Meeting the requirements for a DOE environmental restoration project. The Fernald strategy

Environmental Restoration (ER) of five Operable Units (OU) at Fernald Environmental Management Project (FEMP) includes compliance with the requirements of Comprehensive Environmental Response, Compensation and Liability Act (CERCLA), Resource Conservation Recovery Act (RCRA), National Environmental Policy Act (NEPA), and DOE Orders. Each regulatory driver has differing procedural requirements for documenting calculations, decisions, and actions involved in site cleanup. Integration of documentation and avoidance of duplication can save time and money. Such savings are being achieved by OU specific application of supporting studies, revised procedures, and guidance documents. Each OU is seeking appropriate opportunities to produce single documents that simultaneously fulfill the important requirements of the other regulations and DOE orders. These opportunities are evaluated at all phases of decision making, remedial design, and remedial action. Three essential processes precede environmental restoration/remedial action at a DOE site/project: 1. Completion of decision-making documents required by governing or applicable statutes. 2. Completion of important scientific and engineering analyses of remedial alternatives, and design and implementation of the remedial solution established in the CERCLA Record of Decision (ROD). 3. Preparation of DOE-mandated documentation to record engineering evaluations and cost estimates required for budgeting, decision making, and project management. Methodology and requirements for each process have developed from long, successful practice, but independently of each other. FERMCO, as new DOE contractor at Fernald and first Environmental Restoration Management Contractor (ERMC), is committed to a process of Continuous Performance Improvement (CPI). A major reevaluation of documentation and processes for support of environmental decision-making and design of cleanup activities to remediate the five OUs at the FEMP is being undertaken.