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Department of EnergyNevada Operations Office
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April 13, 2000
Paul J. Liebendorfer, P.E., Chief HYDROLOGIC DATA COLLECTION AND FUNDING REQUIREMENTS TO SUPPORT THE UNDERGROUND TEST AREA (UGTA) PROJECT SITE INVESTIGATIONS/ CORRECTIVE ACTION PROGRAM FOR THE NEVADA TEST SITE Reference: Ltr., Liebendorfer to Gertz, dated 2/28/00 In response to the above-referenced letter, the DOE Nevada Operations Office (DOE/NV) feels that several items mentioned in the letter require additional clarification/discussion as they relate to the subject of the letter. The first item is the UGTA strategy contained in the Federal Facility Agreement and Consent Order (FFACO) and the assumptions associated with this strategy. The second item is the baseline document and funding for the Environmental Restoration Program as it relates to the UGTA Project. The UGTA strategy, contained in the FFACO, was developed as a plan to address groundwater contamination due to past underground nuclear testing. The state is based on using groundwater models to estimate movement of contaminants and define boundaries that encompass the extent of contamination. The plan is based on the principle assumption that the groundwater models can be developed utilizing existing information. This strategy and the underlying assumptions were negotiated and agreed upon between DOE/NV and the Nevada Division of Environmental Protection (NDEP). The corrective action investigation, as presented in the strategy, begins with an evaluation of the existing data followed by modeling and validation. If during this process the model is determined not to be acceptable, a decision point is reached on whether additional data is needed or a new strategy is needed. If additional data is needed. this data will be collected and the process repeated. At this time, Frenchman Flat is the only Corrective Action Unit (CAU) to have gone through this process, and per the strategy UGTA is currently collecting additional data in Frenchman Flat. DOE/NV acknowledged the fact that additional data needs were identified for Pahute Mesa prior to executing this process. However, this does not necessarily mean that the entire strategy is incorrect since each CAU is different. The evaluation of existing data is the first step in the a,-reed to corrective action investigation process following the development of the Corrective Action Investigation Plan (CAIP). It is our feeling that NDEP's comments that additional data collection is required for all CAIPs predetermine the results of the corrective action investigations. In addition, model verification may be achieved using either new data or data not used in developing the model. Therefore, installation of new wells for model verification may not be needed. The current UGTA baseline describes the plan to address groundwater contamination at the Nevada Test Site and the estimated cost and schedule to execute this plan. This plan was developed in accordance with the UGTA strategy and the assumptions associated with it. One of the assumptions in the current baseline is that a single cycle of the investigation process is sufficient. It is evident that NDEP feels that this assumption is no longer valid. DOE/NV would like to discuss potential changes in previously agreed to assumptions and/or strategies at your earliest convenience. The estimates in the baseline were developed for each activity in the process and then combined to provide a total project cost and schedule. This is then used to develop the DOE/NV Environmental Management budget request, which is submitted to DOE Headquarters. A standard management practice is to include contingency in developing estimates. However, due to the hi-h cost of conducting UGTA field activities, the standard method of applying, contingency to each activity would underestimate the cost of performing fieldwork if it is needed. To avoid this situation, the UGTA Project has developed specific contingency estimates in the form of new well installation. These contingency estimates are then used to support additional funding requests after the UGTA Project has gone through the process in the strategy and identified that additional data is needed. They have not been submitted in the past, as part of the FY+2 budget estimates, because the baseline assumption is the funding would not be needed. However, DOE/NV has used this contingency identification to support the additional funding requested for the Pahute Mesa drilling and the Frenchman Flat fieldwork. This is evident by the increases in the UGTA budget for FY 1999 and FY 2000 and the proposed budgets for FY 2001 and FY 2002 as indicated in the following table.
In a letter to Acting Assistant Secretary James M. Owendoff dated October 29, 1998, Governor Bob Miller indicated that an annual increase of $15 to $20 million would be needed to accomplish an acceptable groundwater characterization program. As you can see from the above table, DOE/NV has worked to accommodate this request. However, the State of Nevada is now saying that additional funding is needed to support an acceptable program and that this additional funding should start in FY 2001. Since Section XV.9 of the FFACO discusses FY+2 budgets, DOE/NV is in compliance with the FFACO on budget submittal for FY 2001. Since the President has already submitted the FY 2001 budget request to Congress, DOE/NV will make our DOE Headquarters office aware of the State's concern by reiterating the statements from Governor Guinn's letter to the Secretary of Energy and your letter. DOE/NV will also relay the information in the State's letters along with the FY 2002 budget submittal from this office. Two years have passed since the State indicated that $15 to $20 million would be an appropriate increase for the program (and much of that increase has been realized). As you are aware, in this era of federal fiscal constraints the overall Environmental Management budget has and is predicted to remain essentially level. Therefore, although DOE/NV will aggressively pursue additional funding for the UGTA Project, it will be a challenge to obtain this magnitude ($40 million) of increase. In addition, even with the contingencies noted above, the baseline funding for UGTA would be somewhat less then the $40 million requested in the Governor's letter. DOE/NV believes that the UGTA Project is proceeding in accordance with the strategy and that the funding requested for this project is compliant with the FFACO. However, your letter indicates that NDEP and DOE/NV may not be in agreement on the execution of the strategy. Based on your concerns and with your concurrence, DOE/NV and NDEP have set up a meeting on April 18, 2000, at 2:30 p.m., to address these issues. The current baseline revision was already in process prior to receipt of your letter and therefore will not reflect your concerns. However, as soon as NDEP and DOE/NV have resolved the issue related to the strategy, the baseline can be revised to reflect the new agreement. If you have any questions, please contact Robert M. Bangerter, of my staff, at (702) 295-7340.
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