Remediation activities at the Fernald Environmental Management Project (FEMP) Page: 4 of 11
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Additionally, RCRA closure activities for hazardous waste management units (HWMUs) continued within
OU3 during 1995. The activities included the typical decontamination methods of scrabbling and rinsing
to remove hazardous contaminants from surfaces. The activities were conducted in the accordance with
closure plans approved by Ohio EPA.
OU3 considered the integration of RCRA closure and CERCLA removal/remedial actions during the
cleanup process. The FEMP discussed integration activities with Ohio EPA in 1993. In 1994, a Director's
Findings and Orders (DF&O) drafted by Ohio EPA addressed the integration of RCRA closure and
CERCLA cleanup activities for the RCRA HWMUs. The intent of the draft Order is to eliminate any
duplicative cleanup actions while at the same ensure the environment is protected. The draft Order is in the
final stage of review at the present time.
Operable Unit 4
OU4 at the FEMP consists primarily of four ore silos and ancillary structures (Figure 6). Two of the silos
contain radium-bearing, low-level radioactive wastes generated during the 1950's. A third silo contains
uranium wastes while the fourth silo is empty. The ROD for OU4 signed by U. S. EPA in December 1994
selected the remedy of vitrification (glassification) to stabilize the residues and sludges from the silos.
Following treatment, the vitrified residues will be containerized and sent to the Nevada Test Site for
disposal. Contaminated soil and debris from OU4 will be placed in the on-site disposal facility.
Operable Unit 5
OUS consists of the environmental media associated with the FEMP site. The media includes groundwater,
soils, and sediments. OU5 submitted a draft ROD to U.S. EPA in 1995 for review. The draft ROD proposes
as the selected remedy to excavate contaminated soils and sediments that exceed proposed final remediation
concentrations. The excavated materials would be placed in the on-site disposal facility provided the
appropriate waste acceptance criteria is met. In addition, the proposed remedy includes a pump and treat
process to address groundwater contamination of the site's underlying aquifer.
One of the most difficult issues to resolve pertaining to OUS was the closure of RCRA HWMUs which lie
above underlying soil contamination. The DF&O drafted by Ohio EPA in 1995 allowed many of the RCRA
units to be remediated under CERCLA and the OU5 ROD. However, some HWMUs were already in the
closure process, with approved RCRA closure plans or completed field work. The regulators could not
approve closure of these units without remediation of the underlying soils, even though the contaminants
exist throughout the site. Exceptions were made in those cases where the evidence was clear that the soil
contaminants clearly could not have originated from the RCRA unit. The FEMP decided to complete the
closure field work in those instances where work was already begun and submit a closure certification report
to Ohio EPA. The regulators agreed to accept the report and acknowledge that the work was performed in
accordance with the approved closure plan. Official closure will not be granted until the soils are remediated
using the OU5 ROD. The FEMP hopes that this approach will prevent the invalidation of closure activities
if the regulatory requirements or standards change prior to soil remediation and official closure.
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Walsh, T.J. & Danner, R. Remediation activities at the Fernald Environmental Management Project (FEMP), article, July 1, 1996; United States. (digital.library.unt.edu/ark:/67531/metadc664970/m1/4/: accessed August 16, 2018), University of North Texas Libraries, Digital Library, digital.library.unt.edu; crediting UNT Libraries Government Documents Department.