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Air Force Plant Number 4 (AFP4)

Air Force Plant 4 (AFP4): Kickoff Meeting


Project XL /ENVVEST Kickoff Meeting
Green Oaks Park Hotel, Fort Worth, Texas
November 20, 1997

Action Items

  1. Mr. Rosenthal will talk with Norm Robbins, AFP4's community relations representative, to discuss the possibility of making presentations to local city councils or county labor boards to locate additional participants.
  2. Mr. Scott will personally invite other Sierra Club and Audubon Society members to participate.
  3. Mr. Rosenthal will provide Ms. Stubblefield with a copy of the chart depicting TRI emissions at AFP4.
  4. Mr. Rosenthal will provide Mr. Baig and Ms. Siegmann with electronic copies of the AFP4 presentation.
  5. Mr. Briskin and Lockheed Martin will lead the effort to develop a second invitation letter, which will include the minutes from this meeting, the AFP4 project briefing, an explanation of the types of public participation possible, and the commitments involved. This invitation will emphasize the voluntary nature of participation. A return postcard will be provided, and invitees will be asked to indicate whether they prefer evening or daytime meetings.
  6. Mr. Rosenthal will contact Mike Gross, of the Restoration Advisory Board, regarding RAB participation.
  7. Mr. Fetter and Mr. Briskin will prepare a straw man FPA and groundrules for the December 16 and 17 meetings. These materials will be mailed in advance of the meeting to confirmed attendees. All participants are responsible for reviewing these materials prior to the next meeting.
  8. The next meeting will consist of a second public informational meeting evening session on December 16 with a full-day working session following on December 17 at the Air Force Base Conversion Agency, Carswell Air Force Base (3550 White Settlement Road, Fort Worth, Texas). Mr. Briskin will be in charge of logistics for this meeting.
  9. Participants will be responsible for identifying point contact leads for each involved group (e.g., EPA, TNRCC, Air Force, DOD, and Lockheed Martin) at the next meeting, to establish a mechanism for information distribution.

Meeting Summary
Welcome and Introductions
Sean Casey (ICF Incorporated) welcomed attendees to the Project XL (EXcellence and Leadership) Kickoff Meeting for the Air Force Plant #4 (AFP4) project, sponsored by the U.S. Air Force and Lockheed Martin. Project XL is a critical component of the U.S. Environmental Protection Agency (EPA)'s effort to reinvent environmental regulation. In partnership with states, EPA is providing a limited number of responsible companies the opportunity to demonstrate excellence and leadership. Project sponsors seek flexibility regarding current environmental regulations at specific facilities. Project proposals must meet the following conditions: (1) they must produce environmental performance superior to that achieved by full compliance with current laws and regulations; (2) the process involved must be "transparent" so that the public can examine assumptions and track progress toward meeting promised results; (3) they must not create worker safety or environmental justice problems; (4) they must have the support of the community surrounding the facility; and (5) they must be enforceable through regulatory reinterpretation, a site-specific rulemaking, a national rulemaking, or through a permit condition written into an enforceable permit.
EPA Region 6 Presentation
Adele Cardenas (EPA Region 6) introduced herself as the EPA co-lead for this project, along with Walter Walsh (EPA HQ). She thanked the public attendees present for attending the meeting. She emphasized that public participation is a significant component of EPA's regulatory reinvention efforts, including Project XL. Ms. Cardenas discussed Region 6's objectives for Project XL, their definition of success, and the concepts underlying regulatory integration of pollution prevention. She stressed that the costs of pollution prevention include input and pollution costs, public concern costs (e.g., costs relating to sharing information with the public), and up-front costs for the pollution prevention initiative. The benefits of pollution prevention include raw material efficiency, fostering a positive corporate profile, increased worker health and safety, product asset investment, reduced pollution, and reduced regulatory burden. Pollution prevention is key in XL projects, in addition to technology transferability and streamlined reporting. She said that the regulator's role is to manage interactions to promote pollution prevention. Ms. Cardenas also emphasized that timing is always critical with pollution prevention initiatives, and is particularly a concern for the Air Force and Lockheed Martin regarding this project.

Mr. Bob Scott (Fort Worth Environmental Council) asked if hazardous material control, treatment, and destruction issues would be discussed during the meeting. Ms. Cardenas answered that these topics would be addressed during the Lockheed/Air Force presentation on the specific components of the project.

Other National and Region 6 XL Projects
Mr. Scott asked for more information regarding other XL projects. Ms. Cardenas said that the meeting handouts summarize XL projects that have reached the implementation stage and have signed Final Project Agreements (FPAs). Projects at this stage have been sponsored by Berry, Weyerhauser, Intel, Department of Defense/Vandenberg, Merck, Molex, and OSi. She said this information is also available on the EPA Internet site. Mr. Scott said that he does not access documents on the Internet. Ms. Cardenas invited attendees to request any materials directly from EPA.

Next, Ms. Cardenas presented the "Introduction to Project XL: A Basic Training Course" manual distributed to meeting participants. This manual was developed by Region 6 to introduce EPA employees, state, local, and tribal agencies, and public and environmental groups to Project XL. EPA welcomes comments and suggestions on this document. Ms. Cardenas reviewed in detail the table at the close of the manual summarizing XL projects in Region 6 (e.g., Lucent, Union Carbide, Air Force/Lockheed, Uniroyal, Greater Kerry Development Corporation). David Bond (EPA Region 6) noted that the final pages of the manual contain useful staff contacts in EPA Region 6 and the states in the region.

AFP4 Project XL Public Participation
Ms. Cardenas said that the Air Force and Lockheed Martin are responsible for inviting public participation in their proposed AFP4 XL Project. She stressed again that public involvement is a key component of the Project XL process. She said that EPA hopes that the number of public participants involved with the AFP4 project is expanded beyond the number present at today's meeting. She asked if the public attendees present would provide assistance with locating and encouraging additional public participants.

Categories of Public Participation. There are three categories of public participation in Project XL: direct participants, commenters, and the general public. The type of participation chosen is voluntary. Direct participants commit to attending regular meetings with the project sponsors and regulators, and "sit at the table" during the negotiation of the terms of the Final Project Agreement. Commenters are welcome to attend any or all of these meetings; however, commenters do not "sit at the negotiating table." Commenters provide their input in the form of written comments on the drafts produced by the direct participants, project sponsors, and regulators. The general public is invited to the public kickoff meeting and the meeting held to announce the completion of a draft FPA, and is kept informed through updates and press announcements.

Concerns About Including or Excluding Stakeholders. Mr. Walsh noted that, from a national perspective, EPA wants the XL process to be as open and inclusive as possible. He said that project documents, including correspondence, all meeting and teleconference notes, and interim FPA drafts, are posted on the Internet and are publicly available.

Trace Finley (TNRCC) expressed his concern that some public participants may attempt to "re- negotiate" components of an FPA at the last minute. He recommended a cut-off point for direct participation. Mr. Walsh said that, realistically, EPA cannot set such a cut-off point. He agreed that up-front participation is optimal, however. Ms. Cardenas suggested that Mr. Finley's concern might be addressed through the development of groundrules at the next meeting. Gary Smith (EPA Region 6) stressed the importance of a broad, early effort to include as many participants as possible. Interested latecomers will need to be made welcome to provide input and told what kind of outreach was initially conducted. However, the process should not have to start over. If the project sponsors cannot demonstrate that they made a good faith effort to invite participants, then latecomers will have a legitimate complaint.

Mr. Walsh emphasized that public stakeholders act in an advisory capacity to the project sponsor. After a Final Project Agreement draft has been produced with the assistance of stakeholders, EPA will evaluate the substance of the agreement against the required criteria and evolving policy considerations, as well as the inclusiveness and openness of the participation process. He agreed that, unfortunately, some participant groups may strategically choose to delay their participation until the last minute, and the Agency and project sponsors must deal with this situation if it occurs. Common sense steps should be taken to document outreach efforts in the project administrative record.

Air Force/Lockheed Martin Efforts to Include Stakeholders. Alex Briskin (Air Force) said the Air Force and Lockheed Martin have taken steps to mitigate the risk of latecomers, including publishing public notices in several newspapers and personal invitations. Surendra Joshi (Air Force) reviewed the draft AFP4 stakeholder involvement plan, which has not yet been reviewed by EPA and DOD. Mr. Scott observed that potential participants might have been intimidated by seeing their names listed as direct participants in the stakeholder involvement plan, when they might not have been sure of the commitment involved. He recommended that invitations to participate include a clearly-worded description of the scope of involvement. He agreed that it is difficult to convince individuals to participate in initiatives that require their time. The challenge is to reach more people and to provide them information that convinces them they want to participate, prior to the next meeting.

Mr. Smith stated that the direct participants, with the project sponsors and regulators, should choose their own committee co-chair at the next meeting. The Air Force should not automatically be assigned this position without stakeholder input. He also interjected that stakeholders, project sponsors, and regulators are not functioning in an advisory capacity to the Agency, and therefore project meetings are not regulated by the Federal Advisory Committee Act (FACA).

Ragan Tate (EPA Region 6) emphasized that significant community outreach efforts are necessary for XL projects. For example, the Intel-sponsored project encountered problems despite strong local support and involvement, because national environmental groups came in at the end of the project with comments and delays. Mr. Finley noted that a similar problem occurred with the 3M-sponsored project in Minnesota, despite very high-level support from the President and the head of the state environmental regulatory agency. The TNRCC wants to avoid that situation. Mr. Walsh added that EPA has not approved anything during the project development stage, but has agreed that there is reason to believe that the project sponsor will be able to negotiate a viable Final Project Agreement with stakeholders and regulators.

Mr. Joshi said he did not know why representatives from the AFP4 Restoration Advisory Board (RAB) did not attend today's meeting; when he briefed the RAB recently, he thought he had a commitment from at least one member. No one was able to attend from the North Central Texas Council of Governments because that group was holding its own meeting today.

Bill Rosenthal (Lockheed Martin) summarized participation efforts by organization. He noted that David Faith attended today as a representative of the International Association of Machinists. He said Mr. Faith leads the plant's committee on workplace safety hazards. Mr. Rosenthal noted that he first briefed Mr. Scott's organization, the Fort Worth Environmental Council, over a year ago. One other member of this group, Carolyn Ferguson (Resident, White Settlement), is interested in being a commentor for this project. This council includes the Senior Citizens Alliance, the Tarrant County Environmental Alliance, the Society of Texas Environmental Professionals, the Sierra Club, the Audubon Society, the Fort Worth Geological Society, Fort Worth Clean Cities, and the Fort Worth Industrial Depot. Mr. Rosenthal said that, regarding the Sierra Club, members had been invited from the local club (i.e., Carlton Conley), the Lone Star Chapter (i.e., Ken Kramer), and the national organization (i.e., Dick Tagnson). Mr. Rosenthal said Lockheed Martin sent letters and electronic messages and left voicemail messages, but had not had any personal contact with these individuals affirming or denying their interest. Dr. Vittorio Argento (UT Arlington) has agreed to participate as a direct participant in this project, and is represented by Dr. Clinton Parker (UT Arlington) today. Dr. Leo Newland was invited from Texas Central University, and Dr. Jeff Gaba from Southern Methodist University, but no response was received. Also invited with no response were the national and Austin offices of the Environmental Defense Fund, the national office of the Natural Resources Defense Fund, and reporters from the Fort Worth Star Telegram and TV Channel 8. As mentioned earlier, general public notices were also published in several local newspapers. An article on the project appeared in the Fort Worth Star Telegram this morning.

Mr. Tate asked if Lockheed Martin has a record of the email messages they sent, and/or a record of phone messages. Scott Fetter (Lockheed Martin) said copies of emails were saved, but not records of voicemails. Thom Rennie (Air Force Dallas) said he had a record of his phone calls. Mr. Scott said he was disturbed about the lack of response, even in the negative. He said the silence was worrisome, and that it appeared to him that the right people within the organizations named had been contacted. Mr. Rosenthal said he knows that Mr. Kramer from the Lone Star Sierra Club Chapter is not in favor of the Project XL program. Mr. Finley said that Mr. Kramer wrote a letter opposing the Texas statute (recently signed into law) that grants the TNRCC flexibility for regulatory reinvention projects.

Mr. Faith asked if any presentations had been made to local city councils or county labor boards to find participants. Mr. Rosenthal said no, but that he would talk with Norm Roberts, AFP4's community relations representative to discuss this possibility. Mr. Rosenthal was pessimistic that this approach would work in Fort Worth, but agreed that perhaps some individual members of these organizations might be interested in participating. Dr. Rennie asked Mr. Scott if he would personally invite other Sierra Club and Audubon Society members, and he agreed. Dr. Parker suggested that invitees be sent a letter with a "tear-off portion" and a self-addressed, stamped envelope to indicate their response.

Final Project Agreement Development Process
Ms. Cardenas walked attendees through the "Introduction to Project XL" training manual. This document outlines the general process flow for developing a Final Project Agreement. She stressed that negotiation of an FPA involves time, expertise, and commitment from all of those in the process, and that trust was an important factor. She said that groundrules for the group developing the FPA will need to be established at the next meeting covering roles and responsibilities of participants, treatment of confidential information, and internal and external communication procedures.

Mr. Tate emphasized that a Final Project Agreement is not a contract. It is a "roadmap" document that outlines who is involved in the project, how the project will be accomplished, milestones for the project, an implementation schedule, and what the enforcement mechanism will be, and it is a public document written in plain English.

Joyce Stubblefield (EPA Region 6) asked if the Vandenberg FPA would be used as a guide for the AFP4 FPA. Ms. Cardenas answered that it might be passed out at the next meeting as a handout. Dr. Rennie suggested it might be useful to invite representatives from the Vandenberg project to an AFP4 Project XL meeting to present their "lessons learned." Mr. Walsh noted that there is a Memoranda of Agreement in place between EPA and the Department of Defense (DOD) regarding DOD facilities participating in Project XL. This document is available on the website, and should be a handout at the next AFP4 meeting.

Bill Persky (Lockheed Martin) asked if there would be a single Air Force point-of-contact for the AFP4 project. Dr. Rennie answered that DOD and the Air Force are currently investigating who should be this single point of contact. Mr. Walsh noted that, even if a single point of contact is designated for the Air Force or EPA, this project will still need to be communicated to staff at various levels in the management chains of these organizations to ensure their approval.

Air Force Plant #4 XL/ENVVEST Project
Mr. Rosenthal presented a briefing on the proposed AFP4 XL/ENVVEST project. AFP4 is 602 acres in area, or over seven square miles. It is bordered by Lake Worth, the City of White Settlement, and an naval joint reserve base, which includes a runway. Raw materials are brought in to the plant from the south and finished airplanes are brought out from the north. The plant contains a number of manufacturing processes for building airplanes, including chemical processes and many painting locations.

Background on Air Force Plant #4 Previous and Current Environmental Initiatives. In 1984, it was decided that the only feasible business solution to address the problem of environmental regulations and liability was to set a zero discharge goal. A formal environmental resources management program was instituted. The program initially focused on determining a baseline for hazardous waste generation at the site, and then examined TRI emissions after that program began in 1987. Eventually, the program expanded its baselines to include a multimedia approach and a partnership with Air Force for research and development. In 1991, a formal hazardous material management program office was established.

Mr. Rosenthal said the Lockheed Martin has adopted a goal-oriented approach to pollution prevention, advocating the use of metrics to measure progress. Approximately 78 completed projects have been accomplished. He noted that many of these projects have been extremely research intensive, and have often involved source reduction. The program's initial successes were focused on easier wins (e.g., PCBs removal), and is now focusing on more major scale initiatives like cleanup of old underground storage tanks, which require a major investment on the part of the Air Force. After U.S. Today announced that this plant was the highest military emitter of ozone-depleting chemicals (ODCs) in 1992, the plant redoubled efforts to reduce ODCs with a new goal of completely eliminating ODCs by March 1995, which they achieved. At this time, there are still some ODCs in air conditioning units, but the Air Force is working on that area as well. The plant has achieved a 99% reduction in TRI chemicals, and a 99% reduction in "EPA 17" compounds (a voluntary EPA program). The plant has also achieved a 98% reduction in water contaminant discharges (primarily chrome, which is the major contaminant of concern in the discharges). The plant has reduced VOC emissions and overall air emissions, achieved a 90% reduction in manifested wastes, and recycles 48% of the nonhazardous materials it generates. Lockheed Martin continues to track its pollution metrics monthly.

Areas targeted for future reduction include: chrome; manifested wastes (e.g., heavy metal sludge with chrome in it); and NOx from boilers. Ongoing challenges to address include remaining EPA 17 hazardous waste and air emissions; National Emission Standards for Hazardous Air Pollutants (NESHAPs); Control Technology Guidelines (CTG); evolving Occupational Safety and Health (OSHA) requirements; and ozone non-attainment and global warming concerns. An advantage for the plant is that Lockheed Martin is a large technological company able to transfer information throughout the industry.

Mr. Rosenthal was asked for his definition of pollution prevention. He said pollution prevention runs the gamut from the preferred option of source reduction to end-of-the-pipe controls.

Mr. Rosenthal noted that the plant's pollution prevention efforts have resulted in cost savings, but that Lockheed Martin did not necessarily track these savings for each project. However, he knows that the plant saved $35 million in hazardous waste disposal costs, and that this did not include additional savings from avoided purchasing costs. Lockheed Martin did track the costs associated with a implementing a new, low vapor pressure wipe solvent. To implement this new solvent, employees needed significant re-training. The results of a value engineering study of this project revealed that the plant saved $8 million over five years.

Specific Components of the AFP4 Proposed Project. Mr. Rosenthal summarized that the basic point of the "ENVVEST" project is to trade compliance activities for a gain in pollution prevention. He said the company wants to shift focus from an end-of-life control to pollution prevention. The company believes this will produce cheaper and cleaner results.

The company selected chrome as one of the foci for this project because it is widely used in aerospace government facilities, it represents the largest remaining EPA 17 chemical in use at Air Force Plant #4, and it is a workplace hazard. The chrome NESHAP requires mist suppression, maintenance of workplace standards, and significant monitoring and reporting activities. The aerospace NESHAP mandates two-stage air filters, as well as inspection, monitoring and reporting activities. The cost expected to initially comply with the chrome NESHAP is $167,000, with a recurring cost of $42,000. The cost expected to comply with the aerospace NESHAP is $2 million, with a recurring cost of $214,000. Control costs for these rules are high, with the aerospace NESHAP expected to be $7.5 million per ton (based on a ten year amortization), and the chrome NESHAP at $427,000 per ton. Another reason chrome was selected was because of the Metal Products and Machinery Rule, which was proposed in 1995 but may be deferred until 2002. This rule would require a 90 percent reduction of effluent from the current unit. Lockheed Martin has recently constructed a new industrial waste treatment facility at the plant, but this new treatment facility may not meet these future requirements.

Lockheed Martin proposes to replace the sulfuric acid anodize/low chrome seal process to eliminate the need to comply with the chrome NESHAP for this process. This step is expected to eliminate 11 pounds of air emissions and 13,850 pounds of waste per year in sludge. Lockheed Martin is not requesting any regulatory relief for this step. The company also proposes to eliminate or reduce the use of chrome-containing coatings used at the plant with the best, most technically feasible alternatives. Using this approach would eliminate 90 pounds of air emissions and 1,040 pounds of waste per year. Fall out from painting is what contributes to the production of large volumes of sludge waste. Finally, Lockheed Martin also proposes to replace its tri-acid cleaning tank and replace the use of chromic acid with ferric sulfide, which would eliminate 90 pounds of air emissions and 3,600 pounds of waste per year. The company has already closed one tank, and is ready to test this approach. This tank is not currently regulated but contributes to emissions at the site.

Mr. Rosenthal stated that he felt that the next significant issue at the Federal level will be global warming, and the proposed new boilers would reduce greenhouse gases. The current boilers have actual emissions of 23,000 tons of CO2 per year, based on consumption of natural gas fuel, and that the new boilers would have potential emissions of 400 tons per year with actual emissions ranging from 200-300 tons per year.

In exchange for eliminating these sources of chrome, Lockheed Martin plans to request an exemption (for the existing facility) from the requirement of the aerospace NESHAP to install two-stage filters on all paint booths across the entire plant. The $1.6 million capital investment saved would instead be used to complete replacement of old boilers at the plant. This approach would eliminate 800 tons of potential NOx emissions from the plant annually.

Implementation of Project Components. Mr. Rosenthal said that Lockheed Martin is conducting research and development on these initiatives right now. Lockheed Martin is preparing for construction of the sulfuric acid anodizer, and expects to qualify this new equipment in 1998. Construction is anticipated to be complete by April. The qualification process will run from April to December 1998, after which the company plans to shut down the old anodizer.

Mr. Rosenthal emphasized that it is difficult to persuade the Air Force to use new coatings, because the current F-16 coatings meet established performance criteria very well. However, a significant benefit is anticipated from transferability of these new coatings within the industry. The company is working on researching replacements for all chrome-containing coatings in use at the plant, but in this proposal is only referring to eliminating two of these coatings. The remaining chrome-containing coatings at the plant would still be regulated under the Aerospace NESHAP. Mr. Fetter added that the two coatings targeted by the company are the two that are most commonly used in the industry at large. He said that the other five chrome-containing coatings are more specialized for the F-16. Mr. Fetter said that the cost estimates in their proposal are based on 1994 production levels. In 1994, the plant produced approximately 100 F-16s, which is a good example of the highest level that could be expected. Mr. Fetter said they thought using a high-production year would be a good baseline for comparison purposes.

Mr. Rosenthal displayed a chart depicting costs and emissions with and without ENVVEST. Yearly air emission reductions are higher with ENVVEST than without, and similar reductions are achieved regarding sludge production and NOx emissions. The regulatory relief Lockheed Martin is asking for will enable the company to re-direct funds from installation, monitoring, and recordkeeping under the aerospace NESHAP. Mr. Rosenthal noted that it took a long time to move this project to this point, and that the timeframe left for implementation of this proposal is now very short.

Discussion of the Proposal. Joyce Stubblefield (EPA Region 6) asked why some air emissions show an increase after implementation of the ENVVEST/XL proposal at AFP4. Mr. Fetter answered that, under the proposal, current emissions will stay the same until 1999. The new low-chrome coatings are anticipated to complete qualification to Air Force requirements starting in 1999, after which there will be a one to two year implementation period. In contrast, without the project, the plant would meet the chrome NESHAP restrictions and emissions would be reduced at that time. Lockheed Martin pursued the additional components of the ENVVEST/XL proposal in order to compensate for this difference and to produce a net decrease in emissions. Mr. Rosenthal emphasized that these emission calculations were conservative (e.g., Lockheed Martin assumed 65 percent filter efficiency when 90 percent efficiency may be more accurate).

Mr. Tate asked what the status of this project would be if the Air Force does not approve the new low-chrome coatings by 2000. Mr. Fetter answered that the FPA would need to address this contingency (e.g., by negotiating filters or other controls). He noted that Lockheed Martin is investigating a range of alternatives to mitigate that risk. For example, the project proposes developing replacements for two of the six most feasible chrome-containing coatings, but Lockheed Martin is investigating the remaining coatings with the Air Force as well. Mr. Rosenthal said that Lockheed Martin needs the Air Force to embrace this project, and to provide a test plane to prove or disprove the utility of the coatings. Mr. Tate said that one of the attractive features of the proposal is this driver for technology transfer.

Barbara Driscoll (EPA OAQPS) stated that chrome is regulated because it is very toxic, whereas NOx is not. She cautioned against directly comparing the benefits of reductions in chrome versus NOx emissions, and said that is not the position of EPA. She also noted that there is a difference in potential versus actual emissions. Mr. Rosenthal agreed, but noted that AFP4 emits small amounts of chrome and the chrome NESHAP applies regardless of the quantity of chrome involved. Ms. Driscoll confirmed that this was true. Alex Briskin (Air Force) noted that the low-chrome coatings are not an impossible technical problem, and that Lockheed Martin and others have produced successes in this area.

Dr. Rennie asked what the difference was between ENVVEST and Project XL. Mr. Rosenthal noted that both are concerned with regulatory reinvention, and opportunities for cleaner, cheaper, and smarter environmental results. ENVVEST is a Department of Defense initiative which stands for "environmental investment," with the goal of spending limited environmental compliance dollars in the most effective manner. Mr. Walsh said that, from EPA's perspective, XL projects come from three sources: communities, private facilities, and Federal facilities (including DOD projects). ENVVEST is the process DOD uses for submitting XL proposals to EPA. EPA does not make any distinctions between ENVVEST projects and other XL projects in terms of staff, resources, or procedures. Mr. Joshi noted that ENVVEST projects are competitively selected within DOD, so that only the best projects are eventually proposed for Project XL.

Ms. Stubblefield asked Lockheed Martin for a copy of the chart depicting TRI emissions at AFP4. Ejaz Baig (TNRCC Arlington) and Lora Siegmann (ICF) asked for electronic copies of the presentation.

Mr. Tate asked if process bath water will still be a listed waste. Mr. Rosenthal said yes, but that the facility has submitted a de-listing petition for this sludge. Lockheed Martin expects that either this petition will be granted or the conversion coating will be eliminated. Mr. Tate said he is working in the area of conversion coating de-listing. Mr. Rosenthal asked who he could work with on this topic, and Mr. Tate answered himself.

Next Steps
Mr. Briskin noted that further outreach efforts will be undertaken, including a second invitation letter that will include the minutes from this meeting and the AFP4 project briefing. He said the goal for the next meeting would be to set the groundrules and have all the participants on board. Ms. Stubblefield recommended that the second letter include an explanation of the types of public participation possible, the commitments involved, and when meetings would be held. Mr. Smith suggested that the voluntary nature of participation should be emphasized in these materials -- specifically, that it is up to the individual to decide his or her participation, and that he or she will not be arbitrarily assigned to a participant category. Mr. Finley recommended including a return postcard, and Mr. Smith agreed this would help support the record of outreach conducted. Mr. Rosenthal will contact Mike Gross, of the Restoration Advisory Board, regarding RAB participation.

Mr. Joshi presented a schedule for future stakeholder committee meetings through May. The Air Force and Lockheed would like to develop a draft FPA by May, publish the FPA in the Federal Register and hold the second open public meeting in June, and have a final signed FPA by August. At the end of March, efforts will be made to communicate the project vertically through management at EPA, the Air Force, and the TNRCC. Mr. Fetter asked Ms. Cardenas if it was reasonable to finalize a draft FPA in 30 days, and she answered yes, because the draft FPA will be undergoing continuous EPA review throughout the process.

Mr. Finley asked who will sign the FPA. Mr. Walsh said that in the past some FPAs were signed by the EPA Administrator, but recent projects have been signed by the Regional Administrators. Other signatories include the state, other Federal agencies, and in some cases public stakeholders. Stakeholders need to decide for themselves if they want to sign the agreement.

Mr. Fetter committed to having a straw man FPA and groundrules available by the next meeting. Mr. Finley said that it would be preferable to distribute the draft FPA prior to the meeting to facilitate review. Mr. Rosenthal agreed, but said this would not be possible for attendees that they do not know are coming. Ms. Cardenas noted that the next meeting should cover establishing groundrules, expectations of the process (e.g., participant concerns and needs), and the draft FPA. She emphasized that all meetings should be product-driven.

Negotiating FPA language during working meetings can be laborious, and distributing changes in the draft FPA for review by public commenters can be time-consuming. Ms. Cardenas emphasized that it is the responsibility of the project sponsor to keep the public informed and to provide opportunities for review. Mr. Smith stressed that the FPA is not a legal document, and should be written from a lay perspective. Mr. Bond noted that public stakeholders may identify new issues that have not been considered in the current proposal, and that the point of the stakeholder meetings is to discern the concerns of all the parties. Mr. Scott agreed, and said that a balance will need to be struck to avoid dictating to participants but still moving the process forward. He recommended providing examples for participants as points of departure.

After discussing the alternatives, the group eventually decided that the next meeting should be held as an evening meeting on December 16 with a full-day working session following on December 17. Participants agreed that evening meetings might be useful to obtain participation from working stakeholders, but involve more difficult arrangements for those traveling from out-of-town. Mr. Walsh noted that a combination (working meetings in the day, information/update meetings in the evening) has worked for some projects. It was agreed to poll stakeholders for their preference regarding the scheduling of future meetings, and to provide general information about the participation options and the project in a second invitation. Attendees agreed that it is important to find out if there are other stakeholders available and interested in participating. Mr. Briskin was tasked with the arranging the logistics of the next meeting, which will be held at the Air Force Base Conversion Agency, Carswell Air Force Base (3550 White Settlement Road, Fort Worth, Texas).

To conclude the meeting, Mr. Casey thanked attendees and asked them to write on a piece of paper what concerns them the most about this project. This information is summarized in the following table.

As the process moves forward, the one thing that concerns me the most is....
Baig, Ejaz ... that the committee is bogged down in trivial issues.
Bond, David ... getting bogged down in dealing with less significant issues.
Briskin, Alex ... inflexibility.
Cardenas, Adele ... that not all team members understand the process and the integration involved with varying expertise from everyone at the table.
Driscoll, Barbara ... are all the players for the Air Force covered.
Ellingson, Tom ... keeping it moving forward!
Faith, David ... that it will benefit the workers that I represent, and the areas they live in, by creating a healthier work and community environment.
Fetter, Scottl ... completing the definition of the enforceable agreement.
Finley, Trace ... resolving the implementation mechanism question.
Joshi, Surendra .... people having pre-conceived notions and not being willing to give the process a fair chance to proceed smoothly.
Rennie, Thom ... how to handle all the good news reports when the project is successfully implemented.
Rosenthal, Bil ... that we may turn something that seems very direct and straightforward into something that becomes very difficult and burdensome for all parties.
Scott, Bob ... that participants thoroughly understand the task at hand.
Smith, Gary ... the potential to get bogged down in minutia and lose focus on the ultimate goal (i.e., what is best for the environment and positive results of this project).
Steele, Frank ... later questions/comments from people within other hierarchies of my chain of command concerning "show stoppers" without all the facts/information.
Stubblefield, Joyce ... breaking this all down to the stakeholders in order for them to truly participate.
Tate, Ragan ... time it takes to craft legal implementation mechanism.
Walsh, Walter ... the deadline, which may or may not be the real time frame.
Name Representing Phone Number Fax Number
Baig, Ejaz TNRCC Arlington 817/469-6750  
Bond, David EPA Region 6 214/665-6431 214/665-7446
Briskin, Alex Air Force 937-255-3059  
Cardenas, Adele EPA Region 6 214/665-7210 214/665-3177
Casey, Sean ICF 703/934-3222 703/218-2669
Driscoll, Barbara EPA OAQPS 919/541-0164 919/541-0942
Ellingson, Tom HQ AFMC 937/257-7704 937/257-5875
Faith, David IAM & AW 817/763-7476  
Fetter, Scott Lockheed Martin 817/777-3791 817/763-7476
Finley, Trace TNRCC 512/239-5886 512/239-3939
Joshi, Surendra Air Force (ASC/EMC) 937/255-7716, x415 937/255-9985
Parker, Clinton (substitute) University of Texas, Arlington 817/272-5055 817/272-2630
Persky, Bill Lockheed Martin 817/777-5800 817/763-7476
Rennie, Thom Air Force (REO) 214/767-4678 214/767-4661
Robbins, Norman Lockheed Martin 817/777-8294 817/777-2115
Rosenthal, Bill Lockheed Martin 817/777-6919 817/763-7476
Scott, Bob Fort Worth Environmental Council 817/282-1372  
Siegmann, Lora ICF 703/934-3609 703/218-2547
Smith, Gary EPA Region (OECA) 214/665-7319 214/665-3177
Steele, Frank HQ AFMC 937-255-5270 937-255-7906
Stubblefield, Joyce EPA Region 6 214/665-6430 214/665-7446
Tate, Ragan EPA Region 6 (ORC) 214/665-8020  
Walsh, Walter EPA HQ 202/260-0174  

Meeting Handouts

Air Force Plant #4 Project XL/ENVVEST Project Submission (June 9, 1997)
Draft Air Force Plant #4 ENVVEST Stakeholder Involvement Plan (November 1997)
ENVVEST Kickoff Facility Tour, List of Acronyms, Tank Flow Diagram (November 21, 1997)
F-16 Fighting Falcon: The Choice of 19 Air Forces
Federal Register Publication and Information on Project XL (EPA Headquarters, April 23, 1997)
Introduction to Project XL: A Basic Training Course (EPA Region 6, September 1997)
Lockheed Martin ESH Report: Special Report, Lockheed Martin Tactical Aircraft Systems (vol. 3, no. 1, Fall 1997)
Model Plan for Public Participation (Public Participation and Accountability Subcommittee of the National Project Environmental Justice Advisory Council, November 1996)
XL at a Glance (printout from EPA Project XL Internet site, November 19, 1997)
XL/ENVVEST Kickoff Meeting Agenda
XL Project Objectives: Region 6 Guidance


Directions to FPA Development Meeting


Meetings will be held at the Air Force Base Conversion Agency, Carswell Air Force Base.

FORT WORTH TX 76114-3520

Phone: 817-731-8973
Fax: 817-731-8137

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