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The U.S. Department of Energy's (DOE) Waste Isolation Pilot Plant (WIPP) must comply with EPA regulation 40 CFR Part 191, Subpart B, which sets environmental standards for radioactive waste disposal. The regulation, Environmental Radiation Protection Standards for Management and Disposal of Spent Nuclear Fuel, High-Level and Transuranic Radioactive Wastes (hereafter referred to as the Standard), was vacated in 1987 by a Federal Court of Appeals and is undergoing revision. By agreement with the State of New Mexico, the WIPP Project is evaluating compliance with the Standard as promulgated in 1985 until a new regulation is available. This report summarizes the early-1990 status of Sandia National Laboratories' (SNL) understanding of the Project's ability to achieve compliance. The report reviews the qualitative and quantitative requirements for compliance, and identifies unknowns complicating performance assessment. It discusses in relatively nontechnical terms the approaches to resolving those unknowns, and concludes that SNL has reasonable confidence that compliance is achievable with the Standard as first promulgated. This report is not a formal evaluation of compliance: available data and models are insufficient for a full-scale assessment and 40 CFR Part 191 has not been reissued following remand. The first preliminary performance-assessment report for the WIPP will be completed in December 1990.

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