BOB MILLER
Governor
STATE OF NEVADA
EXECUTIVE CHAMBER
Capitol Complex
Carson City, Nevada 89710
TELEPHONE
(702) 687-4486
Fax: (702) 687-4486
May 5, 1995
    Thomas P. Grumbly, Assistant Secretary for
    Environmental Management
    U.S. Department of Energy
    Washington D.C. 20585
    Dear Secretary Grumbly:
    Thank you for keeping me appraised about issues effecting the Department of Energy's (DOE) Environmental Management (EM) program. In February of this year you advised me, and seven other Governors, about the Administration's plan to restructure DOE's cleanup program and its' subsequent impact on activities at DOE facilities, including the Nevada Test Site. You also acknowledged DOE's commitment to work with states to address impending budget shortfalls in the EM program. In that regard, I must commend recent actions taken by DOE, the National Governor's Association and the states to open a dialogue to address EM budget shortfalls and program priorities on a site by site basis.

    As you know, funding for environmental restoration and waste management activities conducted at the Nevada Test Site comprise less than one percent of DOE's national cleanup budget. Nevertheless, DOE considers the Test Site a candidate for the disposal of vast quantities of low-level and mixed low-level radioactive waste. Most of these wastes are residues left-over from past nuclear production activities or are wastes that will be generated from current and future cleanup at numerous sites located throughout the country. Given these circumstances, I am concerned that DOE is looking at Nevada as a major waste disposal area without an adequate assessment of environmental conditions and priorities for the Nevada Test Site.

    Overall, I believe federal officials must begin to treat the Nevada Test Site as they do other DOE facilities in the weapons complex. While I sympathize with the contamination problems that exist across the complex, Nevada should not be the recommended solution for those problems until there is a more detailed understanding of site contamination at the Test Site. Moreover, DOE officials are faced with significant mission conversion issues at the Test Site that are contingent upon an orderly remediation and site characterization program. Down playing environmental and regulatory compliance, however, while supporting waste management to facilitate disposal of off-site generated waste at the expense of onsite environmental restoration, is not an approach we in Nevada can support. In addition, we must guard against waste disposal activities at the Test Site that might exacerbate existing environmental conditions thereby precluding potential alternative use of the site.

    The impact of the moratorium on nuclear testing continues to cause substantial budgetary and labor force reductions at the Test Site. In the peak years of nuclear testing, DOE employed nearly 10,000 workers in Nevada. Today, that number has dropped by nearly 30 percent and will likely decline further. To counter this trend, State and local officials, union representatives, Nevada's University System and DOE have jointly developed new alternative use strategies for the Test Site. The success of these strategies, however, relies on a clear understanding and assessment of site contamination issues. Over 1,000 nuclear tests were conducted at the Test Site, more than 100 of which were detonated above ground. Contamination from these and other activities have resulted in 2,000 separate contamination sites that require varying levels of investigation and remediation.

    To assess contamination at the site and to address the question of "how clean is clean for what use", Nevada officials have taken action on two fronts. First, a lawsuit was filed to enjoin DOE's low level radioactive waste disposal program as well as persuade the agency to initiate a Site-Wide Environmental Impact Statement (EIS) for the site. The EIS is needed to establish an environmental baseline to support future development decisions and to formalize a land use planning process utilizing concepts of ecosystem and resource management. It should be noted, however, Nevada officials are not yet convinced that the EIS will achieve these ends. Second, a Federal Facility Agreement (FFA) is now being initiated to support remediation of contaminated sites based on negotiated priorities, which address real environmental concerns and not those solely drive by regulatory authorities. Implementation of such an agreement may, however, require additional funding support from DOE.

    While both of these initiatives focus on intensifying site remediation to support economic development alternatives in the wake of the test moratorium, the same cannot be said for DOE priorities at the Test Site. Because of recent and planned budget reductions, I am recommending that DOE redirect funding to support onsite environmental restoration and site characterization at the Test Site, instead of continuing to support waste disposal operations that benefit offsite generators. If this recommendation is ignored, a reduced remediation program at the Test Site will jeopardize regulatory compliance as well as undermine overall program continuity.

    In the future, I would suggest the DOE increase the base level of funding for the Test Site commensurate with anticipated remediation activities negotiated through the FFA process or otherwise mandated through corrective actions stipulated under a pending Resource Conservation and Recovery Act permit. Such an approach, along with development of a suitable EIS, will go a long way in supporting site development and alternative use strategies envisioned for the Test Site.

    Lastly, the Administration's plan to slow the growth in the national EM program will hopefully lead to efficiencies and cost savings comparable to other private and federal cleanup programs. Achieving those efficiencies can only be accomplished, however, with continued state regulatory oversight and citizen involvement. Any action to diminish this involvement would signal a return to the DOE culture of secrecy and neglect, the culture that left us with the legacy of widespread radioactive contamination across the DOE complex.

    I hope these comments are helpful in providing Nevada's perspective on DOE's Environmental Management programs at the Nevada Test Site.


    Sincerely;
    Bob Miller
    Governor
cc:

Nevada Congressional Delegation
Lew Dodgion, Environmental Protection
Robert R. Loux, NWPO
Tim Carlson, Economic Development
Leo Penne, Nevada, Washington Office
Terry Vaeth, Joseph Fiore, Don Elle, DOE/NV
John Thomasian NGA



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