STAKEHOLDER INTERACTION REGARDING CONTAMINATED
GROUNDWATER AT THE NEVADA TEST SITE THROUGH THE
NEVADA RISK ASSESSMENT/MANAGEMENT PROGRAM
Tod Evan Johnson and Kathleen Lauckner
Nevada Risk Assessment/Management Program1
Las Vegas, Nevada
ABSTRACT
Contamination of the Nevada Test Site groundwater has resulted from underground nuclear weapons testing. Potential risk associated with migration of the contamination to existing and future individuals on or near the NTS is being assessed through a forum of science and public interaction. Through the Nevada Risk Assessment/Management Program1 (NRAMP), citizens have been involved in the characterization, modeling and potential remedial options of the water. Development of the public interaction has included survey and public meeting formats. The interactions have occurred through a university organization, without DOE oversight, increasing public perception of independence and credibility in both the process and the results. An initial challenge was educating a general public audience with regard to technical material in order to allow appropriate public comment on the process. Most recently, the process has improved through expanded interaction with a smaller group of citizens formed in a focus group. The group restricts discussion to topics related to Nevada Test Site groundwater contamination and the potential risk associated with the contamination. The group interacts with the DOE through requesting data from the DOE and submitting written comments to the DOE. The group also comments on the technical direction and results of the NRAMP scientific staffs efforts related to groundwater issues.
INTRODUCTION
The Nevada Test Site (NTS) has been contaminated with radioactive and chemical materials resulting from a variety of missions. The Department of Energy (DOE) Nevada Operations Office has attempted to characterize and remediate (as appropriate) the contaminated sites. At the same time, on a national scale, the DOE has recognized that stakeholders 2 should be involved in the DOEs environmental restoration process (DOE, 1997). Through a competitive procedure, the DOE funded several groups to combine risk assessment and stakeholder involvement. The University of Nevada, Las Vegas (Harry Reid Center for Environmental Studies) and E.J. Bentz and Associates were funded to conduct the Nevada Risk Assessment/Management Program1 (NRAMP). NRAMP is part of a nation-wide effort by the DOE to develop new sources of information and approaches to risk assessment, risk management, risk communication and public participation. Following the recommendations of the National Research Council for such programs (Federal Register, 1994), NRAMP has functioned as an independent, credible and neutral entity. NRAMP has focused primarily on risk associated with contamination and related stakeholder issues at the Nevada Test Site (NTS) (Figure 1).
Fig. 1. Nevada Test Site Location Map
NRAMP is predominantly concerned with developing risk assessments of groundwater and soils contamination for which the DOE is responsible for in the State of Nevada. This paper focuses on NRAMP efforts to include stakeholders in the risk assessment of contaminated groundwater at the Nevada Test Site. Stakeholder involvement has continued with respect to other contaminants on site, but is outside the scope of this paper. Groundwater became contaminated as a result of underground nuclear testing. Since nuclear testing began at the NTS in 1952, more than 900 nuclear detonations occurred underground. Approximately 250 of those detonations were near or below the groundwater table, resulting in possible or likely groundwater contamination. Determining the extent and migration of the groundwater contamination have been on-going efforts by DOE/NV and its contractors. NRAMP technical programs have conducted an independent effort using DOE funding, following the National Research Council guidelines of independent, credible and neutral risk assessments. Identifying the nature and extent of the contamination is complicated by the complex hydrologic character, extensive area of the site (3500 sq. km.), great depth-to-groundwater (200 to 600 m below ground surface) and three different aquifers.
INITIAL EFFORTS WITH STAKEHOLDER INVOLVEMENT IN NRAMP
During the first two years of NRAMP, stakeholder input was sought through two primary mechanisms: a state-wide phone survey and a working group. Both the survey and the working group addressed all contamination of various types at DOE sites in Nevada. Contaminant categories included industrial activities, surface and near-surface nuclear detonations, underground contamination of various types, waste storage, and transportation of material to the NTS.
The 1200 respondent statewide-phone survey included 400 opinions each from the two largest population centers in Nevada (Reno and Las Vegas), and 400 from rural Nevada. The NTS is located in predominantly rural Nye County, which lies between Las Vegas and Reno. Groundwater contamination was considered a "very high risk" by 702 survey respondents. A complete summary of the survey results is provided in an NRAMP report (NRAMP,1996a).
Interactive meetings were held in Las Vegas and Reno, beginning in Summer 1995. The monthly meetings were promoted through mailing letters of invitation to individuals and organizations, public service announcements on local radio and television stations, and purchased advertisements in local newspapers. Each meeting was open to all interested citizens, with many of the meetings held simultaneously in Reno and Las Vegas. Simultaneous meetings were connected through tele-conferencing. The various topics related to risk assessment at DOE sites in Nevada. Groundwater contamination was the focus of two brief presentations. Interactions with members of that original Working Group helped establish the scope of the risk assessments undertaken in the first two years of NRAMP. The stakeholders were also instrumental in determining the format of the reported results, including determining the labels of various risk intervals associated with the results. The Working Group completed its task and was disbanded when NRAMP completed the Preliminary Risk Assessment, DOE Sites in Nevada (NRAMP, 1996b).
Through experience with the original Working Group, facilitators made recommendations for future stakeholder efforts as follow (NRAMP, 1995):
Along with the above recommendations, work with early NRAMP stakeholder groups helped identify several significant limitations of the Working Group process. One limitation resulted from the nature of the membership. Members of the public could join in the process at any point. Therefore, interactions would sometimes be complicated by having to bring new participants to the same level of knowledge as those who had heard background material prior to the presentation.
The quality of the Working Group interaction was also affected by the limited educational nature of the Working Group programs. A portion of each meeting was devoted to educational presentations. However, the set of topics covered during the course of the development of the PRA was so large that no subject was covered in detail. The difficulty in educating the group was compounded by the lack of consistency in the attendance by group individuals. Many times it was essentially a new group of citizens, making it difficult to build on material presented in past sessions. And for those who were consistent, it was difficult for them to maintain facility on the diverse topics presented through the course of a single, complex risk assessment.
Another limitation was diversity of topics. Through production of the PRA, the contaminants at the Nevada DOE sites were broken into five categories: 1. Underground Test Areas 2. Radioactive Waste Management Sites 3. Surface Soils 4. Transportation-Related Issues and 5. Industrial Sites. It was observed participants had different foci of interest some were interested only in issues related to transportation of waste in Nevada, others were interested only on the effects of surface nuclear testing, others in the effects of underground testing. It was also apparent through the evaluation of the PRA process, that each source category could be done substantially independent of the others. With planning and organization, the results of individual source categories could be combined near the end of the assessment with minimal loss in continuity.
CURRENT STAKEHOLDER PROGRAM: FOCUS GROUP
To overcome the limitations of the first public participation effort by NRAMP, a new stakeholder group design was chosen. The new design was based on a focus group concept. It was decided to condense the NRAMP stakeholder involvement into groups focused on more limited topics. Stakeholders were not restricted to attending any single focus group, but the topic of discussion within each focus group would be limited. Limiting the bounds of discussion to the focus topic as it relates to risk was intended to reduce the frustration faced by stakeholders who were not interested in other source categories. The source categories at the NTS were used as the basis for dividing the focus topics. The division was supported by the observations and limitations of the Working Group, and the ability for the assessments of different source categories to function independently of other source category assessments. The first focus group was the NRAMP Groundwater Focus Group, which is still actively meeting.
In order to facilitate the discussion more effectively, the size of the group was intended to be between 15 and 20 initially, with expected attrition reducing the group to between 10 and 15 participating in discussions. In order to achieve the designed size, advertising for the group was to be staged in several levels. The first action was to mail invitation letters to original NRAMP Working Group members, the NRAMP mailing list database, environmental groups, and local environmental professionals. Future advertising was to include widespread public service announcement distribution and other forms of wider distribution. However, the groups initial size was sufficient, so no further advertising was conducted.
During the formation meetings in March 1997, the goals of the focus group were established by the 32 attendees. The goals were:
Maintaining the spirit of the original NRAMP Working Group, the mission of the Groundwater Focus Group would allow the members to: learn about the NTS; discover risk to future generations from NTS activities; and make a difference in the government/DOE process. This by no means precluded the Groundwater Focus Group from making its own decisions about the focus group agenda and eventual recommendations to NRAMP.
The focus group addresses the NTS groundwater quality issues in a framework of risk. Instruction from the NRAMP staff members helped citizens to understand the goals set forth by their predecessors in the Working Group but also instructed them that it would be their individual concerns and input that set the agenda for subsequent focus group agendas. Increased understanding about the issue of groundwater contamination and associated risks are essential for the group to make relevant contributions and recommendations to NRAMP and eventually to DOE through the NRAMP documentation process. Issues are expected to include future characterization of the risk and related issues of monitoring and remediation of contaminated areas.
Meeting time was selected by consensus in the introductory sessions. Below is a list of meeting agenda items. Meetings began in March 1997, and have continued through to publication deadline for this document, December 1997. The frequency of meeting has been approximately every 3 weeks. The group expects to meet monthly in 1998 until the objectives are fulfilled.
Meetings 1A and 1B
Duplicate formational meetings.
Meeting 2
NTS overview and explanation of the groundwater contamination problem.
Meeting 3
NRAMP groundwater research program described (Part I). Also, presentation from Dr. David Kreamer, UNLV Hydrologist, on current and potential remedial options.
Meeting 4
NRAMP groundwater research program described (Part II). NRAMP Groundwater Risk Research Letter drafted by the group to the Director of NRAMP, Dr. Don Baepler, supporting the groundwater research direction of the NRAMP program.
Meeting 5
Nevada Test Site Tour, focusing on groundwater-related sites (Figure 2).
Meeting 6
General Radiation Effects: A presentation from Dr. Anthony Hechanova, Nuclear Engineer with the Harry Reid Center.
Meeting 7
A community meeting held in Pahrump, NV on the issue of NTS groundwater contamination and future monitoring by DOE. DOE requested comment and recommendations on their future groundwater monitoring plan.
Meeting 8
Discussion of the community meeting and information disseminated through DOE. Groundwater Focus Group members drafted a letter to Douglas Duncan, DOE Environmental Protection Division, to request more relevant information on groundwater characterization and monitoring procedures being used by DOE, and to make recommendations to be included in future DOE monitoring planning.
Meeting 9
Similarities between the recently publicized organic contamination in the Las Vegas Wash and the groups focus on nuclear contamination at the NTS were discussed. Lloyd Desotell, a graduate student with the Harry Reid Center, presented preliminary results of NRAMP's contaminant transport modeling efforts at the NTS.
Meeting 10
Klaus Stetzenbach, Senior Chemist and Director of the Harry Reid Center, presented groundwater characterization research known as "groundwater fingerprinting," being conducted at the Harry Reid Center by NRAMP.
Meeting 11
Dr. Clinton Case, Nevada Department of Environmental Protection, presented the Federal Facility Agreement and Consent Order, and how the Order affects the regulatory structure of the contaminated groundwater at the NTS.
Meeting 12
Conceptual design and layout of the NRAMP Groundwater Primer was discussed.
Fig. 2. NRAMP Groundwater Focus Group at the Nevada Test Site, June 1997
DISCUSSION
The current focus group effort continues to use the inherent strengths of the pre-existing NRAMP program. Those strengths include a scientific Peer Review Panel (a six member panel of national experts, familiar with DOE programs), direct interaction between scientists and stakeholders, and independence from DOE oversight or control.
Focus group members have been very supportive of the NRAMP research endeavors and the NRAMP process. They have been inquisitive, sometimes skeptical citizens, and are forthright with their beliefs and concerns. The group has become aware of many of the complexities involved with assessing the risks from contaminated groundwater and the overwhelming task of remediating or even monitoring the contamination.
In their understanding the complexities of the situation they also have some insight as to how the NRAMP can assist the DOE in the risk-related issues at the NTS and have made recommendations through letters to and direct interaction with the DOE. As a result of presentations listed above, the group felt compelled to write responses regarding the issues discussed or to recommend some further collaborations they feel could benefit the risk assessment process. However, it is not the design of the group to directly advise the DOE; it is believed the NTS Community Advisory Board should fulfill that function. Instead, it is intended that the NRAMP Groundwater Focus Group would give input to the NRAMP risk evaluation process. Through involvement in the NRAMP process, stakeholder issues and concerns can be included as changes within text or as direct written comments reproduced as addenda to NRAMP documents.
An example of direct comment to DOE was regarding the July 16 presentation by Douglas Duncan and other staff members of DOE. The meeting was intended to be a workshop to gather stakeholder input to a planned revision of the NTS groundwater monitoring plan. The Groundwater Focus Group expected a detailed, comprehensive presentation of DOE models that predict where groundwater is migrating and what contaminants are present in the water that may impact the surrounding communities. The members, having some awareness of the issues involved because of prior focus group presentations, did not believe they were given sufficient information to make comprehensive recommendations to DOE on the groundwater assessment approach, though limited recommendations were possible. A letter was written to Mr. Duncan and included a request by the group for more information. The information has not been released, but the incident highlights the awareness and proactive nature of the group regarding DOE interactions. It should also be noted that the group included in the letter specific recommendations regarding the proposed monitoring plan revisions. The recommendations were in direct response to a DOE request for input.
Other letters by the stakeholders have also been sent. There were two letters of thanks for presentations to the group, a letter of support for a groundwater fingerprinting research task, and a letter of comment on the NRAMP process.
Interaction between DOE and the focus group has been one-way, from the stakeholders to the DOE. However, it is hoped that communication will increase as a result of a DOE representative currently being assigned to attend all Groundwater Focus Group meetings. Future input to DOE likely will include incorporation of the stakeholder opinions in technical documents. The opinions and ideas will be included through incorporation of their concepts in NRAMP document text, direction of research, and as written comments attached to the documents.
The Groundwater Focus group has been a success to date. The number of participants has varied between approximately 10 and 15. In addition, interest and input comes to the group through written correspondence or phone conversations between members as well as between members and NRAMP staff. Interacting with this founding group has been a positive experience for both the members and staff. The group has been meeting longer than originally expected because of delays in release of results from the DOE program, restricting the ability of the group to provide input to the DOE in a timely manner. The original plan for the focus group meetings was to address the general issues in a particular order: Basic Background Education in Groundwater and Risk, Remedial Alternatives, NRAMP Technical Activities Related to Transport and Risk Modeling, Evaluation of the DOE Efforts, and Development of the Educational Document. Unfortunately, the DOE did not release a key document (regarding groundwater contamination and risk estimates) related to their program during the course of the initial NRAMP Groundwater Focus Group meetings. Therefore the stakeholders decided to postpone evaluation of the DOE effort until the stakeholders could review the key document, then invite appropriate speakers to answer the stakeholder questions.
Because of the extended duration of the group, it is possible that more members will be recruited, as attrition reduces the number of involved stakeholders. It is likely that new members will undergo a training period, perhaps utilizing the educational document (primer) which is currently being designed.
The NRAMP Groundwater Focus Group is now developing the educational document. It is expected that the focus group would eventually combine with other NRAMP focus groups to share insights and recommendations in a larger forum. At the time of this publication, a focus group on defense-related low-level waste management sites has begun.
REFERENCES
DOE, 1997. U.S. Department of Energy Strategic Plan. US Department of Energy, Working Draft, 6/16/97.
Federal Register, 1994. Federal Register, Vol. 59, No. 66, Wednesday, April 6, 1994.
NRAMP, 1995. Milestone I: Stakeholder Identification. Nevada Risk Assessment/Management, Las Vegas, NV, July 1995. Draft report.
NRAMP, 1996a. Public Attitudes, Risk Perceptions and the Future of the Nevada Test Site. Nevada Risk Assessment/Management, Las Vegas, NV, July 1996. Draft report.
NRAMP 1996b. Preliminary Risk Assessment, DOE Sites in Nevada. Nevada Risk Assessment/Management, Las Vegas, NV, December 1996.
FOOTNOTES
1
The Nevada Risk Assessment/Management Program is a joint effort of the Harry Reid Center for Environmental Studies at the University of Nevada, Las Vegas and the firm E.J. Bentz and Associates, operated by US DOE Grant #DE-FG08-96 EW56093.2
Stakeholder is a term used to refer to any interested or involved individual (or group) holding an interest or stake in the problem being considered. Therefore, stakeholders can include organizations, but the term more commonly refers to interested members of the public.