THE WASTE ISOLATION PILOT PLANT TRANSURANIC WASTE
REPOSITORY - AN UGLY DUCKLING IN TRANSITION 

George E. Dials
DOE Carlsbad Area Office
P.O. Box 3090
Carlsbad, New Mexico 88221 USA
(505) 234-7300

Leif G. Eriksson
COMPA Industries, Inc
2309 Renard Place, SE, Suite 110
Albuquerque, New Mexico 87106 USA
(505) 843-8421

The United States (U.S.) Department of Energy's (DOE's) Compliance Certification Application (CCA) for a deep geological repository for safe disposal of defense-generated transuranic waste (TRUW) at the Waste Isolation Pilot Plant (WIPP) site in New Mexico (Fig. 1) is being reviewed by the U.S. Environmental Protection Agency (EPA). In a proposed ruling on October 23, 1997, currently subjected to public review and comments, the EPA announced that the proposed WIPP repository complies with all applicable TRUW disposal regulations. Pursuant to current law, the EPA's final ruling is due by May 17, 1998. If the EPA's final ruling is consistent with its proposed ruling and if the Secretary of Energy promptly decides to open the WIPP repository, it may open 30 days later. When opened, the WIPP repository will complete the transition from an ugly duckling, overshadowed for decades by the much greater attention devoted to developing a deep geological repository for spent nuclear fuel and other high-level radioactive wastes (HLW), to a first-of-a-kind facility for deep geological disposal of long-lived radioactive waste.

INTRODUCTION 

In the United States of America (USA), considerable attention, efforts, and resources have been invested during the past 25 years in siting and developing safe disposal systems for long-lived radioactive waste. To date, the main attention and resources have been devoted to the development of a safe, deep geological repository for HLW. The Yucca Mountain site in Nevada (Fig. 1) is the only current candidate site for a HLW repository. The current plan is to complete: (1) a viability assessment of the Yucca Mountain site in 1998; (2) a site suitability assessment, site recommendation, and Environmental Impact Statement in 2001; (3) the license application in 2002; (4) the repository construction authorization in 2005/2006; and (5) the construction of surface and subsurface facilities in 2010, which would allow the Yucca Mountain HLW repository to open in 2010, provided the site is found suitable and the required licenses are obtained. 

The WIPP site in New Mexico (Figure 1) was identified in the early 1970s as a potential site for a TRUW repository. At the end of 1997, the surface facilities, a deep underground test facility, and a portion of the repository (one of eight panels) had been constructed (Fig. 2), and the regulator for TRUW disposal, the EPA, had made a preliminary ruling that the proposed WIPP repository complied with all applicable TRUW disposal regulations. By law, the EPA's final ruling on the CCA is due by May 17, 1998. If the EPA's final ruling is consistent with its preliminary ruling, the WIPP repository may open 30 days later, contingent upon the Secretary of Energy's prompt decision, which may transition the WIPP repository from an ugly duckling to a global showcase by June 17, 1998.

The subsequent text provides a concise background overview and a discussion of the WIPP repository followed by a summary of the authors' conclusions. The background overview addresses the legal and regulatory bases for the safe deep geological disposal of TRUW at the WIPP site, waste types and volumes to be disposed, the geologic setting at the WIPP site, the proposed WIPP repository baseline design, the safety basis for the WIPP repository, successful stratagems and lessons learned by the DOE Carlsbad Area Office (CAO), and potential challenges to the scheduled opening of the WIPP repository. The discussion addresses the CAO's path forward and potential challenges to the scheduled 1998 certification and opening of the WIPP repository. The authors' conclusions conclude the main text. A listing of the main references used in the text follows the main text. Key terms used in the text are defined below. 

Accessible Environment means: (1) the atmosphere; (2) land surfaces; (3) surface waters; (4) oceans; and (5) all of the lithosphere beyond the controlled area. 

Controlled Area means: (1) a surface location, to be identified by passive institutional controls, that encompasses no more than 100 square kilometers (km²) and extends horizontally no more than five kilometers (km) in any direction from the outer boundary of the original location of the radioactive wastes in a disposal system; and (2) the subsurface underlying such a surface location. As indicated in Figure 3, the controlled area at the WIPP site measures only about 41.5 km² and the shortest horizontal distance between the TRUW and the accessible environment is 2.4 km.

Disposal means permanent isolation of the waste from the accessible environment with no intent of recovery, whether or not such isolation permits the recovery of the waste. 

Disturbed Performance means the predicted behavior of the disposal system, including consideration of the uncertainties in predicted behavior, if inadvertent human intrusion(s) or the occurrence of unlikely natural events.  

Performance Assessment (PA) means an analysis that: (1) identifies the processes and events that might affect the disposal system; (2) examines the effects of these processes and events on the performance of the disposal system; and (3) estimates the cumulative releases of radionuclides, considering the associated uncertainties caused by all significant processes and events. These estimates shall be incorporated in an overall probability distribution of cumulative release to the extent practicable. (PA results are typically presented in the form of a complementary cumulative distribution function [CCDF]). 

Regulatory Time Frame means the time period beginning at disposal and ending 10,000 years after disposal. 

Storage means retention of the waste with the intent and capability to retrieve such waste. 

Undisturbed Performance means the predicted behavior of the disposal system, including consideration of the uncertainties in predicted behavior, if the disposal system is not disrupted by inadvertent human intrusion(s) or the occurrence of unlikely natural events. 

Legal and Regulatory Bases 

The WIPP Land Withdrawal Act of 1992 (LWA)¹ is the main law governing the safe disposal of defense-generated TRUW. It withdrew the WIPP site from public use and set it aside for the safe operation and decommissioning of a TRUW repository by the DOE in compliance with applicable laws and regulations. The LWA also directed the EPA to promulgate regulations for DOE's safe disposal of TRUW at the WIPP site. The EPA promulgated the final disposal regulations for TRUW under the LWA ( i.e., 40 CFR 191)² in December 1993. In February 1996, the EPA promulgated criteria (i.e., 40 CFR 194)³ for the WIPP repository's compliance with 40 CFR 191. 

The U.S. Congress amended the LWA in 1996 (LWAA).⁴ It includes provisions eliminating the No-Migration Variance Petition, reducing the waiting period after the Secretary of Energy's decision to open WIPP from 180 days to 30 days, and directing the EPA to rule on the WIPP CCA⁵ within one year after declaring the CCA administratively complete. The EPA announced on May 16, 1997 that the CCA was administratively complete. Thus, pursuant to the LWAA, the EPA'=s final ruling on the CCA is due by May 17, 1998 and the WIPP TRUW repository could open 30 days later. However, the EPA and the CAO are currently ahead of the statutory schedule, and the WIPP repository certification could occur in April 1998 and, if favorable, the WIPP repository could open in May 1998. 

About 60 percent of the TRUW contains a mixture of hazardous and TRUW constituents. The Resource Conservation and Recovery Act of 1976 (RCRA)⁶ is the main law pertaining to the safe disposal of the regulated hazardous constituents in the TRUW, and the EPA has promulgated the applicable hazardous waste disposal regulations.^7-9 However, subsequent to its promulgation of the RCRA-required regulations, the EPA transferred its permitting and oversight authority for storage and disposal of regulated hazardous constituents in the state of New Mexico to the New Mexico Environment Department (NMED). 

There are two main types of TRUW: contact handled (CH) and remote handled (RH). CH-TRUW ranges in radioactivity from more than 3,700 Bq per gram of waste up to a surface dose rate not greater than 2 mSv per hour. The more active RH-TRUW ranges in surface dose rate from more than 2 mSv to 10 Sv per hour. The WIPP repository may receive up to 175,584 cubic meters (m³) of TRUW.¹ However, the total amount of RH-TRUW that may be disposed at WIPP is 7,080 m³ and only 5 percent of this volume, i.e., 354 m³, may exceed a surface dose rate of 1 Sv per hour. In summation, 96 percent of the TRUW to be disposed at the WIPP will be relatively benign CH-TRUW with a maximum surface dose rate of 2 mSv per hour. 

In 1994, the CAO assembled a task force to estimate the amount and types of existing and future TRUW through 2022. (The year currently projected for termination of TRUW disposal at the WIPP site is 2033.) To date the nation's TRUW inventory has been estimated and reported by the CAO in three Baseline Inventory Reports (BIRs) and, most recently, in a National TRUW Management Plan. The BIR data served as input both for the establishment of the WIPP Waste Acceptance Criteria (WIPP WAC) and for PA calculations. (Only TRUW meeting the WIPP WAC may be accepted for disposal at the WIPP site.) 

The last BIR data were updated in the 1997 National TRUW Management Plan,¹⁰ which estimated the current defense-generated TRUW inventory to be about 104,400 m³ CH-TRUW and 1,700 m³ RH-TRUW. Additional TRUW generated through the year 2033, including TRUW resulting from the environmental clean up of current and former nuclear weapons complex sites, was estimated at about 57,000 m³ CH-TRUW and 2,300 m³ RH-TRUW. Some of the CH-TRUW will be treated, resulting in a volume reduction, and, according to the National TRUW Management Plan, the total estimated volume of CH-TRUW and RH-TRUW to be disposed of in the WIPP repository at the end of 2033 is about 130,800 m³ and 5,200 m³, respectively. Thus, the current baseline design for the WIPP repository readily accommodates expected TRUW volumes through the year 2033 and would facilitate disposal of additional CH- and RH-TRUW from activities such as the DOE's environmental clean-up of current and former nuclear weapons complex sites, facility decontamination and decommissioning activities, and future DOE missions such as excess fissile material disposition. For example, the DOE is responsible for 137 sites in 33 states nationwide, representing a total surface area of approximately 8,500 km². Many of these sites contain radioactively contaminated structures, soil, and groundwater. Recent estimates indicate that the nuclear weapons complex has created a 300-billion dollar clean-up legacy, which is the single largest environmental program in history.¹¹ Furthermore, the dismantling of nuclear weapons will also result in radioactive waste that might meet the WIPP WAC.

As illustrated in Fig. 2, the proposed WIPP repository is located about 650 meters (m) below ground surface in the 225-250 million-year-old Salado Formation. The Salado Formation is a 600-m-thick, regionally extensive, essentially impermeable, tectonically and seismically undisturbed, stable sedimentary rock sequence dominated by rock salt (mainly halite). However, the WIPP site is located in a natural resources area and commercial oil and gas exploration and extraction and potash mining occur within ten miles of its boundary.

The WIPP site was identified as a potential TRUW repository site in 1970 and has been subjected to investigations since 1974. Based on promising site characterization data and related preliminary safety analyses, an underground test facility and, subsequently, a portion of the repository were constructed in the candidate host formation between 1980 and 1988, including all surface facilities required to safely receive, handle, and dispose of TRUW. As illustrated in Fig. 2, four shafts connect the underground repository with the surface facilities. The current baseline design comprises eight TRUW disposal panels (one panel was excavated in 1987). Each panel hosts seven disposal rooms. Each room is 4-m high, 10-m wide, and 91-m long. Other dimensions of the proposed WIPP repository and the experimental facility are shown in Fig. 2.

The CH-TRUW will be contained in standard waste boxes and 208-liter standard steel drums that will be emplaced in the disposal rooms. Bagged magnesium oxide backfill crushed to specifications will be emplaced both between the waste containers and between the waste containers and the walls/ribs and the roof of the bedrock. The RH-TRUW will be contained in shielded canisters that will be placed in horizontal, sealed emplacement holes in the walls/ribs.

Although magnesium oxide backfill will be emplaced with the CH-TRUW and all disposal rooms and panels will be sealed off by concrete plugs, the primary containment and isolation of the emplaced TRUW is provided by the geological setting surrounding the repository and the containment properties of the four sealed shafts. The main purpose of the magnesium oxide backfill is to maintain a chemically stable disposal-room environment minimizing the solubility of actinides, microbial activity, and gas generation during the 10,000-year regulatory period. This application of backfill is novel, and its potential benefits and applications to other radioactive waste disposal programs and concepts will be discussed further at a workshop sponsored by the Environment Agency of England and Wales and the CAO in early May 1998 in New Mexico.

The safety basis for the long-term performance of the WIPP repository is defined in 40 CFR 191² and 40 CFR 194.³ The WIPP repository has been repeatedly evaluated against these safety standards and has consistently shown to readily comply. For example, subsequent to the submittal of the CCA,⁵ the EPA requested the DOE to conduct verification test PA (PAVT) based on parameter values and ranges selected by the EPA. As illustrated in Fig. 4, both the PA embodied in the CCA and in the PAVT requested by the EPA clearly demonstrate that the WIPP repository readily meets the EPA's unique and extremely stringent^12,13 TRUW-disposal regulations under the worst conceivable (disturbed) conditions envisioned by the DOE (more than 300 disturbed scenarios were analyzed in the CCA) and the EPA. Specifically, the maximum annual dose allowed by the disposal regulations is 0.15 mSv. In the CCA, the highest calculated radiation exposure from the WIPP repository to an individual living at the boundary of the controlled area and the accessible environment and drinking two liters of radioactively contaminated groundwater per day result in a maximum annual dose of 0.0047 mSv,¹⁴ which is about 1/32 of that defined by the EPA in 40 CFR 191 as safe. It should be noted, however, that the groundwater at the WIPP site is not potable/drinkable by humans or animals because of its high salinity. It should also be noted that the average natural background radiation in the USA is 3.6 mSv,¹⁴ which is about 24 times higher than the aforementioned EPA limit and 766 times higher than the radiation exposure from the WIPP repository calculated in the CCA.

Prior to the establishment of the CAO in December 1993, the opening of the WIPP repository was scheduled for 2001. The WIPP repository is now on schedule to open no later than June 17, 1998. Five important keys to the CAO's almost three-year advancement of the scheduled opening of the WIPP repository are: 

In April 1994, the CAO published a schedule, the DDP, for the accelerated opening of the WIPP repository in 1998. The DDP was based on a detailed analysis of the entire national TRUW management system.

Between March 1994 and August 1995, the CAO conducted a thorough evaluation, the SPM, of proposed research and development (R&D) programs and activities to identify the experimental data and other information required for compliance with 40 CFR 191. The SPM involved 116 experimental programs/activities; 46,000 combinations thereof; and 1,300,000 computational analyzes depicting levels of probable compliance with 40 CFR 191. The SPM identified eight experimental programs/ activities that, if undertaken and providing anticipated results, would provide a 96-percent confidence level that all the scientific information needed to demonstrate compliance with 40 CFR 191 would be obtained. The SPM results were used by the CAO to focus the R&D program, and, as indicated by the EPA's proposed ruling on the CCA, the focused R&D program obtained the data and information required to demonstrate compliance with 40 CFR 191. 

Throughout the implementation of the DDP and the SPM, and during and after the preparation of the RCRA Part B Permit and the CCA, the CAO strived to maintain an early and iterative exchange of information with its regulators, i.e., EPA and the NMED, and other interested parties. The CAO's main intention for these exchanges were to: (1) facilitate the EPA's familiarity with and understanding of the WIPP project; (2) accommodate early external input to ongoing CAO activities; and (3) prepare for challenges of the RCRA Part B Permit and the CCA. 

After the EPA's receipt and initial review of the CCA,⁵ it requested substantial additional materials and data, often above and beyond that explicitly required by the applicable TRUW disposal regulations. These requests focused on experimental data, quality assurance (QA), conceptual models, peer review processes and results, and expert elicitation processes and results. The fundamental principle at work in the DOE's responses to requests for more information from the EPA is that in a licensing process one must give the regulator what it wants to facilitate its decision-making. The CAO remains confident that the WIPP repository is very robust/safe and complies with all applicable laws and regulations, and that any future additional EPA information needs can be promptly met to facilitate the EPA's favorable ruling on the CCA.  

Indeed, the CCA, augmented by the information derived subsequent to the CCA, clearly demonstrates that the WIPP repository readily complies with one of, if not, the world's most prescriptive and stringent radioactive waste disposal regulations and compliance criteria, i.e., 40 CFR 191 and 40 CFR 194, respectively. The unique and costly aspects of these regulations notwithstanding, it should be recognized that, in the absence of internationally consistent waste characterization and safety/disposal standards for radioactive waste, it is the responsibility and prerogative of the regulator(s) to promulgate regulations that satisfy the regulator's concerns about radiation protection of the public and the environment, and that the applicant has to comply with the applicable regulation(s).

The three main categories of past challenges to the opening of the WIPP repository are: scientific, political, and emotional. Procedural challenges and overemphasized attention to marginal details unimportant to the overall safety of the WIPP repository are typical approaches pursued by organizations and individuals lacking the ability to accept or willingness to evaluate the sound science and conservative assumptions involved in the CCA, the RCRA Part B Permit application, and related regulations. The onus of conducting the analyses required to credibly establishing the probability and consequence of any proposed fictional doomsday scenario is on the applicant and the regulator(s) rather than the proponent(s) of a doomsday scenario, i.e., the applicant is guilty until proven innocent. 

The New Mexico Attorney General's (NMAG's) office and local anti-nuclear groups have a long-standing record of challenging the certification and opening of the WIPP repository. For example, the NMAG has spearheaded two legal challenges of the EPA's compliance criteria for the WIPP repository, i.e., 40 CFR 194, which were promptly dismissed by the court. These dismissals suggest that both 40 CFR 194 and the EPA's certification process are legally sound and will withstand any future legal challenge.  

However, in addition to these legal challenges, the NMAG's office is also challenging the pending certification of the WIPP repository with hypothetical inadvertent human intrusion scenarios. For example, the NMAG's office has suggested that water-injection some 300 m below the WIPP repository in a hypothetical well located adjacent to the WIPP site would allow the water to breach the containment provided by two steel pipes with concrete plugs and create a fracture extending laterally more than 2.5 km into the 4-m high WIPP repository. The EPA has discarded this hypothesis in its proposed ruling on the CCA.¹⁵ Another hypothetical human intrusion scenario recently introduced and promoted by the NMAG's office is post-closure air drilling into the repository causing significant gas-borne direct releases of radioactive materials to the accessible environment. This scenario remains to be formally addressed by the EPA. 

The CAO's five near-term goals are to:

The CAO's mission is to cost-effectively integrate the nation's TRUW program and to promptly open and safely operate the WIPP repository. The CAO has an experienced and motivated management organization and support contractors in place to accomplish this mission. However, subsequent to the DOE's submittal of the CCA, the opening of the WIPP repository is largely controlled by the EPA and the NMED rather than the CAO. Whereas the EPA has made significant progress in evaluating the about 84,000-page CCA and the additional information of about 20,000 pages subsequently requested by the EPA, the NMED has not been able to make similar progress on the 13,000-page RCRA Part B Permit application despite having a 17-month head start. Furthermore, whereas the EPA is planning a 120-day public hearing period on its proposed ruling on the CCA, the NMED recently outlined a public hearing process for the RCRA Part B Permit application that could add more than one year to the RCRA Part B Permit process after the NMED reaches a proposed decision at some indeterminate date in the future. 

Based on an annual CAO budget of about 170 million dollars, each day that the opening of the WIPP TRUW repository is delayed will cost the taxpayers about 500,000 dollars for the WIPP project alone. Additional costs will be incurred at TRUW storage and clean-up sites. Fortunately, the Secretary of the NMED has announced that the CAO does not need a RCRA Part B Permit to open the WIPP site for disposal of TRUW not containing regulated hazardous constituents. Consequently, the CAO intends to open the WIPP repository based on the conditions defined in the EPA's final ruling on the CCA. In the meantime, the CAO is focusing on activities ensuring that the NTP is ready to commence safe TRUW disposal operations by May 1998. The underlying assumption is that if the EPA rules that long-lived, radioactive TRUW may be safely disposed of at the WIPP site for at least 10,000 years, the NMED will also find it safe to dispose of the much less dangerous hazardous constituents under the same conditions for only 300 years. As indicated by the CAO's long-standing safety record, safety always has and will continue to govern all CAO operations.  

The DOE is required to conduct safe as well as cost-effective operations. Based on cost analyses, the CAO has decided to privatize mobile characterization and transportation of TRUW. The privatization of mobile TRUW characterization capabilities will facilitate: (1) a faster and more cost-effective characterization of existing TRUW; (2) the development of a detailed statistical TRUW database; and (3) an accelerated program for the environmental cleanup of current and former nuclear weapons complex sites. The privatization of TRUW transportation is estimated to save at least 50 million dollars over the life of the program. 

Again, the CCA contains conservative assumptions and models. The CAO, supported by its primary contractors, will continue to evaluate these assumptions and models to reduce uncertainty in calculated results and to identify and implement potential cost-savings. Two specific objectives of these analyses are to assess whether: (1) the integrated, complex computational system employed for the CCA calculations may be simplified without compromising the credibility of the calculated results; and (2) TRUW integration and disposal operations may be simplified without compromising safety. 

When opened, the WIPP repository will become a first-of-a-kind facility for safe disposal of TRUW, a long-lived radioactive waste. Thus, the CAO intends to expand its future international exchanges with other radioactive waste management organizations and individuals for the following purposes: (1) to leverage existing CAO resources for cost-effective data acquisition on R&D and operations; and (2) to provide other nations access to the state-of-the-art knowledge vested in the CAO and its main contractors. Scientific collaborations are already established with Canada, Germany, and Switzerland and discussions are being held with Belarus, France, Japan, Spain, and Sweden. Other countries are also being considered for more formal information exchanges in the future. 

A broad-based acceptance of the WIPP repository is imperative to its opening and future. Although the CCA and the subsequent PAVT requested by the EPA clearly demonstrate that the proposed WIPP repository readily meets the applicable disposal regulations (Fig. 4), the sophisticated and state-of-the-art science and engineering computations involved in these calculations are not readily available to or understood by the public at large. The CAO, therefore, intends to vigorously continue its public outreach to address and clarify the scientific and engineering complexities of the WIPP repository as well as those of the NTP. The CAO's basic approach is to explain in terms that are readily understood by the general public that (a) the opening and operation of the WIPP repository is safe because it meets all applicable TRUW disposal regulations and (b) that it will reduce radiation risks to and increase the protection of human health and the environment both now and in the future. Three main CAO arguments in support of this approach are: 

A favorable condition to the opening of the WIPP repository, is the strong local political and public support. However, opposition to the WIPP repository appears to increase with distance from the site. Thus, the CAO must continue its public outreach to inform seekers of the truth. A particularly gratifying indication of increased public awareness of the risks involved if the WIPP repository does not open was provided by a local Native American¹⁷ during the public hearings on the CCA in Santa Fe in February 1997, who testified: 

 Potential Challenges

As mentioned above, opponents to the certification and opening of the WIPP repository have introduced two hypothetical scenarios that were not fully addressed and documented in the CCA: well-injection and air-drilling adjacent to or on the WIPP site. The CAO is in the process of evaluating these scenarios. The CAO's preliminary findings are that neither of these scenarios will compromise the WIPP repository's compliance with applicable TRUW disposal regulations.  

Air drilling is not the method of preference used for deep explorations in areas such as the WIPP-site region where aquifers are common. Furthermore, an independent panel comprised by six highly qualified experts concluded in March 1997 that the emplaced TRUW and magnesium oxide backfill would consolidate into an almost monolithic block well within the 100-year active institutional controls period due to the confining pressures of the surrounding rock.¹⁵ For example, the height of the disposal room would only be about two meters about 50 years after the room has been closed. Consequently, even if water/liquid would reach the repository location or if one could air drill at the WIPP site through prevailing aquifers down to depths in excess of 600 m, at the time of the postulated post-closure borehole intrusion: (1) the disposal room content would be solidified in blocks significantly larger than the borehole; (2) the opportunity for liquids to come in contact with the TRUW would be very limited; and (3) any air-drill-related release of radioactive materials would be very limited and confined largely to the waste material broken up by the drill during its penetration of the shrunken disposal room. However, it is likely that anti-nuclear interest groups and other opponents to the WIPP repository will continue to promote the above and other fictional scenarios. The CAO will therefore continue to conduct the analyses required to credible demonstrate whether the WIPP repository is safe to current and future generations and environments. 

The safe disposal of TRUW is an acute societal concern that must and can be safely mitigated at the WIPP site. The safety of the WIPP repository has been repeatedly demonstrated beyond any reasonable doubt. Indeed, the maximum potential radiation exposure during the 10,000-year post-closure regulatory period calculated in the CCA is 1/32 of that allowed by the applicable EPA regulation, i.e., 40 CFR 191, and 1/766 of the current average natural background radiation in the USA. In other words, the WIPP repository poses much less risk to the environment and public health during the next 10,000 years than living in the USA does. Thus, based on currently available information, opposition to the opening of the WIPP repository lacks legal, regulatory, and scientific bases and is neither environmentally responsible nor in the best interest of the welfare of current and future generations. 

1. U.S. Congress, The WIPP Land Withdrawal Act of 1992 (LWA), Public Law 102-579.
2. U.S. Environmental Protection Agency, Environmental Radiation Protection Standards for the Management and Disposal of Spent Nuclear Fuel, High-Level and Transuranic Radioactive Wastes; Final Rule, Code of Federal Regulations, Title 40, Part 191 (40 CFR 191), December 20, 1993.
3. U.S. Environmental Protection Agency, Criteria for the Certification and Re-Certification of the Waste Isolation Pilot Plant's Compliance With the 40 CFR Part 191 Disposal Regulations; Final Rule, Code of Federal Regulations, Title 40, Part 194 (40 CFR 194), February 9, 1996.
4. U.S. Congress, Land Withdrawal Amendments Act of 1997 (LWAA), August 7, 1996.
5. U.S. Department of Energy, Waste Isolation Pilot Plant Compliance Certification Application 40 CFR 191 Subpart B and C, October 29, 1996.
6. U.S. Congress, The Resource Conservation and Recovery Act of 1976 (RCRA), Public Law 94-580.
7. U.S. Environmental Protection Agency, Identification and Listing of Hazardous Waste, Code of Federal Regulations, Title 40, Part 261 (40 CFR 261).
8. Environmental Protection Agency, Standards for Owners and Operators of Hazardous Waste Treatment, Storage, and Disposal Facilities, Code of Federal Regulations, Title 40, Part 264 (40 CFR 264).
9. U.S. Environmental Protection Agency, Land Disposal Restrictions, Code of Federal Regulations, Title 40, Part 268 (40 CFR 268).
10. U.S. Department of Energy, The National TRU Waste Management Plan, DOE Carlsbad Area Office: Leadership in Safe and Efficient Cleanup of Transuranic Waste, (DOE/NTP-96-1204, Revision 1), December 18, 1997.
11. U.S. Department of Energy, Estimating the Cold War Mortgage. The 1995 Baseline Environmental Management Report, Office of Environmental Management, Executive Summary plus 2 Volumes (DOE/EM-0230).
12. National Research Council, The Waste Isolation Pilot Plant: A Potential Solution for the Disposal of Transuranic Waste, National Academy Press, October 1996.
13. Pflum, C.G., Van Konynenburg, R.A., and Krishna, P., Critical Comments on the U.S. Environmental Protection Agency Standards 40 CFR 191, prepared for the U.S. Department of Energy Office of Environment, Safety and Health, January 14, 1993.
14. U.S. Department of Energy, Citizens' Guide to the Waste Isolation Pilot Plant Compliance Certification Application to the EPA (DOE/CAO-96-1207), November 1996.
15. U.S. Environmental Protection Agency, Proposed Ruling on the WIPP CCA, Federal Register, October 31, 1997.
16. U.S. Department of Energy, Expert Elicitation on WIPP Waste Particle Size Distribution(s) During the 10,000-Year Regulatory Post-closure Period, Final Report prepared by the Carlsbad Area Office Technical Assistance Contractor, June 3, 1997.
17. Benny Atencia, Testimony provided on February 21, 1997, in Santa Fe during public hearing on the WIPP Compliance Certification Application.

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