Mixed waste management plans at the Fernald Environmental Management Project (FEMP)

The Fernald Environmental Management Project (FEMP) is a United States Department of Energy (DOE) facility located in southwestern Ohio. The facility began production of uranium metal products in the early 1950's and continued processing of uranium ore concentrates until 1989. The facility used a variety of chemical and metallurgical processes to manufacture uranium metals for use at other DOE sites across the country. Because of the chemical and metallurgical processes employed at the site, some hazardous wastes as defined by the Resource Conservation and Recovery Act (RCRA) were generated during the manufacture of the uranium metal products. Because of uranium metal's radioactive properties, the hazardous wastes generated at the facility typically contain some radioactivity. Wastes which contain both a hazardous component subject to RCRA regulation and a radioactive component subject to the Atomic Energy Act of 1954 are described as mixed waste. In 1989, the FEMP was placed on the National Priorities List (NPL) requiring cleanup of the facility's radioactive and chemical contamination under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). This paper examines the regulatory requirements associated with development of the plan used to manage mixed wastes at the FEMP. In addition, the paper discusses the strategies used to integrate the requirements of the Federal Facility Compliance Act (FFCAct) with CERCLA response actions