RECOMMENDATION 91-3 TO THE SECRETARY OF ENERGY
                   pursuant to Section 312(5) of the
                Atomic Energy Act of 1954, as amended.



Dated:     April 25, 1991



The Board and its staff have received several status briefings and
have conducted several site visits to the Waste Isolation Pilot
Plant (WIPP).  These reviews were directed at ensuring adequate
protection of public health and safety during conduct of the test
phase at the WIPP facility.

During a recent briefing on the WIPP Project, Department of Energy
(DOE) personnel described twelve separate reviews, appraisals, and
assessments by various DOE offices, contractor, and State oversight
organizations that have been conducted at WIPP since October 1988. 
Since DOE's review of the readiness at WIPP was spread over
approximately a three year period, the Board is concerned that DOE
does not intend to perform a final comprehensive readiness review,
after completion of the contractor's readiness review, prior to the
initiation of the test phase.  Therefore, the Board recommends:

      1.   that an independent and comprehensive DOE readiness
           review be carried out at WIPP prior to initiation of the
           test phase.  As indicated in item 2, members of the
           review team may include some personnel from the line
           organization;

      2.   that the team constituted to carry out the readiness
           review consist of experienced individuals whose
           backgrounds collectively include all important facets of
           the unique operations involved and that the majority of
           the team members be independent of WIPP programmatic or
           line management responsibilities to ensure an independent
           and unbiased assessment;

      3.   that the DOE readiness review team confer with the DOE
           teams that are currently performing readiness reviews at
           other DOE facilities to determine what procedures for
           conducting readiness reviews have or have not been
           effective, recognizing that a tailored approach is
           required for WIPP; and

      4.   that the review include, but not be limited to, the
           following items:

                 a.assessment of the adequacy and correctness of waste
                handling and utility systems normal and abnormal
                operating, and emergency procedures;

                                             2



                 b.assessment of level of knowledge achieved during
                operator qualification as evidenced by review of
                examination questions and examination results, and
                by selective oral examinations of operators by
                members of the review team;

                 c.assessment of conduct of operations by observation
                of actual waste handling operations using simulated
                waste containers, and the response to simulated
                abnormal and emergency situations;

                 d.assessment of the interrelationships and the
                delineation of roles and responsibilities among the
                various DOE (Carlsbad and Albuquerque) and
                contractor (Westinghouse and Sandia National
                Laboratory) organizations involved in the test
                phase;

                 e.examination of records of tests and calibration of
                safety systems and other instruments monitoring
                Limiting Conditions of Operations or that satisfy
                Operating Safety Requirements; and

                 f.verification of safety system as-built drawings by
                walkdown of selective systems.



                                                                                                                                                                                                                                                   /s/

                                                                                                                                                                                                   John T. Conway
                                                                                                                                                                                                   Chairman