KIRTLAND JET FUEL SPILL
CITIZEN ACTION ACHIEVEMENT: WATER AUTHORITY APPROVES RESOLUTION FOR ZERO ETHYLENE DIBROMIDE IN ALBUQUERQUE DRINKING WATER
On Wednesday, June 18 the Bernalillo County Water Utility Authority (WUA) Board voted unanimously in favor of Resolution R-14-11. Beginning at the WUA’s April, 2014 public meeting, Citizen Action raised the need for a Resolution to not allow the entry of Ethylene Dibromide into Albuquerque drinking water supplies or distribution of EDB contaminated water after blending of water supplies to bring EDB to acceptable Environmental Protection Agency maximum contaminant levels of 50 part per trillion. On May 21, 2014, Citizen Action provided the WUA a written draft resolution to allow zero levels of EDB into Albuquerque’s drinking water. In a statement of reasons for the Resolution, the WUA cited recent the New Mexico Environment Department’s concern that a proposed interim measure for a pump and treat operation at a KAFB supply well #3 would spread and contaminate even more of the aquifer.
R-14-11's declaration states:
BE IT RESOLVED BY THE WATER AUTHORITY: 11
Section 1. The Water Authority requests that the USAF/KAFB and its contractor to immediately develop and implement an appropriate remediation plan that prevents further migration of the dissolved phase EDB plume.
Section 2. The Water Authority requests that the USAF/KAFB and its contractor continue to monitor the location of the plume and install additional monitoring wells to track the movement if it continues towards the Water Authority’s water supply wells.
Section 3. The Water Authority will not allow EDB contaminated water at any level to enter the potable drinking water system.
Citizen Action applauds this Resolution: Kirtland is many years behind in planning and remediation necessary, to cleanup the jet fuel spill and prevent EDB from contaminating your drinking water through the Ridgecrest municipal wells. This resolution is the first declaration the the WUA Governing Board, drawing a "line in the sand" which acknowledges Kirtland's inadequate effort AND points to much of what must be done soon and should have been done years ago. The Resolution states as background for understanding why this declaration is necessary (numbering added) :
SUMMARY
- This Resolution would establish the policy of the Water Authority to not allow ethylene dibromide (EDB) at any detectable level to enter the potable drinking water system.
- The Water Authority is compelled to respond with this policy proposal based on a June 6, 2014 letter from the New Mexico Environment Department (NMED) to Kirtland Air Force Base (KAFB) disapproving the base’s conceptual plan to allow contamination from their Bulk Fuels Facility (BFF) spill to continue to spread in the aquifer and reach one of KAFB’s production wells (KAFB #3) as an interim measure to contain the plume.
- Recent data from the investigation of the BFF Spill suggests that the plume continues to move northward, directly towards Ridgecrest well number 5, providing field evidence that the plume is moving in the direction of the production well fields to the north of the source area and away from KAFB #3.
- The Air Force Civil Engineering Center and KAFB recently engaged the U.S. Geological Survey and the Water Authority to locate sentinel well locations that will be used as early warning wells and points where aquifer tests will be performed to better understand how groundwater flows to the Ridgecrest well field. Water Authority requests that the regular sampling and drilling of additional sentinel wells be conducted by the Air Force as long as it is needed to monitor the movement of the EDB plume.
Residents of Albuquerque having become increasingly concerned about the jet fuel in recent months, and also uncertain as to who is responsible for cleanup, should welcome this declaration.
BACKGROUND
For several years Kirtland has been telling the public at CAB meetings, in public statements and by representatives of their contractor SHAW (now CB&I) the EDB plume is "stable" and "not dynamic" (not moving/expanding). SHAW's lead project manager stated repeatedly at CAB meetings since 2011, that "all we're doing is watching" quarterly sampling data taken from existing monitoring wells, and observing measured EDB concentrations in the EDB plume. To date, no action whatsoever has been taken to contain or halt EDB's movement towards our nearest municipal wells.
For 15 years, as Councilor Rey Garduno put it: “not a gallon of jet fuel has been removed from the aquifer.” Councilor O’Malley stated, “We cannot afford to lose 20% of our drinking water supply.” No action whatsoever has been taken to remove EDB from the aquifer, and contain or halt EDB's movement towards our nearest municipal wells.
Planning and installation of these wells began in 2010, and ended in the fall of 2012. During this time, NMED and KAFB's most urgent purpose was simply to find the "outer edge", now known to be well over a mile from it's beginning point below the Bulk Fuel Facility (BFF). Only three off base monitoring wells installed by KAFB/SHAW are located to the north of known EDB contamination but it cannot be determined where the EDB plume front is. The EDB plume location delineated on a Kirtland map to the northeast is entirely speculative. Current estimates conclude the plume's north-eastern most edge is +/- 3500 ft. from the Ridgecrest 5 production well.
NMED directed Kirtland over 2 years ago to install over 30 monitoring wells in this uncharacterized area: to date, these wells have not been installed and NMED has not exercised its authority to enforce an order for installation. In the almost 2 years since the last monitoring well was installed, Kirtland has denied the need for and refused to install monitoring wells between EDB's outer edge and Ridgecrest 5. Kirtland's environmental engineer stated the reasons:
- The Air Force did not have sufficient budgeting to pay for them
- The Air Force "did not think" they were necessary.
In November 2012, WUA passed a resolution: R-12-14, written by CANM's Dave McCoy and sponsored by WUA Commissioner Rey Garduno, asking for monitoring wells in close proximity to the Ridgecrest wells. Kirtland has never planned, or installed any of these monitoring wells.
Citizen Action, our world class technical advisors, and many experienced experts in remediation and aquifer hydro-geology have repeatedly said for many years, given Ridgecrest 5 (and 3) 10 million gallon per day production, EDB will inevitably be "pulled" towards these municipal wells. It is also widely known, but never mentioned by Kirtland/SHAW in their public statements and reports that the speed at which EDB moves towards municipal wells will increase the closer it gets.
Kirtland/SHAW statements on record have never acknowledged the basic fact of water hydrology and established aquifer remediation science: one or more production wells "pulling" vast amounts of water from the aquifer will create a "sink" in the aquifer. Gravity guarantees that water surrounding this sink, will fill it. The larger the sink, the more surrounding water "drains" into the sink.
Since Ridgecrest 5 produces +/- 4.5 million gallons per day, this sink is substantial and creates a dynamic whereby water extending at least to the EDB plume's edge will "pour" towards the Ridgecrest well.
The resolution's SUMMARY item 3 acknowledges "recent data" suggesting EDB is moving "directly towards" the nearest pumping station (Ridgecrest 5). SUMMARY item 4 details long overdue action being taken by The Air Force Civil Engineering Center (AFCEC) and the U.S. Geological Survey (USGS) to install "early warning wells", conduct aquifer tests, and fill the "data gaps" needed to reliably understand how fast EDB is moving towards our nearest supply wells. These are actions that should have been done years ago by Kirtland.
The actions described in item 4 will go a long way towards providing reliable data defining the movement of EDB towards municipal wells.
- how fast: what is the "groundwater speed", and rate of acceleration the closer EDB gets to the Ridgecrest 5 "sink".
- what are the "clearest pathways" in the aquifer. The aquifer is not heterogeneous: porosity varies greatly and is minimally mapped in this area of the aquifer. The "fast pathways" must be known. The aquifer follows an ancient river bed of rock and gravel.
- determining the "force" of Ridgecrest 5's "pull" on the plume are well established science in remediation technology, never done or considered by Kirtland here. This needs to be done.
The WUA is responsible for distributing this water to residents and businesses in Albuquerque, and installing and maintaining the infrastructure to do this. WUA must test to ensure the water they deliver to us is clean and non-toxic.
The WUA is not responsible, by law or statute, for cleaning up the Kirtland fuel spill: The Air Force is responsible and the NMED must order and enforce the cleanup. WUA is spending considerable money internally and for outside contractors, during times of extended drought and constrained budgets, doing science and planning the Air Force should have been doing years ago. Albuquerque's water ratepayers and taxpayers tax dollars are beginning to bear a financial burden that should be paid for by the Air Force to protect us from the Kirtland jet fuel in our water. The Air Force must bring far greater resources and action for a cleanup effort and soon.
The activities described in the resolution in SUMMARY item 4 were initiated by WUA, not Kirtland. We are told WUA's Chairman: Mark Sanchez, took the initiative to bypass Kirtland/SHAW and get these things going. They are badly needed, and long overdue. Citizen Action recognizes and applauds WUA for these timely and much needed initiatives.
The larger Albuquerque community should support these efforts. Citizens must take action, contacting our Congressional team to obtain federal funding and action for cleanup of the jet fuel and EDB. Citizen Action and the New Mexico Legislature has strongly recommended the New Mexico Congressional delegation obtain the formation of an independent scientific task force to review the jet fuel spill for recommendations for immediate emergency measures and long term remedies.
