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It
was not until the 1970s and 1980s that the general populace became
aware of the industrial revolution’s effect on the
environment, and the
cost and magnitude of the resulting cleanup effort.
Many of the environmental, safety and
health regulations that are now applicable at the Fernald site did
not exist when the plant was in full production.
Nearly 38 years of uranium metal production and storage and
disposal of waste and nuclear material left the soil, groundwater
and site structures contaminated.
To
begin addressing the contamination problems at the Fernald site,
the U.S. Environmental Protection Agency (EPA) issued a notice of
noncompliance to the Department of Energy (DOE) in 1985,
identifying potential environmental impacts associated with the
site’s operations. For
the next year, DOE and EPA representatives met to discuss the
issues and identify a plan of action to achieve and maintain
environmental compliance at the site.
On
July 18, 1986, three years before site management shut down plant
operations to focus on environmental compliance and waste
management, DOE and EPA signed the Federal Facilities Compliance
Agreement (FFCA). The purpose of this legally binding agreement was to ensure
Fernald’s compliance with existing environmental statutes and
regulations such as the Clean Air Act, the Resource Conservation
and Recovery Act (RCRA), and the Comprehensive Environmental
Response, Compensation and Liability Act (CERCLA).
A federal law enacted in 1980, CERCLA
regulates the cleanup of hazardous, toxic and radioactive
substances. It also created a trust fund, called Superfund, to
finance the investigation and cleanup of releases to the
environment. The 1986
amendment to CERCLA required DOE and other federal agencies to
cleanup their facilities under the FFCA with EPA.
In 1990, DOE and EPA signed a Consent
Agreement that established milestones for the RI/FS, amending the
original FFCA. One year later DOE and EPA signed an amended Consent
Agreement revising the schedules for completing the RI/FS.
Under
CERCLA, the site initiated a remedial
investigation/feasibility study (RI/FS), a comprehensive
environmental investigation conducted in and around Fernald to
identify the nature and extent of contamination and determine the
best cleanup solutions. For
the next few years, Fernald personnel were on a learning curve to
determine the best way to implement this large-scale
investigation. Since
some areas of the site were more problematic and complicated, the
RI/FS team divided the site into five operable units based on
location, physical characteristics and the potential for using
similar technologies during cleanup.
The operable units included:
the waste pit area; other waste units; the 136-acre
production area; Silos 1
– 4; and environmental media (soil, groundwater, etc.).
After completing extensive sampling
and analysis of soil, water and other media, Fernald engineers and
scientists worked with regulators and DOE to determine methods of
removing or containing the contamination.
DOE held a series of public meetings to seek input on the
cleanup alternatives, and adopted final cleanup remedies for each
operable unit. In
all, the RI/FS lasted 10 years, resulting in legally binding
cleanup remedies that are the foundation of Fernald’s
environmental remediation mission.
While the site was engaged in the
RI/FS, there were several environmental issues that needed
immediate attention. To address these concerns, Fernald initiated 31 short-term
cleanup projects, called removal actions.
Under the National Contingency Plan, DOE had the authority
to react immediately to eliminate potential environmental, health
or safety risks without waiting until the RI/FS was completed,
although removal actions required limited public participation.
Some of Fernald’s removal actions included dismantling
the 14 Plant 1 ore silos that were in poor condition, installing bentonite caps
on Silos 1 and 2 to reduce radon emissions, neutralizing and
packaging uranyl nitrate inventory, and pumping and treating
contaminated water from extraction wells underneath several
production plants.
There were many changes and events
over the years that impacted Fernald’s transition to cleanup.
In 1989, after nearly 38 years of uranium production
operations, site management shut down metal production to
concentrate on environmental compliance and waste management
issues. That same
year, EPA placed Fernald on the National Priorities List, a
compilation of Superfund sites most in need of cleanup.
In 1991, Congress formally approved the closure of site
production operations and authorized its new environmental
remediation mission. One
year later, DOE awarded the first environmental remediation
contract to FERMCO, later renamed Fluor Fernald.
Fluor Fernald has managed the site’s cleanup
activities
since 1992 and will complete site remediation in compliance
with its November 2000 final cleanup
closure contract.
To streamline and integrate the
numerous remediation and closure requirements of CERCLA and RCRA,
DOE, Fluor Fernald and Ohio EPA signed the Directors' Final
Findings and Orders in June 1996. The agreement required that DOE
and Fluor Fernald prepare one remediation plan to comply with both
CERCLA and RCRA, and that sampling and analyses costs associated
with RCRA closure activities be integrated into CERCLA remediation
activities, eliminating duplicative sampling efforts.
In the end, implementation of these integrated closure
requirements would save taxpayers millions of dollars and
accelerate site cleanup.
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