Regulation of radioactive mixed-waste cleanup at US Department of Energy facilities: A case study of the Savannah River site

A case study of efforts at the DOE Savannah River Site (SRS) to remediate mixed-waste contamination focused on an analysis of applicable Federal and State of South Carolina laws and the attempt to use an interagency agreement incorporating provisions of CERCLA and RCRA to achieve a comprehensive cleanup of the facility. While not achieving a fully integrated cleanup program, the agreement established a process to coordinate CERCLA response obligations with the corrective measures required by the SRS RCRA permit. Negotiations of the agreement were delayed by the complexity of integrating CERCLA requirements with a RCRA corrective action program already in progress and by the need to determine the role the State of South Carolina would play in cleanup remedy selection. Despite short-term delays, the SRS interagency agreement with a similar agreement negotiated for the DOE Hanford Reservation found that allowances were made for site-specific conditions and circumstances in the development of the two comprehensive compliance strategies