Upload
others
View
1
Download
0
Embed Size (px)
Citation preview
IN REPLY REFER TO:
LCD-10000 1.3.11
United States Department of the Interior BUREAU OF RECLAMATION
Lower Colorado Dams Office P.O. Box 60400
Boulder City, NV 89006-0400
June 24, 2020
VIA ELECTRONIC MAIL
Engineering·& Operating Committee (E&OC) Members (See Enclosed List)
Subject: Request for Information Related to the Hoover Dam Solid Waste Site (Site) on USBR's Property
Dear Boulder Canyon Project E&OC Members:
I have reviewed the enclosed May 28, 2020, request for information related to the Site from the Colorado River Commission of Nevada, the Metropolitan Water District of Southern California, Arizona Power Authority, Southern California Edison Company and Los Angeles Department of Water and Power who asked that responses to the request be directed to the E&OC.
I have considered three approaches to collect this information: 1) Find the money to support this within our current budget and provide the information; 2) Develop a Work Plan and incorporate it into our Ten-Year plan and provide the information as funding becomes available; or 3) Refer the request to the FOIA process. As stated in the letter, the request is substantial. In order to be adequately and appropriately addressed, it needs to be submitted through the Freedom of Information Act (FOIA) process.
After consulting with our Acquisitions office, my gut feeling is that the costs to collect this information will be many thousands of dollars and possibly be in the hundreds of thousands of dollars. My preference would be that the requesting organization(s) fund this effort directly, but the funding for an official FOIA request is problematic. All funding collected for FOIAs must go to the Treasury. However, nearly all costs to collect this data will be charged to the Boulder Canyon Project (BCP). This will require the BCP to fund the effort with available BCP funds. I have discussed this with our FOIA office, and they will share the estimate of the effort to the requesting organization( s) before performing the work and incurring cost.
I recommend that this request be reconsidered after additional information is received/provided before submitting the request. We have not received a final determination from the Nevada Department of Environmental Protection (NDEP), but they have indicated that they will likely accept the plan we submitted with some conditions. Our plan consists primarily of erosion control and waste removal and/or containment. If the additional conditions that NDEP require are not substantial, much of the requested information will not be relevant to t!J_e cleanup of the Site and the
INTERIOR REGION 8 • LOWER COLORADO BASIN ARIZONA. CALIFORNIA*. NEVADA*
• PARTIAL
2
cost and staff time for this effort will not be value added. In addition, we are close to completing our review and providing a response to Resolution #2020-0515, which may help answer at least one of the funding questions.
Freedom of Information Act requests can be submitted at FOIA.gov. If you have specific questions about the FOIA process, please contact Mr. Patrick Jacobs at email [email protected] or call him at 702-293-8576.
I will share the NDEP response to our plan with you after we receive it. If you have any concerns or would like to discuss this further, please email me at [email protected] or call me at 702-494-2301.
Sincerely,
Enclosure( s) - 2
May 28, 2020 Mr. Len Schilling
Area Manager, Lower Colorado Dams Office
P.O. Box 60400
Boulder City, NV 89006-0400
RE: Request for Information related to the Firing Range Waste Disposal Site on USBR’s property Dear Mr. Schilling: The undersigned Contractors of the Boulder Canyon Project (BCP) in accordance with the Amended and Restated Boulder Canyon Project Implementation Agreement request that the United States Bureau of Reclamation (USBR) provide the following information. We recognize the request below is substantial. Accordingly, we would appreciate if the materials are provided to the EOC Representatives as they become available and not held to be produced in a single batch. USBR should view these requests as continuing and on-going such that as new material is received/produced/discovered, it is timely provided to the Contractors. Additionally, our request should be broadly interpreted to include documents or records in any format, whether electronic, hard copies, reports, correspondence, maps, photographs, written notes, written explanations, and so forth. We are not asking USBR to create new documents -- we seek to gather the information USBR had when it made its decisions regarding the Waste Disposal site, so that we can better understand the decisions. Further, please consult with us prior to expending any funds on fulfilling these requests. Information/Document Requests
a. Firing Range / Waste Disposal Site
i. Documents regarding the disposal of waste by any person or entity at
the Firing Range Waste Disposal Site from 1931 to the present.
ii. Documents regarding all locations where waste from the construction
and Uprating of Hoover Dam and the construction of the Visitor Center
was disposed.
iii. Documents regarding the disposal of fluids from the installation or
removal of transformers at Hoover Dam from 1931 to the present.
iv. Documents from 1931 to the present regarding USBR’s policies on
waste disposal and compliance with same, including but not limited to,
the disposal of chemicals, hazardous waste, construction debris,
maintenance debris, and USBR’s debris.
v. Documents from 1960 to the present regarding communications
between the USBR and the Southern Nevada Health District (SNHD)
related to the Firing Range Waste Disposal Site, including permits,
waivers, and USBR’s compliance with SNHD’s Solid Waste
Management Authority Regulations.
vi. Documents regarding how the Federal Government and Six Companies
allocated responsibility for waste disposal.
vii. Documents regarding the construction and use of the Firing Range.
viii. Documents regarding which entities or persons, including but not
limited to local, state or federal agencies, have used the Firing Range
and copies of agreements with those entities regarding their use of the
Firing Range.
b. Environmental
i. Documents regarding groundwater under the Firing Range Waste
Disposal Site, including groundwater samples, where the groundwater
and hot springs vents are located, and any connection between the
two. (USBR’s 1/15/2020 presentation contains a picture of the thermal
image of the hot springs’ vents, and USBR’s 5/15/19 presentation
states that “several hot springs vents were located throughout area
indicating there is a direct connection from the landfill to the water
table.”)
ii. Documents regarding types of materials underneath the top cover of
rock and dirt, including those used to develop USBR’s 5/15/2019
presentation slide 2.
iii. Documents relating to communications between USBR and NDEP
regarding the Firing Range Waste Disposal Site including any site
investigation, air monitoring, remediation plans (including
engineering-type drawings provided in CAD, GIS, or other native
formats), revisions, responses, and comments.
c. Funding
i. Documents regarding efforts by USBR to seek funding sources for
cleanup of the Firing Range Waste Disposal Site, apart from the
Contractors, including contribution from USBR or others, and/or non-
reimbursable Federal funding.
ii. Documents regarding how USBR has funded the cleanup of other
federal lands.
iii. Documents regarding why USBR believes the Resource Conservation
and Recovery Act (RCRA) is the applicable statute instead of the
Comprehensive Environmental Response, Compensation and Liability
Act of 1980 (CERCLA). (USBR’s 10/23/19 presentation slide 13 and
1/15/20 presentation slide 10)
iv. Documents regarding why USBR believes “[a]ny expenses for
treatment of the landfill are appropriately operation and maintenance
(O&M) costs, absent a specific appropriation.” (USBR’s 10/23/19
presentation slide 13)
We thank you for your attention to these requests. Responses should be directed to the EOC representatives, who will in turn distribute to the Contractor Group. If you have any questions, please contact Craig Pyper at [email protected] Sincerely, COLORADO RIVER COMMISSION OF NEVADA Gail Bates Assistant Director, Hydropower
THE METROPOLITAN WATER DISTRICT OF SOUTHERN CALIFORNIA Shawn Bailey Manager, Power Operations
ARIZONA POWER AUTHORITY Ed Gerak Executive Director
SOUTHERN CALIFORNIA EDISON COMPANY Scott Wiedermann Energy Contracts Manager
LOS ANGELES DEPARTMENT OF WATER AND POWER Eric J. Hill Mechanical Engineering Associate
Engineering & Operating Committee (E&OC) Primary / Alternate List
Agua Caliente Band Of Cahuilla Indians Hooks, Todd [email protected] Anaheim Public Utilities Department Krause, Elden [email protected] Valero, Linda [email protected] Anza Electric Cooperative, Inc. Baharie, Brian [email protected] Short, Kevin, [email protected] Arizona Power Authority Gerak, Ed [email protected] Sullivan, Linda [email protected] Augustine Band of Cahuilla Indians Saline, Ken [email protected] Delaney, Dennis [email protected] Finley, Ann [email protected] Azusa Light and Water Department Ellis, Katherine [email protected] Robledo, Manny [email protected] Torres, Richard [email protected] Bishop Paiute Tribe Summers, Allen [email protected] Bailey, Gloriana [email protected] Spoonhunter, Valeria [email protected] Cabazon Band Mission Indians Acuna, Joey [email protected] Barnum, Jacquelyn
[email protected] Hitchcock, Ralph [email protected] California Department of Water Resources Brown, David [email protected] Burk, Deane [email protected] Chemehuevi Indian Tribe Koscielak, Lex [email protected] Urbine, Kelly [email protected] Urbine, Terry [email protected] Wood, Charles [email protected] City of Banning Steffens, Jim [email protected]
City of Boulder City Pelletier, Diane [email protected] Porter, Dennis [email protected] City of Burbank Bleveans, Lincoln [email protected] Hammond, Tim [email protected] Himanshu, Pandey [email protected] City of Cerritos Raufdeen, Ramz [email protected] Vancheswaran, Kanna [email protected] City of Colton Gallegos, Rebecca [email protected] Kolk, David [email protected] City of Corona Moody, Tom [email protected] City of Glendale Valdez, Mindalyn Chie [email protected] City of Pasadena D'Aquila, Anthony [email protected] Johnson, Erik [email protected] Nguyen, Kelly [email protected] Samra, Mandip [email protected] Zhang , Ren [email protected] City of Rancho Cucamonga Lyn, Fred [email protected] City of Riverside Mayne, Jarod [email protected] Park, Andrew [email protected] City of Vernon Alemu, Abraham [email protected] Fandino, Carlos [email protected] City of Victorville Hampton, Brenda [email protected] Harris II, George [email protected] Metzler, Keith [email protected]
Colorado River Commission of Nevada Bates, Gail [email protected] Pyper, Craig [email protected] Witkoski, Eric [email protected] Fort McDowell Yavapai Nation Benally, Diandra [email protected] Dorchester, Phil [email protected] Gila River Indian Community Utility Authority Galloway, Kathy [email protected] Gold, Leonard [email protected] Mejia, Arnold [email protected] Hualapai Nation Clarke, Damon [email protected] Vaughn, Charles [email protected] Imperial Irrigation District Asbury, Jamie [email protected] Escalera, Mario [email protected] Harding, Scott [email protected] Printy, R. Marc [email protected] Stewart, Bryan [email protected] Valenzuela, Belen [email protected] Kaibab Band of Paiute Indians Las Vegas Paiute Tribe Spotted Eagle, Chris [email protected] Tso, Benny [email protected] Los Angeles Department of Water & Los Angeles Department of Water & Power Alba, David [email protected] Hill, Eric [email protected] Schultz, Paul [email protected] Metropolitan Water District of Southern California Bailey, Shawn [email protected] Cherry, Tim [email protected] Morongo Band of Mission Indians Asghar, Titu [email protected] Helms, Shane [email protected]
Navajo Tribal Utility Authority Haase, Walter [email protected] Steiger, Glenn [email protected] Pascua Yaqui Indian Tribe Valencia, Robert [email protected] Yucupicio, Peter [email protected] Pechanga Band Of Luiseño Mission Indians Nu'uhiwa, Breann [email protected] Pitt, Pi-Ta [email protected] Schaff, Margaret [email protected] Taylor, Dan [email protected] Salt River Pima-Maricopa Indian Community Finley, Ann [email protected] Jack, Jennifer [email protected] San Diego County Water Authority Fountain, Brent [email protected] Meda, Jesus [email protected] San Luis Rey River Indian Water San Luis Rey River Indian Water Authority San Manuel Band of Mission Indians Batten, Clifford [email protected] Dupont, Patrick [email protected] Southern California Edison Irwin, Mark [email protected] Litos, Maria [email protected] Wiedermann, Scott [email protected] Southern California Public Power Authority (Member) Ellis, Katherine [email protected] Timbisha Shoshone Tribe Gholson, George [email protected]
Tohono O'odham Utility Authority Bethurem, Mike [email protected] Hobbs, Darrold [email protected] Tonto Apache Tribe Torres-Martinez Desert Cahuilla Torres-Martinez Desert Cahuilla Indians Franco, Desiree [email protected] Powell, Robert [email protected] Tortez, Thomas [email protected] Twenty-Nine Palms Band of Mission Indians Darrell, Mike [email protected] Madrigal, Anthony [email protected] U.S. Dept of the Interior - Bureau of Reclamation Gould, Jacqi [email protected] Schilling, Len [email protected] Viejas Band Of Kumeyaay Indians Teran, Ray [email protected] Tewanger, Darwin [email protected] Western Area Power Administration Amaro, Teresita [email protected] Kendrick, Jimmy [email protected] Moldanado, Christina [email protected]