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INTEGRATING REMOVAL ACTIONS AND REMEDIAL. ACTIONS -
SOIL AND DEBRIS MANAGEMENT AT THE FERNALD
ENVIRONMENTAL MANAGEMENT PROJECT
Lewis C. Goidell, Terence D. Hagen, Michael J. Strimbu, Eva M. Dupuis-
Nouille', Alicia C. Taylor, Todd E. Weese, FERMCO, and Pete J. Yerace, DOE-
Since 1991, excess soil and debris generated at the Fernald Environmental
Management Project (FEMP) have been managed in accordance with the
principles contained in a programmatic Removal Action (RvA) Work Plan (WP).
This plan provides a sitewide management concept and implementation
strategy for improved storage and management of excess soil and debris over
the period required to design and construct improved storage facilities. These
management principles, however, are no longer consistent with the directions in
approved and draft Records of Decision (RODs) and anticipated in draft RODs
other decision documents. A new approach has been taken to foster improved
management techniques for soil and debris that can be readily incorporated
into remedial design/remedial action plans.
In accordance with proposed and selected remedies, the Removal Action Work
Plan has been revised to update the soil and debris management approach to
recognize recent decisions under the FEMP's Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA) process. This paper
describes the methods that were applied to address the issues associated with
keeping the components of the new work plan field implementable and flexible;
this is especially important as remedial design is either in its initial stages or has
not been started and final remediation options could not be precluded. A
sitewide interim policy that will allow each of the five operable units (OUs) to
conduct remedial actions consistent with the respective RODs, yet achieve a
consistent methodology for soil and debris management, has been developed
in the Revised Work Plan. Under the revised work plan, remedial activities can
proceed in advance of the remedial design under the auspices of the removal
action; the removal action work plan can subsequently be integrated into the
This paper finally identifies applications and lessons learned that evolved from
the process of developing the revised removal action work plan, and provides
general examples of how other facilities can benefit from this approach.
Since production operations at the Fernald site were halted in 1989, removal
actions have successfully been used to address threats from the facilities,
structures, and contaminants that remain. These actions have been
implemented as interim measures until the final remedial actions can fully
mitigate the impacts to human health and the environment associated with site
contaminants. As an example, Removal Action No. 17 (RvA 17), which is
programmatic in nature, was initiated to provide controlled storage of excess
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Goidell, L.C.; Hagen, T.D.; Strimbu, M.J.; Dupuis-Nouille, E.M.; Taylor, A.C.; Weese, T.E. et al. Integrating removal actions and remedial actions: Soil and debris management at the Fernald Environmental Management Project, article, February 1, 1996; United States. (https://digital.library.unt.edu/ark:/67531/metadc670969/m1/2/: accessed April 26, 2019), University of North Texas Libraries, Digital Library, https://digital.library.unt.edu; crediting UNT Libraries Government Documents Department.