December 7, 1999

The Honorable Bill Richardson
Secretary of Energy
1000 Independence Avenue SW
Washington, D.C. 20585

Dear Secretary Richardson:

Over the past several years the State of Nevada has continued to express concerns about the adequacy of the Department of Energy's (DOEs) commitment to address surface soil and groundwater contamination at the Nevada Test Site (NTS). State officials have said that DOE must begin to treat the NTS as they do other federal facilities. And while we do sympathize with contamination problems at other DOE sites, there nevertheless needs to be a better understanding of existing site contamination and long-term liability caused by nuclear testing in Nevada.

It is important to realize that radioactive contamination at the NTS is unique in comparison to all other DOE sites. More than one thousand nuclear tests were conducted at NTS, and of these, more than 250 were conducted within or in the vicinity of groundwater. Underground testing alone left more than 300 million curies of radioactive contamination spread through millions of cubic meters of environmental media. No other site in the DOE weapons complex contains a comparable volume of contamination, and no other site is faced with the mounting uncertainties concerning how this contamination can be effectively characterized, monitored, and contained over the long-term.

To address the most significant contamination problems in Nevada, I am asking that DOE commit to a long-term expansion of the Under Ground Test Area (UGTA) program at the NTS. Expanding this program will give DOE and State regulators a better understanding about the movement of contaminated groundwater beneath the NTS and the Nellis Air Force Range.

Current estimates suggest the geographic scope of existing groundwater contamination in the region may exceed 300 square miles to depths ranging from 500 to 5,000 feet. If this contamination moves offsite, it would evidentially affect public and private lands encompassing thousands of square miles. Most of the radiological contaminate of concern resulted from more than eighty underground nuclear tests detonated in groundwater beneath an area known as Pahute Mesa. Pahute Mesa borders the Nellis Air Force Range; it is located on the northwestern border of the NTS about 120 miles from Las Vegas. It was used for high-yield nuclear testing including some thermonuclear devises.

Contamination beneath the mesa is believed to be extensive and groundwater flows are predicted to move across the Nellis Range toward public and private lands. Accordingly, State officials contend that DOE needs to expand the UGTA program to predict existing groundwater flow patterns near the mesa as well as at other sites beneath the NTS. Understanding groundwater flow in the region is vital to assess alternative containment strategies that at a minimum may be necessary to prevent radionuclide contamination from leaving the borders of the NTS and the Nellis Range. In addition, I believe that management of groundwater contamination on site is also a concern and migration to unimpacted areas on site must also be appropriately addressed.

While current efforts by DOE to assess groundwater flow beneath the NTS are underway, because of competing priorities and historically deficient funding, those efforts have largely not been supported by the appropriate level of scientific data needed to fully understand the ground water contamination at NTS. DOE's current program for assessing contamination flow was recently castigated by an independent external peer review group commissioned by DOE. Overall, the peer review report1 found inadequate data to support groundwater flow modeling at NTS; they found that the available groundwater level and permeability data were inadequate for the assessment of groundwater flow directions, rates, and travel times in the vicinity of the contaminated areas. These findings are extremely troubling when considering the focus of the peer review group was in an area where only a few underground nuclear detonations occurred (i.e., Frenchman Flat). In addition, this initial investigation and modeling effort are intended to be replicated at other contaminated areas like Pahute Mesa.

Given all these considerations, I am requesting DOE increase financial support for the UGTA program at NTS. Additional support is now necessary to insure the State's ability to approve future UGTA millstones, as stipulated under the State/DOE Federal Facility Agreement and a Consent Order (FFACO). It should also be mentioned, because DOE's Environmental Management program at NTS comprises less than I percent of DOE's national EM budget, we believe the Department can adjust funding priorities to respond to the evolving groundwater investigation program at NTS. State officials contend that an additional $40 million (beginning in FY 200 1) will be necessary to keep the program on track. The additional funding is needed to address data gaps in the current UGTA program, which can only be accomplished by the rehabilitation of existing well in addition to the construction of new wells.

In a related matter, I am concerned about commitments to environmental restoration and "landlord" related activities by DOE Defense Programs (DP) at the NTS. As you know, significant effort has been expended to assess and market certain portions of the NTS for alternative economic development uses. Those efforts can only be achieved if DOE Defense Programs retain an active redevelopment and infrastructure maintenance program at the site. Providing continued financial support for DP funded environmental restoration activities, initiating an aggressive program to manage closure of the estimated four thousand wells and boreholes on the site, and addressing disposition of some 1,500 structures on the site are examples of DP activities needed to support alternative economic development uses at NTS.

Mr. Secretary, I know you are sympathetic to our concerns in Nevada and I appreciate your continued willingness to work with us on these issues. However, leaving any of the above mentioned issues unaddressed in Nevada will foreclose future uses of the NTS and intensify long-term risks to public health and the environment.



Kenny Guinn

  1. External Peer Review Group on Frenchman Flat Data Analysis and Modeling Task, Underground Test Area Project. September 16, 1999. IT Corporation