut back the proposed scope of the
initial disposal operations.  Since that time, DOE has been
reassessing its plans for WIPP. 

Finally, unresolved issues could affect DOE's accelerated schedule. 
For example, DOE may have underestimated the time necessary for EPA
to review and approve DOE's application for compliance with EPA's
regulatory requirements.  DOE projected that EPA's review and
approval of the final application would take 12 months.  An EPA
official told us, however, that approval could take up to 16 months
because of EPA's desire to obtain public comments on such
proceedings, which is often a lengthy process. 

Another important unresolved issue is DOE's ability to identify the
important physical and chemical properties of the types of
transuranic and hazardous wastes it intends to dispose of in WIPP. 
The identification of these properties is critical in order for DOE
to document compliance with EPA's regulations and for EPA to decide
whether it will certify DOE's compliance decision.  Still another
unresolved issue is the adequacy of program resources, both funding
and staffing, to accomplish the steps necessary to support the
accelerated schedule.  (App.  III discusses DOE's schedule-related
uncertainties in greater detail.)


--------------------
\6 We did not evaluate the reasonableness of DOE's estimate that it
would be able to begin waste storage operations at WIPP in January
2000, had it continued to pursue its former strategy of performing
underground tests in WIPP. 


   AGENCY COMMENTS AND OUR
   EVALUATION
------------------------------------------------------------ Letter :6

We provided a draft fact sheet reflecting the contents of this report
to DOE and then met with the Department's Director of the WIPP
program and other officials in the program to obtain their comments. 
We also provided a draft fact sheet to EPA and met with the agency's
Director, Criteria and Standards Division, Office of Indoor Air and
Radiation, and other agency officials to obtain their comments.  The
EPA officials agreed with the facts contained in our draft fact
sheet.  As requested, we did not obtain written agency comments on
the report. 

The DOE officials agreed that many components of DOE's estimated cost
savings were preliminary but added that these estimates were based on
the best information available at the time they were made.  They
disagreed with our analysis of the savings resulting from deferring
payments of impact assistance to New Mexico.  They pointed out that
DOE had claimed savings only for the period from 1994 through 2000
and that the $88 million in deferred payments represents budgetary
savings for that period.  In our opinion, a meaningful measure of the
true effects of deferring the assistance payments--rather than
avoiding them entirely--can be determined only by looking at the
impacts throughout the entire affected period, as we have done. 

The DOE officials also stated that if cost savings are to be
estimated over a time period that includes the operation of WIPP,
then other long-term savings should also be included in the analysis. 
For example, by opening WIPP 2 years earlier than planned, DOE might
save on the order of $200 million in operating costs over the life of
the facility.  The scope of our review, however, was limited to
evaluating the estimated savings that DOE had announced, and DOE's
savings did not include potential reductions in operating costs. 

In addition, the DOE officials stated that there was no direct cause
and effect relationship between DOE's decisions to cancel the planned
underground waste tests and to increase economic assistance to the
Carlsbad area.  We added additional information to the report to show
that there indeed was such a relationship. 

Although the DOE officials acknowledged uncertainty about achieving
DOE's accelerated schedule for WIPP, they also stated that had DOE
decided to continue the former testing approach, any slippage in the
schedule would also have affected the former schedule.  Therefore,
they said that the 2-year advantage provided by the new program would
be a constant.  As stated earlier, we did not review the
reasonableness of the former schedule. 

On the basis of the comments discussed above and other comments made
by DOE officials of the WIPP program, we made appropriate changes to
clarify and update our report. 


---------------------------------------------------------- Letter :6.1

We conducted our review from February through December 1994 in
accordance with generally accepted government auditing standards. 
Appendix IV provides more information on our scope and methodology. 

As arranged with your offices, unless you publicly announce its
contents earlier, we plan no further distribution of this report
until 30 days after the date of this letter.  At that time, we will
send copies to appropriate congressional committees; federal
agencies; the Director, Office of Management and Budget; and other
interested parties.  We will also make copies available to others on
request. 

Please contact me at (202) 512-3841 if you or your staff have any
questions.  Major contributors to this report are listed in appendix
VI. 

Victor S.  Rezendes
Director, Energy and

List of Requesters

The Honorable Floyd D.  Spence
Ranking Minority Member
Committee on Armed Services
House of Representatives

The Honorable Don Young
Ranking Minority Member
Committee on Natural Resources
House of Representatives

The Honorable Carlos J.  Moorhead
Ranking Minority Member
Committee on Energy and Commerce
House of Representatives

The Honorable Michael Bilirakis
Ranking Minority Member
Subcommittee on Energy and Power
Committee on Energy and Commerce
House of Representatives

The Honorable Dan Schaefer
Ranking Minority Member
Subcommittee on Oversight and
 Investigations
Committee on Energy and Commerce
House of Representatives

The Honorable J.  Dennis Hastert
Ranking Minority Member
Environment, Energy, and Natural
 Resources Subcommittee
Committee on Government Operations

The Honorable Jon Kyl
Ranking Minority Member
Panel on Military Applications
 of Nuclear Energy
Committee on Armed Services
House of Representatives

The Honorable Michael D.  Crapo
House of Representatives


EVOLUTION OF DOE'S DECISION TO
ABANDON UNDERGROUND TESTING
=========================================================== Appendix I

Many scientists, regulators, and others interested in the Waste
Isolation Pilot Plant (WIPP) initially agreed with the concept of
testing transuranic wastes underground in the facility and did not
oppose the Department of Energy's (DOE) efforts to conduct such
tests.\1 In trying to implement these tests, however, DOE discovered
that it could not establish that the tests were essential to
demonstrating compliance with the Environmental Protection Agency's
(EPA) disposal regulations for radioactive and hazardous wastes. 
Furthermore, because of mounting technical concerns about the tests,
DOE continued to change its plans for testing waste underground in
WIPP.  In the end, however, DOE had not satisfied EPA's and others'
lingering questions about the need for underground tests with
transuranic wastes. 

DOE's October 1993 decision to direct the test program away from
underground tests with transuranic wastes to laboratory-based tests
was endorsed by many members of the scientific community, regulators,
and other organizations. 


--------------------
\1 Transuranic wastes are certain nuclear wastes from the nation's
defense program such as tools, paper, and rags that are contaminated
with long-lived, radioactive elements having atomic numbers higher
than uranium. 


   DOE'S RATIONALE FOR PROPOSED
   UNDERGROUND TESTING CHANGED
   OVER TIME
--------------------------------------------------------- Appendix I:1

As the WIPP program evolved, the stated purpose of the underground
tests with wastes changed as did the quantities of wastes that DOE
said would be needed to support them.  In the early years of the
program (1983 through 1988), DOE's plans centered on storing 125,000
55-gallon drums of transuranic wastes in WIPP to conduct a
large-scale "operations demonstration" of efficient and safe
waste-handling techniques and, to a lesser degree, to evaluate the
proposed repository's suitability for the permanent disposal of
waste.\2 However, scientists and experts--such as the National
Academy of Sciences' WIPP Panel and New Mexico's Environmental
Evaluation Group--thought that DOE had placed too much emphasis on
storing large quantities of waste underground before demonstrating
that WIPP could meet EPA's disposal standards.\3 Furthermore, these
scientists noted that DOE had not clearly defined how the underground
tests with wastes would demonstrate compliance with EPA's standards. 

In 1986 and 1987, scientists' discovery that brine (water saturated
with salt) was seeping onto the walls of WIPP's underground
area--when the facility was expected to be dry--raised questions
about the facility's suitability for the disposal of transuranic
wastes.  A panel of New Mexico scientists advanced the theory that
EPA's disposal standards might be violated at WIPP because (1) the
repository would become saturated with brine soon after closure, (2)
the interaction of the waste and the brine would stimulate the
production of gases within the disposal rooms, (3) the combination of
gas build-up and salt "creep" (i.e., the inward movement of the
surrounding rock to fill in open spaces) would eventually pressurize
the gases in the repository, and (4) the pressurized gases would
drive contaminated wastes out of the repository and into the general
environment.  Possible ways that such wastes could escape were
through fracturing in the salt and adjacent rock formations or
through inadvertent human intrusion, such as oil exploration sometime
in the future. 

WIPP advisory groups such as the National Academy of Sciences' WIPP
Panel urged DOE to study the brine inflow and the possibility of gas
generation at WIPP and, in the interim, to limit the quantity of
wastes stored at WIPP to the minimum necessary to demonstrate
compliance with EPA's disposal standards.  Also, we along with
others, recommended in 1989 that DOE provide the Congress with the
technical justification for storing wastes in WIPP, including the
justification for the quantities of such wastes to be used for tests,
DOE's plans for the retrieval of such waste, and the identification
of alternative storage sites if retrieval becomes necessary.\4

As suggested by several parties, DOE reduced the scope of planned
underground tests with wastes in 1989 and 1990 and significantly
reduced the quantities of waste that would be used for these tests. 
Also, DOE developed more detailed underground test and waste
retrieval plans and indefinitely postponed a large-scale operations
demonstration.  In April 1990, DOE published a test plan describing
two types of underground waste tests to study gas generation for the
radioactive components of transuranic wastes and the hazardous waste
components regulated under the Resource Conservation and Recovery Act
(RCRA).  DOE maintained that it was necessary to perform the
following tests over a 5-year test phase: 

Bin tests--tests to be done in specially instrumented and sealed
metal containers (bins), each holding about six 55-gallon drums of
contact-handled transuranic wastes.\5

DOE planned to use 124 bins of waste (the equivalent of about 600
drums) to answer questions about the types and quantities of gases
such as hydrogen that would be generated from transuranic wastes as
they degrade in a repository environment characterized by brine.  DOE
planned to introduce different materials into the bins that would
potentially generate gas into combinations of possible environments
expected at WIPP (dry, wet, with or without oxygen, and with or
without added materials thought to inhibit gas production).  Among
other things, DOE maintained that the tests were necessary to more
accurately predict synergistic effects of different gas production
mechanisms. 

Alcove tests--tests to be done on a larger scale, that is, in rooms
one-third the size of a normal disposal room in WIPP.  Six alcoves
were to be filled with about 3,900 drums of contact-handled
transuranic wastes and the entrances of the rooms were to be
sealed.\6 DOE said that the tests were necessary to approximate the
impacts of the actual repository environment on the wastes as they
degrade over time. 

Both the bin and alcove tests would also provide information to
verify DOE's demonstration that hazardous materials would not migrate
from the repository over the short- and long-term and to test
potential waste treatment solutions, should they be required to bring
WIPP into compliance with EPA's regulations. 


--------------------
\2 Of the 125,000 drums, DOE was to use 100,000 drums to support an
operations demonstration and 25,000 drums for experiments related to
WIPP's compliance with regulations. 

\3 EPA originally developed pertinent radiation standards in 1985 and
amended them in 1993. 

\4 Nuclear Waste:  Storage Issues at DOE's Waste Isolation Pilot
Plant in New Mexico (GAO/RCED-90-1, Dec.  8, 1989). 

\5 There are two types of transuranic wastes in DOE's
inventory--contact-handled wastes, which are generally stored in
55-gallon metal drums and can be moved by workers without additional
protection, and remote-handled wastes, which require special
shielding to protect workers and the public from hazardous exposure. 

\6 One of the alcoves was to remain empty to provide "baseline"
(reference) data on the conditions of the disposal rooms. 


   OPERATIONAL AND TECHNICAL
   DIFFICULTIES IMPEDED DOE'S
   IMPLEMENTATION OF UNDERGROUND
   WASTE TESTS
--------------------------------------------------------- Appendix I:2

The Secretary of Energy determined in June 1990 that WIPP was the
most suitable place to perform the bin tests and recommended that DOE
begin the tests with waste in the facility.  Early in the program,
however, DOE encountered numerous operational and technical problems
associated with these tests, such as the following: 

Planned tests involving injection of brine into the bins could not be
safely performed underground because of the risk of accidentally
contaminating the repository. 

The metal bins were not designed to accommodate high gas pressure. 
Also, to meet EPA's RCRA requirements, DOE had to limit the
concentration of explosive gases (such as hydrogen) that would build
up in the bins.  To accomplish this, the bins would require the
frequent purging of gases.  However, scientists maintained that
purging would introduce sampling errors into the gas generation data
that DOE would collect from the bins. 

Because DOE did not plan to test the bins at high gas pressure, some
scientists did not expect these tests to provide DOE with useful data
on anticipated, long-term conditions in the repository. 

EPA and oversight groups wanted the waste contents of the bins to
statistically represent DOE's transuranic waste inventory and to
present acceptable handling and storage risks.  For these reasons,
identifying the important chemical and physical properties of the
waste (i.e., characterizing) and loading the bins took much longer
than DOE had anticipated.  From 1991 through 1994, according to DOE
officials, DOE characterized only seven bins at a cost of about $1
million per bin. 

The movement of salt rock surrounding the waste disposal rooms at
rates three times faster than DOE originally predicted (salt creep)
led to several large rock falls in the facility.  Scientists and the
state of New Mexico were concerned that the instability of rooms in
the facility might pose a threat to workers and to the retrievability
of the waste.  To address these concerns, DOE spent over $1 million
in installing a roof support system in one of the disposal rooms to
be used for the bin tests. 

The planned alcove tests also experienced technical setbacks.  In
particular, DOE had not demonstrated an effective method of sealing
the room entrances to ensure the accurate identification and
measurements of the gases that would form in the rooms.  DOE spent
several years and over $2 million in trying to develop an effective
alcove-sealing and gas-sampling system, but it was still unclear
whether DOE's proposed seal design would have withstood rock
fracturing at WIPP.  And even if effective seals could be designed,
experts raised questions about whether the planned duration of the
tests would allow enough time for sufficient quantities of gases to
form to provide meaningful measurements. 

Key WIPP scientific and oversight review groups were disappointed
with DOE's slow progress in conducting the proposed underground waste
tests and still had concerns about the operational and technical
aspects of the tests.  In April 1991, for example, the National
Academy of Sciences' WIPP Panel said the planned bin tests were
consuming far more resources than anticipated, but were not
proceeding at a rate fast enough to yield meaningful information
within the schedule.  Such delays, the Panel's Chairman stated, may
further shorten the time available for measuring gas generation
within the repository and thus increase the uncertainty associated
with the data that would be collected. 

Members of a blue ribbon panel, commissioned by the Secretary of
Energy from 1989 through 1991 to review DOE's test program, also
expressed concerns.  Although the panel initially endorsed the
underground tests with wastes and believed that WIPP was the best
available place to do them, two panel members acknowledged, as their
study progressed, that DOE had to resolve many operational and safety
issues associated with the tests.  For example, DOE had not developed
a procedure for safely sampling the waste/brine contents in the bins. 
Also, in August 1991, three of the five panel members reported to DOE
that because the sealing problems had seriously set back the alcove
tests, DOE might have to do those tests elsewhere.  Furthermore, they
did not expect the alcove tests to provide much new information on
the long-term safety of WIPP. 

In June 1992, the Academy's WIPP Panel commented that the bin tests,
as DOE had designed them, had no discernable scientific basis and
probably would not yield meaningful information for assessing the
facility's performance as a repository.  Finally, the Academy's Panel
noted that DOE was not giving other critical research areas timely or
adequate attention.  That same year, New Mexico's Environmental
Evaluation Group commented that DOE's continued preoccupation with
implementing its bin and alcove test plans had diverted attention
from the data collection and analysis that DOE needed to reach a
decision on WIPP's suitability as a permanent repository. 

By the end of 1992, DOE had scaled back the bin test program so that
19 bins (about 95 drums) of transuranic wastes would be tested, with
the possibility that another 25 bins could be tested.  Earlier that
year, DOE's own scientific advisor for WIPP--Sandia National
Laboratories--stated that the alcove tests were no longer essential
for demonstrating WIPP's compliance with EPA's radiation disposal
standards.  However, DOE and Sandia continued to support transuranic
waste tests in at least one alcove primarily to measure gases related
to compliance with RCRA.  In March 1993, at the suggestion of the
Academy, DOE took its bin tests off the "critical path" of its
schedule for opening WIPP.  In a revised test plan issued that same
month, DOE stated that the focus of these tests had changed from
providing a "primary," or direct, source of data for the performance
assessment to a "secondary" source of data for confirming gas
generation data collected from ongoing laboratory tests.  Data from
the laboratory tests would be used as the primary data in the
performance assessment. 

In the revised plan, DOE distinguished between two types of bins that
it would use for tests:  a "type 1," or low-pressure, bin designed to
replicate anticipated conditions for the period immediately after the
facility is closed and a "type 2," or higher-pressure, bin intended
to simulate anticipated conditions in the repository over longer
periods of time.  DOE said that it would need 19 to 44 bins of
varying types of contact-handled transuranic wastes for "specifically
planned tests" and in the event that additional tests were required. 
DOE also noted that one alcove filled with about 1,000 drums of
unmodified transuranic wastes would be tested, and that possibly one
other alcove would be targeted for additional tests. 


   EPA FOUND DOE'S UNDERGROUND
   TEST PLAN INCOMPLETE
--------------------------------------------------------- Appendix I:3

About the same time that DOE was refining its test plan, the Land
Withdrawal Act of 1992 was enacted, mandating that EPA must approve
DOE's (1) plans for performing tests with waste in WIPP and (2) DOE's
plans for retrieving such waste before the Department could begin
underground tests with transuranic wastes.  In March 1993, DOE
submitted revised test and retrieval plans to EPA for its review. 

In May 1993, after a preliminary review of DOE's submittal, EPA
informed DOE that its test plan was incomplete.  Among other things,
EPA noted a lack of technical detail in the plans for underground
tests.  For example, DOE had not submitted design plans to EPA for
the type 2 bins nor had it completed many of the details of the
alcove tests, such as a specific test plan, the fabrication of an
alcove entrance seal, and gas management/sampling systems.  Also, EPA
observed that DOE's justification for the bin and alcove tests was
not linked to EPA's radiation standards, which raised a question of
whether the tests would yield information "directly relevant" to
compliance with EPA's radiation standards.\7

In attempting to address EPA's concerns, DOE submitted additional
information to EPA in June 1993.  However, DOE's internal
correspondence in early August 1993 noted that EPA still had
outstanding questions about the test plans, including clarification
of the linkage of the tests to the WIPP performance assessment and
the "directly relevant" issue. 


--------------------
\7 According to an EPA official, EPA never formally defined what is
meant by "directly relevant" in its radiation standards.  This
official stated that had DOE continued to pursue underground testing
in WIPP, EPA would likely have had to clarify the term "directly
relevant" through a future rulemaking. 


   DOE REVERSED TESTING STRATEGY
--------------------------------------------------------- Appendix I:4

While DOE continued to pursue its underground test strategy, in July
of 1993, it also reassessed the need for the underground transuranic
waste tests and eventually reversed its position.  In late July 1993,
DOE held a program "summit" on WIPP, to give interested scientists,
regulators, and other groups an opportunity to meet and discuss
various test program issues.  Participants raised many concerns
paralleling those of EPA.  For example, some participants said that
at best, the bin and alcove tests were not designed to yield
meaningful information for the performance assessment and, at worst,
were unnecessary.  Some participants also believed that the tests
would take too much time, be expensive, or not yield results when
needed. 

In September 1993, a team comprising a DOE official, staff of DOE
contractors, and private consultants not involved with the WIPP
testing program completed a review of the need for, and the technical
validity of, the bin and alcove tests.  The review team concluded
that there was no operational, regulatory, or scientific imperative
that the bin and alcove tests with transuranic wastes be conducted in
WIPP.  The team also found that laboratory tests such as (1)
larger-scale tests using off-the-shelf or custom-built equipment with
simulated radioactive wastes and (2) smaller-scale tests using actual
transuranic wastes would explain both the effects of individual
gas-generation mechanisms and the synergistic effects of combining
different waste materials.  The team recommended that DOE drop the
bin and alcove tests and initiate the laboratory-testing activities
in their place. 

In the same month, senior managers at DOE weighed whether to improve
the underground tests or to abandon them.\8 For example, they
considered increasing the bin design pressure through more costly
modifications.  In an October 7, 1993, memorandum, DOE's Assistant
Secretary for Environmental Management informed the Secretary of
Energy that EPA might not approve DOE's underground test plan ".  . 
.  because of its [the plan's] perceived failure to demonstrate a
clear relationship between the proposed waste tests and regulatory
requirements .  .  .  and EPA may have a great deal of difficulty
concluding the tests will in fact provide data that is 'directly
relevant' to demonstrating compliance.  .  .  ." The Assistant
Secretary also stated that the alcove program had little chance of
meeting the "directly relevant" standard and, therefore, had been
removed from the current test plan. 

On October 21, 1993, DOE announced the elimination of the underground
tests and replaced them with additional laboratory tests using both
simulated and real transuranic wastes. 


--------------------
\8 In April 1993, the WIPP project had set up a group--The
Contingency Test Task Force--to identify potential alternatives to
the underground waste tests at WIPP in case DOE decided not to go
ahead with the waste tests in WIPP.  This, along with the results of
the independent technical review, was provided to DOE management for
its consideration. 


   OUTSIDE GROUPS SUPPORTED CHANGE
   IN WIPP'S TESTING STRATEGY
--------------------------------------------------------- Appendix I:5

Regulators, experts, and others interested in WIPP generally
supported DOE's decision to abandon the underground tests with
transuranic wastes.  For example, in a press advisory dated October
22, 1993, EPA stated that performing laboratory tests in lieu of the
underground waste tests is a more efficient and effective means for
DOE to arrive at a final disposal decision on WIPP.  The Director of
EPA's Office of Radiation and Indoor Air told us that in October
1993, DOE's Assistant Secretary for Environmental Management met
EPA's Deputy Administrator prior to the decision.  According to the
Director, EPA agreed to support, in principle, DOE's decision to
abandon the underground tests because of the substantial
incompleteness of DOE's plans for bin and alcove tests.  Also, EPA
believed that the waste tests could be controlled more carefully in a
laboratory setting rather than in WIPP.  The Director emphasized that
the decision to abandon the tests was DOE's alone and that from EPA's
viewpoint, there was no regulatory imperative that DOE emplace
transuranic wastes in WIPP to demonstrate compliance with EPA's
radiation standards. 

EPA had previously supported the concept of underground testing in
WIPP and, in fact, recommended in late 1989 that DOE fill two
instrumented test rooms with waste in order to continually monitor
compliance with EPA's radiation standards.  However, the Director of
the Criteria and Standards Division of EPA's Office of Radiation and
Indoor Air said that following the passage of the Land Withdrawal
Act, EPA's perspective changed.  Consequently, EPA had to ensure that
DOE fulfilled the statutory requirements of the act.  Because DOE's
underground test plans were so incomplete, the director said, EPA
could not continue to review DOE's plans for underground tests and
retrieval of waste unless DOE provided EPA with additional
information on the tests. 

Several technical review and oversight groups also supported DOE's
decision to cancel the underground tests. 

The National Academy of Sciences' WIPP Committee (formerly the WIPP
Panel), in an October 21, 1993, press release, stated that the new
DOE strategy appeared to address many of the Academy's concerns about
the old test program and was a "significant step in the right
direction." Two members of the WIPP Committee told us that it was
apparent that DOE would have had continued difficulties had it stayed
on its course of pursuing its underground test plans and that the
value of the underground tests with transuranic wastes as DOE had
designed them had become highly questionable.  They stated that the
program's new test strategy appeared promising, although they did not
oppose the concept of underground testing. 

For several years, New Mexico's Environmental Evaluation Group had
recommended that DOE start immediately collecting gas generation data
through other means, such as collecting data at another DOE facility. 
The group's Deputy Director stated that if DOE had started such tests
earlier, it might have already collected much of the data that it
would need to support its gas generation models for the performance
assessment. 

The Southwestern Research and Information Center--a nonprofit
educational and scientific organization based in Albuquerque, New
Mexico--had urged DOE to cancel the underground waste tests because
they were expensive, unnecessary, and unscientific. 

The Natural Resources Defense Council--an environmental interest
group--agreed with DOE's decision to abandon the underground tests
and endorsed DOE's move to above-ground testing.  In an October 1993
letter to DOE, an official with the Council noted that above-ground
testing is the most cost-effective and expeditious way of
demonstrating WIPP's compliance. 

The Governor of New Mexico stopped short of endorsing DOE's new test
strategy but noted that the state was open to considering the changes
as long as they (1) did not adversely affect the health and safety of
New Mexicans, (2) furthered the goals of promoting the environmental
cleanup of DOE facilities in New Mexico, (3) led to a plan better
suited to achieving or demonstrating compliance with applicable
federal and state regulations, and (4) did not adversely affect
economic assistance commitments that DOE had made to the state. 
Officials from the state's Environmental Division told us that DOE's
abandonment of the underground tests with wastes and adoption of
additional laboratory tests should not have any impact on whether DOE
can or cannot demonstrate compliance with EPA's standards. 


COST SAVINGS COULD NOT BE
VERIFIED, AND OTHER RELATED COSTS
WERE OMITTED
========================================================== Appendix II

In October 1993, DOE estimated that it would save $139 million over
the 7-year period 1994 through 2000 by changing the test strategy for
WIPP.  DOE computed the savings by calculating the difference between
the estimated expenditures under two options.  Under the first
option, the underground testing program would be continued with
certain modifications to planned tests.  Under the second option, the
underground tests would be replaced with enhanced, above-ground
laboratory tests intended to replicate expected underground
conditions at WIPP. 

In analyzing the costs of the two options, we were unable to verify
most of DOE's individual cost estimates.  Furthermore, we identified
additional costs that DOE is likely to incur that are related to the
change in test programs. 


   MOST COSTS COULD NOT BE
   VERIFIED
-------------------------------------------------------- Appendix II:1

The validity of many of the individual cost items that DOE presented
in its analysis could not be verified.  In some cases, supporting
documents contained incomplete or conflicting information; in other
cases, supporting documents were lacking altogether.  DOE itself
recognized the preliminary nature of its cost calculations; for
example, it developed specific cost elements for option 2 without
detailed supporting analyses. 

We could not validate the cost of the scope of new work under DOE's
option 2 because DOE's documentation was incomplete and conflicted
with the numbers that DOE used in its cost estimate.  DOE's estimate
showed that $21 million would be needed for the scope of new work--$7
million per year for 3 years beginning in fiscal year 1994.  However,
the documentation that DOE provided--a contractor's proposal for nine
new projects--equaled twice as much as the estimate that DOE used in
its analysis and covered only a 1-year period.  According to an
official in DOE's Office of Environmental Management, the
contractor's proposal overreached DOE headquarters' expectations.  On
the basis of his judgment, the official selected four new work
projects from the contractor's proposal.  However, the 1-year
estimated cost of the four projects was $5.9 million rather than the
$7 million that DOE used in its analysis. 

Similarly, we could not validate DOE's cost estimate for the option 2
enhanced laboratory program.  DOE's analysis showed that the enhanced
laboratory program would cost $18 million; according to the DOE
official mentioned above, this total was a rough estimate made by the
contractor on short notice.  After the change in the test strategy
was announced, the contractor provided a written estimate that
totaled $22.7 million, or 26 percent more than the $18 million total. 
This official said that the difference was due to the fact that the
contractor did not consider the accelerated schedule.  Another
official, the former Planning and Administrative Branch Chief of
WIPP's Project Integration Office, said that the $18 million total
represented the laboratory activities that DOE considered to be
absolutely essential.  According to the Director, WIPP Program
Office, the initial estimate did not take into account a 1998 start
for disposal operations and was reduced by the former WIPP Project
Integration Office.  Furthermore, the Director said that because the
enhanced laboratory program is now more mature, the current cost
estimate has decreased to $10 million. 

Furthermore, DOE could not provide us with documentation to support
other related cost items in option 2.  Specifically, DOE lacked
supporting documentation for its cost estimate for retraining staff. 
According to DOE's analysis, the cost of reassigning and retraining
WIPP staff of the Department's management and operating contractor
(Westinghouse) totaled $3 million.  This cost applied to those staff
whose positions would be eliminated or reassigned when the planned
underground tests were canceled.  A DOE official said that he
estimated the amount on the basis of his professional judgment. 
According to the Director, WIPP Program Office, the estimate was
subsequently endorsed by Westinghouse staff and included in their
transition plan for the new test strategy. 

Finally, conflicting information from DOE's supporting documents also
prevented us from verifying DOE's costs to modify and continue the
bin experiments.  Although DOE had spent considerable time in
planning the underground bin tests, it had not decided on a final
design for a key component of the tests--the type 2 (high-pressure)
test bin.  DOE and its contractors had developed several widely
varying cost and requirements estimates around the same time that DOE
prepared its cost analysis.  One estimate--$143 million to construct
26 bins--included a "level of confidence" that the costs would range
between $113 million and $173 million.  A second estimate was $66
million for 15 bins.  DOE used yet a third estimate of $66 million
for 12 bins as the basis for its cost analysis.  The former Planning
and Administrative Branch Chief of WIPP's Project Integration Office
told us that the differences between estimates were due to changing
design specifications--such as the required internal pressure
capabilities for the bins--as DOE modified its plans for the final
requirements for the bins.  This official said that, had DOE
proceeded with the underground tests, the requirements and DOE's
final costs would have probably changed once again. 


   OTHER COSTS MAY BE INCURRED
   BECAUSE OF CHANGES IN TEST
   STRATEGY
-------------------------------------------------------- Appendix II:2

Not only was DOE's projection of the $139 million in cost savings
questionable, but DOE may incur up to $10.6 million in costs for
local economic development and the formation of the DOE Area and
National Transuranic Program Offices in Carlsbad, New Mexico.  While
DOE appeared to have made the decisions to incur these costs after
its October 1993 analysis, these costs are relevant nevertheless and
are attributable in part to the change in test strategy. 

In response to the concerns that local citizens of Carlsbad had
raised about the economic effects of discontinuing the underground
test program, DOE increased its commitment to economic development in
that community by more than $9 million.  Specifically, in March 1994,
DOE increased its funding commitment to the Carlsbad Environmental
Monitoring and Research Center--an independent monitoring facility
funded by DOE through the Waste Management Educational Research
Consortium and administered by New Mexico State University.  The
increase was for $7 million over and above the $25.9 million that DOE
had already committed to support the procurement of equipment and to
support the center's operations.  In addition, DOE extended the grant
period from fiscal year 1997 to 2003, which will enable the center to
acquire a building for its operations.  DOE has also approved other
proposals for economic development.  These include $2 million to
establish an Advanced Manufacturing and Innovation Training Center
for southeast New Mexico that would facilitate the transfer of
advanced manufacturing technologies to public and private concerns
through business training and support.  A February 24, 1994, DOE
memorandum discussing these commitments specifically noted that DOE
made the commitments "in part" because of the change in test
strategy. 

Furthermore, DOE decided to establish an Area and National
Transuranic Program Office in Carlsbad to centralize WIPP's program
management functions in that city.  This decision could increase
WIPP's costs by as much as $1.3 million.  DOE officials did not
attribute the decision to establish the new office to the change in
DOE's test strategy and said that DOE had been considering making
such organizational changes several months prior to its October
decision.  However, several events clearly suggest a link between
this decision and local concerns about the economic effects of DOE's
change in test strategy.  These are (1) Carlsbad community leaders'
continuing efforts to have DOE centralize the management of WIPP's
functions in Carlsbad, (2) DOE officials' interest in maintaining
local support for WIPP, (3) the fact that the formation of the
Carlsbad offices reversed DOE's June 1993 decision to retain 14 of 24
WIPP management positions in Albuquerque rather than centralize them
in Carlsbad, and (4) DOE's decision, within 1 week after the change
in test strategy, to consolidate WIPP's management at Carlsbad. 

The increased costs of $1.3 million included staff relocation costs
and other expenses that may be incurred because of the transition
period.  About $860,000 of these costs relate to DOE.  The remaining
costs of approximately $440,000 are related to the formation of the
Area Office and National Transuranic Program Office that Sandia
National Laboratories expects to incur. 


NUMEROUS UNCERTAINTIES AFFECT
DOE'S CLAIMED SCHEDULE SAVINGS
========================================================= Appendix III

As previously discussed, DOE's predicted 2-year savings in the
scheduled opening of WIPP due to its change in testing strategy
proved to be unrealistic.  Furthermore, we identified some
uncertainties, both internal and external to WIPP, that also continue
to raise questions about DOE's projected schedule.  First, DOE's
schedule lacked specifics such as intermediate milestones for meeting
an accelerated date for the disposal of waste at WIPP.  Second, when
DOE added 5 months to the accelerated schedule in December 1993, it
also cut back the scope of its proposed initial disposal operations. 
Third, DOE faces major uncertainties with the WIPP program that could
significantly affect the Department's ability to meet the accelerated
schedule.  The uncertainties include DOE's efforts to identify and
characterize the types of transuranic and hazardous wastes that it
intends to dispose of at WIPP and the level of staffing and resources
necessary to support the accelerated schedule. 


   DOE'S ACCELERATED SCHEDULE
   LACKED ESSENTIAL DETAILS
------------------------------------------------------- Appendix III:1

DOE's schedule accompanying its October 1993 decision lacked details
on the specific steps necessary to support DOE's claim that the
Department could accelerate WIPP's scheduled opening by 2 years.  For
example, the schedule included milestones for both beginning and
ending the enhanced laboratory program--DOE's substitute program to
collect gas generation data necessary to validate the performance
assessment models.  But when DOE had prepared the schedule, it had
not yet determined the enhanced laboratory program's scope nor had it
identified the participants in the program who would be doing the
additional tests supporting this effort. 

The schedule also lacked details on the timing of other key elements
of the WIPP program, such as tests to describe the fraction of
regulated radioactive and hazardous materials within WIPP that could
be potentially mobilized and escape the repository because of
naturally occurring events (e.g., flooding) or from inadvertent human
intrusion (e.g., drilling for oil or natural gas).  Such materials,
referred to as the source term, potentially can be transported to the
general environment through dissolution into groundwaters.  DOE's
planned source term tests may span several years, and it was unclear
from the schedule whether their timing was such that results could be
obtained to complement the enhanced laboratory program's results. 
According to DOE, data from both experimental programs will be
important to feed into DOE's models for assessing the repository's
long-term performance. 


   DOE CUT BACK SCOPE OF
   ACCELERATED SCHEDULE
------------------------------------------------------- Appendix III:2

Two months after DOE's October 1993 decision, DOE changed the
accelerated schedule.  In December 1993, DOE released a working draft
of its "disposal decision plan"--a more detailed schedule that showed
various activities and milestones leading to WIPP's opening.  In
addition to adding 5 months to WIPP's projected opening date, the
December schedule also reduced the proposed scope of WIPP's initial
disposal operations.  Prior to December 1993, DOE made no distinction
in its accelerated schedule between DOE's readiness to receive
contact-handled and remote-handled wastes when it began disposal
operations. 

DOE's December schedule, however, did not include a date for the
initial receipt of remote-handled waste at WIPP.  According to the
schedule, the decision on receiving that waste would not occur until
July 1999 or later.  DOE's timing of emplacing remote-handled waste
may have important implications for waste handling and management and
workers' safety.  The reason for this is that DOE's initial plans
called for remote-handled waste to be placed into horizontal holes
bored into the walls of WIPP's disposal rooms before the loading of
contact-handled waste onto the floors of the rooms. 


   UNCERTAINTIES COULD AFFECT
   ACCELERATED SCHEDULE
------------------------------------------------------- Appendix III:3

Because DOE's schedule for achieving accelerated compliance was so
optimistic, there may be little time built into the schedule to
resolve critical issues that could affect the success of DOE's
research program for WIPP.  In meeting its accelerated schedule, DOE
must address challenging issues, including some that are beyond its
control.  These include waste characterization, DOE's dependence on
regulators' actions, and the availability of sufficient resources for
the program. 


      EVOLVING WASTE
      CHARACTERIZATION ACTIVITIES
      WILL TAKE TIME
----------------------------------------------------- Appendix III:3.1

EPA and others are concerned that DOE needs to increase its
understanding of the characteristics of waste that will be placed at
WIPP.  Such an understanding is necessary before DOE can submit a
complete application to EPA requesting that EPA certify DOE's
compliance with EPA's waste disposal standards pertaining to WIPP. 
The reason for this is that variances in the characteristics of waste
could affect WIPP's ability to comply with EPA's regulatory
requirements.  When DOE announced its change in test strategy, its
efforts to study the characteristics of the waste inventory across
the DOE complex were substantially incomplete.  Also at that time,
DOE indicated that it would develop a new approach--the establishment
of performance-based waste acceptance criteria--for determining
current and future waste streams bound for WIPP.\1 However, the
acceptability of this approach was not discussed with EPA. 

The uncertainty associated with waste characterization is illustrated
by the fact that EPA, in a November 8, 1993, letter to DOE, raised
significant concerns about the adequacy of DOE's efforts to study the
comparative characteristics of remote-handled versus contact-handled
wastes.  Among other things, EPA stated that it was unclear how DOE
planned to perform comprehensive comparative remote-handled and
contact-handled waste characterization within the schedule provided
when the contact-handled waste characterization program was "at its
infancy."


--------------------
\1 The establishment of performance-based waste acceptance criteria
is a concept for "screening" waste streams before they enter WIPP. 
DOE would use its performance assessment as a starting point to
establish bounding conditions, or an "envelope," in which wastes
stored in WIPP will fall.  By comparing DOE's waste characterization
database with the "envelope," DOE can demonstrate which existing and
future wastes are expected to be acceptable for disposal at WIPP and
which are not. 


      UNCERTAINTY EXISTS OVER
      FUNDING AND STAFF RESOURCES
----------------------------------------------------- Appendix III:3.2

Uncertainty also exists over whether DOE will have adequate resources
to accomplish the accelerated schedule.  As discussed earlier, DOE
recognized the preliminary nature of the cost estimates for the
enhanced laboratory program but neither identified the specific
funding requirements nor the actual scope of work needed to support
the new WIPP research activities.  Thus, it was uncertain whether DOE
would have sufficient funds available to meet the revised schedule at
the time of the change in test strategy.  Also, DOE had not
considered how this funding would be phased into the program over
time. 

Furthermore, in October 1993, when DOE announced that it would
transfer critical program management functions for WIPP from
Albuquerque to Carlsbad, the efficiencies of this decision on the
project were unclear.  That is, DOE did not know which of the
affected staff were willing to relocate to Carlsbad, and DOE did not
consider the potential effects on the program's schedule if some or
all of the affected staff chose not to relocate.  For example, delays
in the program could result from a need to fill key management
vacancies and to retrain staff. 


SCOPE AND METHODOLOGY
========================================================== Appendix IV

We performed our work at DOE's headquarters in Washington, D.C.; at
DOE's Albuquerque Operations Office and at Sandia National
Laboratories in Albuquerque, New Mexico; at DOE's Carlsbad Area
Office in Carlsbad, New Mexico, and at DOE's Waste Isolation Pilot
Plant near Carlsbad; and at WIPP's support contractors' locations in
Albuquerque and Carlsbad.  We also performed our work at EPA's
headquarters in Washington, D.C. 

To evaluate the scientific soundness of DOE's October 1993 decision
to replace underground tests with radioactive wastes with laboratory
tests, we interviewed officials from DOE and its contractors.  We
obtained and reviewed DOE's and its contractors' correspondence,
reports, test plans, and other pertinent documents, particularly
covering the period from December 1992 through January 1994.  We also
reviewed the minutes of past EPA and DOE meetings regarding DOE's
test and retrieval plans.  In addition, we spoke with officials and
obtained documentation from EPA's Office of Radiation and Indoor Air;
the National Academy of Sciences' WIPP Committee; the state of New
Mexico (including its Environmental Evaluation Group); members of
DOE's former Blue Ribbon Panel on WIPP (commissioned from 1989 to
1991); and interested groups located in New Mexico. 

Furthermore, we attended meetings held by the National Academy of
Sciences in December 1993 and in April and June 1994 and meetings
held by EPA in February and June 1994.  To supplement the historical
perspective on DOE's WIPP test program, we drew largely upon our
previous testimonies and reports issued from 1988 through 1991.  (See
list of related reports and testimonies in app.  V.)

To ascertain whether DOE's projected cost savings were reasonable, we
reviewed and analyzed DOE's and its contractors' documents supporting
DOE's comparison of the estimated costs of either continuing
underground tests with radioactive wastes or replacing these tests
with above-ground laboratory tests.  We discussed the documentation
with and obtained the views of officials at DOE's headquarters
office, Albuquerque Operations Office, and Carlsbad Area Office and
with DOE's contractors. 

We also attempted to identify other costs related to the change in
test strategy that DOE did not include in its analysis.  To
accomplish this, we reviewed and analyzed DOE's documents concerning
DOE's budgeting process for WIPP for fiscal years 1993 and 1994 and
the documents supporting DOE's October 1993 decision to abandon
underground tests.  In addition, we discussed these cost items with
officials of DOE and its contractors. 

To determine the validity of DOE's claim that it would shorten its
schedule for opening WIPP by changing its testing strategy, we
reviewed, analyzed, and compared DOE's schedules before and after its
October 1993 change in test strategy.  In addition, we reviewed DOE
and EPA documents related to DOE's schedule and discussed DOE's
schedule with officials at DOE headquarters, Albuquerque Operations
Office, and Carlsbad Area Office, and with officials of EPA and other
interested groups. 

We discussed the facts presented in this report with DOE headquarters
officials and incorporated their comments where appropriate. 
However, as requested by representatives of the congressional
requesters' offices, we did not obtain written agency comments on a
draft of this report from DOE or other parties.  We conducted our
work from February through December 1994 in accordance with generally
accepted government auditing standards. 


RELATED STUDIES
=========================================================== Appendix V

GAO PRODUCTS

Nuclear Waste:  Delays in Addressing Environmental Requirements and
New Safety Concerns Affect DOE's Waste Isolation Pilot Plant
(GAO/T-RCED-91-67, June 13, 1991). 

Nuclear Waste:  Issues Affecting Land Withdrawal of DOE's Waste
Isolation Pilot Project (GAO/T-RCED-91-38, Apr.  16, 1991). 

Nuclear Waste:  Storage Issues at DOE's Waste Isolation Pilot Plant
in New Mexico (GAO/RCED-90-1, Dec.  8, 1989). 

Status of the Department of Energy's Waste Isolation Pilot Plant
(GAO/T-RCED-89-50, June 12, 1989). 

Status of the Department of Energy's Waste Isolation Pilot Plant
(GAO/T-RCED-88-63, Sept.  13, 1988). 

OTHER PRODUCTS

Current Status of the Waste Isolation Pilot Plant.  Lokesh Chaturvedi
and Robert H.  Neill, New Mexico Environmental Evaluation Group
(paper presented at the Waste Management '94 Conference in Tucson,
Arizona, Mar.  2, 1994). 

Experimental Program Plan for the Waste Isolation Pilot Plant
(Revision 0).  Carlsbad Area Office, U.S.  Department of Energy
(DOE/WIPP 94-008, Jan.  1994). 

Independent Technical Review of the Bin and Alcove Test Programs at
the Waste Isolation Pilot Plant.  Office of Environmental Restoration
and Waste Management, Department of Energy (Dec.  1993). 

Background Paper:  Waste Tests at the Waste Isolation Pilot Plant-Bin
and Alcove Program Recommended Alternatives.  Department of Energy
(Sept.  1993). 

Contingency Test Task Force Report:  Evaluation of Alternate Tests as
Contingencies to Replace the Currently Planned Bin and Alcove Tests
at the WIPP.  Department of Energy (Sept.  1993). 

Test Plan:  WIPP Bin-Scale CH TRU Waste Tests (Type 2 Bin).  Sandia
National Laboratories (SAND93-1550, July 9, 1993). 

Test Plan Addendum #2:  Waste Isolation Pilot Plant Bin-Scale CH TRU
Waste Tests.  Sandia National Laboratories (SAND93-1676, July 1993). 

Preliminary Review of the DOE Test Phase Plan for the Waste Isolation
Pilot Plant (DOE/WIPP-89-011, Rev.  1, March 1993).  New Mexico
Environmental Evaluation Group (May 14, 1993). 

Test Phase Plan for the Waste Isolation Pilot Plant (Revision 1). 
WIPP Project Integration Office, Department of Energy (DOE/WIPP
89-011, Mar.  1993). 

Waste Retrieval Plan for the Waste Isolation Pilot Plant (Revision
1).  WIPP Project Site Office, Department of Energy (DOE/WIPP 89-022,
Mar.  1993). 

Gas Generation and Source-Term Programs:  Technical Needs Assessment
for the Waste Isolation Pilot Plant Test Phase (Revision 0).  WIPP
Project Integration Office, Department of Energy (DOE/WIPP 92-062,
Dec.  1992). 

Final Report of WIPP Blue Ribbon Panel Member Thomas G.  Bahr to the
Secretary of Energy.  Department of Energy (Aug.  26, 1991). 

Final Report of WIPP Blue Ribbon Panel Member Robert W.  Bishop to
the Secretary of Energy.  Department of Energy (Aug.  20, 1991). 

Final Report of WIPP Blue Ribbon Panel Member Leonard C.  Slosky to
the Secretary of Energy.  Department of Energy (Aug.  20, 1991). 

A Letter Report by the Panel on the Waste Isolation Pilot Plant Board
on Radioactive Waste Management.  Commission of Geosciences,
Environment, and Resources, National Research Council, National
Academy of Sciences (June 1992). 

An Evaluation of the Proposed Tests with Radioactive Waste at WIPP. 
Lokesh Chaturvedi and Matthew Silva, New Mexico Environmental
Evaluation Group (paper presented at the Third International
High-Level Radioactive Waste Management Conference, Las Vegas, Nev.,
Apr.  12-16, 1992). 

WIPP Test Phase Activities in Support of Critical Performance
Assessment (40 CFR 191 B) Information Needs.  Department of Energy
(Feb.  1992). 

Final Safety Analysis Report Addendum:  Dry Bin-Scale Test, Waste
Isolation Pilot Plant (Revision 0).  Department of Energy (WP 02-9,
Aug.  1991). 

A Letter Report by the Panel on the Waste Isolation Pilot Plant. 
Board on Radioactive Waste Management/National Research Council,
National Academy of Sciences (Apr.  1991). 

Test Plan Addendum #1:  WIPP Bin-Scale CH TRU Waste Tests.  Sandia
National Laboratories (SAND90-2082, Dec.  1990). 

Final Safety Analysis Report, Waste Isolation Pilot Plant. 
Department of Energy (WP 02-9, May 1990). 

WIPP Test Phase Plan:  Performance Assessment (Revision 0). 
Department of Energy (DOE/WIPP 89-011, Apr.  1990). 

Waste Retrieval Plan:  Waste Isolation Pilot Plant.  Department of
Energy (DOE/WIPP 89-022, May 1990). 

Test Plan:  WIPP Bin-Scale CH TRU Waste Tests.  Sandia National
Laboratories (Jan.  1990). 

Test Plan:  WIPP In Situ Alcove CH TRU Waste Tests.  Sandia National
Laboratories (Jan.  1990). 

Final Supplement Environmental Impact Statement Waste Isolation Pilot
Plant.  Office of Environmental Restoration and Waste Management,
Department of Energy (DOE/EIS-0026-FS, Jan.  1990). 

Draft Final Plan for the Waste Isolation Pilot Plant Test Phase: 
Performance Assessment.  Department of Energy (DOE/WIPP 89-011, Dec. 
1989). 

Evaluation of the DOE Plans for Radioactive Experiments and
Operational Demonstration at WIPP.  New Mexico Environmental
Evaluation Group (EEG-42, Sept.  1989). 

Draft Plan for the Waste Isolation Pilot Plant Test Phase: 
Performance Assessment and Operations Demonstration.  Department of
Energy (DOE/WIPP 89-011, Apr.  1989). 

Report on Brine Accumulation in the WIPP Facility.  National Academy
of Sciences Panel on the Waste Isolation Pilot Plant; Board on
Radioactive Waste Management; Commission on Physical Sciences,
Mathematics, and Resources; National Research Council (Mar.  3,
1988). 

Evaluation of the Waste Isolation Pilot Plant (WIPP) as a
Water-Saturated Nuclear Waste Repository.  Scientists Review Panel on
WIPP, Albuquerque, N.M.  (Jan.  1988). 

Review of the Scientific and Technical Criteria for the Waste
Isolation Pilot Plant (WIPP).  National Academy of Sciences Panel on
the Waste Isolation Pilot Plant, Board on Radioactive Waste
Management, Commission on Physical Sciences, Mathematics, and
Resources, National Research Council (DOE/DP/48015-1, 1984). 


MAJOR CONTRIBUTORS TO THIS REPORT
========================================================== Appendix VI

RESOURCES, COMMUNITY AND ECONOMIC
DEVELOPMENT DIVISION, WASHINGTON,
D.C. 

Dwayne E.  Weigel, Assistant Director
Victor J.  Sgobba, Assignment Manager
Casandra D.  Joseph, Adviser

DENVER, COLORADO

Cynthia S.  Rasmussen, Evaluator-in-Charge
Julia A.  DuBois, Senior Evaluator
Sarah N.  Renfro, Evaluator
Pamela M.  Tumler, Reports Analyst

OFFICE OF THE GENERAL COUNSEL

Mindi G.  Weisenbloom, Senior Attorney

