Integrating removal actions and remedial actions: Soil and debris management at the Fernald Environmental Management Project Page: 4 of 10
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and expanded the waste acceptance criteria for the soil; additional FRLs were
developed for contaminated soils within the OU5 area. The WAC were not
consistent with the thresholds that existed in RvA 17. The OU5 ROD also
adopted a sitewide Corrective Action Management Unit for soil remediation
which includes the OSDF to replace the AOC concept that was previously
utilized. Finally, the draft OU3 Remedial Investigation/Feasibility Study for final
disposition of D&D debris was issued, which recommends disposal of the D&D
debris in the OSDF and establishes appropriate WAC for the debris.
As the RODs were moving towards approval, it was recognized that
management of soil and debris under RvA 17 needed to be consistent with the
anticipated remedial actions. Additionally, it was necessary to integrate the
implementation of approved or anticipated RODs and individual remedial action
plans with the management approach for soil and debris. Therefore, a team
representing each of the key projects, the environmental compliance program,
the environmental monitoring program, construction, and the waste
management program was assembled to develop a revised removal action
work plan that attained that consistency.
The key objectives established by the team included the need for the work plan
to be practical (i.e., field-implementable) and the need for an easy transition for
the existing soil and debris storage into the new concept. This involved
integrated planning in recognition of the final disposition options for soil and
debris. A flow chart was developed to aid in the development of the strategy
(see Figure 1).
Information from the selected remedies or preferred alternatives for each
operable unit will determine the potential to combine and reduce soil staging or
storage areas. The needed information includes knowledge of:
* Planned final disposition (e.g., on-property or off-site disposal);
" Location and mode of transport to off-site disposal facility(ies) as
* Total number of soil staging/storage areas projected during
" Projection of on-site treatment requirements for on-property/off-site
" Types of staging areas required (e.g., stockpiles, container storage
areas, construction of new facilities, use of existing
The strategy for segregating or combining soil within an operable unit or from
several operable units creates a commitment to manage each staging area
according to the common planned disposition of the soil in that staging area.
Generally, these criteria are based on the WAC for the designated disposal
facility (see Table 1); further, location criteria are based on general
environmental protection requirements (e.g., floodplains/wetlands standards)
and the designated FRLs for that location. . Additionally, several criteria will be
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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/m1/4/: accessed April 25, 2019), University of North Texas Libraries, Digital Library, https://digital.library.unt.edu; crediting UNT Libraries Government Documents Department.