Nuclear Cleanup: Difficulties in Coordinating Activities Under Two
Environmental Laws (Letter Report, 12/22/94, GAO/RCED-95-66).

In cleaning up waste sites within its nuclear weapons facilities, the
Energy Department (DOE) must comply with two major environmental
laws--the Resource Conservation and Recovery Act of 1976 and the
Comprehensive Environmental Response, Compensation, and Liability Act of
1980.  The first law regulates the management of facilities that treat,
store, or dispose of hazardous wastes and the cleanup of hazardous
wastes released from such facilities.  The second governs the cleanup of
inactive waste sites--that is, sites where disposal is no longer
occurring.  This report discusses (1) what DOE has done to coordinate
its cleanup activities under the two acts, (2) what problems with
coordination continue and how cleanup activities have been affected, and
(3) how DOE plans to improve the coordination of cleanup activities in
the future.

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

 REPORTNUM:  RCED-95-66
     TITLE:  Nuclear Cleanup: Difficulties in Coordinating Activities 
             Under Two Environmental Laws
      DATE:  12/22/94
   SUBJECT:  Nuclear waste disposal
             Compliance
             Reporting requirements
             Nuclear waste management
             Interagency relations
             Radioactive wastes
             Nuclear waste storage
             Energy research
             Environmental policies
             Environmental law
IDENTIFIER:  EPA National Priorities List
             
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Cover
================================================================ COVER


Report to the Chairman, Subcommittee on Energy, Committee on Science,
Space, and Technology, House of Representatives

December 1994

NUCLEAR CLEANUP - DIFFICULTIES IN
COORDINATING ACTIVITIES UNDER TWO
ENVIRONMENTAL LAWS

GAO/RCED-95-66

Coordinating Activities Under RCRA and CERCLA


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

  CERCLA -
  DOE -
  EPA -
  GAO -
  RCRA -

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


B-258744

December 22, 1994

The Honorable Marilyn Lloyd
Chairman, Subcommittee on Energy
Committee on Science, Space,
 and Technology
House of Representatives

Dear Madam Chairman: 

In cleaning up waste sites within its nuclear weapons facilities, the
Department of Energy (DOE) must comply with two major environmental
laws--the Resource Conservation and Recovery Act of 1976, as amended
(RCRA), and the Comprehensive Environmental Response, Compensation,
and Liability Act of 1980, as amended (CERCLA, commonly known as
Superfund).  RCRA regulates the management of facilities that treat,
store, or dispose of hazardous wastes and the cleanup of hazardous
wastes released from such facilities.  CERCLA governs the cleanup of
inactive waste sites--that is, sites where disposal is no longer
occurring. 

Many DOE facilities have both active and inactive sites and therefore
must meet the requirements of both RCRA and CERCLA.  Thus, DOE and
its federal and state regulators often have to coordinate cleanup
activities and schedules that stem from each act's requirements. 
Your Subcommittee found indications that DOE facilities may be having
difficulty coordinating these activities and schedules.  Most
recently, in a field hearing in August 1993, you identified problems
in coordinating activities under RCRA and CERCLA at DOE's facility at
Hanford, Washington.  You asked us to provide more information about
the issues involved by determining

  what DOE has done to coordinate its cleanup activities under RCRA
     and CERCLA,

  what problems with coordination continue and how cleanup activities
     have been affected, and

  how DOE plans to improve the coordination of cleanup activities in
     the future. 


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

The facilities in DOE's nuclear weapons complex that are contaminated
with hazardous and radioactive materials are among the many public
and private sites being cleaned up under RCRA and/or CERCLA.  To help
coordinate its activities under the two acts, DOE in 1988 developed
general operating principles (called "model provisions") for its
facilities to use in negotiating interagency agreements with the
Environmental Protection Agency and the state agencies overseeing
cleanup activities.  These agreements, which vary among facilities,
establish a general framework for how cleanups under the two acts
will be coordinated. 

Despite the general frameworks provided in the interagency
agreements, difficulties persist in coordinating cleanup activities. 
For example, at facilities that became subject to CERCLA after
cleanup activities under RCRA had begun, disagreements have sometimes
occurred between DOE and its regulators as to how CERCLA's
requirements should be incorporated into ongoing cleanup activities
under RCRA and how much additional paperwork is needed to document
compliance with CERCLA.  Furthermore, DOE and its regulators had
difficulty coordinating schedules for cleanup activities under the
two acts. 

DOE has recognized these continuing difficulties and is considering
actions to address them.  It plans to issue additional guidance for
coordinating activities under RCRA and CERCLA in the spring of 1995. 
It also tentatively plans to work with the Environmental Protection
Agency and state regulatory agencies to improve strategies for
cleanups at DOE's facilities and to address how the requirements of
RCRA and CERCLA are to be met.  At the time of our review, DOE had
not yet finalized its plans for the second effort. 


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

DOE is responsible for environmental cleanup and waste management at
15 major contaminated facilities and more than 100 smaller facilities
in 34 states and territories.  These facilities encompass a wide
range of waste sites, including tanks or other storage facilities
containing radioactive waste from nuclear weapons production,
production facilities that are now idled and in need of cleanup, and
locations where hazardous chemicals were dumped into the ground. 
Cleaning up these sites is an enormous task.  DOE's most recent
estimate is that the cleanup will cost at least $300 billion (and
perhaps as much as $1 trillion) and take more than 30 years to
complete. 

The cleanup of DOE's facilities is subject to CERCLA's and RCRA's
requirements.  The Environmental Protection Agency (EPA) is
responsible for administering both acts, but EPA may authorize state
agencies to implement all or part of its RCRA responsibility.  Table
1 summarizes the purposes and selected features of the two acts. 



                           Table 1
           
            Selected Provisions of RCRA and CERCLA

                                          Comprehensive
                                          Environmental
                      Resource            Response,
                      Conservation and    Compensation, and
                      Recovery Act of     Liability Act of
                      1976, as amended    1980, as amended
                      (RCRA)              (CERCLA)
--------------------  ------------------  ------------------
Purpose and selected  RCRA regulates the  CERCLA provides
features              management of       authority for the
                      hazardous waste     cleanup of the
                      treatment,          nation's inactive
                      storage, and        or abandoned waste
                      disposal            sites. The most
                      facilities through  hazardous sites,
                      a permit program.   including federal
                      In 1984,            facilities, are
                      amendments          listed on the
                      required            National
                      corrective action   Priorities List.
                      (cleanup) for       In 1986,
                      releases of         amendments
                      hazardous wastes    required that
                      from any active or  federal facilities
                      inactive site       be addressed under
                      within such         interagency
                      facilities.         agreements between
                      Corrective actions  the agency
                      are incorporated    responsible for a
                      into a facility's   waste site and
                      RCRA permit.        EPA.

Agency responsible    EPA or authorized   EPA
for administration    state agency

Substances addressed  Hazardous wastes    Hazardous
                      and the hazardous   substances,
                      constituents of     including
                      mixed waste--       radioactive wastes
                      waste that
                      contains both
                      radioactive and
                      hazardous
                      material\a
------------------------------------------------------------
\a The Federal Facility Compliance Act of 1992 established additional
requirements with respect to the storage and treatment of mixed waste
at federal facilities.  These requirements are discussed in our
report Nuclear Waste:  Much Effort Needed to Meet Federal Facility
Compliance Act's Requirements (GAO/RCED-94-179, May 17, 1994). 

The requirements of both RCRA and CERCLA can apply at a DOE facility
that has active and inactive hazardous waste sites.  This is because
a federal facility regulated under RCRA may also be listed on the
National Priorities List for cleanup under CERCLA if it meets the
listing criteria.  EPA first included federal facilities that were
subject to RCRA's corrective action requirements on the National
Priorities List in 1989, and 19 DOE facilities are currently on the
list.  Once included on the list, facilities are subject to the
cleanup actions and procedures specified under CERCLA as well as to
RCRA-related requirements for corrective action established by EPA or
a state regulatory agency. 

DOE's facility in Oak Ridge, Tennessee, is an example of the dual
application of RCRA and CERCLA.  At Oak Ridge, DOE started corrective
action work under RCRA in 1988 on a storage site for solid waste
(called Waste Area Grouping 6).  In 1989, Waste Area Grouping 6 also
became subject to CERCLA's requirements when Oak Ridge was placed on
the National Priorities List.  At some DOE facilities, sites
regulated under RCRA are near sites addressed under CERCLA.  For
example, Hanford's B-pond, a disposal site for liquid wastes, is
being cleaned up under RCRA, while abandoned trenches that formerly
brought wastes to the B-pond are being cleaned up under CERCLA. 

Cleanups under CERCLA and corrective actions under RCRA have broadly
similar objectives.  Under both statutes, releases of wastes needing
further investigation are identified, the nature and extent of the
releases are characterized, cleanup alternatives are developed, a
cleanup remedy is proposed for public comment, and the selected
remedy is authorized and carried out.  However, the two programs
differ in their highly detailed sets of procedural regulations and
guidelines and in the particulars of their implementation.  For
instance, according to environmental restoration officials at DOE,
corrective actions under RCRA are generally implemented unit by unit,
while cleanups under CERCLA may address contamination over a wider
geographic area, such as groundwater contamination that underlies
several units. 


   DOE HAS TAKEN STEPS TO
   COORDINATE CLEANUP ACTIVITIES
------------------------------------------------------------ Letter :3

In 1988 and 1989, DOE and EPA took steps designed to coordinate
cleanup efforts in those instances when both RCRA and CERCLA applied. 
EPA took the lead in developing general guidance on coordinating the
requirements of the two acts.  EPA believed that in most situations,
coordination could be achieved by using the interagency agreements
between DOE and its regulators required by CERCLA.  Among other
things, interagency agreements (1) can divide responsibility for
regulation between EPA and the states, if necessary; (2) establish
milestones and priorities for the cleanup process; and (3) establish
processes for resolving disputes between DOE, EPA, and the state
regulators. 

DOE and EPA also jointly developed model provisions to be included in
the interagency agreements.  The model provisions created a general
framework for how the cleanup is to be coordinated under the two
acts.  Among other things, they

  established the integration of activities under RCRA and CERCLA as
     a goal of the agreement,

  specified that the cleanup actions undertaken should satisfy the
     requirements of both acts, and

  called for RCRA permits that include corrective actions to be
     compatible with the schedules for cleaning up the facility set
     out in the interagency agreement. 

In planning the cleanup of a specific site, the facility and the
regulating agency or agencies must still translate this general
framework into specific actions. 

By design, this general framework has been subject to considerable
adjustment to meet the local situation.  DOE headquarters directed
that the model provisions be included whenever possible in the
interagency agreements but also recognized that unique local
conditions, requirements established by state regulators, and other
factors could affect the agreements.  Each agreement was separately
negotiated by the DOE facility; the EPA regional office; and, where
applicable, the state regulatory agency.  These parties may also
renegotiate the agreements to adjust schedules and other terms.  The
Office of Environmental Management and the Office of the General
Counsel in DOE headquarters oversee and approve the agreements for
DOE. 

Each of the four agreements we reviewed\1 established a different
strategy for coordinating activities under RCRA and CERCLA.  For
example, at the Savannah River facility in South Carolina, the
approach concentrated on continuing cleanup activities that had
already begun to meet RCRA's requirements and coordinating CERCLA's
requirements with these ongoing efforts.  By contrast, at the Idaho
National Engineering Laboratory, where cleanup plans under RCRA were
not as far along, DOE, EPA, and the state elected to give preeminence
to cleanup procedures under CERCLA. 


--------------------
\1 These agreements concerned Hanford, Savannah River, the Idaho
National Engineering Laboratory, and the Oak Ridge Reservation. 


   DIFFICULTIES WITH COORDINATION
   CONTINUE
------------------------------------------------------------ Letter :4

Despite efforts to coordinate activities under the two acts through
the general frameworks of the interagency agreements, coordination
problems have continued to arise.\2 In particular, agencies have
sometimes disagreed over details of implementation and have had
difficulty coordinating schedules. 


--------------------
\2 In addition to the difficulties in coordinating activities under
RCRA and CERCLA, other factors (such as regulators' disagreements
related to technical matters or interpretations of regulatory
requirements) have also played a part in the problems DOE has
experienced in managing cleanups. 


      AGENCIES HAVE NOT ALWAYS
      AGREED ON HOW TO INTEGRATE
      REQUIREMENTS
---------------------------------------------------------- Letter :4.1

At the four DOE facilities that we reviewed, CERCLA's requirements
had to be incorporated after cleanup activities under RCRA (or the
planning for them) had already begun.  Although each facility's
interagency agreement addressed this issue in general terms, the
agencies involved sometimes disagreed about the detailed
implementation of specific cleanup activities, and these differences
took a long time to resolve. 

For example, one location at Oak Ridge, called Bear Creek Valley,
included a series of active disposal sites for hazardous wastes that
had been regulated by the Tennessee Department of Environment and
Conservation under its authorized RCRA program.  Following Oak
Ridge's placement on CERCLA's National Priorities List in 1989, a
2-year disagreement between DOE and Tennessee officials resulted over
whether to address the dangers posed to groundwater by the hazardous
wastes on a site-by-site basis under RCRA permits or to address all
of Bear Creek Valley's groundwater problems under CERCLA's
requirements.  State officials favored the first course of action,
while DOE officials favored the second.  In 1993, the disagreement
was resolved by adopting the CERCLA cleanup approach and modifying
the RCRA permits to reflect the resulting changes in schedules and
procedures. 

At Savannah River, disagreements arose over the preparation of
additional documentation addressing CERCLA's requirements at sites
where activities had already taken place under RCRA.  DOE officials
at the facility decided to prepare additional documentation,
estimated to cost about $33,000, for the Mixed Waste Management
Facility, which had been cleaned up and closed in 1990 under RCRA. 
In preparing this documentation, DOE will basically be modifying
paperwork prepared under RCRA to suit formats used under CERCLA; it
will not be conducting additional cleanup activity or disclosing new
information.  Officials in South Carolina and EPA's regional office
told us they believe DOE could use a simpler, less expensive
approach.  DOE officials at Savannah River told us they believe that
unless this documentation is done, the administrative record under
CERCLA will be incomplete. 

Similarly, in September 1994 the Director of DOE's Office of
Environmental Activities wrote a memorandum expressing concern about
decisions by Savannah River officials to prepare proposed cleanup
plans under CERCLA for groundwater beneath two areas of the facility
and issue the plans for public comment.  The cleanup approach for
these areas had already been decided under RCRA.  The Director noted
(1) the potential waste of resources, given that more than 200 other
pollution sites at Savannah River were scheduled for cleanups under
RCRA, and (2) the inappropriateness of requesting public comment
after decisions about the cleanup approach had already been made. 


      AGENCIES HAD DIFFICULTY
      COORDINATING SCHEDULES FOR
      ACTIVITIES UNDER CERCLA AND
      RCRA
---------------------------------------------------------- Letter :4.2

DOE, EPA, and state agencies share the responsibility for
establishing schedules that allow cleanup activities under the two
acts to be well coordinated.  Each of the four interagency agreements
we reviewed contained provisions addressing the coordination of
schedules, but in practice, the agencies had difficulty developing
schedules that coordinated related activities and reflected the
relative risks present at the facilities. 

For example, DOE and the Washington State Department of Ecology had
difficulty developing a coordinated schedule for related cleanup
activities at Hanford, resulting in a delay in the cleanup of one
site.  Hanford's B-pond formerly received wastes through a series of
trenches, some of which were found to be contaminated with
radioactive materials in the 1970s and taken out of service.  A
different method was then used to transfer wastes to the B-pond,
which continued to operate.  Between 1990 and 1993, interim
stabilization under RCRA of the pollutants in the B-pond was delayed
because DOE and the Washington State Department of Ecology disagreed
about whether to complete the RCRA action as scheduled or to delay it
and include actions on adjacent abandoned trenches covered under
CERCLA.  In 1993, the state agreed to a later action that would
integrate the requirements of the two acts.  In September 1994, DOE,
the Washington State Department of Ecology, and EPA's regional office
reached a tentative agreement that the approach used at the B-pond to
coordinate activities under the two acts, if successful, would be
extended to the 63 other sites at Hanford covered by RCRA but located
within sites covered under CERCLA. 

In another type of scheduling difficulty, cleanup schedules have not
always reflected the relative risks posed by different sites within a
facility.  For example, at Oak Ridge's Waste Area Grouping 6, cleanup
work started under RCRA was scheduled ahead of cleanup work under
CERCLA without full consideration of the relative risks that
pollutants at the site presented.  The site contained active and
inactive trenches for disposing of hazardous wastes that were a
source of pollution to surface water and potentially to groundwater. 
Before the facility was placed on CERCLA's National Priority List,
the trenches were being closed under a RCRA permit that called for
finishing the closure by 1993.  DOE planned and proposed a $140
million remedial action that would have cleaned up the area and
protected against potential pollution of the groundwater in a way
that met both this deadline and CERCLA's requirements.\3 At a meeting
on this proposal, members of the public objected to spending such a
large sum of money because they believed that other waste sites at
Oak Ridge posed a greater risk to people living near the site.  DOE
subsequently modified its plans, moving planned expenditures for the
remedial action to higher-priority CERCLA activities.  Groundwater at
Waste Area Grouping 6 will instead be monitored for potential
pollutants using a series of wells drilled at the site's perimeter. 
Monitoring will continue until Waste Area Grouping 6 is reevaluated
under CERCLA at a later date. 


--------------------
\3 In 1992, as provided in the Oak Ridge Federal Facility Agreement,
cleanup of the entire Waste Area Grouping 6 was placed under CERCLA. 
However, for those units where activities had begun under RCRA, DOE
concluded that the original compliance schedules still applied. 


   DOE HAS TENTATIVE PLANS TO
   IMPROVE COORDINATION
------------------------------------------------------------ Letter :5

As DOE cleans up additional waste sites, problems such as the
difficulty coordinating schedules described above could continue to
arise.  As of August 1994, only about 10 percent of the individual
waste sites within DOE's facilities had been cleaned up. 
Furthermore, three DOE facilities--two of them undergoing cleanup
activities under RCRA--were added to CERCLA's National Priorities
List in May 1994.\4 As noted above, incorporating CERCLA's
requirements into cleanup activities taking place under RCRA has
resulted in difficulties at Savannah River and Oak Ridge. 

DOE is aware of the potential for continued problems and plans to
address it by developing additional guidance for its facilities about
coordinating activities under the two acts.  Officials in DOE's
Office of Environmental Activities told us that they hope to issue
such guidance in the spring of 1995.\5 At the time of our review,
they anticipated that the guidance would include an overview of the
legal requirements, a discussion of issues that have arisen in
implementing the two acts, options and preferred approaches for
integrating activities under the two acts, lessons learned by field
staff about coordinating procedures and technical requirements under
RCRA and CERCLA, and contact points for further sharing of
information.  The section on the lessons learned would be developed
with input from staff at DOE's facilities, according to one
official.\6 Officials from the Office of Environmental Activities
have also met with staff in EPA's Office of Solid Waste and Emergency
Response about working jointly on a number of issues, including
coordinating activities under RCRA and CERCLA. 

EPA officials from the Office of Solid Waste and Emergency Response
and Office of Federal Facilities Enforcement told us that although
details would need to be addressed with each state, additional
guidance on overall principles for coordinating activities under RCRA
and CERCLA would be beneficial.  According to the EPA officials, it
is important to obtain information and viewpoints from states and DOE
facilities as the guidance is developed because such input will allow
the parties to learn from each other and will increase acceptance of
the resulting guidance. 

DOE is also planning a pilot project to improve its approach to
interagency agreements.  In the pilot project, DOE tentatively plans
to work with EPA regional officials and state officials to develop an
overall technical strategy for cleaning up a facility and to address
how the requirements of RCRA and CERCLA are to be met.  If this pilot
project succeeds, DOE hopes to extend the effort to additional
facilities.  According to an official in DOE's Office of
Environmental Activities, the planned location for the pilot project
is the Laboratory for Energy-Related Health Research in California,
which was recently added to CERCLA's National Priorities List.\7
According to draft plans for the pilot project, development of a
cleanup strategy is expected to begin in January 1995 and take 5 to 6
months to complete.  The interagency agreement for cleaning up the
laboratory could then be negotiated to reflect this strategy.  At the
time of our review, however, DOE had not yet obtained formal
commitments from the relevant EPA regional office and state agency to
participate in the pilot project or finalized detailed plans for it. 


--------------------
\4 These three facilities are the Pantex Plant (Texas), the Paducah
Gaseous Diffusion Plant (Kentucky), and the Laboratory for
Energy-Related Health Research (California).  Pantex and Paducah had
ongoing corrective action activities under RCRA.  The facilities did
not yet have interagency agreements under CERCLA at the time of our
review. 

\5 DOE previously drafted guidance on integrating activities under
RCRA and CERCLA, completing a draft in May 1993.  However, according
to DOE officials, the guidance was not issued at that time because of
possible legislative changes to CERCLA.  Because DOE officials
consider the 1993 draft to be outdated, a new effort is needed. 

\6 DOE also plans to obtain input on ways to coordinate activities
under RCRA and CERCLA from the Compliance and Legislative Workgroup
of the National Association of Attorneys General, a group that
includes representatives from the offices of the attorneys general of
the states in which DOE has facilities. 

\7 In addition, DOE plans to review cleanup strategies for the
Paducah Gaseous Diffusion Plant and the Pantex Plant to ensure that
the best technical approaches to cleanup have been incorporated. 


   CONCLUSIONS
------------------------------------------------------------ Letter :6

Despite a general framework for coordination, DOE and its regulators
have had difficulties in coordinating cleanup activities under RCRA
and CERCLA.  Some of the agencies' disagreements about particular
cleanups have been resolved, but coordination problems could continue
because much cleanup work remains and more DOE facilities have
recently been added to the National Priorities List for CERCLA
cleanups.  DOE plans to provide additional guidance and to negotiate
better strategies for coordinating its activities under RCRA and
CERCLA.  DOE's plans for developing guidance include obtaining
information from facilities about approaches to specific problems
that have worked well.  We believe that DOE's efforts to apply
lessons learned to the practical difficulties involved in
coordinating cleanup activities under the two acts will be
beneficial. 


   AGENCY COMMENTS
------------------------------------------------------------ Letter :7

As requested, we did not obtain written agency comments on a draft of
this report.  However, we discussed its contents with officials in
the Office of Environmental Activities and the Office of Program
Integration within DOE's Office of Environmental Management.  These
officials generally agreed with the information presented.  They
provided technical clarifications and updated information on their
plans for the pilot project, which we have incorporated where
appropriate. 


   SCOPE AND METHODOLOGY
------------------------------------------------------------ Letter :8

We performed our work between January 1994 and November 1994 in
accordance with generally accepted government auditing standards.  As
agreed with your office, we concentrated our review on four
facilities:  Hanford, Savannah River, the Idaho National Engineering
Laboratory, and the Oak Ridge Reservation.  Among DOE's facilities,
these four had the highest expenditures for environmental management
in fiscal year 1993. 

To determine what DOE has done and plans to do to coordinate its
cleanup activities under RCRA and CERCLA, we reviewed EPA's guidance,
the model provisions for the interagency agreements, the four
facilities' interagency agreements, and documentation of a review by
DOE of interagency agreements.  In addition, we discussed DOE's plans
and practices with officials in the Office of Environmental
Management at DOE headquarters, DOE environmental restoration
officials at the four facilities, and EPA officials in the Office of
Solid Waste and Emergency Response and the Office of Federal
Facilities Enforcement.  To determine what problems continue with
coordination and how the cleanup activities have been affected, we
reviewed project files at the four facilities.  We also discussed
experiences in implementing RCRA's and CERCLA's requirements with DOE
environmental restoration officials at the four facilities and with
state officials who oversee DOE cleanups in Washington, South
Carolina, Idaho, and Tennessee. 

We are sending copies of this report to the Secretary of Energy and
other interested parties.  We will make copies available to others on
request. 

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

Sincerely yours,

Victor S.  Rezendes
Director, Energy and
 Science Issues


MAJOR CONTRIBUTORS TO THIS REPORT
=========================================================== Appendix I


   RESOURCES, COMMUNITY, AND
   ECONOMIC DEVELOPMENT DIVISION
   WASHINGTON, D.C. 
--------------------------------------------------------- Appendix I:1

James Noï¿½l, Assistant Director
Rachel J.  Hesselink, Assignment Manager


   SEATTLE REGIONAL OFFICE
--------------------------------------------------------- Appendix I:2

William R.  Swick, Regional Energy Issues Manager
Robin C.  Reid, Evaluator-in-Charge
Angela M.  Sanders, Evaluator
Stanley G.  Stenersen, Evaluator


   OFFICE OF THE GENERAL COUNSEL
--------------------------------------------------------- Appendix I:3

Doreen Stolzenberg Feldman, Assistant General Counsel
Susan W.  Irwin, Staff Attorney
