The Challenge of Achieving Site Closure of a Complex Groundwater Plume - 20531
Over the last three decades, DOE has made substantial progress in nearly every area of nuclear waste cleanup and has closed and transitioned 91 of the 107 sites in the EM complex. Several of the remaining groundwater plumes at Hanford, Los Alamos, Paducah, Oak Ridge, and Savannah River are complex and tend to have unique site or contaminant characteristics which provide an almost impossible challenge to remediate to regulatory levels. As a result, these complex sites will require a large investment to remediate. In order for DOE to achieve regulatory closure, a technically sound case must be developed and presented to regulators and stakeholders that clearly demonstrates that remedial goals have been or will be irreversibly achieved or that there is an alternate acceptable end-state. Five lines of evidence are required: - A conceptual site model that is as complete as possible, with the knowledge that it may continue to evolve with time; - Demonstration that trends in contaminant concentrations, or flux, versus time indicate that remedial goals will be achieved on schedule or within a reasonable time thereafter and that trends that deviate from this path are explainable by the conceptual model; - Demonstration that remobilization of attenuated contaminants is unlikely to occur in the future; - Explicit consideration of remedial contingencies, should deviations in the path toward remedial goals occur; - Development of an effective long-term monitoring plan to detect any conditions that might alter the path toward remedial goals. SRS has made significant progress in the remediation of contamination associated with the F-area and H-Area Seepage Basins, and it is currently developing a strategic closure path that addresses each of these lines of evidence and identifies both basic and applied scientific issues that will need to be addressed in order to obtain regulatory closure. (authors)