Savannah River Site Public and Regulatory Involvement in the Cercla Low-Level Waste (LLW) Program and Their Effect on Decisions to Dispose of LLW Generated by Cercla

The key to successful public involvement at the Savannah River Site (SRS) has been and continues to be vigorous, up-front involvement of the public, federal and state regulators with technical experts. The SRS Waste Management Program includes all forms of radioactive waste. All of the decisions associated with the management of these wastes are of interest to the public and successful program implementation would be impossible without including the public up-front in the program formulation. Serious problems can result if program decisions are made without public involvement, and if the public is informed after key decisions are made. This paper will describe the regulatory and public involvement program and their effects on the decisions concerning the disposal at the Savannah River Site (SRS) of LLW generated from CERCLA Removal and Remedial Actions. At SRS the Deactivation and Decommissioning (D and D) project has generated large amounts of LLW from the removal of buildings and processing facilities. The D and D project is expected to generate even larger amounts of LLW in the future. The most cost effective disposal alternated is to use the onsite LLW disposal facility in E-Area. The E-Area LLW Facility is owned and operated by the Department of Energy (DOE) under its authority granted by the Atomic Energy Act of 1954, as amended. Since the disposal of CERCLA generated waste is also governed by the Environmental Protection Agency (EPA) CERCLA regulations, it is important that EPA, DOE, and the South Carolina Department of Health and Environmental Control (SCDHEC) work together to resolve any conflicts in implementation of the D and D project so that all regulations are followed and the project can be continued successfully. An issue of particular significance will be described in this paper that, were it not resolved successfully, would have jeopardized the completion of one project and resulted in higher overall project costs. The EPA determined in review of the E-Area LLW Facility groundwater monitoring that a 'release' under CERCLA had occurred. As a result, EPA determined that it was necessary to issue a 'Notice of Unacceptability' to SRS revoking the CERCLA Off-Site Rule approval for the E-Area LLW Facility, thus, no longer allowing the E-Area LLW Facility Slit trenches to receive CERCLA waste for disposal. It became critical to the success of the D and D project to reestablish CERCLA Off-Site Rule approval. The discussions and negotiations Comment [HB1]: with the South Carolina regulators and EPA were conducted in full view of the public and as such, an informed decision as to resolution included the public interactions. This paper will describe the successful results of this technical, regulatory, and public involvement program, explore the challenges, how the accomplishments occurred, and describe the future challenges along with the road map for the future. In doing this, the SRS D and D project must be described to give the readers an understanding of the technical complexities that must be communicated successfully to achieve constructive stakeholder participation and regulatory approval. (author)