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PERCHLORATE REMEDIATION AND PROPERTY TRANSFER SUCCESS AT A CLOSING FEDERAL FACILITY

PERCHLORATE REMEDIATION AND PROPERTY TRANSFER SUCCESS AT A CLOSING FEDERAL FACILITY. Naval Weapons Industrial Reserve Plant McGregor, Texas. 2007 Region 4 EPA – DoD – States Environmental Conference June 20, 2007. NWIRP McGregor Facility Background.

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PERCHLORATE REMEDIATION AND PROPERTY TRANSFER SUCCESS AT A CLOSING FEDERAL FACILITY

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  1. PERCHLORATE REMEDIATION AND PROPERTY TRANSFER SUCCESS AT A CLOSING FEDERAL FACILITY Naval Weapons Industrial Reserve Plant McGregor, Texas 2007 Region 4 EPA – DoD – States Environmental Conference June 20, 2007

  2. NWIRP McGregor Facility Background • NWIRP McGregor was a 9,700-acre government-owned, contractor-operated facility in McGregor, Texas approximately 20 miles southwest of Waco. • The U.S. Army Ordnance Corps originally established the facility in 1942 as the Bluebonnet Ordnance Plant. Over the facility’s 50-year history, owners included the U.S. Army, U.S. Air Force, and its final owner, the U.S. Navy’s Naval Air Systems Command (NAVAIR). • Past industrial activities at the site included weapons and solid-fuel rocket propulsion systems manufacturing. • At its operational peak, the facility employed nearly 1,400 people, making it the largest employer in the area. • Manufacturing operations at NWIRP McGregor ceased in late 1995 and the last operator vacated the facility in early 1996. • The FY1996 National Defense Authorization Act authorized the conveyance of the NWIRP to the City of McGregor for purposes of economic redevelopment.

  3. NWIRP McGregor Investigation Background • A multi-phased Resource Conservation and Recovery Act (RCRA) Facility Investigation (RFI) was initiated in 1992 at NWIRP McGregor. • In March 1998, perchlorate was identified as a contaminant of concern in both soil and groundwater and additional investigations were undertaken. • Extensive areas of perchlorate affected soil and groundwater were identified both on and offsite. • The extensive perchlorate contamination in groundwater raised significant concerns among local stakeholders due to the close proximity of two lakes used to supply drinking water to approximately 500,000 people.

  4. NWIRP McGregor Partnering Success • The complex environmental and redevelopment issues associated with NWIRP McGregor required that the Navy work closely and collaboratively with many other agencies. • Formal partnering was implemented in 1996 between the Navy, USEPA and Texas Commission on Environmental Quality (TCEQ). • Quarterly meetings were held in McGregor • Open and candid discussions were encouraged • Technical data was shared as it became available • An GIS-based internet website was used to share data, maps and reports with the partnering team • Partnering encouraged a greater sense of ownership by all parties involved and expedited decision making. As a result, the project was completed more quickly and efficiently and achieved many “firsts”.

  5. NWIRP McGregor Partnering Success • Beyond the core partnering team, the Navy worked collaboratively with many other government agencies including: • the City of McGregor to address property transfer and redevelopment concerns, • the Brazos River Authority (BRA) and City of Waco to address concerns over potential impacts to nearby Lakes Waco and Belton, and • the Army Corp of Engineers to share data with their offsite study in support of the BRA and their work on an adjacent formerly utilized defense site. • Working in a collaborative fashion minimized “surprises” for the Navy and resulted in greater cooperation from all agencies.

  6. NWIRP McGregor Risk Communication • Beyond just communicating with regulatory and other governmental agencies, the Navy realized the importance of communicating with the local community and stakeholders. • To facilitate that communication the Navy established a community based Restoration Advisory Board (RAB) in 1996. • The RAB included representatives from the local community, the Navy, TCEQ, USEPA and City of McGregor. • At quarterly meetings, information was shared openly and RAB members and those in the audience were encouraged to ask questions. • Early RAB meetings had a large number of people in the audience as well as television and newspaper reporters. • The open and honest sharing of information with the RAB helped to build trust in the local community and allayed their concerns regarding perchlorate.

  7. NWIRP McGregor Risk Communication • In addition to the quarterly RAB meetings, the Navy held a perchlorate symposium in Temple, Texas in 1999 and invited national experts to speak and share information with the local community. • Also, the Navy frequently met with local landowners whose properties were impacted by contaminated groundwater to discuss the type, design, and locations of remedial systems that would be installed on their properties. • Congressional and senatorial staffers were also routinely updated on NWIRP McGregor’s progress in Washington, D.C. and McGregor, Texas.

  8. NWIRP McGregor Regulatory Innovation • From 1998 to 2005, a total of 6,000 acres had been transferred to the City of McGregor, all of which were either uncontaminated, had contamination which was below applicable cleanup criteria, or were remediated to applicable cleanup standards prior to transfer. • Environmental investigation and cleanup activities at NWIRP McGregor have been governed by a RCRA permit and Compliance Plan. • In order to complete property transfer of the remaining 3,700 acres, several issues had to be resolved.

  9. NWIRP McGregor Regulatory Innovation • The City needed title to the remaining Navy owned portions of the NWIRP in order to effectively redevelop the NWIRP’s assets. • Successful redevelopment of the NWIRP would result in numerous new owners and/or operators of the remaining 3,700 acres of the property. • Under the RCRA Post-Closure Permit, all new owners would have to be identified on the permit and sign future permit renewal applications. • The City did not want to become the “owner” (or co-owner with others) on a RCRA permit and believed that retaining the current permit would negatively affect property marketability. • The Navy had its own regulatory compliance, cost, and liability concerns about retaining (potentially for many years to come), permittee status over property which they no longer either own or operate. • Working cooperatively, an ingenious plan was developed by TCEQ and the Navy called a Post-Closure Order (PCO), the first to be issued in the State of Texas.

  10. NWIRP McGregor Regulatory Innovation • The PCO takes the place of the RCRA permit for all affected portions of the facility except the Area S burn pads, which then allowed a shrinkage of the RCRA Permit from the original 9,700 acres to only 16.4 acres. NWIRP McGregor Area S Burn Pad Cap • The PCO sets out all of the long-term remediation and monitoring requirements.

  11. NWIRP McGregor Regulatory Innovation • This solution eliminated the need for the City to be named as owner on a permit that would cover all 3,700 acres left to be conveyed. • By modifying the RCRA permit to only include the burn pads, it eliminated the need for any successors in interest to be named in the permit thereby enhancing property marketability. • This solution limited the range of regulatory requirements and associated liability exposures normally associated with permitted facilities to just a small portion of Area S.

  12. NWIRP McGregor Regulatory Innovation • The PCO provides an alternative enforceable mechanism for oversight of the Navy’s facility-wide groundwater cleanup. • The PCO only had to be signed by the responsible party, the Navy. • The PCO better defines the Navy’s clean-up obligations and future on-site involvement so as to minimize potential redevelopment impacts and stigma. • The PCO also serves to minimize the Navy’s regulatory/cost liability exposures associated with the future actions of new owners and operators. • The final PCO and a revised RCRA permit were finalized on October 3, 2006 and October 6, 2006, respectively. • This was the first PCO ever issued by the TCEQ.

  13. NWIRP McGregor OPS Determination • In addition to the PCO, because some of the treatment systems installed by the Navy will have to operate for years into the future, EPA concurrence that all remedial measures were operating properly and successfully also had to be obtained before property transfer. • The process of obtaining this concurrence took approximately one year. • During a meeting held on June 29, 2006 EPA indicated that all of their questions had been addressed and they could issue an OPS determination for all of the remaining 3,700 acres. • The OPS approval letter was issued by the EPA, October 12, 2006, after they received a copy of the PCO. • First Navy facility to receive an EPA “Ready for Reuse” Determination.

  14. NWIRP McGregor Redevelopment • Final property transfer at NWIRP McGregor was completed on October 31, 2006. • The results of the investigation, remedial, and transfer efforts are now paying off. • Economic redevelopment has created over 1,000 new jobs for the City of McGregor (new tenants include two Fortune 500 companies). • New tenants have invested over $3 million in the facility and employment is increasing. • Companies like Dell Computer, SpaceEx, Ferguson Enterprises, and McClennan Electric Co-Op have moved onto the property. • Additionally, there are four smaller companies that have operations onsite with several more in negotiations with the city. • An indoor rodeo arena has also been built that has brought more than 40,000 people through McGregor.

  15. NWIRP McGregor Process Optimization • One of the areas of greatest concern was of former manufacturing complex known as Area M that is located in the southwest corner of NWIRP McGregor. • Concentrations of perchlorate up to 91,000 µg/L were found in groundwater monitoring wells in Area M and a groundwater plume covering an area of approximately 360 acres was delineated in and around Area M. • Perchlorate concentrations up to 5,600 µg/L were detected in surface water samples collected from a surface water body running through Area M (Tributary M). • Perchlorate concentration up to 200 µg/L were detected in surface water approximately 1 mile downstream of the property boundary and concentrations up to 56 µg/L were detected at a location 3 miles downstream of the property boundary. • There were no detected impacts to the Leon River or Lake Belton, which is nearest source of drinking water, but concern was high.

  16. NWIRP McGregor Process Optimization • The highest priority was given to Area M due to the relatively high concentrations detected and the proximity of Lake Belton. • A series of collection trenches were installed near the property line south of Area M beginning in September 1999. Several water storage lagoons were also constructed. • Various exsitu treatment technologies were tested from late 1999 through mid-2001. • In November 2001, construction began on the final ex-situ treatment system, a 400 gallon-per-minute (gpm) fluidized bed reactor (FBR) supplied by Envirogen. • The FBR began operation in May 2002 after receiving the necessary permits and regulatory approvals. These allowed for the discharge of treated effluent to Tributary M.

  17. 0 400 Onsite Treatment System B-LINE TRENCH C-LINE TRENCH A-LINE TRENCH

  18. NWIRP McGregor Process Optimization • The collection trenches and FBR effectively minimized the offsite migration of perchlorate. However, for the following reasons the system required intensive operator involvement: • The Texas Pollutant Discharge Elimination System (TPDES) permit for the system required daily sampling for perchlorate when there was a discharge. • The TPDES permit also required analysis of a grab sample if the system was being operated such that water was being discharged in a batch mode. • One of the operational goals of the trenches is to prevent seeps to Tributary M. As a result, pumping rates have to be adjusted frequently. This required daily, manual adjustments at the FBR. • ORP readings are critical to monitoring the performance of the reactor and these had to be performed manually twice each day at the FBR. • During periods of heavy rain and high groundwater levels, contaminated groundwater could seep into the treated water storage lagoons causing significant water management issues.

  19. NWIRP McGregor Process Optimization • In the pre-optimization operating mode, daily staffing of the treatment system was required. • During the first several months of operation, approximately 72 to 90 operator hours per week were required to effectively operate the system and meet the TPDES permit conditions. • Annual pre-optimization operator labor costs were estimated at approximately $190,000.

  20. NWIRP McGregor Process Optimization • In late 2004, NAVFAC EFDSOUTH undertook a series of studies to optimize the performance of the Area M FBR and associated collection, conveyance and storage system. • Recommendations for improvements and/or modifications were developed considering the following objectives: • Optimization of the existing groundwater treatment system, • Selection of the most appropriate and reliable mode of operation, • Implementation of an efficient operations program to minimize O&M cost, in particular labor, • Incorporate automatic process control and monitoring to reduce labor, and • Provide highest assurance of compliance with permit limits.

  21. NWIRP McGregor Process Optimization • The original TPDES permit, issued in November 2002, was up for renewal at approximately the same time the optimization study was conducted, providing an opportunity to renegotiate sampling requirements. • Several beneficial modifications were successfully negotiated based on the past operational reliability of the system and the enhancements to the system that were planned based on the optimization study. • The most significant change was a reduction in the required outfall sampling for perchlorate from daily to weekly. • A new TPDES permit was issued on July 13, 2005.

  22. NWIRP McGregor Process Optimization • Navy contractors (EnSafe Inc. and CCI) completed a treatment system upgrade in September 2005. • This upgrade included the following major elements: • A control and communication system to provide remote monitoring, remote control, and continuous, uninterrupted remote alarming capability to reduce operator labor and to simplify operation. • Water management modifications to an existing treated effluent water polishing/storage unit (Soil Cell C) to increase operator flexibility and eliminate the potential for groundwater infiltration.

  23. NWIRP McGregor Process Optimization • Specific elements of the process optimization included: • Selection of a direct discharge mode of operation utilizing only Soil Cell C for effluent polishing • Rehabilitation of Soil Cell C through the clearing of vegetation, the raising of the cell bottom (to prevent contaminated groundwater infiltration), the installation of an HDPE liner, and the installation of a cascade aerator. • Installation of a Human Machine Interface (HMI)/Supervisory Control & Data Acquisition (SCADA) system with software, configuration, back up power supply and necessary programming to allow day-to-day monitoring and process tracking to be conducted remotely. • Installation of dual inline ORP probes to provide constant, real time monitoring of FBR performance. • Installation of an automated diversion valve to automatically divert water to Lagoon A in the event of a problem with the FBR. • Completion of various minor piping changes to allow greater flexibility in managing untreated water during periods of heavy rainfall.

  24. NWIRP McGregor Process Optimization • Optimization of the Area M groundwater treatment system has been a success in terms of both cost savings and greater operational efficiency. • Sampling has been reduced • Operator labor has been reduced • Problems with contaminated groundwater infiltrating into treated water storage lagoons has been eliminated • The approximate cost of the optimization effort was $1,070,000. • Based on savings in operator labor, laboratory analysis, and periodic maintenance of the soil cells; the payback period for the optimization effort is 4.75 years.

  25. NWIRP McGregor Accomplishments • First Navy and State of Texas PCO • First Navy non-Base Realignment and Closure (BRAC) OPS determination by the USEPA • First Navy facility to receive an USEPA “Ready for Reuse” determination • First full-scale permeable reactive barrier (PRB) (also called biowall) for groundwater remediation of perchlorate and volatile organic compounds (VOCs). • World’s longest biowall application (nearly three miles) • Savings of more than $20 million in remedial construction costs and expected savings of more than $1 million annually as a result of the innovative remediation approach, as well as the progressive operation and maintenance (O&M) and project management strategy • More than 1,000,000 construction man-hours with no reportable health and safety incidents • No regulatory violations during the environmental restoration of the facility

  26. Questions • Further questions, please contact: Mark Craig Remediation Project Manager NAVFAC Southeast (843) 820-5517 mark.craig@navy.mil

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