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the results of analyses of alternative approaches to the proposed repository in the Secretary s comprehensive statement of the basis for a

site recommendation.
program and to provide To improve the management of the nuclear the Congress and the public with aCcurate 'info~on on the repository program, we recommend that the Secretary of Energy

w~

~her

.reestablish the baseUn:e for the nuclear waste program through the . submission of a license application, including incorporating the remaining
technical work required to submit the application and the estimated cost and schedule to. compiete this work, . follow the Departtnent's requirements for ma,naging major programs and proj~ts, :including a forow change control procedure.

and

Agency COrnm~nts
and Our Evaluation

We provided DOE with a draft of this report for review and comment DOE dis~eed with our repo~ contending that we did not understand the
relevant statutory and regUlatory requirements related to a recommendation. Bechtel , DOE' s management contractor, also provided us with a letter .asserting unspecified factual and legal inaccuracies in our

si~

draft report; however, the company added that it would provide specific conunents through DOE. While it was not clear from DOE's comments which ones had come from Bechtel , weare responding ta all comments received on the fallowing pageS. , AccOrding to DOE, 01,ir misunderstanding of the requirements resulted in a contention in the draft report that it is
premature for DOE 'to make a sUe reconimendati.o~ because all th~ technical work for license application is not complete. (DOE's comments

are in app. R) We agree tluit the Secretary has the discretion to make such a recommendation at this time; however, We question the prudence and
practicality of making 'such a reconunendation at this time, given the express statutory time frames for license application and the significant

amount of work rem~g

ta be done for NRC t.o accept a license

, applicat;ion from pOE. Our concluSion is based on the relationship

between a site recomnlendation and -DO~' s readiness to submit acceptable license application t.o NRC, as set out in DOE' s siting guidelines and the Nuclear Waste Policy Act The preanlble to DOE' s siting guidelines states that DOE expects to use essentially the same data for a site recommendation and a license application. Also , the Nuclear Waste
Policy Act states that a presidential site recommendation is to be made if the President considers the site qualified for a license application and sets

out a time frame that could be as short as 5 to8 months from a presidential site recommendation to a license application. This includes

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the requirement that the Secretary of Energy submit a license application
not later than 90 days following congressional approval of the site. Thus

the statutoIY time frame is decidedly shorter Ulan the 4-year estimate between site ~ommen~ation and license application tbatwas recently
proposed by DOE's inanagement coilQ:actor.
DOE also pointed out the difference between the decision at hand-

, detennining whether a potential site is liCerisabI~and the licensing NRC of a repositoxy facili.ty at the site. The latter d~ision would come at the end of a 3- to' 4-year licensing proCeeding. In contrast, our report addresses the relatioOs~ between a site recommendation and the submisSion of the license application.
DOE said that our draft report incorrectly stat~ that DOE' s siting

guidelines require the Secr~~" iIi making asite.reconunendation, to
determine if the site currently complies with N RC' s licensing requirements ra.ther than' detemuning if the site is "likely" to meetNRC' s radiation protection standards. We agree that the standard in DOE' s guidelines is likely" and have added thislaitguage t.o the report The report accurately states the relationship between a site recommendation and a license
.application under the ~uclear Waste Policy Act and the siting guidelines.

In addition , DOE stated that the Nuclear Waste Policy Act chargeS the Secretary with establishing criteria for detero\iriing the suitability of a site for a r~positary and that Ule Department'sstand~ (siting guidelines) are

the most inlportant legally relevant guidance on the question of whether the Department is ready to make a site recon;unendation: Our report, DOE
Said, ignores these standards and instead asserts a standard of our own devising. Contf&Y to DOE.s assertion; we did not evaluate DOE' . performance against a standard we devised. We used the Nuclear Waste Policy Act and DOE' s standards-thatthe site is likely to meet NRC.

radiation protection standards-for a sit.e suitability recommendation.

Moreover, a presidential site recommendation triggers statutaxy time
, frames that requiie DOE to submit a license application to NRC within about 5 to 8 months. Thus, our conclusion regarding whether DQE should

make a site recommendation relies on both the relationship between the
standards for site reconmlendation and license application and the statutory time frames. While recommending to the President that the

Yucca Mountain site is suitable for a repository is within the discretion of
the Secretary of Energy; such a recommendation may be premature
, because of the large number of technical issues remaining to be resolved

before an acceptable license application can -be filed with NRC.

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DOE also stated that NRC's licensing process is an iterative and

continuous process; even the liCense application is not eXpected. to be "set in concrete." We agree with DOE' s statement The ~portant point, however, is that DOE and NRC ,have made 293 specific agreements on techniCal w~k that DOE, will need to complete and incorporate into a license application that would be acc~iable to NRC. This also assumes that no new issues surface that would neoo t.o be addressetl
DOE said that ounlraft, report eJ.uphasized the inventory of issues between DOE and' NRC but ~oIDpletely ignored the technical work that h8s been

done over the past 2 decades and the technical groups who have said that DOE' s ~ata are sufficie~t for a site recommendation. We have added
infonnatl.on to the report recognizing the body of work that J:)OE has completed to date and the views of other teChnical parties mentioned by DOE. As discussed above, how~ver, the central issue is not Whether

technical partieS are of the opinion thatDOE haS enough infommtion for a
site reconunendation but the r~lationship" in sbitute and regul:ation between the site recoi:nmendation and the submission of an acc~ptable

license application.
DOE also said our report gives short shrift to NRC's recent "sufijciency letter" that, according to DOE, memorializes NRC' s conclusion that the
data and' analyses existing and under way likely will be sufficient for a license aPplication. Instead, DOE added, our report over-relies on the views of an NIlC adviSOry committee. Our ,characterization of NRC' sUfficiency comments is acCurate. NRC did state that the agreements between DOE' s al\d NRC's st3ffs regarding the collection of additional

infonnation provide the basis for cOncluding tl~

the development of an accept3ble license application is achievable; however, NRC co~ditioned ' this conunent on DOE's successful campletion of "significant" additional work prior to a license application. Also, the Nuclear Waste Policy Act does not refer to work "underway, " but ~es the phrase "seem to be sufficient" FinallY, we included the views of NRC' s advisory committee because NRC's letter included these views.

In addition , DOE stated that our report promiIiently emphasizes ' the views of the Board as reqlUring the Department to accommodate them before a site deterounation is made. DOE added that the report does not emphasize that the substance of the Board' s criticisms is directed to licensing~ot site reconm\endation. Contrary t.oDOE's assertion, we did not. assertthat DOE is "required" ta accommodate the Board. We

discussed the Board' s continuing concerns as outlined in its October 2001 . letter to DOE. In that letter, the Board not.ed that gaps in data and

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ana)y$es make the evaluation of DOE's technkal bases on whether to recommend the site-not apply for a license-more difficult Also, we' gave the Board' s current ~ncems about DOE's site characterization work as summarized in its Octom;r letter, prominent mention in our report because of the Board' s 'statUtory missi9n to independently evaluate the
technical and scientific validity of DOE'sinvestigatlon of Yucca Mountain.

Finally; DoE said that our statement that delaying a site recommendation
decision Will have no effect on the timing of the ultimate opening

of a

repository'is contrary to all common sense and exp~rience. , We have

removed that statement from the report. However, we note that the key factors that bear on opening a repository currently lie ill the lIcensing One such factor is the 4 more yearn of licensing-related work that Bechtel, in its ' September 2001 detailed reassessment that proposed a new cost and schedule baseline, estimates would be needed to submit' lice~
application that is acceptable to NRC. ' In addition, other licens~~g-:l'elated

conditions could continue to affect the timetable for developing a its reassessment leading repository. For example~ Bechtel to the submission of a licenseapplicatiori in January 2006 as a high-risk

chara~d

schedule that does not include any contingency or reserve---in effect, .an 9ptimistic schedule. Also, NRC, in its preliminary comments on the sufficiency of site characterization, Stated that if DO E ad9ptsa lowc-temperature repository operating approach, such as described in a recent technkal document, then additional infonnation would' be needed

for a potential license application.

Although we have clarified our discussion of the statutory and r-egulatory

requirements for site reconimendation, approval, and licensing, we
continue to believe that the SecretarY ofEDergy should consider the timing of thiS statutory process as he decides when to make a site recommendation to the President Therefore, while we have modified the

language, we have not changed the intent of our recommendation on this luatter. DOE did not conunent on our findings conclusions ' and teconunendationS ~out (l) potential delays on, and alteroatives to, its ' proposed repository design and (2) its management of the nuclear waste
progran:t.

Scope and

Methodology

We performed our review at DoE' s headquarters in Washington, D. , and its project office in Las Vegas, Nevada. We also met with officials of NRC in Rockville , Maryland; the Nuclear Waste Technical Review Board in Clarendon , VIrginia; and the state of Nev3.da s Agency for Nuclear Projects ' in Carson City, Nevada. We conducted our review from April through

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December 2001 in accordance with generally accepted government auditing standards. (See app. I for details of our scope aQd methodology.

We will send copies of this report t.o the of Energy; the DireCtor Budget; and other interested parties. We will Office of ~anagement and you or you staff have any queStions . make cppies available upon tequest about this report, please call me at (202) 512~1. Key contribut.ors to this

report are listed in appendix llL '

/dobl

Director, NattIral Resour~es artd Environment

(Ms. Gary L. Jones

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Appendix I: Objectives , Scope , and Methodology
Our objectives f~rthis report were to detennine whether (1) the Department of Energy (DOE) haS completed the work necessary to
support a site recommendation for the development

Yucca Mountain, and (2) DOE' s goal Mountain ,in ~10 is reasonable.

of

of a repository at opening a repository at Yucca

To determine whether DOE , through its Office of Civilian Radioactive

Waste ,Management (OCR~, has completed the ~ork necessary to support a site recommendation, we discussed with DOE officials the two nature and extent of such work and their relati(mshipto the processes. We also discussed technicai iSsues still outstanding with staff of the Nuclear Waste Technical Review Board, the Board' s Chairman, and

the staff of the Nuclear Regulatory Commission s
Materials~afety and Safeguards. We,

(NRC) Office

of

Nucl~

analyzed the Board' s annual. rePorts

of concern and other correspondence to DOE, and swumarized issues affecting a, site recommendation raised by the Board to DOE. We also

reviewed documents obtained from NRC to identify key ~chnical issues affecting readiness to s!lbmit an acceptable license application. We visited DOE' s Yucca Mountain' Site Characterization Office in Las Vegas, Neyada, and interviewed. officials in that office on the Department' s response to the issues raised by the Board and NRC. We also reviewed project management documents at OCRWM' s headquarters and at the project office to identify and characterize how OCRWM's response to the issues raised had been incorporated into the project' s work plans and guidance to the office s management contractor for the nuclear waste program. We interviewed offic~ of Bechtel SAlC Company, LLC, DOE' s management
contractor, and obtained and analyZed documents prepared by the

contract.or-such as its September 2001 detailed reassessment of the ongoing and future project how nuclear waSte program.-to determine workwould address tllese issues, and the subsequent effeCts on the ' project schedule and milestones.
To detemune whether DOE' s goal of opening a repository at Yucca MOlmtain in 2010 was reasonable, we analyzed OCRWM's reports and project doctnnents. We int.erviewed officials in OCRWM' s headquarters and the project office to deteroline how total project and program costs

, had been captured, estimat.ed, and reported

to the Congress and the

public. We summarized the estinlated program costS and associated time. We also determined the reasons for the lllilestones and changes over

procedures usedbyOOE to revise its cost and schedule estimates for site recommendation and license application, and assessed its use of those

procedures.
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Appendix I: Objeeth-es, Scope, and Methodology

Our work was conducted from April through December 200 1,

in accordance with generally accepted government auditing standards.

: ,c

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Appendix

ll:

Department

of

Comments Froin the' Energy

G).

The Under Secretary, of Energy
Washington. DC
December

2ool

The H!H19rable David M. Wallccr

Comptroller Gcnerat U.s. GcnCQI Accounting Office 441 OStrecI. N. Washington. D.c. 20543
Dear Mr. Complroller GcnCQI:
The Department has received, by November 28 letter, the General A(;ooW1ting

~;f) ,

Office s proposed report. "Nuclear Waste: Technical, Schedule. and Cost UncertaintieS OlI the Yucca Mountain RepositorY t,troject." The proposed report, addresseS the qUC$tiOn ~iictbcr the Department of Energy is ready to make a recommendation to Ihe President reganling wbethetYucca Mountain is a suitable silc for a potential repository - a recommendation the ~tary of Energy is called upon to make by Ihe Nuclear Waste Policy Act of 1982.
Let me emphasize at 'the outset that, press tqKIns to the coRtrary; Ihe &actlry has not decided on a linn lime fuunc for deteimining whether or not to recommend Yucca Mountain for this purposc.lel'alone having decided what the content of such a recommcnclatioa might be. 1'hit being said, the Department believes the approach the- proposed n:port takes to these issues is profoundly

flawed forreasoos we explain below.
The proposed repo,n asks, in effeCt. " why now?" jlbout making a site

u~
mc

deteimirtation regarding the Yucca MoUlltainproject. Wbatit rcalistkally leaves is "then whenr should the tesWu of years of scientific inquUy reVeal the President have enough information to make that the Secrc:tary of Energy
their determinations on the merits. The Nuclear Waste Policy Act instructs that
the Socrc:la1y' s R:COntIIlcndation is to be made W1dcr Department siting guidelines that use the standard that a' facitity at the site is likely to mcd NRC radiation

protection standards, and aact receiving the conclusion of the NRC whclher the infonnation developed and underway will be sufficient for a licerise application. recently rendered Ihe sufficiency advice called for by , the Act. The

Avoidance of a timely decision - should it be otherwise called, for on its merits would be a derelictioo (If duty owed to cuqent and future genCQtions of Americans to pursue with thoughtful expedition the taste of making safe ail high

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Appendix II: Comments From the Department or Euergy

level nuclear waste. Because: theproposcd report is a ;'Brandeis brief' fordclay. wcmust in these comments aitieally cvatuate its majorpoints.
The ccnlral contention ofthc prop(lSCdrcport is that it is pmnaturc Cor. thC

Dcpattm~ to make a Site

r~tion

for Yucca Molllilaia because the
Cor a,

Department bas yet to complete all the remaining technical WOtk

license application. Th\$ contention reflects a profound lack oCWldemaniJing

the statutory and regulatory requirementsbascd on an

d\eircontex1.
a~.

~rale depiction of

First, the decision at band involvcsdctcrmining a potcntiai not the licensing The construction and operatiOn of a facility - bcce the repositorywould be licensed by the Nuclear Regulatory Commission iftg: site detcnnioatiolL The site itselCis not licensed; iuSte;.d its features, may affect dcsignofthe facility which is licensed.. Thus detennininga site must ocCur
of

before begiooing the licensing procedure..

That is why the Nuclear Waste Policy Act specifically envisions two distinct decisions: ~e by, the President, on the advice ofthc Secn:caay ,of Energy, as to ~itory at Yucca Mountain is potentially licciisable by whether- a hypotlletieal the NRC; then one by the MRC as to whether a proposed rqJOSitory, cOmplete; witlidesign specifications. should be allowed to be built and uItimatcly operate

th~
issues. .

Second, the proposed tqKKt misstates, in its brief Icealment of thent. the Dcpattmcnt' s siting guidelines as ~uiring the judgment that the site CUlTCntlv complies willi NRC licensing requirements, Not only is this not what the s guidelines ~uire, hut dUtfug the notice and conuncnt nalcmaking
held on them over a period many years. not a single coriuncnter suggested that the Dcpadmcnt adopt SUCh a standard. Rather, consistent with the Stl'I1Ctt1t'c outlined " above, the Dep:artmcnt' s guidelines call for the judgmcn,t tbat a facility at the Site

, is liG!x to meet NRC tadiation protection standards - a predictivi: judgment that
illhCCClltIy embraces the existence of incompletely
resolved potentiallicensiDg

Third, because the NWr A charges the Secretary with establishing "criteria to be used to detcnnine the suitabilityof (a) site for the localion ora rc;pository," the: , Depattmcnt s standards - in which the NRC has. concun-ed, as the NWP A also requires - provide the most importanllegally releVant guidance on the question whctha' the Department is ready, to make a site recommcndatiOIL Y ct the propoSed report. despite purporting to answer that question, ienores these standards altogether and instead evaluates the Department's readiness agaiilst a standard orits own devising,

.1\

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Appendix II: Comm~Dts From the Departiucnt of Energy

I~ ~on

Founh, Ihe NRC liccming process Is cmc that the ~C has descnOod as iteralivc an "'intcgmed and COIItinuous,proc.ess. That means that even chc "
8J1P1iQtion envi$ioaed by the

&IIICI1dInCnt duriag

1hc Iiocasing process, as was indicated in chc NRC Rgulatiolis in effect when the Nliclear WaSte Policy Act was adopted by Congrm in 1982.
Fifth, thc JIfOPO$Cd
rqJOrt alToRfs heavy

NWP A was not expected to be set in Its submission but was instead cxpectcd:to cxpCnCllCC ldinement and

and central emphasis to the existence of

an inventory ofissucs as to whicl.t the Depa(tmcnt "as IIg(ced with the NRC fudbe( to develop for licensing puqIOSCS. At the same time it c:ompletely' ' ignores the enormous body of scientific and work completed regarding lite site C!veI tile last !;\Yo decades, ii1cIuding the invcntOl)' of some 6:00 papers cited in the:

~I

; J

Dcpaibncnt' May, 2001 Science and EngiIIccriog Report on Yucca Mountain. NOF does lite proposed report toltCh Upon - or even ac1mowledge lite exisCcncc or - chc substantial body of ~.. directly relevant ~Iytic: lit~tuR: publistd by the Department, including the (998 Viability Assessmcn(, tbe 2001 Prcliltlinaty ~ite Suitability, Evaluation, the 200 I Supplemental Science and Pc:rfonnal1CC
Anal)'$CS, the 1999 Draft EnvirOllltleotallmpact Statement, and the 200 (

Supplement to lite 01111\ fitS.
Much less doeS lite proposed report aUcliJpt to evaluate the significance or tbe

u!.Uisolved issues as compared with those that have been addressed and resolved

in appropriate timing r()Ca site iecomntcndation. Nor does it address the fca:nt formal conclu.~ions or independent, tcclutically-Jitclate bodies

~ing ~

bb the U.s. Geological Survey, the Intemaliooall'cer Rc:ViewTeam or\he
IntcnJationaJAtomic Enei'gy Agency and ibc Organization ofEco09mic Cooperation and Development' s Nuclear Energy Agency, and the Energy Commilt~ of the COuitcii on Engineering of the American Society !If Mechanical
Engineers. In SlIbstaBce each oftbcsc has advised \he Depaitment that, fiom the

sWulpoint oCIhe disciplines within its institUtional expatise, the, infonnatioR

addu~ to date ,is sulflclcnt for a site recommcqdatioiL
Sixth, lite proposed repod gives short shrift to the NRC' s recent "sufficiency 1cttcr," that memorializes a site determination judgment called fur specifically by the Nuclear Wascc Policy Act to the effect thai the NRC has concluded that the data and analyses eXisting aiKI undaway iikely will be ~fficieat for a license application. Instead \he proposed report centers ilS attention OR views attributed to an advisory committee to the NRc. ignoring that it is the NRc. rather titan any afits individual or c:oIledive adviso:s, that is responsible under the Nuclear Waste Policy Act (as in all else) rorthc conductofits statutory functions.
Seventh, and in a similar \-ein, lite proposed report prominently emphasizes the
views or the Nuclear Waste Teclmicat Review Board as requiring the Dcpanmeat to a.:commodate 1Itc!u before a site dctenninatioa is to be made. The Department regards the BOard' s advice as extremely valuable and anticipates continuing to

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Appendix II: Comments Front the Department of Energy

Nonetheless. bcyOOd receive that advice throughout tbc cnti~ of.thc program. ,

Ibis advisory functiou. Congress gave the Board no foQnaI role in the siting it established thiS body. And in any event what is not cmphasiicd, prOcess s criticisms, is directed, to in die proposed report is th~ the subs~ of die BoaId'
factocs thatbcaron liccosingthe (acUity, not the idcntity ofthc: site.
rccoJDinendation decision

Finally, the proposcchq,OIt asserts !hat delaying a site

wiU have no effect on the timing of the ultimate opening of a

~ory. That is

9OI\IJ'a1Y to all coounon sense and experience. Y ct this assa;1ion plays a critical role 1n the S!IUcIUrc of the report. Had the rqJOrt made the only realistic ~y on ~e rcco~dation will indeed lead IISSIIRtpbon 00 ' this, qucstion ..: that to dclay in opening a rcpOsitOQ' - it woUld have had to come to grips with the costs 11$ well as the benefits of delay. , Foccxampte: bigb level ra4ioactive wasle is

currcnt1y sto~' iD sunace facilities at 129 sites in 39 Slates around the country.
with attendant Vulncritbilities. Y ct the report gives no weight to the interests of , the communities where this Waste in located ill. having a decisiOn on a site roc '
tcpositmy made promptly OIlC wayoe the
other as soon as it can be made '

responsibly.

We look rorwa~ to worki~g with tbe GAO on this important issue.
Sincerely, '

I(~ i.ru i G: C~ hiif'
Robert G. Card ,

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Appendix ill: GAO Contact and Staff Aclmowledgments
(j-AO Contact,
Dw~yne E. Weigel (202) 512-6876

AcknQwiedgments

In addition, D~etJ. Feehan, Robert E. Sanchez, John C. Furutani
Jonathan 8. McMUrray, Lindy Cae, ' Doreen
S. Feidman, and Susan vi.

Irwin

ntade key contributions to this report:

(3GOO68)

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Viability Assessment of a Repository at Yucca Mountain

Overview

S. Department of Energy
Office of Civilian Radioactive

Waste Management
DOE/RW-O5O8

0044

P A- 196032