CERCLA and RCRA requirements affecting cleanup of a hazardous waste management unit at a Superfund site: A case study

The Fernald Environmental Management Project (FEMP) attempted to address both RCRA and CERCLA requirements at the fire training facility (FTF) by integrating a CERCLA removal action work plan with a RCRA closure plan. While the regulatory agencies involved with the FTF cleanup agreed the integrated document was a good idea, implementation proved complicated, owing to disposition of clean debris from a Superfund site, treatment of contaminated media, duration of cleanup activities, and cleanup certification. While all the complications have not been resolved, solutions to all have been proposed to Ohio EPA and U.S. EPA. Both agencies have worked closely with FEMP to find the most effective fulfillment of RCRA and CERCLA requirements.