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December 2001 in accordance with generally accepted government

auditing standards. (See app. I for det3ils of our scope and methodology.
.7.

We will send copies of this report to the of Energy; the-DireCtor Office of ~anagement and Budget; and other mterested Parties. We will

. make cppies available upon tequest.1f you or you staff have any queStionS about this report, please call me at (202) 512-3841. Key contributors to this reportare-listed in appendix IlL.

Director, Nat!Jral Resources and Environment

(Ms.) Gary L. Jones

Ji:a

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Appendix I: Objectives , Scope , and Methodology
Our objectives fQr this report were to determine wh~er (1) the Department of Energy (DOE) haS completed the work necessary to

support a site recommendation for the development of a repository at
Yucca Mountain, and (2) DOE' s goal of opening a repository at Yucca Mountain -in ~10 is reasonable.

Waste Managmtent (OCR~, has completed the ~ork necessary to support a site. recommendation, we discussed with DOE officials the nature and extent of such work and their relati()nship to the two processes. We also discussed technicai iSsu.es still outstanding with staff. . . of the Nuclear Waste Technical Review BQard, the Board' s Chairman, and the staff of the Nuclear Regulatory Commission s (NRC) Office of Nuclear Materials$afety and Safeguards. We analyzed the Board' s annual rePorts and other correspondence to DOE , and summarized issues of concern 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 submit an acceptable license application. We visited DOE' s Yucca Mountain' Site Characterization Office in Las Vegas, Nevada, . and interviewed. officials In that office on the Department' s response to the
issues rais~ 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

To determine whether DOE , through its Office of Civilian Radioactive

raised had been incorporat;ed into the project's work plans and guidance to the office s management contractor for the nuclear waste program. We interviewed offid~ of Bechtel SAlC Company, LLCj DOE' s management
contractor, 3ll,d obtained and analyZed documents prepared by the

contract.or-such as its September 2001 detailedreassessment-Ofthe nuclear waSte program-to dete11niI\e how ongoing and future project work-would addresS these issues, and the subsequent effeCts on the '
project scheduleaud milestones.
To detemune whether DOE' s goal of opening a repository at Yucca Molmtam in 2010 was reasonable, we analyzed OCRWM' s reports and project doctnnents. We int.erviewed officials in OCRWM' s headquarters

and tile project office to detem1ine how total project and program costs . had been captured, estimat.ed, and reported to the Congress and the
public. We summarized the estimated program costS

and associated

reasons forthe rtulestones and changes over time. We also detemuned the . procedures used by DOE to revise its cost and schedule estimates for site recommendation and license application , and assessed its use of those

procedlffes.
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Appendix I: Oldecth-es. Scope, and Methodology

Our work was conduct.ed from April through December 200 1, m accordance with generally accepted government auditing standards.

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Appendix ll: Comments From the'
Department of Energy

The Under Secretary. of Energy

C!).
ComperoUcc General

Wasftlngton. DC 20:!85

Decem~S, 2001

The Hon9rable David M. Walker
u.s. General Accounting Office
441 oStrcd. N.

Washington, D.c. 20548
Dear Mr. Comptroller Oatcral:

The Department has received, by November 18 lettcc, the General A~W1ting

~:D

Office s proposed report. "Nuclear Waste: Tccbnica1, Schedule, and Cost UncertaintieS on the YUC(;I Mountain RcpositOljo I'roject... The proposed report. addresses' the questiOn ",iictber!be Department oCEncrgy is ready to make a recommendation to the President regarding wbet!tc(Yucca Mounlain is a suitable of Energy is silc for a potential repository - a recommendation the called upon to make by the Nuclear Waste Policy Act of 1982.
Let me emphasize at the outset thaI. pteSS (q1Ods to the contrary; the Secretary has not decided on a linn time fuune lOr dctcimining whethcc or not to

rccomitiend Yucca Moun~ for this putpOsc.letalone having decided what the content of such a recommendation might be. "fh;it being said, the Department

believes the approach the proposed report takes to these issues is profoundly flawed for reasons we explain below.
The proposed rcPo,rt asks, in effect. " why now?" llbout making a sjte

u~
The

dctcimirtation regarding the Yucca MoUntainprojett. Whatit realistically leaves
is '"then "oJtcqr should the tesWlS oryears of scientific inquUy m-eal have enough information to make that the Secretary of Energy anjJ the their detcnninations on the merits. The Nuclear W me Policy Act instructs that the Secn:Wy' s recommendation is to be made under DcpaJ1mcnt siting guidelines that use the standard that a facility at die site is likely to meet NRC radiation protection standards, and after receiving the conclusion of the NRC whethcc the

~ent

infonnaUOIl developed and underway will be sufficient for a liCClisc application.

mc recently rendered the sufficiency advice called for by the Act

A voidance of a timely decision - should it be otherwise called . for on its merits wool\! be a dereliction of duty owed to cuqent and future generations of

Americans to pcusue with tItoughtfut expedition the task of making safe ail high

' i

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Appendix D: Comments From the Department

of Energy

level nuclear waste. Because the.proposed report is a !'fkandcis brief' fordclay. wcmust in these comments aitically evatuate its majorpoints.
' , o

The central contention of the pro~repod is that it is pmnature Cor. the for Yucca Molllitain because the. . Depamnetit to make a Site

~mnent bas yet to complete all the remaining technical worlc

r~tion

license application. Th~ contention reflects a profound I8ck of lDiderstanding or" the stalutoty and regulatory requirelnentsbased on an depiction of

dleir context.
a~.

for a.

~rate.

First, the decision at band involves. determining ~ potentiai i& not the licensing The constI1lction and operatiOn of a faCIlity - ha-e the repositoryof woulclbc licensed by the Nuclear Regulatexy Commission !fig: site determination. The site ilSClfis not licensed; inStead its features. may affect design of the facility which is Iiunsed. Thus detennining a site must occur

bcforcbeginning the licensing procedure.

That is why the Nuclear Waste Policy Act specifically envisions two distinct decisions: one by the President. on the advice of the Secretary of Energy, as to whethcl" a hypothetiCal ~pository at Yucca MoUntain is potentially ticen$able by the NRC; then one by the III"RC as to whether a proposed rwositOlY, cOmplete wididesign specifications, should be allowed to be built and"ultimatcly operate

thc~
held OD than over a period

Second, the proposed repod misstates , in its brief kealment of th6q, the Department' s siting guidelines as n:quiring the judgment that the site ClJlTentlv complies willi NRC licensing mJuirements. Not only is this not what the s guidelines n:quire, but dtiring the notice and comment rulcmaking
many years. not a :siogle coriunenter suggested that the
Department adopt $UCh a standard. Rather, cousistaIt with the StI'UC:Cute outlined .. above, the Department' s guidelines call for the judgntCll.t tbat a facility at the Site is likely to meet NRC radiation protection standards - a pRdicti~ judgment that

inherently embraces the existence ofincomplctcly resolved potentialliccnsing

issues. '

Third. because the NWP A charges tbe Secretary with establishing "criteria to be used to determine the suitability of (a) site for the lOcation ofa repository," the . Department s standards- in which the NRC hasconcum:d,as the NWPA also mJuirc:s - provide the most important legally releVant guidance on the question
whether the Department is ready. to make a site n:commcndation. Y ct the

proposed report, despite pwporting to answer that question, ignores these
standards altogether and instead evaluates the Department's readiness against a

standard ofits own devising.

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Appendix ll: Co_~nts From the Depanment oCEnergy

I~

Fow1h, Iho NRC liceasing process Is 0110 that Iho bas described: IS iterativc.. ao.d an "'integrated and COCItinuousprocess. " that means that even

the

appIQ~on envisioaed by the NWP A was not expect,ed to be set in

on its submission but was instead cxpectccUo cxpCriCl1CC

rc:fincmeatand

amendment cturia& thc Iiccosiug process, as was indicated in the NRC aquIalioris in effect when thc NUclear- waSte: Policy Act was adopted by Congress in 1982.

. fifth, dtc proposed report alfotds

an inventol)' ofissues as to wbid) the Depaitmcnt "as agt~ with the NRC furtbcc: to devewp for Jkeosing putpOSI:S. At the same time it 'completely' ignores the enonnous body of scientific and ,,0I'Ic completed n:garding Ihc site CIVCf the last JWo decacks , iIicIucfmg the inventoty of SO/!1C papen; cited in the

h~ and central
t~cal

. emphasis to the existA:ncc

Dcpaitmcnt' May, 2001 Science and Engineering Report 011 Yucca Mountain. Nor docs the proposed n:port touch Upon - or c:ven ac1mowledge the .wstencc or - the substantial body of ~; dircctly relevant analytic lit~ture published by the Depamnent. including the 1998 Viability Asscssmcnt.the 2001 ~Iintinaly ~itc Suitability. Evaluation. the 200 1 Supp1cmcntal Science and Pcrfonnancc Anal)'$CS, the 1999 Draft Environmental Impact Statement. and the 200 1 Supplement to the Draft EIS.
Much less doeS the proposed report attcriJpt to evaluate the significance or tbe

ul.1lisOlved issues as compared willi those that have been addccsscd and resolved in jiSSCSSing the appropriate timing r~ a site ~eO.dation. Nor docs it address the iecent formal' conclusions or iDlfcpcndcnt, tecl1nically-litaate bodies
hlcc the U.s. Geological Survey. !be IntC11l:lliooal Peer RcYiewTeam of the

IntcrnationalAtomie Enei-gy Agency and tbe Organization ofEc0n9mie Cooperation and Development' s Nucltar Energy AcencY, IIIId the Energy Committee of the COui1cil on Engineering of the American Society !If Mechanical that, ftom !be Engineers. In substance each of these bas advised the standpoint or thC disciplines within its institUtional expertise, thc. infonnation

8ddu~ to date is 51Iff!Cicnt for a sile recommcndatioil..

Sixth, the proposed 1'qIOd' gives short sluift to the NRC' s fC(;C/it "sufficiency

letter," that memorializes 8 site detcnnination judgment called foe specifically by the Nuclear Waste Policy Act to the effect that the NRC bas concluded that the data and analyses eXisting ai1d underway iikely will be sufficient for a license aPPlication. Instead the proposed rcjJort centers its attention on views attributed to an advisocy committee to the NRc, ignoring that it is the NRc, rather than any of its individual or OOtlcctive advisors. that is responsible under the Nucltar Waste Policy Act (as in all else) for the conduct orits statutory functions.
Seventh, and in a similar \'Cin, the proposed report prominently emphasizes the

views orilie Nuclear Waste Teclmical Review Board as requiring !be Department
to a.:commodate thC!t1 bcCoo: a site dctenninatioa is to be made. The Depmme/ll regards the BOard' s advice as extremely valuable and anticipates continuing to

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Appendix 11: ColftJlleJtts Fl'Onl the Department

of Energy

NonetheIess. bcyOOd receive that advice duoughout \be c:alUety of.the program. .

. prOcess

role in the siting gave the Board no Ibis advisocy 1Unctioa. it established thiS body. And in any c:veot what Is not ofdie Board' s criciclsms. is dircctcd. to
iI1 the proposed report Is ch~ die substance

f~

Cadocs lllat bear 00 licc:osing the facility, not the identity ofllle: site:.

Finally, the proposcdnpart asserts UIat delaying a site I"CCQIJIincndati~ decision will have no effect on the timing of the ultima~ opening of a tq)OSitory. That is plays a critical 9011~ to alt c:onunOn sense ,ooc:xpcriencc. Yet this rote: 1n the s!lUctute of the RpOrt. Had the repOrt made the only tealistie will indeed lead thisquestion ':' that d~tay on ~e

~on

IISSUIDJIIion on .

~~dation

to delay iI1 opening a repOsitory - it woUld have had to come to grips ra~oactivc waste is costs as wdlas the benefits of detay. Fcc example:: bigb level

with the

c:urrmtly stom\' in surtacc: facilities at 129 sites in 39 States around the with attendant wtnaibilitics. Yet the report gives no weight to the inten:sts of . the communities where this Waste iI11ocated ili baving a decision on a site f~' or the other as soon as it can be made' tcpository made promptly o!\c way responsibly.

QOUOtfy.

We look forwa~ to working with the GAO on this impottant issue.
Sincerely, .

f(~

i.Ju i:.

G.

C.:A.

13--1"

Robert G, Card .

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

AclmQwiedgments

In addition, D~etJ. Feehan, Robert E. Sanchez, John C. Furutani Jonathan S. McM~, Lindy Coe, -Doreen S. Feidman, and Susan vi. hwin
nta~e key contrIbutions t() this repQrt:

(~600G8)

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GAQ'

~ion

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Viability Assessment of a Repository at Yucca Mountain

Overview

S. Department of Energy
Office of Civilian Radioactive

Waste Management
DOEjRW-O508

0044

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DOFJRW- O508

Viability Assessment of a Repository at Yucca Mountain
Overview

December 1998

S. Department of Energy

Office of Civilian Radioactive Waste Management Yucca Mountain Site Characterization Office

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This publication was produced by the U. S. Department of Energy Office of Civilian Radioactive Waste Management.
For further infom1ation contact: S. Department of Energy Yucca Mountain Site Characterization Office P~O. Box 30307 North Las Vegas , Nevada 89036-0307
or call:

Yucca Mountain Information Center 800-225-6972
or visit: Yucca Mountain Site Characterization Project website http://www.ymp. gov

Printed with soy ink on recycled paper.

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.... ................ :............................................................. ..... ,.... .......... ...,................,...,............... ............................,...,............... ......' .... :..... .... ......................... ....... .. ;................... ..... :.............................................. ........................................................... .................... ........ ...................................... :...... ,... .. , ..... ,.., .. :....... """""" ......... ....,........................................... ............ ...... .... ...... .....,............... .........." ....................... ..... :.........,................ ..,....... ,................................................................. ~........................ ....................... ............. ....,. ~.......................... .......... ,...,............. ............... ... ~..,. . :......... "........""""""""""....................,...,......... .....

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Contents
Introduction The Viability Assessment ... Results in brief..... ,.....
:...... ............................................................. 1
............... ..... ......... 2

Background
'I'

he nuclear waste problem """""""""""""""""""""""" "",,""""""""'"..................

4

Geologic disposal..... .....

The law and the regulations ......................................... How geologic disposal would work ..............................................................................

Why. Yucca Mountain? ....,.......................................,...... ;............................................ 10
............... ......... ,..... ............. 12

Reference design
The reference design ................................... :..........................................................,.... 13
rhe design process

Performance assessment Performance assessment models ............................................................................... 18 The attributes of safe disposal......................... ~......................................................... 19 ...,............ 24 Possible dose............................ .....

Iii

Other safety issues.
What we are learning .................................................................................................
License application Plan to complete a license application ......................................................................

Operational safety .............................. Long. tern, safety ,.................
Estimated cost

......................... 29

Cost of licensing, building, operating, monitoring, and closing
a repository.... ...." .................., Repository costs .......
Who pays? ................. .....

............ ........."... 32

Total system life cycle costs .

;............ .................. .......... 33 ~.......... 34 :............... .,.. ............................... .....................,.. 35

Conclusion Concluding observations ........,...................................................................................
Back matter
Endnotes .,................. ....." ...................... ........... ........ ........ ...".. ...".. ....... ....,...... ........... 38

Glossary..... ....... Acronyms .........

...".......... ..,..,........,...... ....,... 42

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The Viability Assessment
The U. S. Department of Energy (DOE) has

been studying a site at Yucca Mountai~, Nevada , for more than 15 years to determine wh(,ther it is a suitable place to build . a geologic repository for the nation s commercial and defense spent nuclear fuel and high- level radioactive waste. This overview presents the results of DOE' s study to date.
In 1996, DOE announced that it would com-

tary of Energy on whether to recommend the Yucca Mountain site for a repository.
This overview of the of

Viability Assessment describes Mountain the nuclear waste problem and explains
Repository at Yucca

why the United States and other nations
are considering deep geologic disposal as the

solution. The overview describes why the United States is considering Yucca Moun.

plete in 1998 a viability assessment of the Yucca Mountain site that would describe
the following:
. The preliminary

tain and how a monitored geologic repository would work in the mountain, It presents a repository design, an assessment of
its expected performance, and an evalua-

design concept for the

critical elements of a repository and
waste package

tion of the possible effects on people living near Yucca Mountain. Also presented is the work remaining to be completed prior to a

license application, along with the esti. A

total system performance assessment ., based on the design concept and the scient. ific data and analyses available by 1998 , that describes the probable behavior of a repository in the Yucca Mountain
geologie setting

mated cost of building and operating a geologic repository at Yucca Mountain. Finally, based on the information in the viability assessment, the overview concludes with

DOE' s

assessment of whether work at

Yucca MOlintain should proceed.

. A plan and cost

estimate for the remaining work required to complete and submit a license application to the Nuclear

Regulatory Commission

. . An estimate of the costs to construct and operate a repository in accordance with
the de.sign concept

In th(! 1997 Appropriations Act,! Congress

required DOE to prepare the viability assessment.
The purpose of the viability assessment is
to provide Congress, the President, and the
public with information on the progress of

the Yucca Mountain Site Characterization Project, The assessment also identifies the

critical issues that need to be addressed
before a decision can be made by the Secre-

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