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KAFB Jet Fuel Spill Monitoring and Remediation

Citizen Action NM Presentation at KAFB Fall Public Meeting

November 10, 2016

This paper addresses Citizen Action concerns about the cleanup of the Kirtland jet fuel spill. 

The horizontal and vertical reach of the Ethylene Dibromide plume is still not identified.  Two new sentinel monitoring wells #106026 and #106230 are not monitored.  The Mightiest Air Force in the history of the world could not monitor two new monitoring wells at the Northwestern portion of the jet fuel plume due to the threat of being shot by a private homeowner.  After the AF complained about the threat, the NM Environment Department (NMED) relieved the AF of groundwater monitoring for the two wells. Both wells are near to the most northerly extraction well KAFB-106234 (at Anderson, East of Louisiana) where EDB was estimated in the sample at 0.112 µg/L that is double the maximum drinking water limit of 0.05 µg/L.  Toluene and Xylenes were also detected at this extraction unit.  The extent of the plume in the northwestern area is still not realizedhttps://hwbdocuments.env.nm.gov/Kirtland%20AFB/KAFB4442.pdf 

Four of the nineteen newly installed groundwater monitoring wells had EDB detection: 106220 at 0.013 µg/L; 106225 at 0.40 µg/L; 106225 at 0.47 µg/L, and; 106230 at 0.020 µg/L. Sentinel well #106205 near Kathryn shows an EDB J detect.  The most northerly deep monitoring well at 610.7 ft. has no dedicated sampling system. 

Spreading of the EDB plume into the aquifer continues from the source area of the fuel spill. There is no plan in place to remediate the source area.  

Incorrect data representation to public.  Contrary to recent representations made by Kirtland on its jet fuel remediation website, there is no technical, data-supported assurance that forward movement of the EDB plume has been halted, or “thwarted” (NMED June 26). There is no evidence that the current “cone of depression” from three extraction wells has had any effect whatsoever on the advance of the EDB plume.  The errors were corrected after Citizen Action and Dr. Eric Nuttall brought the matter to the attention of NMED.  This is yet another example of why there should be a Remediation Advisory Board and involvement of the public stakeholders in the technical working group discussions.  

There still is no 3-dimensional computerized flow path view of the Jet fuel spill and no way for the public to determine whether or not the EDB plume has traveled beneath and beyond the cone of depression as occurred in the Long Island, NY TCE spill.

Work Plan for 2 additional extraction wells and injection wells.  https://hwbdocuments.env.nm.gov/Kirtland%20AFB/KAFB4449.pdf   The RCRA Facility Investigations that are necessary for the data base prior to planning for more extraction and injection wells are not completed.  On September 9, 2014, the Air Force promised 8 extraction wells by 2016. Three are installed. Regional aquifer injection wells and additional wastewater disposal locations are not identified in the Work Plan.  Two injection well target areas near the Golf Course did not have sufficient data to be approved by NMED.

Questions and issues regarding extraction volumes and disposal areas have consistently been raised by Citizen Action. The Groundwater Treatment System operated at 77% during the 1st Quarter 2016.  There were unplanned shutdowns of the discharge system at the TA Golf Course Main Pond caused by high water levels. Of 25 million gallons extracted in 1st Q, 2016, approximately 23.5 million gallons of treated water were discharged to the Kirtland AFB Tijeras Arroyo Golf Course Main Pond and 1.5 million gallons to pilot injection well KAFB-7.  If further closures of the Golf Course occur in winter 2016-17 where will extracted water be disposed?  What volume of water can be disposed of at the Golf Course Pond during winter months’ freezing temperatures?  What volume can be injected into KAFB-7?  What is the possible effect of injection at KAFB-7 on spreading the surrounding Nitrate and TCE plume of contamination where KAFB is located?  KAFB-7 is located near the Tijeras Arroyo that feeds to the Rio Grande. In general, there needs to be an overlay presentation of maps showing plume contamination where injection wells and disposal areas may be planned.

As of 9/19/2016, 102,600,000 gallons of water had been extracted and 34.02 gm of EDB removed (about 8 ½ teaspoons).  Millions of grams of EDB remain in the aquifer.  The 1st Q report (p. 5-3) states that “EDB was not detected above the 0.05 µg/L discharge limit in any effluent samples.”  What level, if any, was detected for EDB in effluent samples?

There does not seem to be any plan for participation by the public for comment and review of the nearly 2,000 page work plan.  The Work Plan is undergoing modification due to “new data acquired as work progresses.” However, the Quarterly reports are so late in being filed for the remediation that the public has no clue what new data is being acquired.

Late filed Quarterly Reports.  The January-March 1st Quarter 2016 was not filed until July 25, 2016.  The subsequent reports for the 2d and 3rd Q are both late.  The RCRA Facility Investigations for the jet fuel spill that were supposed to filed in late summer are past due.

Defective groundwater monitoring wells.  Drilling muds were used to speed up drilling.  The drilling fluids are known to adsorb contaminants of concern. 

Failed interim measure technologies due to inadequate data.  Regulators are stuck on pump and treat technology with unresolved problems such as where to place extraction wells, where to dispose of extracted effluent water, potential for further movement of contamination in areas where effluent water is placed, and potential aquifer depletion. The proposed increase in pumping of KAFB #3 supply well would have induced migration of EDB through uncontaminated water.  The Air Sparging interim measure proved not feasible due to rebound of EDB from soils. The very expensive CATOX Soil Vapor Extraction (SVE) system (the “Super sucker”) is being decommissioned despite the December 2, 2014 KAFB claim that “Data from a shutdown test was going to be used in the design of SVE expansion at the BFF site.” Kirtland AFB submitted a notice of intent to decommission the CATOX SVE system on November 20, 2015.

Monitored Natural Attenuation (MNA). The public would like to know whether the use of monitored natural attenuation signifies a change in remediation objectives such as the control of source materials, prevention of plume migration, and remediation of contaminated groundwater.  There is no evaluation of whether MNA will not significantly delay the achievement of site cleanup objectives within a “timeframe that is reasonable compared to that offered by other methods.”

NMED should deny Kirtland’s request to avoid the residential cleanup standard for land and water.  Citizen Action opposes the August 24, 2016 request of Kirtland AFB to only perform industrial level cleanup, rather than the residential standard for the Bulk Fuels Facility areas. https://hwbdocuments.env.nm.gov/Kirtland%20AFB/KAFB4444.pdf  The BFF is in close proximity to Bullhead Park and the Sunport. Any “impracticability demonstration” performed to conclude that the area cannot over time be restored to residential cleanup should be performed by an independent source and not left to Kirtland.  Kirtland AFB through its gross negligence contaminated the area with an estimated 24,000,000 gallons of jet fuel and aviation gas through its decades long failure to inspect and monitor the BFF pipeline. This resulted in the largest underground EDB contamination of an aquifer in the history of the United States. 

Safety of municipal water is still not verifiable. There is no approved backup plan for municipal well replacement in the event of EDB contamination. Groundwater monitoring wells have not been placed in the vicinity of the municipal wells.  The well screen lengths for the Ridgecrest supply wells are 800 ft long and pumping is at a rate of nearly 3000 gallons per minute. This results in tremendous dilution of samples taken from the municipal wells.