Streamlining Corrective Action at Reese Air Force Base, Texas
Reese AFB is located in the northwest part of Texas. It is approximately 10 miles from the City of Lubbock. The surrounding area is predominately rural, although the continued residential expansion of Lubbock has brought a large number of homes within a few miles of the former base. The base includes 2,987 acres. Reese AFB has been a training base almost continuously since 1941. The primary mission at the base was an undergraduate pilot training facility. Reese closed as an Air Force base in 1997.
The base is currently 40% leased to the Local Redevelopment Authority (LRA). At this time only 520 acres have been transferred to the LRA. The majority of reuse has been for educational needs. Texas Tech University established research laboratories, the local community college has established a campus and the police and fire departments are using some areas for training.
There is limited groundwater recharge if any in the Lubbock area. Reese receives an average of 19 inches of rain per year. Heavy irrigation pumping has reduced the thickness of the aquifer in the area surrounding the facility. The aquifer is the primary drinking water source for the area. Groundwater occurs under unconfined conditions, within the gravelly sands of the Ogallala Formation at depths from approximately 120 ft to 200 ft below ground level.
In 1993, Reese was the first federal facility to be issued an imminent and substantial endangerment, 7003 Order. The Order addressed off-base contamination of public water supplies by a trichloroethylene (TCE) plume. The Order required sampling of private drinking water wells and irrigation wells in a 36 square mile area around the base. Over 500 private wells were sampled within 45 days. Reese provided an alternate water supply to approximately 40 homes . Some of the homes were connected to the City of Lubbock water system, others outside the city limits have had carbon filters installed and are receiving supplemental bottled water.
In 1994, Reese was assessed a penalty of $81,439 by TNRCC. The Consent Order required investigation and remediation of three areas, including the suspected source area of the TCE plume. The Order required Reese to construct a groundwater treatment system to address the highest off-site concentration. In 1996, TNRCC issued the Air Force a Permit and Compliance Plan requiring Reese to investigate 21 SWMUs and two former surface impoundment's. The majority of corrective action investigation began at this time.
Due to past problems, the media, neighbors, community and regulators were skeptical of any action being taken by the Air Force.
The major environmental concerns at the facility include two TCE plumes and a Benzene plume. The Tower area TCE plume extends off-site approximately 2.5 miles and impacts numerous private drinking water wells. The plume originates in the Tower Area, along the flight line shops. An industrial drain line (IDL) was used for storm water drainage along the flight line. Floor drains in some of the shops also drained to the IDL. The IDL was connect to an oil/water separator and discharged into a playa. The playa was initially called the Industrial Waste Pond, but was later renamed Picnic Lake. Numerous broken sections of pipe allowed the contaminated water to discharge into the surrounding soil and to the groundwater. A pump and treat system, located both on and off-site has been installed. To prevent pumping the aquifer dry, groundwater is injected back into the aquifer after treatment. The pump and treat system consist of 50 extraction/injection wells and over 10 miles of piping. To accomplish this, the Air Force and Corps of Engineers completed real estate negotiations for over 200 rights of entry and 19 easement purchases.
Another TCE plume is located in the area of a former landfill. A 24 acre RCRA landfill cap has been installed and pump and treat system is now operational. The plume is off-site, however the area is largely undeveloped. No drinking water wells are impacted in this area.
A Benzene plume is contained on-site in the area of the former POL storage area. A soil vapor extraction system was installed and continues to intermittently run. The plume is decreasing and at this time no additional corrective action is anticipated.
Along with these three areas, removal actions/investigations have been completed at 21 SWMUS and over 200 other sites. The sites included underground storage tanks, above ground storage tanks, storage areas and other miscellaneous sites.
Corrective Action Process at Reese
The Base Realignment and Closure (BRAC) process establishes a BRAC Cleanup Team. The team consists of an EPA representative, a state representative and the DOD installation BRAC Environmental Coordinator. Although in the BRAC process DOD funds the EPA FTE and State representative, a similar process could be established at other facilities. The ultimate goal of the process is to allow transfer of property for reuse.
All three members have the authority to make decisions and therefore expedite the process. Although funded by DOD, EPA and Texas Natural Resource Conservation Commission (TNRCC) representatives are not dedicated only to the Reese cleanup. Both members have multiple sites.
At Reese, BCT decisions are real-time and have resulted in time and cost savings. This real-time process involves monthly meetings, where the background of a site is discussed and clear direction on how the investigation should proceed is discussed. As the investigation proceeds progress is briefed and course corrections as necessary are completed. The team knows at least on a monthly basis the regulators inputs/thoughts about the investigation.
The teams approach to "no surprises" has led to open communications and trust which has developed into a high level of credibility. This mind set has spilled over into the community as well. In the past the public did not trust the Air Force and to a certain extent the regulators. Restoration Advisory Board meetings involved a lot of finger pointing and limited information exchange. The current BCT has regained the trust and confidence in the public and the Local Redevelopment Authority.
- Building a team that has ownership in achieving the installation's milestones
- Understanding the goals and how to manage the daily events to achieve the goals
- Constructing the decision logic to guide all remediation activities
- Embracing the reuse process and including local reuse officials in the cleanup process (this becomes critical when long-term remedies are required)
- Determining the exit strategies for each site up front (what is required to achieve the goal)
- Orchestrating contracting actions that provide maximum flexibility
Understanding risk was also a critical component of the strategy. The leadership had to balance the risk of moving forward with investigations without written concurrence from the regulators. This risk was continually assessed to ensure prudent actions with taxpayer resources. The level of risk that the leadership was willing to accept was directly influenced by the amount of trust in the team. The entire strategy shown above greatly reduced the overall risk but the leadership also had several risk analysis discussions to evaluate the potential benefits of proceeding compared to waiting for additional information. The knowledge of "incremental risk" was greatly used to map the decreased risk over time (also the decreased risk with increased information); action was taken at the appropriate level of risk.
The most important was early buy-in from the regulators. The motto of "No Surprises" was reinforced and trust was increased as the Air Force followed through on what they had agreed to do. Another key advantage was the Air Force was able to give clear direction to contractors. They knew exactly what would take place so their costs and scope were simplified and all resources were available when needed, thereby minimizing delays. Up front decision-making also helped keep the team focused and minimized lengthy discussions at each step of the process; they didn't have to wait to talk with the regulators before proceeding to the next steps. Other advantages include continuity of decisions and standardization across the various sites. And these tools are continuing to be used as the team moves from investigations into treatment system performance and site closeout objectives.
Streamlining the Traditional Investigation Process
Traditional Approach Time: From 1-3 years depending on complexity (per project).
- Submit a detailed workplan (over 10 individual steps)
- Perform a complete and thorough investigation
- Prepare draft report
- Submit draft report
- Receive formal regulator comments
- Comment on formal regulator comments;
- Meet on comments
- Submit revised comment response table
- Receive regulator comment approval
- Revise report
- Submit final report
- Receive approval letter
Reese Approach Time: From 3-9 months depending on complexity (per project).
At a monthly BCT meeting, discuss the background of the site and lay out a decision matrix on how the investigation should be completed with clear direction on the first steps. As the investigation proceeds, continue to follow decision matrix, briefing the progress and making course corrections as necessary (i.e., the team knows at least on a monthly basis the regulators inputs/thoughts about the investigation). Submit final report (all information has already been briefed over time at the monthly meetings). Receive approval letter.
Cost of the Cleanup and Savings
- Total Spent to Date: $83 million
- Total Cost Avoidance to Date: $9.6+ million
- $5.5 million on reducing need for a landfill cap on the golf course)
- $2.4 million from multiple expedited projects
- $600,000 reduced sampling parameters/frequency
- $550,000 used innovative biotic barrier in RCRA landfill cap
- $550,000 expedited soil removal which allowed for disposal under the SW landfill cap
- Current Remaining to Spend (FY00-FY30): $77 million
- Total Planned Cost Avoidance: $37+ million (48%)
- $10 million by eliminating long-term monitoring at two lakes with hot spot removal
- $12+ million by eliminating sampling of private wells through the construction of an off-base water line to serve residents
- $15 million with reduced sampling frequency/# wells