For 27 years,, the U.S. Environmental Protection Agency has been mandated to be a steward over the area and towns adjacent to and around the Nevada Test Site (NTS) and in Utah, both populated and unpopulated. Hundreds of nuclear weapons have been detonated both above and below ground at NTS; Some of these devices have failed to detonate partially or completely. Many NTS areas are contaminated with large quantities of radioactive soil and equipment on the surface of the land. The monitoring program was designed to determine if radiation was spreading to areas surrounding the NTS and to mitigate these situations if necessary.

With the implementation of one document, the U.S. Department of Energy has ended the funding arrangement which gave EPA independent oversight of areas and people surrounding the NTS. This funding cancellation went into effect October 1, 1998 under protest with EPA and with no public forum for information. Did you know this?

A new, significantly smaller monitoring program will be run by a DOE contractor. The contractor is bound to obtain results approved by DOE to maintain their contract It must always answer to DOE. Only DOE will be privileged to see the data until it is published in one of their annual reports, typically four or five months past the first of every year. Their will be no independent verification of the data. If anything changes at NTS, DOE will be the only federal agency to know until this report comes out each year. It will be unavailable to anyone else until published. DOE will have the opportunity to edit, omit, or explain away any DOE unacceptable results.

The people living or working around the Test Site were not informed during the planning phases for these changes; their comments were not solicited. The strong trust of these people forged by committed EPA Monitors throughout the years has been highly compromised. One may only surmise their opinions and concerns don't matter.

Native Americans were not informed that ancestral and reservations sites would no longer be safeguarded by the EPA. Their opinions do not matter either.

Environmental organizations, were not informed of the proposed changes, eliminating their ability to assess the effects of this change in order to inform their political representatives of their concerns.


Therefore, as politicians in Nevada were not informed, their comments and approval were not solicited, negating their ability to serve the public.

Accordingly, the media were not informed, effectively completely suppressing any information flow.

DOE-Nevada is now in violation of law (the National Emissions Standards for Hazardous Air Pollutants) and its own environmental programs as directed by DOE's headquarters office in Washington, D.C. These arc programs DOE assured Congress it would follow. DOE staff have been overheard by other DOE staff inferring they (DOE Management) would rather pay a fine (which would be small in comparison to what a good environmental monitoring program would cost) than operate within the Federal Law. We think that logic is criminal and flawed, possibly hazardous.

DOE also violated the Community Right-to-Know Act, which protects citizens from radical changes in monitoring at the Nevada Test Site by simply failing to inform them.

The old plan, which was put into effect almost, thirty years ago by now-retired DOE and EPA staff, was completely discarded by people in DOE who don't care about radioactivity at the Test Site. The details are in the Routine Radiological Environmental Monitoring Plan (RREMP), which you can request from DOE.

Is radioactivity moving past the "security" of the Test Site? Assuredly, yes, although it has only been detected in small quantities in recent years. Are old bomb test cavities leaking? Yes, radioactive tritium in water has been reported to have breached the NTS boundaries and is moving toward the town of Beatty, Nevada and the Amargosa Valley areas.

Is continued oversight necessary? Given the massive quantities of radioactivity still within and below the surface of the Test Site, both above and underground in unsecured bomb cavities, the answer should be clear. Leaks and offsite radioactivity continues to be found at other DOE sites in the U.S. and will be found off site at NTS. DOE is using computer models, not actual data, to pronounce that EPA monitoring is no longer necessary. Can it assure the public that radiation would not leave the Test Site by an air or groundwater pathway? Of course it can't, and lack of independent monitoring will ensure this outcome in the future.

EPA discussed with DOE a smarter, more cost-effective monitoring system, in good faith, having been informed funds were tight. DOE ignored EPA's concerns and EPA very


strongly requested any references to the Agency be removed from the final RREMP because it is not what EPA agreed to in the interagency agreement. We learned that EPA's initial recommendation was to leave the old program alone.

DOE stopped EPA from monitoring milk from most dairy producers, as only two samples are collected annually around the Nevada Test Site.

DOE stopped EPA from monitoring vegetation.

DOE stopped EPA from monitoring deer, bighorn sheep, and other desert species.

With the stroke of a pen, DOE is closing monitoring stations in Utah. This is, where the "Downwinder's Suit" first started, which proved cancer-effects from above ground nuclear testing had, in fact, occurred. Utah's public and politicians were not informed nor given opportunity to comment on the implementation of the new plan. It is expected the populous, is still trusting that they are being monitoring by EPA.

Over the past few years, DOE funding to EPA for this program has been drastically cut. DOE is letting its monitoring program fall apart by designed neglect. Is it the kind of Agency one would believe to be completely candid with monitoring data, especially if an unexpected event were to occur? DOE's programs/budget cuts are ridiculous. Of the massive amount of money that comes into the Test Site for its nuclear weapons research programs, only of 1% of the DOE-Nevada budget is spent on environmental monitoring. Money and making a better bomb arc the only issues of concern to DOE.

DOE gutted its own environmental laboratory a few years ago, claiming on-site monitoring was not necessary. The very svelte new program is a humorous "tech" toy which laughingly measures nothing. Perhaps their point exactly?

The proof is in the RREMP. The document was implemented October 1, over the objections of EPA. Crucial funding to EPA was cut, and EPA is faced with the realistic possibility of laying off highly qualified EPA staff who have spent their professional careers monitoring the environment around the Nevada Test Site for the citizens of Nevada and Utah.

EPA may not be able to maintain other crucial support to DOE because of these (budget) cuts, including radiation emergency response. EPA's objections were documented in a letter to DOE, which DOE ignored (it is attached). EPA's objections to its funding cuts


were sent to DOE (We were not able to get that letter but will be pursuing it and EPA staff internal comments under the Freedom of Information Act). Media may be able to get the, letter simply by asking.

DOE is attempting to slip these changes through in an election year, hoping the public and politicians will be distracted by other issues. EPA is prohibited from informing Nevada and Utah politicians by a law preventing "lobbying Congress." Concerned DOE employees arc also prohibited from informing politicians. Their management would take actions against them. DOE is a repeated violator of protections afforded to employees under the federal "Whistleblower's Law." No wonder no employees will step forward!

We think citizens of Nevada and Utah have a right to know that a decision which affects, their lives, and the lives of their children has been made without their input. DOE doesn't seem to care about the public's safety or health, and it gives one the strong impression the environment is entirely disposable. We know DOE is wrong. We are a group of retired DOE and EPA employees who spent our careers making these environmental measurements. Apparently, DOE thinks our work means nothing. We live in Nevada and expected these programs to continue; that was certainly our scientific opinion. We devoted our careers to ensuring the safety of the citizens of Nevada and Utah. We are concerned about our own safety and that of our loved ones now that NO protections will be in place.

DOE proposes to put high level radioactive waste at the Yucca Mountain Facility which is located within the Test Site boundaries. Is it coincidence that environmental monitoring is being functionally eliminated?

DOE almost eliminated its environmental monitoring program at Los Alamos National Laboratory in New Mexico and it took a lawsuit to put it back into place. Let's hope this action isn't necessary and an honorable retraction of this "New" agenda will quickly be employed before too much valuable data will be lost and the affected populous will not be without protection.

Please inform yourself. Call DOE at (702) 295-1000. Request a copy of the Routine Radiological Environmental Monitoring Plan (RREMP) DOE/NV/11718-244. Please ask questions. Their "spin doctor" may lie to you; persist until the truth sees the light of day.


Retired scientists, monitors, and individuals from DOE and EPA who too great pride in their honest efforts to protect all living things around the NTS.