Audit of groundwater remediation plans at the Savannah River Site

The Department of Energy was required to reduce groundwater contamination that represented a risk to human health or the environment. To achieve this goal, the Savannah River Operations Office (Savannah River) entered into several formal agreements with Federal and State regulators. The agreements described how Savannah River would reduce the level of contamination until the risks to human health and the environment were lowered to an acceptable level. The agreements called for decreasing groundwater contamination to levels that would comply with South Carolina groundwater regulations, which would allow a hypothetical future resident to someday live above the F and H Areas and drink the groundwater. We believe basing the agreements on drinking water standards was unreasonable because no one will likely live above these areas or drink the groundwater. The more stringent drinking water standards were included in the planning process because Savannah River had not developed a Land Use Plan that would permit rational decision making for the entire site. Lacking a Land Use Plan, the environmental regulators assumed, and Savannah River acceded to, the most stringent usage scenario, that the groundwater under the F and H Areas might one day be used as a source of drinking water. It will take more than one hundred years for the subterranean groundwater to become safe enough for drinking water purposes. Consequently, Savannah River may continue to pursue expensive remediation projects for longer than would be necessary to protect human health and the environment. However, the cost impact of unnecessary clean-up activities is indeterminable because acceptable contamination limits would still have to be negotiated with the South Carolina Department of Health and Environmental Control