Characterization and remediation of 91B radioactive waste sites under performance based contracts at Lackland Air Force Base, San Antonio, Texas

This paper describes the challenges behind the implementation of the characterization, remediation, and the Site Closure for three 91b Radioactive Wastes under a Performance Based Contract at Lackland Air Force Base, San Antonio, Texas. The Defense Environmental Restoration Program (DERP) was established by Section 211 of the Superfund Amendments and Reauthorization Act of 1986 (SARA). A part of the DERP provides for the cleanup of hazardous substances associated with past Department of Defense (DoD) activities and is consistent with the provisions of the Comprehensive Environmental Response, Compensation and Liability Act (CERCLA). It is the Air Force Installation Restoration Program (IRP) that has responsibility for the cleanup activities associated with CERCLA. Under contract to the Air Force Center for Environmental Excellence (AFCEE), the ECC Project Team, that included ECC, Cabrera Services, and Malcolm Pirnie, was responsible for the implementation of the actions at three sites. The three IRP (91b) sites included RW015, a 0.02 square kilometer (5.5 acre) site, RW017 a 0.003 square kilometer (0.9 acre) site, and RW033 an 0.356 square kilometer (88 acre) site. Adding to the complexities of the project were issues of archaeological areas of interest, jurisdictional wetlands, land open to hunting, issues of security as well as compliance to the myriad of air force base rules, regulations, and Air Force Instructions (AFI). The award of the project task order was July of 2005, the project plan phase started in July of 2005 followed by the remedy implementation that included characterization and remediation as required reached completion in June of 2006. The project closure including the development and approval final status survey reports, proposed plans, and decision documents that parallel the CERCLA process was initiated in June of 2006 and is expected to reach completion in August of 2007. This paper will focus on the issues of working to achieve radiological and chemical closure under a performance based contract vehicle and the challenges encountered while reaching this goal. (authors)