Successful completion of a RCRA closure for the Fernald Environmental Management Project

This paper discusses the successful completion of a RCRA (Resource Conservation and Recovery Act) closure of a HF (hydrofluoric acid) tank car at FEMP, which is on the national priorities list of hazardous waste sites and is undergoing CERCLA remediation. The HF tank car closure was conducted by FERMCO. Through a combination of sound planning and team work, the HF tank car was closed safely and ahead of schedule. During > 22,000 hr field work required for construction modifications and neutralization of 9,600 gallons of HF and decontamination rinseates, there were no OSHA recordable incidents. The system design avoided additional costs by maximizing use of existing equipment and facilities. This successful closure of the HF tank car demonstrates FEMP`s commitment to reducing risks and cleaning up the facility in a manner consistent with objectives of RCRA regulations and the Ohio EPA hazardous waste rules. This in turn facilitated ongoing negotiations with Ohio EPA to integrate RCRA closure and the ongoing CERCLA remediation activities. This paper addresses why the unit was clean closed under an approved RCRA Closure Plan. Integration of EPA regulations for RCRA and CERCLA programs and the DOE-Orders impacting design, construction and operation of an acid neutralization system is also reviewed. The paper concludes with a discussion of lessons learned in the process in preparing the closure plant and through final project close out.