Kirtland AFB Discovered Leaking Jet Fuel Earlier Than 1999

Then Failed to Investigate and Remediate --

 

Report Prepared for Citizen Action New Mexico

by Dave McCoy, Esq., Executive Director

July 2013

 

SUMMARY

 

Kirtland Air Force Base spokespeople and Pentagon Air Force top brass have repeatedly misinformed the public and media about when problems at the Bulk Fuels Facility^[1] were first known. Documentation of waivers for pipeline testing, obtained under the Freedom of Information Act, reveal that the AF knew much earlier than 1999[2] that jet fuel was leaking at the fuels facility, that the pipelines could not meet safety requirements and needed repairs/replacement.  

• In 1985 Kirtland knew fuel facility pipeline tests would fail if conducted. The AF issued a waiver for the 5 year pressure test because the pipelines did not meet AF requirements. Pipelines were not repaired and annually tested as ordered in the waiver. (See Attachment).
• The Air Force knew the fuel facility was leaking in 1992^[3] from a location identified as pump house Bldg 1033 and from contamination at a nearby evaporation pond; other pipelines were leaking elsewhere at Kirtland. (See pp. 3-5).
• In 1994 the AF issued waivers for both the 5 year pressure test and the annual pipeline testing because it was known that pipeline valves would fail. Replacement and repair of defective valves and piping was not done. The 1994 waivers described pipeline testing as “impossible.” (See p. 3 and Attachment).
• Kirtland’s claim that it did not know the aquifer was contaminated until 2007 is false. (p. 4)
• Kirtland knew from a feature on a 1951 aerial photograph that the historical fuel offloading/dispensing location showed soil contamination;^[4]
• Soil levels of diesel fuel were so high at the fuels facility offloading rack (ST-106) that the risk of an explosion existed from drilling monitoring wells. (See p. 5).   
• Kirtland has repeatedly not complied with New Mexico Environment Department orders to determine the magnitude of the leak, how far and how fast it is traveling. (Pp.3-4, 8, 9-10).
• Kirtland has no plan or actions to clean up the dissolved plume of contamination, but has embarked on a public propaganda campaign that “Albuquerque drinking water remains unaffected by the fuel plume and is expected to remain so indefinitely.”[5] That scenario can only be accomplished, however, if municipal wells are shut down or the drinking water is treated.  Treatment facilities do not currently exist at the Ridgecrest municipal well locations.
• Albuquerque’s municipal wells, Kirtland’s supply wells and the Veterans Administration Hospital supply well are all at risk from the spreading plume of contamination of Ethylene Dibromide, a potent carcinogen. Military personnel, sick veterans and residents receive water from these wells. (See p. 2, 4).
• Albuquerque’s plans for furnishing another 400,000 people with water are unrealistic and improbable given drought and contamination of 30 square miles of groundwater at other Albuquerque (See p. 11- Albuquerque – Where Dreams Die Thirsty in the Desert).
• The Agency for Toxic Substances and Disease Registry 2013 report has inaccurate conclusions and recommendations based on inadequate data and errors. (See p. 12).

 

 

Kirtland failed to conduct an early and complete investigation into the leaking at the bulk fuels facility, missing an opportunity to remediate and halt the spread of a massive plume of aviation gas and jet fuel contamination that is now estimated at 24,000,000 gallons[6], the largest toxic spill into a public water supply in U.S. history. 

Mark Holmes, an Air Force project manager with Kirtland’s environmental unit stated in 2000, “I don’t think personally we’re going to find that much (that spilled).” ^[7]

 

Kirtland dragged its boots by not comprehensively investigating the integrity of the entire fuels facility for many decades and remained conveniently silent about early internal reports showing pipeline problems.  In its FOIA response, Kirtland could provide no evidence whatsoever of compliance with AF pipeline and inspection requirements in force prior to 1985. (See fn 11).  After the knowledge and waiver of pipeline defects in 1985 and leaking in 1992, more than a decade went by before Kirtland inspected the underground pipelines connecting the fuels facility pump house to the offloading rack.  This allowed the additional release and spreading of hundreds of thousands of gallons of jet fuel that could have been prevented. 

 

Had Kirtland extended its investigation from the facility’s leaking pump house to the fuels facility offloading rack[8] that were both connected by underground pipes, perhaps 20 years of the spreading off base plume of jet fuel and a 6000 ft long plume of dissolved Ethylene Dibromide (EDB) could have been prevented. Ethylene Dibromide is an exceptionally potent carcinogen with high solubility, mobility and persistence in groundwater.[9] EDB also has been found to be carcinogenic to fish (Hawkins et al. 1998). In addition to being carcinogenic, EDB causes neural tube damage in rat embryo culture (Brown-Woodman et al. 1998), and has been implicated in liver and kidney damage, and reproductive lesions such as reduced sperm levels (Scharder et al. 1988).[10]

 

Kirtland neglected for decades to make the five year pipeline integrity tests that federal law and Air Force regulations required.^[11]  Kirtland exhibited negligence per se in contaminating Albuquerque’s drinking water aquifer by ignoring and violating Air Force and federal regulations, New Mexico statutes^[12] and non-compliance with environmental clean up orders.^{[13] [14]} [15]

 

One of Kirtland’s excuses, recently concocted, for missing the largest jet fuel spill in history, is that the vacuum pipelines that sucked fuel to the pump house from the offloading rack were supposedly exempt from inspection.^[16]  Kirtland made certification under 40 CFR 270.11, which provides for criminal penalties, that the information was true, accurate and complete. The AFM 85-16 requirements for annual and 5 year inspections of pipelines applied to:

“All Air Force operated above and underground fuel piping systems at transfer operations, pumping and in-plant processing operations.” (Emphasis supplied).

 

Kirtland has provided no evidence -- in the references for the July 2011 work plan nor evidence of any written waivers in the Administrative Record or in the FOIA response -- to support or justify the failure from the 1950s until 1985 to inspect the pipelines as was required at the time by Air Force Manual 85-16.^[17] Five year hydrostatic pipeline pressure tests and annual pipeline inspections were required by Air Force Manual 85-16. 

A waiver for testing the fuels facility pipelines at Kirtland was issued based on known pipeline defects in 1985. (See attached waivers.) Evidence obtained under the Freedom of Information Act reveals that on October 22, 1985 Col. Wesley Nottingham, AF Director of Maintenance and Operations issued a waiver for the 5 year hydrostatic testing of the fuel lines (at 1½ times operating pressure).   The waiver ordered the continuance of annual pipeline testing with repair/replacement on a priority basis.  “Leaking lines are to be removed from service until repaired.”  Since it is admitted by KAFB that the lines were leaking for decades, it is evident that at least the annual inspections and repairs were not performed as required in the waivers. 

 

In June 1994 two separate waivers were granted – one for the 5-year hydrostatic test and one for the annual test requirements because the piping and valves could not be tested (see attached): 

“The reason for this request is the 1950 vintage plug valves that are presently used in this fuel system, will not positively shut off and isolate the fuel and pressure. Thereby testing is impossible.  At this time an MCP project to replace piping and valves is pending that will rectify this problem.  But until completed this situation to isolate piping due to a[n] emergency fuel spill or to perform required maintenance will exist.”

 

The requirement that “Lines with known leaks or repair requirements should be repaired prior to testing,” was contained in the 1985 and 1994 waivers.  No repairs were made.  Kirtland did not perform a hydrostatic pipeline test (at 150% of operating pressure) at the fuel facility offloading rack until 1999.  Although the fuel facility was installed in the 1950s, Kirtland claims it did not test the integrity of the pipelines for decades even though federal law required testing every five years.^[18] When Kirtland tested the fuel supply lines in 1999, pressure was lost in seconds and some 200-400 gallons of jet fuel spilled into the ground from the two, 48 year old, corroded pipelines #22 and #23. The so-called “small spill” was from Kirtland’s own testing and did not encompass the volumes already released before testing.

 

The three types of fuel handled by pipelines at the BFF were aviation gas (AvGas; high-octane gasoline), Jet Propellant-4 fuel (JP-4), and JP-8. The use of AvGas and JP-4 at Kirtland AFB was phased out in 1975 and 1993, respectively.^[19]  The presence of all three fuels in the soil shows that the leaking occurred for decades without investigation.

 

Soil samples taken in 1992 around pump house Bldg #1033, which was part of the bulk fuels facility, showed “the presence of elevated concentrations of petroleum hydrocarbons and associated compounds” that exceeded environmental limits up to 3600 times.^[20]  The pump house was about 275 ft distant from the offloading fuel rack and the areas were connected by fuel pipelines for the supply of fuel.^[21] 

 

In the early 1990s Kirtland was pumping between 20-25 million gallons of fuel per year. The soil area was visibly contaminated around pump house building #1033.  In 1993 the area of the pump house was identified as a solid waste management unit (SWMU ST-341) that required investigation.^[22] This information should reasonably have caused Kirtland to fully investigate its entire fuel facility. Federal and state law required Kirtland to determine the rate, direction and the distance that such spills travel.^[23] Until 1999, Kirtland took no steps to sample the nearby soil at the bulk fuels offloading rack area or the pipelines that delivered the fuel to the nearby pump house.

 

Kirtland was aware from visual observation and samples taken in 1992 and more than 100 soil samples taken during 1994 through 1996 that leaking was occurring in the vicinity of the pump house from a condensate holding tank and an evaporation pond.^[24] Seven years supposedly passed before Kirtland investigated or reported whether leaking was occurring around the fuel offloading racks to where the pipelines extended from the pump building.^[25] 

 

Boreholes were only drilled 12 ft deep near Building #1033.^[26]  There were “data gaps” for knowledge about the horizontal and vertical extent of the contamination.^[27] The U.S. Environmental Protection Agency (EPA) identified high levels of gasoline and diesel contamination in 1998 and stated that Kirtland needed to specify the depth to groundwater and provide more environmental information about the ST-341 pump house site.^[28]  

 

Kirtland’s claim that it did not know the aquifer was contaminated until 2007[29] is false.  In 2006 Kirtland learned from skimmer pumps that the jet fuel plume was off base at Bullhead Park.  However, the contamination of groundwater from jet fuel, including Ethylene Dibromide, was known as a threat to “receptors,” i.e., the municipal wells, five years earlier, as shown by an internal Kirtland April 1, 2002 memorandum:[30]

“Contamination exceeding WQCC standards was detected in the subsurface soil to

a depth of 300 fbgs with an areal extent of 6-7 acres. Contamination has been detected in the groundwater beneath the site at a depth of 480 fbgs, 180 feet below the vertical extent of the contamination, which also exceeds WQCC standards. The groundwater contamination was caused by downward diffusion & the soil gas to the water table.

… “The extent of the contamination is significant and continued corrective action is required. The Relative Risk Evaluation is High based on groundwater contamination and identified receptors.”  (Emphasis supplied).

 

The Veteran’s Administration Hospital supply well is nearest to the EDB plume. It lies approximately 1200 feet north of the fuels facility offloading rack and a little more than 500 ft west of the EDB plume.  In 2006 monitoring well KAFB-1064 was constructed in the VA parking lot, 200 ft away, to serve as a “sentinel” monitoring well upgradient of the VA Hospital’s production well. TPH-DRO, TPH-GRO, toluene, naphthalene, phenanthrene, nitrate, dissolved iron, and dissolved manganese were detected from the very first groundwater sample.[31] 

 

KAFB currently has shut down supply wells KAFB-15 and KAFB-16 and is not sampling them for contamination, reportedly for excessive NO_x emissions and pump failure, respectively.[32] A bent valve was found in a cylinder of the #16 pump and the cost to repair the problem is around $30,000. “Mr. Wilson had stated during his ride around inspection that he didn’t want to spend any more money on Well 16 since it is also the highest arsenic level Well KAFB operates.”  

 

The Air Force knew in the 1980s that spills and leaks were commonplace at Kirtland and other bases and highly toxic to drinking water.  Kirtland began review of waste generation sources, including the Fuels Management areas in November 1981. Underground tanks were pressure tested quarterly to find unseen leaks.[33]  Hundreds of contaminated sites were identified by the EPA at Kirtland in the 1980s and 1990s. For example, an Underground Tank Storage (UST) pipeline for intermittent vehicle refueling at a different Kirtland site had tightness tests performed in September and October 1991; results indicated that the product line from UST 58 was in a state of failure.[34] News articles in 1987 raised the issue that UST petroleum storage was a contributor to contamination at Mountain View. EPA called for sampling and hydrology evaluations to address the Mountain View problem.[35] Chemicals still remain today in the soil and aquifer at Kirtland dumps, burn pits, explosive sites, labs, radioactive training sites, septic lines, underground tanks, radioactive animal carcass pits.^[36] The Agency for Toxic Substances Disease Registry identified the problem existing at Air Force bases.^[37]

 

Kirtland also abandoned a buried 8-inch fuel line (ST-108) that supplied Aviation Gas and JP-4 to the refueling area from the pump house. The ST-108 fuel line was originally part of the Kirtland AFB Bulk Fuels Facility installed in approximately 1953.  That pipeline was part of the bulk fuels facility, 4500 ft long, and was more than 40 years old. A total of 915 gallons of fuel was later pigged and drained from the buried pipeline. It was discovered according to this document “During site preparation for the construction of a new fire station at Kirtland.”[38] The date of the fire station construction is not given. Use of the buried line was discontinued sometime in the 1980s.

 

Another version of the ST-108 pipeline: “The distribution station and a section of the southern portion of the fuel line were removed by the City of Albuquerque (COA) during taxiway construction for the Albuquerque International Sunport in 1993.” “The period of operation of the fuel line is not known, and no records exist that document either the partial removal by the COA or any tightness testing of the line.”[39] 

 

The observable stained surface soil at the ST-106 offloading rack in 1999 was from an area approximately 25 ft by 75 ft.  The ground was “saturated” with fuel so the staining did not just occur overnight and would have been observable well prior to 1999. Approximately 76 cubic yards of soil was excavated and disposed offsite in November 1999 after “discovery” of the release.^[40]

 

Kirtland found that the soil levels of diesel fuel were so high at the bulk fuels facility (ST-106) that the risk of an explosion existed from drilling. 

“Concentrations of contaminants in the vadose zone reached 100% of the lower

explosive limit during drilling activities. This required changes to drilling

techniques to minimize explosion risks. Also detected were vinyl chloride in soil gas, necessitating additional health and safety precautions.”^[41]

 

For Kirtland authorities not to have known of the spill prior to 1999 requires that fuel facility personnel were blind, had no sense of smell, or were completely indifferent to a large area of soil that was visibly stained and saturated from decades of leaking jet fuel, and; that they utterly failed to perform their regulatory duties for inspection, keeping inventory, clean up, spill prevention and response, annual reports, sampling, testing, ongoing communication with other personnel, workplace safety evaluations, emergency planning, and safety exercises. 

 

Under AF guidelines, the Key Compliance Personnel who had numerous duties to perform to keep a fuel facility safe included^[42]:

• Base Environmental Protection Committee (EPC). The EPC is usually responsible for drafting and reviewing the spill prevention and response (SPR) plan prior to its promulgation by the Base Commander and for the annual review and update of the SPR plan. Often, the EPC delegates the specific preparation of the plan to the Base Civil Engineering (BCE) for implementation by the Base Environmental Coordinator (EC). The EPC also is responsible for review and implementation of the Base Plan for recoverable and waste petroleum.
• Spill Response Team (SRT). The SRT is tasked to respond to spills when requested by an On-Scene Commander (OSC) and to perform spill containment, recovery, cleanup, disposal and restoration activities as directed by the OSC. The SRT is a multidisciplinary team often including the following persons: BCE, Base Environmental Coordinator, Bioenvironmental Engineer (BEE), Base Disaster Preparedness Officer (BDPO), Fire Chief, Security Police Chief, Public Affairs Officer (PAO), Base Fuels Flight Commander, Safety Chief, and Staff Judge Advocate (JA).
• Base Fire Department. The fire department provides support in emergency response, spill events, exercises, and fire protection activities. In addition, the department will be responsible for making periodic fire safety inspections of flammable or combustible storage and handling areas, hazardous waste storage areas, and accumulation points on the installation.
• Safety Manager. This individual is responsible for conducting workplace safety evaluations and inspections of the handling and storage of hazardous materials and waste. They will provide the appropriate manager with a report of their findings and recommended corrective actions. They are also responsible for ensuring the prompt and accurate investigation of any hazardous material mishaps that result in injury or property damage.
• Base Fuels Management Officer (BFMO). The BFMO is responsible for the safe and efficient receipt, storage, handling, issuing, and accounting of all petroleum products to include all general operations and inspections.
• The Base Civil Engineer (BCE). The BCE is responsible for the maintenance of all installed petroleum storage and dispensing systems. This responsibility often is discharged by the Liquid Fuels Maintenance (LFM) shop. The BCE also is responsible for the calibration of permanently installed meters.
• Base Environmental Coordinator (EC). The EC monitors all POL activities that may affect the environment and usually is responsible for the coordination of the EPC review and updates of the SPR plan. The EC also often coordinates the reportable spills notification of appropriate Federal and state agencies on behalf of the Base OSC. Generally the EC comes under the BCE.
• The Bioenvironmental Engineer (BEE). The BEE takes samples to determine the chemical nature, pollutant concentration, and extent of each reportable quantity spill as required for response actions and documentation.
• The Base Disaster Preparedness Officer (BDPO). The BDPO is responsible for emergency planning and training of installation disaster response forces. When appointed as Emergency Planning and Community Right-to-Know Act (EPCRA) coordinator, the BPDO will exchange emergency response plans with the LEPC and participate in LEPC meetings.

 

Could these above personnel all have failed to perform their duties, not provided written reports or observed what amounted to decades of leaking aviation gas and jet fuel?  An environmental assessment team reviewer with written questions and a checklist was tasked with: reviewing records for spills; interviewing the above fuel facility personnel for compliance with applicable standards, and; inspection of the fuels facility to see that there was compliance with environmental regulations that included:

“Verify that a file of Federal and state POL, Spill Prevention, Control, and Countermeasures (SPCC) plan (Spill Prevention), and Oil and Hazardous Substance Pollution Contingency (OHSPC) plan Regulations are maintained and kept current at the installation:

- Executive Order (EO) 12088, Federal Compliance With Pollution Standards. (1978)

- 33 CFR 153, Control of Pollution by Oil and Hazardous Substances, Discharge Removal.

- 40 CFR 110, Discharge of Oil.

- 40 CFR 112. Oil Pollution Prevention.

- 40 CFR 279, Standards for the Management of Used Oil.

- 40 CFR 300, National Oil and Hazardous Substances Pollution Contingency

Plan.

- Air Force Instruction (AFI) 23-201, Fuels Management.

- AFI 23-502, Recoverable and Unusable Liquid Petroleum Products.

- AFI 32-7044, Storage Tank Management.

- AFM 85-16, Maintenance of Petroleum Systems.

- Technical Order TO 35-1-3, 36-1-3, 37-1-1, 42B-1-1, 42B-1-23, and 00-25-172.

- applicable state and local regulations.

Verify that the Base Staff Judge Advocate reviews Federal, state, and local regulations that may affect ongoing and proposed activities and keeps the EPC informed as needed.

Verify that the installation has an appointed Fuels Environmental Coordinator.”

   

In November 1999 Kirtland informed NMED that fuel facility personnel “recently contacted” Kirtland Environmental Management about the line spill.^[43]  No date for when personnel first contacted EM was given.  What were fuel facility personnel doing in relation to the fuels facility for the decades before 1999?  Could it have been reported earlier? Was it reported earlier but just deliberately ignored? The offloading rack was in regular use and the area would have been observed on a recurring basis. The Kirtland memorandum informed NMED:

“Environmental Management was recently contacted by personnel of the KAFB Fuels Management Facility after they observed stained soils at the facilities' offloading rack. EM staff went to the site and instructed site staff to dig down to determine if the staining indicated more than just a surface spill event. The ground was found to be saturated with fuel.” (Emphasis supplied).

 

Kirtland surmised there could have been an earlier history of the lines leaking. “The primary below ground transfer pipeline (pipeline #22) had been in a state of failure for an unknown duration and therefore the total amount of fuel released is unknown.”^[44]  Upon testing Pipeline #23 the second time, “product visibly bubbled from the ground.”^[45] Both of the 48-year old pipelines “failed from corrosion” within seconds of the pressure testing. 

 

Just how Kirtland accounted for fuel inventory and loss is unexplained and conflicting.  The Air Force required fuel management accounting, including metering, for decades before Kirtland’s unexplained lack of records: “To prevent fraud, theft, and misappropriation, the organization commander manages, controls, and accounts for all fuel issued to and received in their organizational tanks.” The quantity for each tank was to be determined and a record of it kept on file for auditing purposes.[46]

 

Kirtland inventory records for the one year prior to the “spill” showed JP-8 fuel loss of 97,171 gallons for pipeline #22. However, in a November 2000 addendum to its Abatement Plan, Kirtland claimed that inventory records were only kept from 1996 forward and showed a loss of 157,353 gallons of JP-8 for a 5-year period but with no records for JP-4 fuel.^{[47] [48]}  The earlier investigation of the pump house and evaporation pond (ST-341) were later described as being “pertinent” to investigation of the pipeline leak (ST-106). 

 

NMED’s Ground Water Quality Bureau (GWQB) informed Kirtland in July 2000 that its  Abatement Plan for sampling only along pipelines #22 and #23 would not be adequate to

determine the full horizontal and vertical extent of the contamination.^[49]

 

In 2000 Kirtland claimed it would only need to spend $400,000 investigating the missing 157,000 gallons.^[50]  Ten years later on May 22, 2010, former NMED Secretary Curry announced that the cost of cleaning up the fuel leak could top $100 million. But that cost estimate was made when it was believed the leak was 8 million gallons, not the triple-sized 24 million gallon gusher estimated in 2012.^[51] The magnitude of the spill and the spread of the plume of EDB might have been significantly reduced had the pipelines been tested on the five year schedule.^[52] 

 

After decades of purportedly failing to inspect the bulk fuels facility‘s components, in 2012 Kirtland could confirm with conviction its ignorance about the source(s) and timing for the jet fuel and aviation gasoline spills:

“The exact history of releases is unknown. Conceptually, releases could have occurred when fuel was transferred from railcars, through the fuel offloading rack (FFOR), to the Pump House, and then to the bulk fuel storage containers on the south end of the site (aboveground storage tanks [ASTs] 2420 and 2422).”^[53]

 

In 2002 NMED again criticized the investigation of the pump house contamination (ST-341) as being inadequate for the plan to locate the bottom of the plume of contamination.^[54]

 

Perhaps the concept of “plume boundaries” related to differing source areas of contamination at Kirtland and Sandia Labs needs re-examining.  Should the concept instead be more along the lines of “contamination without borders?”  A total of more than 560 sites of contamination were identified at Sandia Labs and Kirtland in the presence of a very large and mobile aquifer. 

 

Despite Sandia Labs and Kirtland’s possession of some of the most powerful computers in the world, no real time three-dimensional model for the aquifer and contamination movement exists at present.  Groundwater analysis by boreholes and monitoring wells has not been adequate to convey a full picture of the complex relation between past and present contamination and potential transport between all the various sites where releases occurred at Kirtland and Sandia Labs.^[55]  

 

In 2004 CH2M Hill estimated that the prospects for bioremediation of the jet fuel were “not significant:”^[56]

“Because of the depth of the contamination, the lack of oxygen, and the lack of moisture in much of the Kirtland AFB subsurface soils, the reduction in contaminant concentrations by biodegradation would not be expected to be significant (USAF, 200l b).”

 

Despite insignificant prospects for bioremediation, in March 2011, the Air Force Report to Congressional Committees was that: “Using natural processes without further active treatment, modeling indicates that the dissolved constituents would meet drinking water standards by 2025.”^[57] Of course that modeling estimate was made before NMED announced that the spill is three times as large as it was thought to be in 2011. NMED later informed Kirtland that EDB does not naturally biodegrade.^[58]  Estimates for the arrival time of EDB at the municipal wells is between less than 5 to 10 years.  Maps for the extent of the EDB plume are only drawn to show where the EPA drinking water limit is (50 parts per trillion), not where the laboratory limit of detection is (10 ppt).  This makes the EDB plume map appear smaller than it really is. 

 

Beginning in 2004, Kirtland claimed that soil vapor evaporation (SVE) technology would clean up any remaining contamination at the bulk fuels facility within 3 years with no further action necessary.^[59] Between 2004 and 2009, Kirtland only installed four SVE units, an insufficient number of units for the area of contamination. As explained above, Kirtland knew in 2002 that the jet fuel was already in the aquifer. Kirtland misinformed the public that SVE technology would solve the problem, despite EPA statements in 1994 that SVE could only treat unsaturated zones and was not effective treatment for diesel fuels and ethylene dibromide that do not readily volatilize.^[60] 

 

In 2009, the NMED Ground Water Quality Bureau (GWQB) demanded that Kirtland take remediation activities at the “soonest practicable juncture.” The GWQB rejected Kirtland’s plan for a three-year delay after investigation to commence the full-scale abatement of off-base remediation of dissolved ground water contamination.^[61] NMED also disapproved of the phased approach to implementing an interim measure to contain the fuel plume and directed the Air Force to install 16 SVE wells with internal-combustion engine (ICE) vacuum units to contain the fuel plume.^[62] Kirtland refused to operate more than the original 4 SVE units that were at times placed inefficiently or shut down for months and with deferred maintenance. The four units were indefinitely shutdown in December 2012. 

 

On April 2, 2010, the GWQB transferred the jet fuel spill to the Hazardous Waste Bureau (HWB) harshly admonishing Kirtland that:

“KAFB has not complied with the requirements of the GWQB's first and second Notices of Deficiencies (NODs). KAFB has failed to provide an interim work plan with specific dates for task completion, or a revised timeline that provides for the investigation and abatement of off-base plumes in a reasonable time frame. Additionally, KAFB's December 30, 2009 letter indicates that it will not be moving expeditiously to begin active remediation of off-base contamination. Given the scope and severity of the contamination plume, KAFB's proposed approach is not acceptable.”^[63]

 

The orders of the HWB have been largely ignored as well.  The Air Force ignored four NMED orders beginning in April 2, 2010 to produce an Interim Measures (IM) Work Plan that would bring about full remediation of the LNAPL plume within 5 years.^[64] No IM plan providing remediation other than the use of SVE has been submitted by the Air Force. A plan for a containment well was only partially approved by NMED because it could make the plume travel further toward the northeast where municipal wells are located:

“NMED staff said that the light non aqueous phase liquid (LNAPL) containment well that was drilled to stop the forward movement of the fuel product floating on the water table have been delayed due to some concerns raised at the NMED that the wells may act to pull the LNAPL plume further downgradient, rather than halt its movement. NMED staff told the board that the three concerns they have for the status of this site is the data gap that exists for the extent of the dissolved phase plume, the existence of ethylene dibromide (EDB) above the drinking water standards at all depths, and the evidence of a “diving” EDB at the farthest reach of the dissolved phase plume.^[65]

 

The first off base monitoring wells were not drilled until 2010, eighteen years after leaking was discovered at the fuels facility.  Three new clusters of monitoring wells installed northeast of the EDB plume in 2012, have not detected contamination.  Some see that as a hopeful sign and count on many more years before the EDB plume may reach municipal wells.^[66]  However, the plume is still moving at an unknown velocity.  Monitoring Well KAFB-10615 detected ethylene dibromide (EDB) in 3^rd Quarter 2012 sampling at a concentration of 0.075 micrograms per liter (μg/L); that is 1½ times the EPA drinking water limit.^[67] That monitoring location, which lies southeast of Gibson and Louisiana, signals a possible widening of the EDB plume to the east by nearly 1000 ft.  A lithographic depiction of monitoring wells from the 4^th Q Report shows the presence of EDB at the outer toe of the plume at a 100 ft depth that is attributed to the “pull” of the Ridgecrest municipal wells.  The flow velocity of the plume will continue to accelerate as it draws nearer to the municipal wells. The flow velocity still has not been calculated, according to NMED.[68]

 

Shaw Environmental is informing regulators and the public in 2013 that the LNAPL plume is “stable.” NMED isn’t buying the stability story and points to the conflicting language in Kirtland’s own technical reports saying that “stability” doesn‘t mean the plume isn‘t still moving.  NMED further challenges Kirtland’s claims about bioremediation of the plume and states ^[69]:

“The fact that EDB is not naturally attenuating or biodegrading indicates that this particular compound is not part of a stable plume.” 

 

Shaw reported that the jet fuel became trapped beneath a rising water table due to conservation efforts. The trapped jet fuel will be “an ongoing source of dissolved groundwater contamination indefinitely.”^[70]

 

The Albuquerque Bernalillo County Water Utility passed resolutions in 2012 seeking to accelerate the timetable to December 2013 for producing a plan for remediation.^[71]

 

Now, 20 years after discovering contamination at the fuel facility, Kirtland still has not determined the flow velocity nor the full lateral and vertical extent of the dissolved plume of ethylene dibromide that has traveled more than 6000 feet from the fuel facility toward  Albuquerque‘s municipal wells.^[72]  Nor has Kirtland offered any comprehensive work plan to remediate or halt the spreading plume of cancer-causing ethylene dibromide headed for Albuquerque‘s municipal drinking water wells.^{[73] [74]}

 

Kirtland’s continuing mantra that it “owns the problem” provides no real relief, especially since the Air Force only sees a duty to keep the level of contamination in the drinking water below the maximum limits imposed by the EPA.  Because EDB is classified as a probable human carcinogen, as a matter of public policy, EPA sets the recommended level at zero. The allowable limit in New Mexico is 50 parts per trillion but only 10 ppt in California and Massachusetts.  Why should residents feel secure if the water only contains 49 parts per million of EDB at the tap?

 

The challenge that the best remediation companies seem to have with the Kirtland site is addressing the contractual relationship with the Air Force.  These companies are unwilling to engage in a pay for performance contract with the Air Force. The contracting terms are too uncertain and the cost to apply for one of these contracts is unreasonable. Hence the public gets second rate companies, as Shaw Environmental, now acquired by CB&I,[75] has proven to be. 

 

Albuquerque -- Where Dreams Die Thirsty in the Desert

 

Albuquerque Water Supplies-- Pipe Dream or Wet Dream?

 

The Water Utility Authority claims that there is sustainable water supply until 2050 for another 400,000 more people in Albuquerque (ABQ), giving ABQ a population of over 1 million.^[76] Where will the water come from?^[77]  The City of Albuquerque currently delivers roughly 35 billion gallons of water annually. Another 400,000 people will require an additional 12 billion gallons more than Albuquerque currently produces.  The shortfall of water that ABQ can get from its allotment from the San Juan Chama diversion on the Rio Grande is approximately 3.3 billion gallons annually.  But can that difference be made up from increased ground water pumping? 

 

It can quickly be realized that Albuquerque may exceed the limits to growth that will be imposed by the Rio Grande and groundwater shortages from severe drought, loss of watershed due to fires and a poisoned aquifer. Given the drought, the major source of drinking water is the groundwater.  It is not being protected from contamination.  As NMED puts it:^[78]

“The [Kirtland Air Force Base] Bulk Fuels Facility Spill is the most significant groundwater contamination site in New Mexico because of contaminant types and concentrations, and the plume’s proximity to water supply wells serving the most populated community in the state.”

 

The Ridgecrest municipal wells that are the largest providers of groundwater for ABQ are threatened with a plume of Ethylene Dibromide (EDB) coming from the 24,000,000 gallon jet fuel and aviation gas release at Kirtland AFB. The EDB alone has the potential to contaminate trillions of gallons of groundwater.  Increased groundwater pumping can accelerate the movement of contamination from Kirtland AFB toward municipal wells.  

 

Three Superfund sites already exist in Albuquerque-- the South Valley Superfund Site, the AT&SF, and the Fruit Avenue Plume.^[79]  Many other contaminated sites exist in Albuquerque.[80]

 

The Agency for Toxic Substances and Disease Control Registry (ATSDR) provided the following public health assessment regarding unhealthful groundwater resources and that did not include the Kirtland jet fuel gusher:[81]

“In Albuquerque and Bernalillo County, over 150 documented ground-water contamination events have contaminated vast amounts of ground water, its quality degraded to an extent that affects its usefulness as drinking water. More than 20 of these cases may reach Environmental Protection Agency Superfund National Priorities List. The New Mexico Environmental Improvement Department (NMEID) estimates that, so far, this pollution has affected about 20 public supply wells and 450 private wells in Bernalillo County. As much as 30 square miles of land area may overlie contaminated ground-water supplies. Septic-tank systems, underground storage tanks, landfills, industrial facilities, and releases of hazardous materials from other sources caused this pollution.”

 

A July 12, 2013 ATSDR Evaluation of Potential Exposures: Bulk Fuels Facility Groundwater Plume[82] for Albuquerque concludes:

 

“There are no past, present, or expected future exposures via the groundwater (down-gradient water supply wells) pathway. BFF-related contaminants have not been detected in the water supply wells. Although it is expected that BFF contaminants would eventually migrate downgradient to water supply wells in the absence of remedial or contingency actions, such actions are already occurring and will be upgraded in the near future (Shaw, 2012c).”

 

The ATSDR conclusions that alternate supplies of water will be found and that effective remediation of EDB contamination will occur are speculative at best and based on errors.  There is no plan or ongoing remediation of the dissolved plume of LNAPL and EDB. The bulk of the LNAPL is trapped beneath the water table and cannot be removed with SVE technology.  Thinking that 24,000,000 gallons of jet fuel in the aquifer is not a crisis is not justifiable given the unknowns and the AF track record of contaminating other communities’ drinking water. The efficacy of removal technology is in serious doubt as there is currently no utilization of any technology by Shaw that will contain the plume trapped beneath the groundwater table and that has moved off base. The report does not mention that KAFB supply wells #15 and #16 are now shut down and are no longer being monitored for EDB contamination.  SVE is not effective for groundwater removal of EDB which is not readily volatile.  SVE equipment was shut down in December 2012.  Also, the edge of the plume is unknown, the velocity is unknown, the amount of contamination in the vadose zone is unknown, and the monitoring wells that were supposed to be placed near the municipal wells are not in place as per WUA resolutions. The new USGS well is 2000 ft away. The existence of an "alternate" source of water is not identified at present and there are about 30 square miles of contaminated groundwater in ABQ not counting KAFB and Sandia. 

The ATSDR remedy for protection, shutdown of the Ridgecrest municpal wells, ignores the 45+ wells to the north of Ridgecrest that will still create a cone of depression for further travel of EDB to additional wells. 

 

EPA, out of political deference to the Governor, Air Force and developers, has not placed the jet fuel spill on the National Priorities List[83] or imposed emergency cleanup action although the jet fuel contamination clearly meets all the necessary requirements as the largest underground toxic spill threatening a municipal water supply. 

 

Nitrate and TCE contamination are in numerous other locations at Kirtland and Sandia National Laboratories. Kirtland’s unlined dumps often contain dozens of organic solvents that lie above Albuquerque’s aquifer.[84] Some dumps contained for example, radioactive isotopes such as Cesium-137, Plutonium-239 along with irradiated animal carcasses placed in plastic bags in dirt trenches.[85] Decisions for leaving wastes in place have been made on computer modeling results instead of requiring accurate water quality data from a reliable network of monitoring wells.[86]

 

The Water Utility Authority and NMED refuse to request Sandia Labs to clean up the Mixed Waste Landfill with 1,500,000 cu ft of radioactive and hazardous waste leaking into the aquifer. No clean up is underway for the Tijeras Arroyo area with contaminated groundwater from TCE and nitrates.  A large nitrate plume is present in much of the same area where the EDB plume is located.

 

The Office of the State Engineer/Interstate Stream Commission (OSE/ISC) informed the NM State Legislature in a report for a funding request to update the lower Rio Grande regional water plan that:[87]

“OSE/ISC concludes as more time passes, and water problems increase in magnitude statewide, existing regional water plans are outdated and useless in addressing emerging water crises.”(Emphasis supplied).

 

The rosy Water Utility Authority estimate for servicing increased population growth does not take into consideration such factors as: reductions in SJC water, unsettled Navajo river claims, reduction in river water from groundwater mining, extensive contamination of the groundwater aquifer, changing climate, drought and loss of watershed from fire, shortages for agriculture, endangered species requirements (silvery minnow), accelerated runoff from urban growth and arsenic levels that must be diluted.[88]  The estimate does not identify the future growth already on the planning books that has not been supplied, nor does it show the levels of growth that may be applied for in the future.[89] 

 In 2013 water diverted from the Rio Grande is being halted for four months due to drought conditions.[90] Eleven thousand farmers will not receive Rio Grande water.  That means mining more groundwater sources and that means even less groundwater entering the Rio Grande. 

 

Example, the Mesa del Sol residential development will have 35,000 homes with another 100,000 residents that need water.  Residential usage (average 150 gallons per day per capita) X (100,000 planned residents) X (365 days) will require an additional delivery of 5,475,000,000 gallons per year (16,800 afy) just for Mesa del Sol. Add to Mesa del Sol’s water consumption the numerous other large scale real estate developments planned for Albuquerque for more hundreds of thousands people.^[91] Forest City is bailing out of its investment in Mesa del Sol.[92]  

 

Kirtland has an infrastructure to supply 2 billion gallons of water annually.  If KAFB supply wells become contaminated or shut down, Kirtland will seek water from the city. Sandia Labs uses over 555,000,000 gallons annually supplied by Kirtland’s infrastructure. 

 

Albuquerque’s fantasy of unlimited growth may soon have a sharp collision with reality and the existing businesses, homeowners, residents and fish that are demanding the supply of plentiful and clean water.  Watch for spiraling water rates from water scarcity induced by overdevelopment and poor political land use planning.  Contaminated drinking water from Kirtland could result in a crush of homeowners seeking to sell real estate at rock bottom prices.

 

 

Dave McCoy, Esq. Executive Director

Citizen Action New Mexico

This email address is being protected from spambots. You need JavaScript enabled to view it.

505 262-1862

 

ATTACHMENTS

 

 

 

 

 

 

 

 

 

REFERENCES

 

^[1] https://kirtlandafb.tlisolutions.com/sitedocs/PDFS/33/3382.PDF , p.1-1 Comprehensive Site Evaluation of Bulk Fuels Area, September 2004. “The ‘Bulk Fuels Facility’ refers to a group of buildings, piping and associated appurtenances used to store and transfer jet fuel from tankers and rail cars to the flight line at Kirtland AFB. The JP-4, JP-8, and AVGAS were pumped from the tanker trucks through the offloading rack (Building 2405) to a pump house (Building 1033) under suction via two 14-inch-diameter underground transfer lines. The fuel was then pumped under pressure to the aboveground storage tanks through underground and above ground piping of varying diameters.”

[2] http://www.kirtland.af.mil/shared/media/document/AFD-080731-037.pdf, p.1. Kirtland AFB Fuel Leak Public Meeting July 31, 2008

^[3]  https://kirtlandafb.tlisolutions.com/sitedocs/PDFS/00/35.PDF , FINAL NON-WASTE LINE INVESTIGATION WORK PLAN, May 1994, p. 16-1:“During a previous base environmental compliance and monitoring program inspection, a spill was observed near the UST standpipe. In December 1992, Kirtland AFB Compliance and Assessment personnel collected a soil sample near the suspected spill area. The sample was analyzed according to EPA Methods 8020 and 418.1 and contained petroleum hydrocarbons, ethylbenzene, toluene, and xylenes. The site was revisited on March 3, 1993 by Kirtland AFB personnel. Shallow soil samples (6 to 7 inches below grade) were collected at four locations in the spill area. Hydrocarbon odors were noted at all sample locations and Kirtland AFB personnel reported a small area of surface soil contamination around the base of the UST Stand pipe and extending a few feet west. Based on this information and previous analytical results, the Condensate Holding Tank was added as a SWMU to the RCRA Part B Permit.”

^[4] https://kirtlandafb.tlisolutions.com/sitedocs/PDFS/31%5C3159.PDF , 3/9/2007 NMED letter to Carl J. Lanz, P.G., p. 2, Item 3. “A plan to assess soil contamination near the historical fuel offloading/dispensing feature identified in the 1951 aerial photograph nearest the KAFB-1065 well …”

[5] http://www.kirtland.af.mil/shared/media/document/AFD-130212-025.pdf Bulk Fuels Facility Project Update February 8, 2013

[6] http://www.huffingtonpost.com/2012/07/20/kirtland-air-force-base-fuel-spill_n_1688603.html Kirtland Air Force Base Jet Fuel Spill Threatens Albuquerque Water Supply 07/20/2012

^[7]  See ABQ Journal, John Fleck, http://www.abqjournal.com/main/2012/06/21/blogs/nm-science/the-very-first-kirtland-fuel-spill-story.html

[8] https://kirtlandafb.tlisolutions.com/sitedocs/CABMeetings/Documents/CAB%20Meeting.test.pdf See p. 11, photo of offloading rack.

[9] Ethylene Dibromide and 1,2-Dichloroethane Contamination from Leaded Gasoline Releases, Ronald W. Falta, p.1 http://webcache.googleusercontent.com/search?q=cache:LbZzwu1R6DIJ:info.ngwa.org/gwol/pdf/041980217.pdf+Ethylene+Dibromide+and+1,2-Dichloroethane+Contamination+from+Leaded+Gasoline+Releases,+Ronald+W.+Falta&cd=1&hl=en&ct=clnk&gl=us

[10] http://water.usgs.gov/wrri/00grants/NMaquifers.pdf  Genetic Techniques for the Verification and Monitoring of Dihaloethane Biodegradation in New Mexico Aquifers, Dr. Rebecca Reiss (2001).

 Fresh water supplies throughout the world are threatened by the release of the dihaloethanes 1,2-dibromoethane (EDB) and 1,2-dichloroethane (EDC).  In New Mexico, approximately 175 locations have or have had EDB or EDC contaminated soil and groundwater, our primary drinking water source.

^[11] AFMAN 85-16, Maintenance of Petroleum System, 15 March 1956, 18 August 1981. Superseded by AFMAN 32-1275 http://www.wbdg.org/ccb/DOD/UFC/ufc_3_460_03.pdf, UNIFIED FACILITIES CRITERIA (UFC) OPERATION AND MAINTENANCE: MAINTENANCE OF PETROLEUM SYSTEMS Section 2.3 Maintenance of On Base Pipelines. “2.3.3.2. Five-Year Hydrostatic Test. Perform a hydrostatic pressure test every five years on all

underground fuel transfer pipelines (product is typically the test media for this test).”

See AFM 85-16 requirements at: http://www.dtic.mil/cgi-bin/GetTRDoc?AD=ADA297390 The Environmental Compliance Assessment and Management (ECAMP) Supplement for The Environmental Assessment Program and Management (TEAM) Guide, p. 8-15 “Air Force operated offsite pipelines should be inspected at least once per week by air patrol, and once a year by line walker or vehicle patrol. All Air Force operated above and underground fuel piping systems at transfer operations, pumping and in-plant processing operations should be managed according to specific parameters. All underground aviation fuel transfer pipelines should be subject to a hydrostatic pressure test on a 5-yr reoccurring basis.” (Emphasis supplied).

^[12] http://wrri.nmsu.edu/publish/watcon/proc32/Goad.pdf Historical Overview of New Mexico Ground Water Protection Programs, Maxine Goad, p. 36-37 -- Burden of proof is upon discharger to demonstrate discharge would not pollute the groundwater. See, http://lawlibrary.unm.edu/nrj/19/3/12_whitham_newmexico.pdf Bokum Resources Corp., et. al. v. New Mexico Water Quality Control Commission, no. 2869 (Ct. App. 1978).

^[13] http://elr.info/sites/default/files/litigation/17.21178.htm  Clark v. United States No. C85-97TB (660 F. Supp. 1164) (W.D. Wash. April 20, 1987) McChord AF base held liable for negligence and emotional distress for TCE contamination of drinking water wells.  TCE leached from AF golf course in Washington. AF negligence caused diminution in value of plaintiff’s property.

^[14] http://www.nmenv.state.nm.us/HWB/documents/KAFB_4-2-2010_Bulk_Fuel_Spill_GWQB_Letter.pdf; http://www.nmenv.state.nm.us/HWB/documents/KAFB_4-2-2010_Bulk_Fuel_Spill_GWQB_Letter.PDF; http://www.nmenv.state.nm.us/HWB/documents/KAFB_4-2-2010_Bulk_Fuel_Spill_HWB_Letter.PDF; ftp://ftp.nmenv.state.nm.us/hwbdocs/HWB/KAFB/Bulk_Fuels_Facility_Spill/KAFB_8-6-2010_Fuel_Spill_NOD_and_Direction.pdf

[15] http://www.nmenv.state.nm.us/HWB/documents/KAFB-12-024_5-23-2013_Disapproval_SVE_Treatment_System_WP.pdf

16 http://www.kirtland.af.mil/shared/media/document/AFD-110719-015.pdf Light Non-Aqueous Phase Liquid (LNAPL) Containment Interim Measure Work Plan Part 1 Characterization Plan Bulk Fuels Facility Spill Solid Waste Management Units ST-106 and SS-111 July 2011(p.3-2): “Fuel transfer from the railcars to the Pump House was done under vacuum transfers. Transfer of fuel from the Pump House to the bulk storage containers was performed under pressurized conditions. Fuel-transfer infrastructure for vacuum transfers was exempt from pressure testing, whereas fuel infrastructure for pressurized transfer did undergo regular pressure testing. Only when the vacuum portion of the fuel system underwent pressure testing in 1999 was any problem noted in the fueling system.”

^[17] See fn 11.

^[18] (Albuquerque Journal, Kirtland Jet Fuel Spill ‘Significant,’ Section E, August 5,2000).  Also see fn 15.

^[19] ftp://ftp.nmenv.state.nm.us/hwbdocs/HWB/KAFB/Bulk_Fuels_Facility_Spill/KAFB_1-3-2012_Indoor_Air_Eval_WP/KAFB-011-0060c_Indoor_Air_Pathway_WP_1-12-12_ALL_BKMKED.pdf p. 3-1

^[20] https://kirtlandafb.tlisolutions.com/sitedocs/PDFS/01/177.PDF Stage 1 Abatement Plan ST-106, Kirtland AFB Bulk Fuels Facility, April 19, 2000, p.2-4:“Diesel range organics (DROs) (5.2 to 2,000 mg/kg) were detected in 12 samples and gasoline range organics (GROs) (0.22 to 360,000 mg/kg) were detected in 16 samples. The NMED action level (100 mg/kg) was exceeded in nine samples by DROs and six samples by GRO.”  “A condensate holding tank, designated as SWMU ST-341, is located at Building 1033, which is the pump house building associated with ST-106 [the fuel offloading rack]. Several RCRA investigation phases have been conducted at the ST-341 site and data from these investigations is pertinent to the overall investigation of ST-106.”

^[21] See attached map.  Also Figure 2-1 at ftp://ftp.nmenv.state.nm.us/hwbdocs/HWB/KAFB/Bulk_Fuels_Facility_Spill/KAFB_1-27-2011_Pre-Rem_SVE_Sys_OM_WP/KAFB_010_0007_r1_Pre-Remedy_Monitor_WP_02-04-2011_BOOKMARKED.pdf

^[22] https://kirtlandafb.tlisolutions.com/sitedocs/PDFS/22/2291.PDF Legal Notice June 24, 1993 adding ST-341 condensate tank as a solid waste management unit (SWMU).

^[23] http://www.epa.gov/osw/hazard/correctiveaction/resources/guidance/sitechar/rfi/rcrav1.pdf  INTERIM FINAL RCRA FACILITY INVESTIGATION (RFI) GUIDANCE May 1989, p. 3-1 procedures designed to verify suspected releases (if necessary), and to evaluate the nature, extent, and rate of migration of verified releases.

^[24] https://kirtlandafb.tlisolutions.com/sitedocs/PDFS/02/210.PDF Phase 4 RFI Report for CAU WP-339 and Environmental Monitoring Report for CAU ST-341, CAU 8-28, and CAU 8-35 (August 21, 2001), p. 3-4, section 3.3.2.3 “3.3.2.3 Previous Investigations            “Previous investigations conducted at CAU ST-341 include Environmental Compliance Assessment Management Program (ECAMP) investigations and the Appendix III Phase 1 and Appendix III Phase 2 RFIs (USAF, 1995a and 1997). During the Appendix III Phase 1 RFI in July 1994, 29 soil samples were collected from five boreholes surrounding the holding tank, one borehole near the overflow pipe outflow, and one background borehole in an area away from any known or suspected sources of contamination.            “During the Phase 2 RFI in October and November 1996, 72 soil samples and five field replicates were collected from 16 boreholes at CAU ST-341. Four boreholes were drilled or advanced by direct-push methods near the condensate holding tank, three direct-push boreholes were advanced along the overflow pipe, and nine boreholes were advanced or drilled in and around the evaporation pond.”

^[25] https://kirtlandafb.tlisolutions.com/sitedocs/PDFS/00/20.PDF RCRA Facility Investigation Report Appendix III Non-Wasteline Sites, (October 23, 1995) p.18-1. “Analytical results from the 1992 soil sample collected near the UST standpipe indicated that petroleum hydrocarbons were present in the soil at concentrations of 7,660 mg/kg and that ethylbenzene, toluene, and xylenes were present at concentrations of 52.2, 82.4, and 338 mg/kg, respectively (USAF, 1993). A follow-up visual survey by Kirtland AFB indicated that the lateral extent of soil contamination may extend a minimum of 7 ft away from the standpipe.”  https://kirtlandafb.tlisolutions.com/sitedocs/PDFS/02/210.PDF Phase 4 RFI Report for CAU WP-339 and Environmental Monitoring Report for CAU ST-341, CAU 8-28, and CAU 8-35 (August 21,2001), p.3-4:

“The Appendix III Phase 1 RFI concluded that a contaminant release has occurred at ST-341. Petroleum hydrocarbon contamination extended to at least 12 ft below ground surface (bgs) near the holding tank and 58 ft bgs at the evaporation pond. Additional work was recommended to fully characterize the degree and extent of contamination at the site. …

“The Appendix III Phase 2 RFI also recommended that additional sampling be done near borehole ST-341-09 to determine the nature and extent of SVOC contamination. None of the previous investigations addressed potentially contaminated groundwater in the regional aquifer or in any perched groundwater.”

^[26] https://kirtlandafb.tlisolutions.com/sitedocs/PDFS/00/20.PDF RCRA Facility Investigation Report Appendix III Non-Wasteline Sites DRAFT FINAL (October 23, 1995) p. 18-4.

^[27] https://kirtlandafb.tlisolutions.com/sitedocs/PDFS/00/35.PDF FINAL NON-WASTE LINE INVESTIGATION WORK PLAN (May 1994) Section “16.3 DATA GAPS Additional soil samples are necessary to define the horizontal and vertical extent of potential soil contamination at this site.”

^[28] https://kirtlandafb.tlisolutions.com/sitedocs/PDFS/11/1189.PDF EPA comment letter (July 29, 1998), p. 005-6.“SWMU ST-341, Building 1033, Condensate Holding Tank (ST-341)The Appendix HI investigation revealed high levels of gasoline range organics (GROs) (up to 360,000 ppm) in seven boreholes. Diesel Range Organics (DROs) were also detected at high concentrations in eight boreholes. Four SVOCs were detected at concentrations exceed human health screening levels. The Phase 2 investigation included the completion of eight Geoprobe and eight hollow-stem auger boreholes. 1,1,2,2-tetrachloroethane was detected above the screening level. One Semi-Volatile Organic Compound, benzo(a)pyrene, exceeded the screening level. DROs and GROs (up to 12,000 ppm) exceeded the state UST action level to 35-37 feet below grade at the holding tank, and to 65-67 feet below grade at the evaporation pond. Jet fuel A is believed to be the predominant petroleum hydrocarbon at this site. The depth to groundwater at this site is not specified, nor is any information given concerning the proximity of this site to arroyos, etc. Kirtland should present more information on the environmental setting of this site. EPA concurs with Kirtland's recommendation that a CMS should be completed for this site. Further sampling in the vicinity of borehole ST-341-09 should also be conducted. Additionally, the extent of contamination to the east of the condensate holding tank should be determined.”

[29]  http://www.kirtland.af.mil/shared/media/document/afd-080825-042.pdf  Questions and Answers

for Fuel Leak Public Meeting: “In early 2007, the well was installed and the fuel product discovered on the groundwater.”

[30] https://kirtlandafb.tlisolutions.com/sitedocs/PDFS/23/2345.PDF

[31] https://kirtlandafb.tlisolutions.net/sitedocs/PDFS/29%5C2917.PDF p. ES-1; See also http://newmexicomercury.com/blog/comments/what_are_our_troops_and_their_families_drinking_at_kirtland_air_force_base

[32] http://www.nmenv.state.nm.us/HWB/documents/KAFB_6-19-2013_BFFS_Weekly_Activity_Report.pdf

[33] https://kirtlandafb.tlisolutions.com/sitedocs/PDFS/00/14.PDF , p.ii and p. 4-22.

[34] https://kirtlandafb.tlisolutions.com/sitedocs/PDFS/02/0280.PDF

[35] https://kirtlandafb.tlisolutions.com/sitedocs/PDFS/17/1741.PDF EPA letter

^[36] https://kirtlandafb.tlisolutions.com/sitedocs/PDFS/01%5C144.PDF, Supplemental Information and Site Summary Report for SWMUs Recommended for No Further Action (April 1999) p.5 and 6. https://kirtlandafb.tlisolutions.net/sitedocs/PDFS/16%5C1651.PDF

^[37] See Agency for Toxic Substances and Disease Registry http://www.atsdr.cdc.gov/toxprofiles/tp76-c5.pdf  -- “JP-4 and JP-7 may be released into groundwaters as a result of seepage from contaminated soils during storage, aircraft maintenance, and fuel storage and dispensing operations (Twenter et al. 1985). A fuel layer of approximately 2 feet was identified in groundwater from shallow wells at Robins Air Force Base (Georgia) on a site where an undetermined amount of JP-4 was released into the soil from an underground fuel supply line in the 1960s (Air Force 1985a).

[38] https://kirtlandafb.tlisolutions.com/sitedocs/PDFS/04%5C459.PDF

[39] https://kirtlandafb.tlisolutions.com/sitedocs/PDFS/02/213.PDF Section 4.1.1

^[40] https://kirtlandafb.tlisolutions.com/sitedocs/PDFS/33%5C3382.PDF

^[41] https://kirtlandafb.tlisolutions.net/sitedocs/PDFS/16%5C1651.PDF Quarterly Report June 2003, p. 13.

^[42] http://www.dtic.mil/cgi-bin/GetTRDoc?AD=ADA297390 The Environmental Compliance Assessment and Management (ECAMP) Supplement for The Environmental Assessment Program and Management (TEAM) Guide (1995) p. 8-1 to 8-2.

^[43] https://kirtlandafb.tlisolutions.com/sitedocs/PDFS/12/1256.PDF Newly ldentified Area of Concern (AOC) Fuel Offloading Rack and http://www.nmenv.state.nm.us/HWB/documents/KAFB_7-20-2000_Additional_Stage_1_AP_reqts_ST-106.pdf

^[44] http://www.kirtland.af.mil/shared/media/document/AFD-110719-015.pdf Light Non-Aqueous Phase Liquid (LNAPL) Containment Interim Measure Work Plan Part 1 Characterization Plan Bulk Fuels Facility Spill Solid Waste Management Units ST-106 and SS-111 (July 2011), p.4-6.

^[45] http://www.nmenv.state.nm.us/HWB/documents/KAFB_11-19-1999_Memo_Failure_Offloading_Pipeline.pdf  And look at the pictures!!

[46] http://webapp1.dlib.indiana.edu/cgi-bin/virtcdlib/index.cgi/821003/FID2/pubs/af/23/afi23-204/afi23-204.pdf

^[47] “While fuel tanks now have gauges and modern technology that allow officials to more closely monitor how much fuel goes in and out, Kirtland civil engineer Brent Wilson says the leak dates back to the days when ‘the way to measure was to take a long stick and dip into the tank.”  (Mr. Wilson fails to explain how personnel would dip a stick into a tank containing more than a million gallons of fuel).  http://www.huffingtonpost.com/2012/07/20/kirtland-air-force-base-fuel-spill_n_1688603.html

^[48] http://www.nmenv.state.nm.us/HWB/documents/KAFB_11-16-2000_Cond_Appr_Add_Stage_1_AP_ST-106.pdf p. 1-2 NMED letter for Conditional Approval of Addendum to Stage 1 Abatement Plan ST-106 (November 16, 2000)

^[49] http://www.nmenv.state.nm.us/HWB/documents/KAFB_7-20-2000_Additional_Stage_1_AP_reqts_ST-106.pdf  Additional Requirements for Stage 1 Abatement Plan: “KAFB must determine the full vertical and horizontal extent of the JP-8 discharges reported in November 1999.  Especially in the area of of pipelines #22 and #23, sampling only along the ppeline may not be sufficient to define the full 3-D extent of the contamination.  The reason for this condition is to comply with 20 NMAC 6.2.4106.C.2.”

^[50] Albuquerque Journal, Kirtland Jet Fuel Spill ‘Significant,’ Section E, August 5,(2000).  

^[51] http://www.huffingtonpost.com/2012/05/23/kirtland-air-force-base-spill_n_1537913.html

^[52] ABQ Journal, Overdue Test Finds Kirtland Fuel Leak, p.A8 (8/8/2000).

^[53] http://www.kirtlandjetfuelremediation.com/articles/KAFB-012-0035c_Phase_II_Remed_IM_Plan.pdf p. 1-2

^[54] https://kirtlandafb.tlisolutions.com/sitedocs/PDFS/15/1528.PDF “However, the sampling program should also include the goal of tagging the bottom of the plume to determine whether or not measurable contamination migration has occurred since plume boundaries were determined during earlier project phases. The current extent of the TPH plume at both site locations should be adequately defined.”

^[55] http://www.nmlegis.gov/lcs/handouts/WNR%20110812%205.%20Paul%20Robinson%20KAFB-SNL%20G'water%20Contamination.pdf

^[56]Comprehensive Site Evaluation of Bulk Fuels Area 4-3 September2004 https://kirtlandafb.tlisolutions.com/sitedocs/PDFS/33%5C3382.PDF SECTION 4, p.4-3

^[57] http://www.kirtland.af.mil/shared/media/document/AFD-110412-031.pdf , p.4.

^[58] http://www.nmenv.state.nm.us/HWB/documents/KAFB-12-026_3-27-2012_BFFS_In-well_treatment_disapproval.pdf

^[59] https://kirtlandafb.tlisolutions.com/sitedocs/PDFS/33/3382.PDF “CH2M Hill implemented a full-scale SVE system at ST-106 this summer after pilot testing achieved effective removal of fuel contamination at this site. It is anticipated that this SVE system, possibly with modifications, will address any remaining contamination and that No Further Action (NFA) status could be obtained within the next 3 years as the remedy nears completion.”

^[60] http://www.epa.gov/oust/pubs/tum_ch2.pdf, p. II-3

^[61] June 23, 2009 Ground Water Bureau letter https://kirtlandafb.tlisolutions.com/sitedocs/PDFS/34/3402.PDF “3. NMED expects that off-base remediation activities, including both LNAPL recovery and dissolved-phase ground water remedial action, will be undertaken at the soonest practicable juncture. The proposed schedule does not reasonably accomplish this goal.”

^[62] ftp://ftp.nmenv.state.nm.us/hwbdocs/HWB/KAFB/Interim_Measures_WP_Part_1-FieldInvAct_BFFS/KAFB-010-0003-r0_Int_Meas_WP_rev25_11-04-2010.pdf, p.24

^[63] https://kirtlandafb.tlisolutions.com/sitedocs/PDFS/34/3450.PDF , April 2, 2010 GWQB letter.

^[64] August 6, 2010 ftp://ftp.nmenv.state.nm.us/hwbdocs/HWB/KAFB/Bulk_Fuels_Facility_Spill/KAFB_8-6-2010_Fuel_Spill_NOD_and_Direction.pdf ;December 10, 2010ftp://ftp.nmenv.state.nm.us/hwbdocs/HWB/KAFB/Bulk_Fuels_Facility_Spill/KAFB_BFF_Workplan_Approval_with_Modifications_12-10-2010.pdf ; March 31, 2011 http://www.nmenv.state.nm.us/HWB/documents/KAFB_3-31-2011_Cover_Letter_3_WPs.pdf

^[65] http://www.abcwua.org/pdfs/wpab/wpab_minutes_051112.pdf

^[66] http://www.abqjournal.com/main/2012/12/01/news/no-kirtland-jet-fuel-in-newest-tests.html

^[67] http://www.kirtland.af.mil/shared/media/document/AFD-130222-079.pdf

[68] http://www.nmenv.state.nm.us/HWB/documents/KAFB-12-026_3-27-2012_BFFS_In-well_treatment_disapproval.pdf, p.5, item 6.

^[69] http://www.nmenv.state.nm.us/HWB/documents/KAFB-12-026_3-27-2012_BFFS_In-well_treatment_disapproval.pdf

^[70] http://www.kirtlandjetfuelremediation.com/articles/Quarterly_Rept_July-September%202012_TEXT.pdf p. ES-3

^[71] http://abcwua.legistar.com/LegislationDetail.aspx?ID=1224200&GUID=E0DE5496-CCF2-408B-8BF7-2FCEB28D30E5  Click on 12-14.PDF

^[72] http://www.kirtland.af.mil/shared/media/document/AFD-110719-015.pdf, fig 4-1 (2011);
ftp://ftp.nmenv.state.nm.us/hwbdocs/HWB/KAFB/Bulk_Fuels_Facility_Spill/KAFB_3-28-2013_Quarterly_Report_Oct-Dec-2012/Figures/Qrt_Rt_Oct-Dec%202012_FIGS.pdf See figs. 5-13 to 5-15 for EDB concentrations in groundwater.

^[73] http://www.abcwua.org/pdfs/board/agenda_11_28_12.pdf See Agenda item 9.B. Resolution R-12-14.  Also, http://www.nmenv.state.nm.us/HWB/documents/KAFB_ABCWUA_12-5-2012_FS2-R-12-13.pdf

^[74] http://www.nmenv.state.nm.us/HWB/documents/KAFB-12-026_3-27-2012_BFFS_In-well_treatment_disapproval.pdf

[75] http://www.businesswire.com/news/home/20120730005581/en/CBI-Announces-Agreement-Acquire-Shaw-Group

[76] http://www.bizjournals.com/albuquerque/news/2013/06/11/abq-sustainable-water-supply-thru-2050.html

[77] http://www.vbprice.com/columns/ce_27.html; http://www.vbprice.com/columns/ce_14.html 

^[78] http://www.nmenv.state.nm.us/HWB/documents/KAFB-12-026_3-27-2012_BFFS_In-well_treatment_disapproval.pdf

^[79] http://alibi.com/feature/38173/Superfund-Sites.html

[80] http://www.abcwua.org/pdfs/wpab/wpab_minutes_041511.pdf

[81] http://www.atsdr.cdc.gov/HAC/pha/pha.asp?docid=1199&pg=1

[82] http://www.atsdr.cdc.gov/HAC/pha/KirtlandAFB/KirtlandAFBHCPC07122013_508.pdf , p. 25

[83] http://www.epa.gov/superfund/programs/npl_hrs/hrsint.htm

[84]  https://kirtlandafb.tlisolutions.net/PDFS/30/3037.PDF   Landfill-001. “Interviews conducted during previous investigations implied that the landfill contained general refuse, construction and demolition debris, and, possibly, hazardous waste that included chemical drums, oil-soaked insulation, and numerous 5-gallon cans containing unspecified liquids. Photographs taken in 1971 showed numerous 55-gallon drums at this site. These materials were buried at depths ranging from 10 feet (ft) to 30 ft over approximately 49 acres. The estimated volume of the landfill was approximately 603,000 cubic yards (cy).”

https://kirtlandafb.tlisolutions.net/PDFS/31/3127.PDF. Landfill-02 “... metals, total petroleum hydrocarbon, semi-volatile organic compounds (SVOCs), and volatile organic compounds (VOCs) have been detected in soil samples, some at concentrations exceeding applicable action levels.”

https://kirtlandafb.tlisolutions.net/PDFS/30/3025.PDF Landfill-008 covers a total area of 65 acres and contains an estimated waste volume of 2,346,000 cubic yards. It is 3 combined landfills. “The city of Albuquerque and Kirtland AFB jointly operated Landfill 4 from 1964 to 1969 as a general refuse landfill, although no written records are available that confirm the type of refuse disposed.” [H]azardous materials such as arsenic, chromium, lead, benzene, and xylene were disposed…”

[85] https://kirtlandafb.tlisolutions.net/PDFS/32/3209.PDF

[86] http://radfreenm.org/pages/GroundWater.htm

[87] http://www.nmlegis.gov/Sessions/13%20Regular/firs/SB0135.PDF

[88] http://www.nmlegis.gov/Sessions/13%20Regular/firs/SB0135.PDF  The dry conditions have prompted the Office of the State Engineer and the Interstate Stream Commission to conclude that “as more time passes, and water problems increase in magnitude statewide, existing regional water plans are outdated and useless in addressing emerging water crises.”

 

[90] http://www.abqjournal.com/main/214656/news/rio-level.html

 

[92] http://www.bizjournals.com/albuquerque/blog/morning-edition/2013/05/covington-official-deal-mesa-del-sol.html?page=all

Hits: 4353

HIDDEN FROM THE PUBLIC – SECRET DOCUMENTS ABOUT THE FLAWED INVESTIGATION OF THE KIRTLAND AIR FORCE BASE (KAFB) JET FUEL AND AVIATION GAS CONTAMINATION OF THE ALBUQUERQUE DRINKING WATER AQUIFER

 

Prepared for Citizen Action New Mexico by

David B. McCoy, J.D., Executive Director

January 15, 2019

 

1. INTRODUCTION

 

From 2014 to 2018, a secret arrangement between KAFB and government regulatory agencies responsible for cleanup of the massive multi-million gallon jet fuel and aviation gas spill[1] [2] led them to withhold from the public dozens of technical documents totaling hundreds of pages.  The public was cut out of the loop about unresolved technical concerns and the often bungling investigation regarding a moving plume of disease- and cancer-causing chemicals,[3] heading for Albuquerque’s municipal water supply wells.

That data gaps are unresolved and that the 6800 ft  long by half mile wide plume of  disease and cancer causing chemicals is not characterized, shrinking and under control is shown below in excerpts provided from documents of the US Environmental Protection Agency, the NM Environment Department, and the Albuquerque Bernalillo County Water Utility Authority.

 

The regulatory documents obtained by Citizen Action New Mexico are highly critical of the Air Force’s failure to adequately monitor and gather reliable and representative data for their Resource Conservation and Recovery Act (RCRA) Facility Investigation (RFI) reports. The RFI reports are supposed to provide all the technical information necessary to evaluate necessary cleanup measures for the toxic spill contaminating Albuquerque’s drinking water aquifer.  Unless there is a RFI that has addressed all of the data gaps and has produced a competent Conceptual Site Model as basis for a Corrective Measures Evaluation, no Corrective Measures Implementation Plan can be put in place.  The RFI reports are some 10,000 pages long, very costly to the taxpayer and demand much review time by the regulators. 

 

None of the documents cited below that are highly critical of the 2014 and the 2017 Resource Conservation and Recovery Act (RCRA) Facility Investigations (RFIs) were ever seen by the public.  Several documents were stamped as “DRAFT” although they appear to be in a final form but were subsequently not formally submitted to the Air Force and date stamped.   Instead, documents were shown informally to the Air Force to avoid being posted officially on websites and could thus be kept from the public’s eyes. 

 

The Air Force and the NMED have repeatedly squashed requests by the public to become privy to -- whether by representation at regulators’ technical workshops, agendas and minutes thereof, formation of a Citizens Advisory Board or Citizens Remediation Board -- the real depth of technical problems surrounding the KAFB site investigation and interim measures for remediation. Denying the public access to complete and accurate technical information defeats the goals of transparency, full, fair and equitable public participation as well as creating a lack of trust between community members, regulatory agencies, and KAFB.

 

One reason for such deference being shown to the Air Force instead of public transparency may have been the appointment of Ryan Flynn as NMED Secretary in 2014.  In 2011 Gov. Martinez stated she wanted a “kinder, gentler approach” with the Air Force. That resulted in a gag order and the removal of Hazardous Waste Bureau Chief James Bearzi, who had made strict demands regarding timetables for RCRA reporting requirements and interim measures for cleanup.[4]  During the February 2014 NM Senate confirmation hearing for then Secretary-Designate Flynn, Senator Ivey-Soto raised the conflict of interest issue about Mr. Flynn’s simultaneous employment in the USAF and by the NMED.  While working as a state employee for the Environment Department, Mr. Flynn also received pay as an active Assistant Judge Advocate in the United States Air Force Reserves giving an obvious appearance of conflict.  No Notices of Disapproval or financial sanctions were filed by the NMED against the Air Force for the many delays in providing the necessary RFI documents, incompetent technical performance, and poor data quality. 

 

On July 14, 2016, the New Mexico Office of State Auditor sent a letter that advised Secretary Flynn to consider the adequacy of "your internal controls related to compliance with the Personnel Act and Procurement Code."  Secretary Flynn then announced his retirement on July 29, 2016.  The Auditor stated that 20 employees had made allegations regarding managerial problems related to procurement and other processes at the NMED that resulted in high staff turnover and that "may have set up unnecessary conflicts, creating incentives, pressures and opportunities for fraud, waste and abuse."  Even gifts and bribes from contractors with a potential for procurement code violations were among the allegations.  

Denial of data gap in the RFIs.  In March 2014 Kirtland Air Force Base submitted two RFI reports to the New Mexico Environment Department[5] about the jet fuel and aviation gas contamination of the vadose zone (region from the surface to the groundwater) and Albuquerque’s groundwater.  Abruptly, in late August, the Air Force retracted the reports with a brief letter[6] without any record explaining to the public the technical data gaps for the withdrawal of the two reports. Both RFI reports for the groundwater and the vadose zone had claimed that there were no data gaps[7] and that corrective measures could be developed for cleanup.  Without informing the public, the conclusions and technical data of the 2014 RFIs had in fact been subject to withering criticism by the US Environmental Protection Agency (USEPA) Region 6, the USEPA National Risk Management Research Laboratory Ground Water Technical Support Center, the New Mexico Environment Department (NMED) with two Notices of Disapproval, and the Albuquerque Bernalillo County Water Utility Authority (ABCWUA).   Notwithstanding two NMED Notices of Disapproval for the RFIs that were not formally provided to the Air Force, a Risk Assessment Report was presented to the public based on the flawed assumptions and data contained in the later retracted 2014 RFIs. 

 

In January 2017, KAFB released a third RCRA Facility Investigation Report.[8]   Again, the 2017 RFI report continued to be highly criticized for many of the same failings that were found three years earlier in the 2014 RFI.  And again, a NMED Notice of Disapproval (Agnew, et al) with 100 concerns and a later Technical Review of the ABCWUA were withheld from the public and not formally sent to the Air Force.  The 2017 Water Utility Authority INTERA, Inc. Review was never shown to the public but was obtained by Citizen Action by a Public Records Request along with emails between the Air Force and NMED.  An EPA critique of the 2017 RFI was not shown to the public. 

In August 2018 yet another RFI attempt[9] was issued by the Air Force and described as an “RFI Phase I” even though several data gaps identified for the 2014 Groundwater and Vadose Zone RFIs and the 2017 RFI were unresolved.  Strangely, the 2018 RFI would supposedly only use data that had been acquired through 2015 [10] and then use data later acquired from a future “RFI Phase II” investigation for the identified data gaps. Data gaps identified in the 2018 RFI Phase I are primarily attributed to the rising water table at the Site that caused many shallow groundwater monitoring wells to become submerged. 

 

The 2018 RFI reiterates many times the following statement:

“Changes in dissolved-phase concentrations and apparent plume configuration could be influenced by the rising water table. The effects of the rising water table will be evaluated in the Phase II RFI Report.”

That particular data gap is so important that a Phase II RFI is now required.  The rising water table would affect: the length and width of the plume; how much LNAPL remains vertically smeared beneath the water table; how degraded the existing LNAPL is, and how it may be contributing to the dissolved contamination in the groundwater. The northwestern edge of the shallow Q4 2015 EDB plume has not been completely defined due to the increasing trend at groundwater monitoring well KAFB-10626.

 

Need for independent overview for the RFI.  The glaring question remains whether data gaps and misinformation previously identified by the internal regulatory documents may still be present from earlier reports or if they are adequately addressed by the 2018 RFI Phase I.  This is another reason that independent overview needs to be undertaken for the project. Independent Overview for the jet fuel spill is necessary and was requested by the NM Legislature in 2014 and by the WPAB in 2018. Currently, the ongoing lack of transparency and failure to provide any semblance of inter-organizational structure also demands independent review. 

All the prior and present technical concerns of the regulatory agencies should be put onto a matrix and examined by independent overview for whether they were in fact addressed by the 2018 Phase I RFI.  Independent review should come before a Corrective Measures Evaluation.  A financial audit of the project is additionally recommended. 

There are emails (see below) between NMED and the AF that show that a July 2017  decision to cancel a KAFB public meeting was to obscure the facts about inadequate groundwater monitoring well data due to the rising groundwater table thus downplaying serious data gaps about the size and extent of the EDB plume. The public was not informed of the actual reasons for the meeting cancellation. The emails discuss how to minimize “backlash” about the cancellation of the KAFB July 2017 public meeting and to “strengthen public trust.” 

 

The Water Protection Advisory Board (WPAB) recognized as early as 2011 in its Annual Report [11]the following from a report by INTERA, Inc.:

“… elements of the proposed activities to contain the light nonaqueous phase liquid  (LNAPL) and dissolved-phase jet fuel plume, which has spread below the KAFB and beyond the base boundaries, may be insufficient to meet the goals of interim containment.

“… In addition, Intera suggested that the tests being performed to determine hydraulic parameters of the vadose zone and aquifer may also not be adequate for developing an accurate conceptual model for designing a final remediation system.”

 

One questions why, since a monitoring well was placed 200 ft from the Veteran Administration’s supply well, there is a refusal to similarly place groundwater monitoring wells close to Albuquerque’s most productive Ridgecrest  municipal supply wells?  On January 25, 2013, the Water Utility Authority passed Resolution 12-14 that requested that groundwater monitoring wells be placed as close as possible to the Ridgecrest municipal supply wells along with other emergency measures.  As of this date, the nearest monitoring well to the most productive Ridgecrest municipal wells is 1500 ft distant. 

 

The WPAB in June 2018 passed Resolution Number: WPR-2018-02 that requested transparency, independent overview of the KAFB Site, and rejected Monitored Natural Attenuation [MNA] as the perceived new strategy from the Air Force to protect Albuquerque’s aquifer and drinking water.  The WPAB recommended:

• Installation of a new deep down-gradient groundwater monitoring well
• Reassembling technical working groups composed of multi-stakeholders and contractors to develop remediation technology options for the Corrective Measures Evaluation (CME)
• Transparency and the emphasis on public involvement enhancement
• USAF updates on evaluation of remediation criteria for a final remedy
• An independent evaluation of the site should be completed prior to initiation of the CME

Both the Air Force and the NMED objected strenuously to the passage of the WPAB Resolution at the July 13, 2018 WPAB meeting.  WPAB passed the Resolution by a vote of 7 to 0.

 

2. SUMMARIES AND EXCERPTS OF DOCUMENTS RECEIVED FROM PUBLIC RECORDS REQUEST REGARDING THE 2014 RCRA FACILITY INVESTIGATION REPORT

 

Discussion Notes RFI Meeting Bulk Fuels Facility (BFF) Spill Solid Waste Management Units (SWMU) ST-106 and SS-111 Kirtland AFB, NM February 13, 2014

This was the first meeting held between NMED, KFAB, USACE and CB&I (contractor) to discuss expectations for the submission of the RFI reports for the KAFB Bulk Fuel Facility [BFF] spill.  A separate Risk Assessment document was also to be submitted.  The discussion provided that “if factual errors and deficiencies are extensive, a disapproval will be issued.”

 

Citizen Action Comment:

The NMED Notices of Disapproval for both the Groundwater and Vadose Zone RFIs were not formally issued to KAFB.  No reasons were presented to the public for the retraction of the two RFI reports.

 

The May 30, 2014 Memorandum from Sid Brandwein to Tom Blaine discussed the EPA’s Final Geophysical Log Review Report Kirtland Air Force Base Fuels Spill, Kirtland AFB, NM April 8, 2014[12] and found that the RFI Vadose Zone and RFI Groundwater reports were inadequate and technically flawed.

Two separate geophysical logging subcontractors generated different types of data from split samples.  Reliable logs were not created because the contractors did not use properly calibrated tools or did not follow exactly ASTM [American Society for Testing Materials] standards. This failure created “an unacceptable level of uncertainty with respect to understanding the geologic and hydrologic conditions at the BFFS, which, in turn, precludes selection of an appropriate final remedy with respect to optimizing the design and location of remedial options.” … “The geophysical logs are critical to conducting remedial actions at the BFFS project.” 

 

The NMED was particularly concerned about two zones at depth of 250 feet and at 450 feet below ground surface. The fine grain zone at 250 feet controls both vertical and horizontal migration of contamination and the deeper zone may affect distribution of soil vapor and extraction efficiency and migration rate and the pathway of dissolved contamination in the groundwater.  Those conditions “must be understood to properly design effective remedial actions.”

 

The Brandwein Memorandum found that the Vadose Zone and Groundwater RCRA Facility Investigation Reports submitted in March 2014 were “inadequate to design and operate a final remediation system(s).”

• “The interpretation of the subsurface is of extremely poor quality and suffers from undue oversimplification.” There was inadequate understanding of a fine grain unit A at 250 feet and fine grain unit B at 450 feet
• The differences in hydraulic conductivity near the intersection of Unit C underlying Unit B where the water table lies was not set forth. ‘As the water table rises, differing hydraulic properties can impact estimates of travel times, duration of cleanup, and treatment effectiveness.’ ” 

 

USEPA MEMORANDUM JULY 11, 2014 Laurie King to John Kieling

RCRA Facility Investigation Report, Groundwater Zone, Bulk Fuels Facility

Spill, Solid Waste Management Units ST-106 and SS-111, Kirtland Air Force

Base, Albuquerque, New Mexico, March 2014

The EPA finds that a major data gap of this RFI is characterization of the extent (vertical and

horizontal) of ethylene dibromide (EDB) in the dissolved phase plume. Section 2.4 Data Gaps states that the vertical extent and the leading edge were characterized but the EPA disagrees.

1.

• The vertical extent of EDB is not adequately delineated.
• The extrapolated contour of the leading edge of the plume in each depth interval cannot be verified due to the limited number of wells in the leading edge area. … Consideration should be given to monitoring well locations within the extrapolated plume core, at or near the projected leading edge, and downgradient of the plume. It also appears that lateral control in the intermediate and deep intervals is lacking near the intersection of Louisiana and Gibson where only a single shallow well is installed.

2. Hydraulic conductivity estimates for the shallow plume area (e.g. less than ~100 feet below the water table) are based entirely on slug test data. Slug tests only provide aquifer property estimates in the immediate vicinity of the test well and do not provide insight into potential boundary conditions or the nature and degree of anisotropic conditions [differing physical properties that are different in different directions] which are likely to be considerable in the fuel spill area due to the depositional environment of the Ancestral Rio Grande. Aquifer tests of sufficient discharge rate and duration and having multiple properly located and spaced observations wells should be performed.
3. Table 5-7: Comparison of Water Table and Shallow Well Screen Elevations April 2013 shows that 15 wells have groundwater elevations ranging from 0.38 feet to 6.12 feet above the top of the well screen. If the water table continues to rise, these values will increase as will the number of wells with flooded screens.
4. Section 5.1.6 of the report provides the geophysical logging results. The EPA contracted a subject matter expert to review the geophysical logs. The report notes discrepancies and

concerns with the geophysical logs.

5. Section 5.2.4 and Appendix L of the report provide an analysis of the compound specific isotope analysis (CSIA) and biological parameter sampling results. The EPA requested assistance from the EPA’s National Risk Management Research Laboratory in Ada, OK (Ada Lab) to review the CSIA and biological parameter sampling results. A memo summarizing Ada Lab’s review is provided as an attachment to this memo (Attachment 2). In order to provide a defensible dataset supporting claims of biological and/or abiotic degradation of EDB and benzene, the Air Force should proceed with the recommendations contained in the attached memo.

 

ATTACHMENT 1 FINAL GEOPHYSICAL LOG REVIEW REPORT

RECOMENDATIONS

To resolve the conflicts and concerns, we recommend the following possible

measures.

• Provide an independent review of all raw data from both Colog and Jet West. The

raw data will report the count rates and conductivity values before conversion.

The header in the raw data will provide the true calibration values used. Then

both data sets can be converted using the same normalization factors.

• Conduct direct resistivity measurement in the field or laboratory. Field resistivity

measurement includes either electric log in an open borehole under the water table

or cross-hole electrical resistivity tomography between two boreholes above or

below the water table. The laboratory test would measure soil resistivity using

core samples. These resistivity values would then be used for calibration.

• Conduct more tests in both open and cased boreholes to evaluate the impact from

borehole diameter and grout.

 

ATTACHMENT 2

We found that insufficient information was available in the SOP to determine whether appropriate analytical methods were used for the CSIA sampling.

 

Based on review of the KAFB CSIA SOP and the KAFB CSIA analytical data reports, it is

unlikely that EDB was separated from the other fuel components by two-dimensional gas

chromatography, which is the method outlined in Wilson et al. (2008) to attain complete

separation of EDB from the petroleum hydrocarbons. If the compounds are not separated, the

values determined for the stable isotope ratio of EDB will be in error.

 

If MNA [Monitored Natural Attenuation] is selected as the remedy for EDB in ground water at KAFB, it is recommended that the Site be resampled for CSIA analysis every five years.

In Wilson et al. (2008) there is a discussion of the need for two-dimensional gas chromatography

to successfully determine the isotopic ratio of EDB in the presence of gasoline hydrocarbons.

The isotopic ratio is determined on carbon dioxide produced from the combustion of the

substance being analyzed. If there is a co-eluting compound, the co-eluting compound will

contribute to the isotopic ratio. As a consequence, successful determination of the isotopic ratios

requires base line separation of the compound for which the isotopic ratio is being determined.

There are compounds in gasoline that elute near EDB. To achieve baseline separation it is

necessary to first separate EDB on one gas chromatography column, then take the compounds

that elute from the first column and separate them again on a second column with separate

properties. This is called two-dimensional gas chromatography.

 

INTERA, Inc. May 1, 2014 Technical Memorandum ABCWUA comments on the Interim Measure for EDB Dissolved Plume of April 2014

 

INTERA, Inc. criticized a white paper written by the Air Force contractor CB&I that would have used an existing KAFB supply well, KAFB-3, or one constructed nearby to extract contaminated water from the plume.  INTERA found that the well “could not achieve removal within decades, let alone 6 to 12 months, and if it were to function as described, would spread, not contain, the EDB plume over an additional 3,500 ft of clean aquifer.”   

 

11 August 2014 INTERA

Re: ABCWUA comments on the Resource Conservation and Recovery Act Facility Investigation Report Vadose Zone Bulk Fuels Facility Spill Solid Waste Management Units ST-106 and SS-111 dated March 2014

 

“In summary, the five most important conclusions from the vadose zone RFI report, conclusions 1, 2, 4, 5, and 7, are seriously flawed and the RFI data and analyses are far from sufficient for determining future actions at ST-106 (Executive Summary, pages ES-5).

 

1. The vadose zone RFI document incorrectly concludes that the nature and extent of vadose zone contamination have been “adequately determined” (RFI Conclusion 1). This conclusion is not defensible because the document defines contamination as COCs present on the soil and as vapor but ignores the light non-aqueous phase liquid (LNAPL) contamination in the vadose zone. This conclusion also cannot be justified with regards to delineation of soil contamination because less than 6% of the vadose zone soil intercepted by CB&I’s vadose zone soil bores was characterized

 

2. CB&I discuss their failure to adequately quantify the amount of vapor-phase EDB in the vadose zone (Conclusion 2)

 

3. CB&I identify ten COCs for vadose zone soil but fail to include EDB (Conclusion 4). EDB must be added to the list of vadose zone soil COCs and included in all fate and transport analyses. EDB trapped in residual LNAPL in the vadose zone may be remobilized by migrating JP-4 or JP-8 and so could pose a potential threat to the regional aquifer.

 

4. CB&I concluded that the areas encompassing VOCs and benzene have decreased since mid-2011 based on the trends discussed in Section 5.4.2.3 (Conclusion 5). CB&I do not discuss the mechanisms causing these decreases.

 

5. Based on the missing or erroneous RFI information described above, there is no basis for CB&I’s conclusion number 7, which states that the RFI data collected “…are sufficient for informing future actions at ST-106”. Missing from the RFI are the following data that are critical for determining future actions: a) the vertical and lateral distribution of LNAPL saturation in the vadose zone, b) the location and mass of EDB contained in vadose zone LNAPL, and c) estimates of contaminant mass in the vadose zone using continuous core sampling.

• Ignoring vadose zone LNAPL as a contaminant phase is not defensible.
• The RFI contains no data about the spatial distribution of LNAPL saturation within the vadose zone and so precludes a determination of the areas where LNAPL is migrating through the vadose zone and into the regional aquifer.” (Emphasis in original).

 

The RFI Review Comments New Mexico Environment Department (August 14, 2014)

Conclusions of CBI that were rejected for the Groundwater Zone RFI:

The Review found that 11 of 14 RFI conclusions were invalid and that the RFI could not be used to develop successful corrective measures.  NMED met with KAFB and CB&I (contractor) to discuss RFI content on February 13, 2014 and offered to meet further to discuss the RFI requirements and content.  KAFB and CB&I did not request additional meetings and submitted the RFIs on March 31, 2014.  Part of the RFI was submitted to the DOE Oversight Bureau that was inappropriate and violated permit requirements for document submission. 

 

#1. CB&I The nature and extent of contamination and aquifer characteristics have been defined.

NMED comment: Unknown how deep EDB and Benzene contamination are. Unknown lateral extent. No representative data for aquifer characteristics.  Geologic controls on extent ignored.  Ineffective for corrective measures.

#3. CB&I CSIA data indicate anaerobic degradation of benzene and EDB and an unquantified amount of aerobic degradation of EDB also occurs.

 

NMED comment: Conclusion neither correct nor justified by RFI data and analyses. Multiple lines of evidence either invalid or misrepresented.  EDB plume data says that anaerobic degradation is not occurring at a rate faster than the rate of EDB groundwater migration. 

 

CB&I #4. Groundwater flow and transport modeling results indicates fuel contamination reached groundwater in 1980 and created a residual LNAPL smear zone from 400 to 500-feet .

 

NMED comment: GW flow model based on incorrect conceptual model. Biased historical calibration.  Cannot recreate time history of head change in unconfined aquifer. Model is very poorly constrained for BFF unconfined aquifer. 

 

CB&I #5. Groundwater levels have risen since 2009. The source of dissolved contamination is the submerged LNAPL

 

NMED comment: Ignores source added monthly by rising water table. No data on LNAPL mass in bottommost 50 feet of vadose zone. Provides no data on extent, saturation, or mass of LNAPL in bottommost vadose zone or below water table.  No data about EDB fraction in these LNAPL sources.

 

CB&I #6. RFI data collected are sufficient for determining future actions at SS-111.

 

NMED comment: [The]RFI documents cannot be used to develop successful corrective measures because:

• Inadequately define the nature and extent of vadose zone and groundwater contamination
• Misrepresent other known processes as degradation
  • This skews the selection process for corrective measures
• Anaerobic degradation may occur, but are the rates significant for controlling groundwater EDB migration?
  • RFI evidence supports a negative answer
• GW flow model is flawed and too poorly constrained to simulate flow and transport in BFF unconfined aquifer
• Do not determine LNAPL sources and EDB fraction

 

Conclusions made by KAFB that were rejected by NMED for the Vadose Zone RFI

 

CB&I #1. Nature and extent of contamination in the vadose zone have been determined barring 1,2-dibromoethane

 

NMED Comment:

Did not assess present-day LNAPL migration through vadose zone

• At what rate is LNAPL migrating through vadose zone?
• Migrating LNAPL poses a long-term future threat to the groundwater and public health.

 

CB&I #4. Ten contaminants of concern (COCs) have been identified in the vadose zone soil.

NMED Comment:

Did not include EDB

• EDB trapped in residual LNAPL in the vadose zone may be remobilized by migrating JP-4 or JP-8 and/or submerged if water levels continue to rise and could pose a potential threat to the regional aquifer.

 

CB&I #5. The areas encompassing soil vapors of volatile organic compounds (VOCs) including benzene have been decreasing since the second quarter of 2011.

NMED Comment:

• Does not discuss the mechanisms causing these decreases.
• Decrease at the deepest interval most likely caused by the drowning of the LNAPL.
• Soil vapor network is limited to “standard depths”. No information provided between these depths.

 

CB&I# 7. The RFI data collected meet the Quality Assurance Project Plan requirements and are sufficient for “informing” future actions at SS-106.

NMED Comment:

RFI documents cannot be used to develop successful corrective measures because

• Inadequately define the vertical and lateral distribution of LNAPL saturation in the vadose zone
• No data on location and mass of EDB contained in vadose zone LNAPL

 

NMED found Conceptual Site Model (CSM) Deficiencies.

NOTE!  Figure 7-1 at p. 23 for the Conceptual Site Model suggests possible vapor exposure pathway to KAFB workers and for the public at Bullhead Park that is offsite.

 

NMED Comment:

#1

• Vapor exposure is not discussed in the RFI
• What is the basis exposure pathway?
• What concentrations might workers be exposed to?
• What precludes vapor exposure pathways in other directions and off the base?
• #2 -Analysis of groundwater background quality, critically important with regard to hydrocarbon biodegradation and other impacts to the aquiferIncomplete in the RFI report.
• #3 -The anaerobic plume core and other redox zones are not illustrated and discussed relative to each other and to dissolved contaminant phases.
• #4 -The sulfate reduction and methanogenesisredox zones were not identified either in the RFI or in the conceptual model.
• #5 -The CSM does not contain readily available hydrogeologicinformation and data that has been discussed at length in previous meetings.
• Model fails to provide a comprehensive understanding of the physical, chemical, and biological processes that influence contaminant fate and transport. Understanding all processes that occur at the site is critical for corrective measure evaluation and selection.

Plume Definition

The following activities were not completed:

• Characterization of the vertical extent of the dissolved-phase contamination in the groundwater and the effect of vertical gradients.
• Characterization of the leading edge (northern) and eastern and western margins of the NAPL, benzene, and EDB plumes” (RFI, page 2-7)

Slug Test Data and Analysis

Poor quality early time data in slug tests and errors and inconsistencies in the analysis

Erroneous/Misleading Graphics

Graphics indicate sediment contamination 150 feet deep in the aquifer.

This is deeper than any boring/monitoring well at the site and is not discussed in the text. Graphics are misleading and most likely wrong.3

Strange Hydrographs

No description or correction of major change in water level.

Recurring issue -NMED has made prior comment on this and previous slide.

Conflicting Lithology Interpretation

KAFB 106-030 at 475 feet:Borehole log describes it as 100% very fine to fine sand; Particle size analysis describes it as gravel.

Lack of Analysis and Conclusion Geophysical Borehole Logging

• No discussion of the findings of the geophysical logging.
• Gamma, neutron, and induction logging was conducted:
  • When appropriately interpreted, geophysical logging provides information on lithology, stratigraphy, water content, and other important subsurface information.
• Useful for site specific hydrologic characterization and contaminant migration pathway analysis.

Invalid Data Collection Geophysical Borehole Logging

Many induction geophysical logs were not calibrated properly. The work plan called for calibrated logs.

The EPA review of geophysical logs stated:

“a calibration issue was noted in the induction data…” and “ the induction probe used by Jet West may be faulty due to the unrealistic readings in the casing and underwater.”34

SVE Radius of Influence

The VZ RFI states:

“[t]o determine the ROI [radius of influence] of the CATOX SVE system, the corrected observed vacuum pressures for each well depth and type were plotted against radial distance from the nearest extraction well, and a best-fit line was fit to the data…The distance at which the best-fit line crosses the corrected observed vacuum pressure of 0.2 inWCis the ROI observed in that well depth and type.”

However, …

EPA’s 1998 Innovative Site Remediation Technology, Volume 7: Vacuum Extraction and Air Sparging states:

“[h]istorically, radius of influence has been determined by plotting the log of subsurface pressure with distance from the extraction well, regression, and interpolating the regression line to an arbitrary pressure value, typically ranging from 0.01 to 1 inch water column… The radius of influence evaluated in this way is arbitrary, because the vacuum cutoff level is arbitrary….Many alternative approaches have been developed that focus on air flow.”

In addition, …3

The 2002 US Army Corps of Engineers’ Engineering and Design Soil Vapor Extraction and Bioventing Engineer Manual specifically states:

“[t]he radius of vacuum/pressure influence does not provide, in most cases, an estimate of the zone of effective air exchange of the vent…, which is often much smaller than the radius of pressure influence.”

and

“[p]ractitioners who use ROI testing to design soil venting systems assume that observation of subsurface vacuum ensures sufficient airflow in contaminated soils for timely remediation via organic compound volatilization and/or biodegradation. As Johnson and Ettingerpoint out, however, measurement of vacuum says very little about pore-gas velocities that prevail within the subsurface.”

 

Errors and Omissions

Examples:

Groundwater Chemistry Time Trends Not Analyzed

• DO data for the shallow groundwater zone suggest that the anaerobic zone has generally decreased in area from 2011 to 2014. This suggests a larger anaerobic plume zone occurred in the past.
• DO, nitrate, manganese, iron, and sulfate in terms of biodegradation of dissolved phase hydrocarbons.

Significance of Anaerobic (Low Dissolved Oxygen)Zone Footprint

• DO is an important parameter and was not discussed in the RFI.
• Anaerobic conditions with high concentrations of electron donors (BTEX) are most favorable for EDB biodegradation.
• If the anaerobic zone has been shrinking, this has profound implications for corrective measure evaluation and selection.

Sulfate Data Misinterpreted

• The RFI (p. 6-10) states:“No obvious pattern is apparent in the Shallow, Intermediate, and Deep Zone sulfate results, and none has been observed since monitoring began in First Quarter CY 2011.”
• However: RFI Figure 6-19 clearly shows very low sulfate concentrations (i.e. sulfate reducing conditions) at several monitoring wells located in the LNAPL area.

Compound Specific Isotope Analysis (CSIA) for EDB needs to be Correctly Investigated

• CSIA used as the sole quantitative tool to demonstrate biodegradation of benzene and EDB.
• The CSIA is a key element in the RFI to support the conclusion of biodegrading benzene and EDB.
• EPA and NMED, however, has identified serious problems with the CSIA study (insufficient concentrations of EDB in many CSIA samples, inappropriate analytical method, and co-elution of hydrocarbons with EDB in samples submitted for CSIA).
• The study must be redone.

NMED summarized the numerous RFI deficiencies as follows:

• Numerous errors and omissions:
• Incorrect/incomplete site history
• Inaccurate and invalid data
• Some data not discussed or interpreted
• Anomalous data ignored
• Incorrect calculations
• Incomplete mass balance
• Conflicting data presented and interpretations
• Invalid conclusions
• RFI is overly simplistic and incomplete:Many basic analyses of contouring data, graphing concentrations over time, and comparing relations between parameters are missing.
• Consequently, the RFI has failed to make some important observations with existing data.

 

EMAIL Wednesday, September 24, 2014 9:41:59 AM Stephen Reuter, NMED to Tom Blaine, NMED, describes “several significant difficulties with the KAFB slug test data as submitted, and then later retracted, in the RFI.” Slug tests are used to determine the permeability of sediments at a site and that calculation is that is a factor relevant to determining groundwater velocity and the prediction of the spread of contaminants. Since the slug tests were only accurate within an order of magnitude, “the limitations of the data cannot adequately constrain the model to give significantly meaningful results.”  The tests also ignored the variability of the field condition.

 

11 August 2014 Water Utility Authority Technical Memo  Comment on the Resource and Recovery Act Facility Investigation Report Vadose Zone Bulk Fuels Facility Spill Solid Waste Management Units ST-106 and SS-111 dated March 2014. Submitted by Rick Shean, ABCWUA, to Tom Blaine, NMED.

The Water Authority concerns were that the purpose of the investigation to characterize the site for the nature and extent of the contamination had not been accomplished.  The Authority stated that the five most important conclusions from the vadose zone report were “seriously flawed and the RFI data and analyses are far from sufficient for determining future actions at the ST-106 [site].” Concerns were summarized as follows:

1. Less than 6% of the soil in the vadose zone was characterized and the RFI did not address whether LNAPL would continue to migrate into the regional aquifer along with understanding distribution of the contaminants.
2. Failure to quantify the amount of vapor-phase EDB present in the vadose zone and the amount of EDB present in vadose zone LNAPL. Absence of this critical information could likely lead to recontamination of the regional aquifer.
3. EDB was not quantified and included as a vadose zone soil contaminant that was trapped in residual LNAPL and could be remobilized as a threat to the regional aquifer.
4. The RFI failed to explain that “the apparent decrease at the deepest depth interval, 450 feet, is wholly or in part caused by the rising water table that has drowned the deepest vadose zone LNAPL.”
5. Based on the erroneous data above there is no basis for the CB&I conclusion that the RFI data collected “are sufficient for informing future actions at ST-106 [site].” Critical missing data in the RFI: a)vertical and lateral distribution of LNAPL in the vadose zone; b)the location and mass of EDB contained in the vadose zone LNAPL, and c) estimates of contaminant mass in the vadose zone using ontinuous core sampling.

 

A secret November XX, 2014 Environment Department Notice of Disapproval [NOD] for the Kirtland [RFI] groundwater investigation report, discussed:

 “inadequate characterization of the geology, hydraulic conditions, contaminant concentrations, extents of contaminant plumes, and poor interpretation and presentation of data leading to failure to generate an adequate Conceptual Site Model (CSM).”

A CSM is supposed to provide the foundation for risk assessment and processes to adequately conduct a corrective measures evaluation for a final remedy selection.  The Environment Department described the RFI Conceptual Site Model as a “cartoon of no use” as a “rigorous synthesis of data for conveying site conditions to technical reviewers.”

The 45 page NMED NOD disputed many Air Force claims such as that there were no more data gaps, that the plume is stable or that the vertical and horizontal extent of the plume was known.

 

A secret March XX, 2015 Environment Department Notice of Disapproval for the Kirtland vadose zone investigation report stated similar concerns that were in the November XX, 2014 NOD.  One hundred and one concerns were presented by NMED.  There were also references to reports from the US Environmental Protection Agency (July 11, 2014 and August 8, 2014) and the Albuquerque Bernalillo Water Utility Authority (August 11, 2014) that likewise were withheld from the public.  NMED agreed with the major concerns of the USEPA and the Water Authority.

 

The EPA report described that critical data from geophysical logging for understanding site groundwater flow conditions was obtained from tools that were not properly calibrated:

“This failure by the Permittee to provide reliable logs creates an unacceptable level of uncertainty with respect to understanding the geologic and hydrologic conditions of the BFFS [Bulk Fuels Facility], which, in turn, precludes selection of an appropriate final remedy with respect to optimizing the design and location of remedial options.”

The NMED described that:

“The interpretation of the subsurface is of extremely poor quality and suffers from undue over simplification.”

… As the water table rises, these differing hydraulic properties can impact estimates of travel times, duration of cleanup, and treatment effectiveness.”

 

 

3. SUMMARIES AND EXCERPTS OF DOCUMENTS RECEIVED FROM PUBLIC RECORDS REQUESTS REGARDING THE 2017 RCRA FACILITY INVESTIGATION

 

 [Citizen Action note: the following is an email for an agenda for stakeholder meeting that does not include public.  No accompanying minutes for the meeting were given in the PRR response.].

From: O"GRADY, HOLLY M GS-12 USAF AFCEC AFCEC/CZOW

 

To: Agnew, Diane, NMENV; BODOUR, ADRIA A CIV USAF HAF AFCEC/CZRX; CASAREZ, ANGELINA M GS-12 USAF

AFMC AFCEC/PA; DEVERGIE, SUZANNE C GS-12 USAF AFCEC AFCEC/CZOW; FISHER, JAMES A GS-12 USAF

AFGSC 377 ABW/PA; Faris, Bart; Fuentez, Estela; Hobbs, Rachel; Jercinovic, Devon; Kieling, John, NMENV; King,

Laurie; Kunkel, Tara; Leonard, Mary Lou; LYNNES, KATHRYN D HQE USAF AFGSC 377 MSG/SAF/IEE; McQuillan,

Dennis, NMENV; Roberts, Kathryn, NMENV; Romalia, Kathleen; Shean, Rick; Simpler, Trent; Turner, Jill, NMENV;

This email address is being protected from spambots. You need JavaScript enabled to view it.

Cc: Ellinger, Scott; GRUSNICK, CARL P GS-13 USAF AFGSC 377 ABW/PA; Phaneuf, Mark; Rust, Colleen; Salazar,

Carlos; Sanchez, Amy; Wortman, Ryan; Ziegler, Ken; CLARK, SCOTT C GS-13 USAF AFCEC/CZO

Subject: Agenda for Wednesday"s stakeholder meeting

Date: Monday, March 06, 2017 3:54:43 PM

Subject: Kirtland BFF Stakeholder Meeting

When: Wednesday, March 08, 2017 2:00 PM-4:00 PM Mountain Time

Where: Marriott Courtyard ABQ Airport at 1920 Yale Blvd SE, ABQ, NM 87106 Mesa Conference Room or 1-

800-768-2983 4011181#

Good Afternoon,

The following is a limited agenda put together by Suzanne Devergie and Holly O'Grady:

- CBI

ESTCP

- Sundance

Vadose Zone Sampling

Update on Risk Assessment

- EA

GWTS

New Vadose Zone Contract

- USAF

Update on Permits

- Additional Items

Thank you,

Holly O'Grady, P.E., MS, PMP

Environmental Engineer

Environmental Restoration, AFCEC/CZOW IST

Kirtland AFB, NM 87117

This email address is being protected from spambots. You need JavaScript enabled to view it.

(505) 853-3484/DSN 263-3484

 

 

TECHNICAL MEMORANDUM DATE: 29 June 2017

FROM: John Sigda, Ph.D. and Eileen Marcillo, INTERA Incorporated

TO: Rick Shean, Water Quality Hydrologist, Albuquerque Bernalillo County Water Utility Authority (ABCWUA) SUBJECT: Review Findings for RCRA Facility Investigation Report Bulk Fuels Facility Release Solid Waste Management Unit ST-106/SS-111 dated January 2017

 

The Memorandum rejects the conclusions made by the RFI Executive Summary:

The data and analyses presented in this RFI report do not support Sundance’s conclusions that the nature and extent of contamination are sufficiently well understood or that there are sufficient data to move forward with the RCRA process. Our evaluation found that the RFI document does not provide the evidentiary basis for conducting a CME and its conceptual model contains errors and omissions that could lead to an inappropriate or ineffective set of corrective measures. Specifically, our review demonstrates that the RFI report lacks important data needed for the CME, inaccurately characterizes important features and processes in the subsurface, underestimates contaminant sources, and overestimates degradation rates.

 

… [Th]is RFI document downplays the remediation challenges ahead. It tries to show degradation is quickly removing contaminant mass, especially ethylene dibromide (EDB) mass, at rates that are not justified by the actual data and it underestimates the mass of EDB and other contaminants remaining in the vadose zone and the groundwater.

2.1 Insufficient Soil Data to Estimate Vadose Zone Source Mass and Mass Flux

… Missing from the RFI are the following data that are critical for determining future actions: a) the vertical and lateral distribution of LNAPL saturation in the vadose zone, b) the location and mass of EDB contained in vadose zone LNAPL, c) estimates of contaminant mass in the vadose zone using continuous core sampling, and d) the rate of mass transfer of contaminants from the vadose zone to the saturated zone (mass flux). …

These serious flaws in the RFI determination of contamination extents must be rectified before cost effective corrective measures can be identified or designed.

the RFI data set most likely does not represent the actual presence of LNAPL in the vadose zone, but only an arbitrary 50-ft sampling interval below the topmost 50 feet of the vadose zone. Consequently, it is imperative that the Air Force remedy this data gap in the source area before the RFI is approved so that all stakeholders understand the potential contaminant loading from fuel in the vadose zone to the drinking water aquifer. … The RFI states in several locations that continuous sampling was conducted in the vadose zone, but this is supported at only a few locations.

… Given the persistence of ethylene dibromide (EDB) in the subsurface at the site, it is vital that the mass of EDB be quantified across the vadose zone in the source area.

2.2 Insufficient Data and Inaccurate Description of LNAPL in and near Aquifer

By ignoring available data, the RFI report incompletely characterizes the extent of LNAPL in and near the aquifer. … [The RFI] says nothing about how LNAPL presence is also demonstrated by groundwater concentrations of fuel constituents that exceed their effective solubility values. … The lack of any discussion or analysis about effective solubility and historical concentration data in the RFI is a serious deficiency.

 

The RFI should be revised to discuss all indicators of LNAPL presence, including effective solubility for benzene, TPH-DRO, and other constituents.

 

The RFI states that LNAPL has only been observed at one or two monitoring wells since 2012 (Figure 5-4). In fact, the RFI presents an incomplete picture of all the information about LNAPL extent, greatly underestimating its extent in the aquifer.

 

The RFI identified a data gap about the location of LNAPL below the water table and the effects of weathering. This data gap should be revised to state that the Air Force will determine the saturation and composition of LNAPL at to depths that extend below the estimated minimum water table elevation in the source area. One cannot estimate the future production of dissolved EDB or other constituents of concern (COCs) from the smeared LNAPL without knowing the mass and composition, especially the mass of EDB. … This trapped or smeared LNAPL will act as long-term contaminant sources, thus the RFI should be revised to include the full extent of the smear zone because proper selection and design of corrective measures depends on delineation of the extent and mass of this source. …

2.3 Analysis Misrepresents Groundwater Contaminant Trends

The RFI report’s characterization of benzene and EDB concentration trends over time is seriously flawed and overestimates degradation rates in groundwater. The statistical analysis summarized in Section 6.2.2.3 and detailed in Appendix T is not scientifically defensible because it assumes all concentration changes are solely a function of degradation when there are many other controls on concentration changes over time. The concentration time trends must be re-analyzed with corrected data sets and Section 6.2.2.3, Appendix T, and all references to their findings should be revised throughout the RFI report. The end result is that degradation of benzene and EDB is proceeding much more slowly than is purported in the RFI report.

… [T]he RFI statistical analyses for EDB and benzene concentration changes over time assume all concentration changes are from degradation, which is not only not scientifically defensible but overestimates the actual degradation rates and severely underestimates the half-lives of COCs at the site.

… The RFI states “In the downgradient aerobic portion of the plume, data indicate that hydrolysis, an abiotic process is a significant factor in the degradation of EDB”. Abiotic degradation of EDB is reported to have been observed in the laboratory but there are no reports of it being observed in field conditions anywhere. The RFI presents no site-specific evidence to demonstrate that there is abiotic EDB degradation in the downgradient groundwater plume. Such concentration changes may be caused by drowning, migration of degradation products from source area, or other factors. Calling abiotic degradation “a significant factor” is unsupported interpretation and should be removed from the RFI report.

• Incomplete Delineation of Groundwater Plume

 

The RFI report states that the horizontal extent of the EDB groundwater plume is well defined except for the data gap at the northwest margin of the plume. We agree that there is a data gap at the northwest margin of the plume, but there much more important data gaps in the vertical extents of the EDB plumes. The vertical extent of the distal EDB plume at depth remains undefined.

… The upper vertical extent of the groundwater contaminant plumes is no longer defined and is increasing as the water table rises. Most of the shallow screened intervals in the monitoring well network within the source area have been submerged for a few years. The high concentration part of the EDB plume is now located above the tops of these screens, so it is not possible to know the extent of the plume. Furthermore, the rising water table may be intercepting fuel LNAPL in the deep vadose zone, which may cause dissolved phase concentrations to increase significantly. Consequently, the RFI should be revised to describe these vital data gaps and all text about shrinking or stable plume size should be removed from the current document.

2.5 Remove Unsupported Interpretation and Incorrect Text

As shown in Table 1, the RFI report contains many instances of unsupported interpretation and incorrect statements. All unsupported interpretation should be removed from the report as it is intended to provide the evidentiary basis for carrying out the CME.

Review of RCRA Facility Investigation Report for Bulk Fuels Facility Kirtland Air Force Base, New Mexico January 2017 on behalf of the Albuquerque Bernalillo County Water Utility Authority (PowerPoint presentation)

This summarized concerns presented in the analysis of INTERA, Inc.

1. Soil data insufficient to estimate vadose zone source mass and mass flux to aquifer
2. Insufficient data and inaccurate description of LNAPL near and in saturated zone
3. Analysis presented misrepresents groundwater contaminant trends
4. Incomplete groundwater plume delineation
5. Interpretive presentations should be omitted from the RFI.

 

INTERA challenged the RFI claim of EDB degradation as follows:

RFI states “.. In the downgradient aerobic portion of the plume, data indicate that hydrolysis, an abiotic process is a significant factor in the degradation of EDB”

• No evidence presented to show that there is abiotic EDB degradation in groundwater plume. Concentration changes may be caused by drowning [of well screens], migration of degradation products from source area, or other factors
  • Calling abiotic degradation “a significant factor” is unsupported interpretation and should be omitted from the RFI

 

INTERA also identified unsupported statements regarding EDB concentration decrease:

RFI contains statements that are unsupported or provide incorrect interpretation

• All interpretation should be removed from the RFI

• Examples include LNAPL migration through vadose zone driven by gravity Insufficient as it omits other driving forces
• LNAPL formed a layer that floated on top of the water table A false interpretation that underestimates source mass in the residual
• Degradation is reducing dissolved phase concentrations No evidence or analysis to separate out other causative factors
• EDB plume capture will be most effective with 5 extraction wells. This is unsupported conjecture because this system has been demonstrated to fail to capture EDB for reasonable values of system characteristics
• Decrease in EDB soil vapor concentration indicates anaerobic degradation of EDB in vadose zone (p 4-24) Overlooks other potential influences: number of sample events
• EDB and benzene plume stability –indicative that submerged LNAPL is stable or shrinking (pg5-9)No other supporting evidence that LNAPL is stable or shrinking
• Disregards effective solubility
• Can this be determined with current groundwater monitoring network? Horizontally it may appear to be stable but what about the vertical component? State later on that the vertical extent is unknown, but water levels are rising, possibly intercepting new source mass. If so, plume is not stable.
• Low permeability, high hydrocarbon zone in AOI 5 and 6 based on permeability testing (ES-7)No data to support low permeability zone is retaining fuel
• Decrease in average EDB and benzene concentrations between Q4 2012 and Q4 2015 (ES-12) No discussion about whether the average was calculated for an identical set of wells. Did the additional 19 new wells installed in 2015 cause an unjustified bias in average concentration?
• Disregards impacts from the rise in water levels (potentially shift shallow plume upwards making a thicker plume; are monitoring wells sufficient for monitoring plume?)
• [Citizen Action note: As subsequent memos show, the RFI was nowhere near completion as claimed by the following news release].

NEWS RELEASE

• For Immediate Release
• January 12, 2018
• NMED’s Technical & Regulatory Review of Kirtland AFB’s
• RCRA Facility Investigation (RFI) Nears Completion
• NMED Chief Scientist Dennis McQuillan Leads Review Which Will Describe
• Requirements for RFI Modifications and for RFI Addendum
• …A key part of environmental protection is the successful completion of the RCRA Facility Investigation (RFI Report). The RFI characterizes the KAFB jet fuel leak by capturing historic and current data in light of dynamic conditions such as a rising water table and the pump and treat interim cleanup measure which is now active. McQuillan said that NMED’s final RFI review is expected in weeks, and that the U.S. Air Force’s next steps will be to respond to the modification requests resulting from the review, and to provide an RFI addendum document with additional, required characterization data.
• “The regulatory and cleanup process for a complex site like this can seem daunting, but the four phases are actually simple. First there was site investigation which took a number of years. Second, interim cleanup measures began as the characterization process continued in parallel. Now, we are nearing completion of the RFI Report based on that extensive characterization work. The finalized RFI Report is the cornerstone for the third and fourth phases which are the selection of the best corrective measures for cleanup, and ultimately, their implementation,” said McQuillan.

 

[Citizen Action Note: Serious problems with the RFI were evident in the following agenda].

 

July 13, 2017 Kirtland Air Force Base Fuel Leak RCRA Facility Investigation Report

2 p.m. – 4 p.m.

1. General overview
2. Delineation and monitoring of groundwater plumes
3. Submerged well screens – insufficient monitoring well network across water table for shallow plume definition
4. Capture zone analysis not representative
5. Projected water table rise à urgent need to address sentinel wells
6. Monitoring network and frequency
7. Add in KAFB-106041 and KAFB-106231
8. Quarterly monitoring of complete network for EDB and BTEX
9. Degradation analysis in RFI Report
10. Appendix T degradation analysis fundamentally flawed
11. Over-estimate of degradation rates
12. Delineation of LNAPL extent
13. RFI fails to evaluate effective solubility concentrations in groundwater
14. Multiple lines of evidence point to existence of LNAPL at and near the groundwater
15. RFI Report Path Forward
16. Public Meeting Path Forward

 

The Associated Press
July 24, 2017 06:44 PM

Canceled Kirtland jet fuel spill meeting irks activists

ALBUQUERQUE, N.M. (AP) - Environmental activists are expressing anger at Kirtland Air Force Base for canceling a meeting on the cleanup of a jet fuel spill in Albuquerque.

Advocates from Citizen Action New Mexico and the Albuquerque Center for Peace and Justice say they don't see why the air force base and state environmental officials canceled the meeting scheduled for Thursday aimed at giving residents an update on cleanup efforts.

Kirtland Air Force Base and the New Mexico Environmental Department announced last week they were canceling the quarterly community meeting so officials could review two reports. They say reports give more information on the extent of fuel contamination and an evaluation of exposure risk.

First detected in 1999, the fuel leak is believed to have been seeping into the ground for decades.

[Citizen Action Note: Emails re July 27^th public meeting -- cancellation based on concerns for “public trust” and “backlash” rather than completion of major milestones].

 

From: ZUCH, OTHANA R GS-12 USAF AFGSC 377 ABW/PA

To: Lisa Mathai; Agnew, Diane, NMENV

Cc: LYNNES, KATHRYN D HQE USAF AFGSC 377 MSG/SAF/IEE; BLAYLOCK, EVA D GS-11 USAF AFGSC 377 ABW/PA;

O"GRADY, HOLLY M GS-13 USAF AFCEC AFCEC/CZOW; BODOUR, ADRIA A CIV USAF HAF AFCEC/CZRX;

CASAREZ, ANGELINA M GS-12 USAF AFMC AFCEC/PA; CARABAJAL, SHANNON R GS-11 AFMC AFCEC/DSP;

Majure, Allison, NMENV; Sanchez, Amy E. SPA; Salazar, Carlos F SPA; Rachel Hobbs; Dreeland, Linda E CIV

USARMY CESPA (US); Julie McNeill; Gabriele Caligiuri; RENAGHAN, BRIAN J GS-13 USAF AFMC AFCEC/CZRX;

GRUSNICK, CARL P GS-13 USAF AFGSC 377 ABW/PA

Subject: RE: [Non-DoD Source] Re: September Public Meeting

Date: Monday, July 24, 2017 2:39:11 PM

Good afternoon everyone,

It is AFCEC/PA and 377th/PA’s collective recommendation that we stick to what was sent in the cancellation advisory. As described previously, “The July meeting is being cancelled to provide more time to review two major milestones on the project: the Resource Conservation and Recovery Act Facility Investigation Report characterizing the leak and the Risk Assessment Report delineating risk in support of future decision-making. Both of these documents present technical evaluation information about the Bulk Fuels Facility investigation activities conducted to determine nature and extent of fuel contamination; interim cleanup measures implemented as part of this project; and an evaluation of exposure risk associated with the fuel release.”

We believe going forward with the risk assessment specific meeting in Sept will strengthen the public trust more than changing the intent of the meeting due to backlash. Our reasons for cancellation/postponement were legitimate and we proceed as planned. While we still intend to have the public meeting in November to discuss updates, the risk assessment meeting should come first. Lastly, there is no reason we can’t provide the public with an update on the water table and how this is affecting collection of data.

Allison,

Would you please give us your thoughts from NMED PA perspective?

Respectfully,

OTHANA ZUCH, GS-12, DAF

Public Affairs Specialist

377th Air Base Wing

Kirtland AFB, New Mexico

DSN 246-5991 COMM 846-5991

From: Lisa Mathai [mailto:This email address is being protected from spambots. You need JavaScript enabled to view it.]

Sent: Monday, July 24, 2017 11:29 AM

To: Agnew, Diane, NMENV <This email address is being protected from spambots. You need JavaScript enabled to view it.>

Cc: LYNNES, KATHRYN D HQE USAF AFGSC 377 MSG/SAF/IEE <This email address is being protected from spambots. You need JavaScript enabled to view it.>; BLAYLOCK,

EVA D GS-11 USAF AFGSC 377 ABW/PA <This email address is being protected from spambots. You need JavaScript enabled to view it.>; ZUCH, OTHANA R GS-12 USAF

AFGSC 377 ABW/PA <This email address is being protected from spambots. You need JavaScript enabled to view it.>; O'GRADY, HOLLY M GS-13 USAF AFCEC AFCEC/CZOW

<This email address is being protected from spambots. You need JavaScript enabled to view it.>; BODOUR, ADRIA A CIV USAF HAF AFCEC/CZRX

<This email address is being protected from spambots. You need JavaScript enabled to view it.>; CASAREZ, ANGELINA M GS-12 USAF AFMC AFCEC/PA

<This email address is being protected from spambots. You need JavaScript enabled to view it.>; CARABAJAL, SHANNON R GS-11 AFMC AFCEC/DSP

<This email address is being protected from spambots. You need JavaScript enabled to view it.>; Majure, Allison, NMENV <This email address is being protected from spambots. You need JavaScript enabled to view it.>; Sanchez,

Amy E. SPA <This email address is being protected from spambots. You need JavaScript enabled to view it.>; Salazar, Carlos F SPA

<This email address is being protected from spambots. You need JavaScript enabled to view it.>; Rachel Hobbs <This email address is being protected from spambots. You need JavaScript enabled to view it.>; Dreeland, Linda E

CIV USARMY CESPA (US) <This email address is being protected from spambots. You need JavaScript enabled to view it.>; Julie McNeill

<This email address is being protected from spambots. You need JavaScript enabled to view it.>; Gabriele Caligiuri <This email address is being protected from spambots. You need JavaScript enabled to view it.>; RENAGHAN, BRIAN J

GS-13 USAF AFMC AFCEC/CZRX <This email address is being protected from spambots. You need JavaScript enabled to view it.>

Subject: [Non-DoD Source] Re: September Public Meeting

Hi Diane,

We currently have Thurs, Sept 28 reserved at the PAC if we want to have a meeting. My two

cents are that providing a project update/overview from the technical working groups would

be a good idea. Presumably, a path forward on the risk assessment will be known by then

because you know it'll come up!

lisa

On Mon, Jul 24, 2017 at 10:59 AM, Agnew, Diane, NMENV <This email address is being protected from spambots. You need JavaScript enabled to view it.>

wrote:

Good morning:

Below is a link to a KOB story that ran on BFF this morning:

http://www.kob.com/albuquerque-news/canceled--jet-fuel-spill-meeting-irks-activistskirtland-

air-force-base-kafb/4550818/?cat=500

I believe that the Air Force has September 29th reserved and held for a public meeting, if

warranted. I know that the brainstorm behind that was to present on the Risk Assessment

but given the public response to the cancellation of the July meeting I wanted to see what

the group thought about using September 29th to present the outcome of the technical

working group meetings. It can be a brief presentation of what our objectives were with a

30,000 ft outline of what is next and the timeline.

Diane

Diane Agnew

Hydrologist

New Mexico Environment Department

121 Tijeras Avenue, NE Ste 1000

Albuquerque, NM 87102

(505) 222-9555 (Direct)

(505) 660-3809 (Mobile)

https://www.env.nm.gov

--

Lisa Mathai

Applied Anthropologist/Stakeholder Involvement

Neptune and Company, Inc.

1435 Garrison St, Suite 201

Lakewood, CO 80215

Office: 720-746-1803, ext. 1016

Mobile: 719-661-4610

 

9.6.2017

January 2017 NMED RFI (Agnew)

Overview

2

 RFI Report has three major areas of concern, as

detailed in NMED’s August 3, 2017 letter

Incomplete characterization of the dissolved-phase groundwater plume(s)

Technically incomplete and biased concentration trend analyses and estimation of degradation rates

Incomplete delineation of vertical and horizontal extent of light non-aqueous phase liquid (LNAPL)

 Incomplete and inaccurate conceptual site model

 Omission of supporting data and documentation for

crucial analyses of soil vapor and contaminant fate and

transport

 RFI does not include or discuss anomalous data

 Some data not discussed or interpreted without explanation

 RFI appendices include reports not previously submitted or reviewed

 

The NMED 9/6/17 report is critical of the 2017 RFI with respect to the following:

 

Regulatory Context – screening must be to the residential level on and offsite;

 

Vadose Zone analysis – inadequate evidence for LNAPL migration and vertical distribution;

 

LNAPL analysis – inadequate understanding of LNAPL horizontal and vertical 3-dimensional distribution -- Soil vapor concentration data represent single points in the vadose zone and are not representative of a large area, by design;

Increasing benzene concentrations between Q4 2015 and Q4 2016 point to residual LNAPL in vadose zone and a continuing source

• Use of historic LNAPL thickness measurements is flawed
• Increasing benzene concentrations between Q42015 and Q4 2016 point to residual LNAPL in vadose zone and a continuing source
• Use of historic LNAPL thickness measurements is flawed
• Water tables started to rise in2009 when the well network wasl imited in extent to the north.
• Submerged well screens are not reliable data points for presence/absence of LNAPL
• 85% of current well network submerged
• No measured LNAPL doesn’t mean that no LNAPL present

 

Groundwater  --  RFI references slug test results without addressing comments and concerns of data quality and data analysis [Note: See USEPA comments re: failure to calibrate tools],

Assignment of shallow, intermediate, and deep well designations based on original drilling classification and independentofQ4 2015 water table

RFI minimally discusses rising water table

Concentration trend analyses and discussion need to address potential impact of rising water table

InQ4 2015, 15 of water table wells were not submerged

Water table is as much as 13feet above well screens, more equivalent to intermediate well classification

Q4 2015 monitoring data “missing” top/water table portion of EDB plume

Compound Specific Isotope Analysis(CSIA)  referenced in the RFI report and associated appendices includes 2013 dataset

Lacks discussion of 2013 CSIA data quality and usability concerns expressed by NMED and EPA

Degradation analysis and discussion is inadequate

Robust analysis of degradation indicators crucial for supporting RFI statements on dominant degradation mechanisms (e.g., hydrolysis)

Degradation analysis technically flawed,

 Groundwater CSM erroneously oversimplifies groundwater contaminant transport forces to just advection and hydraulic dispersion

 CSM in general lacks a comprehensive synthesis of degradation indicators and potential mechanisms of contaminant degradation

 

Conceptual Site Model --  

RFI oversimplifies forces influencing LNAPL migration, attributing migration solely to gravity

RFI conceptual site model (CSM) incorrectly assumes LNAPL did not reach groundwater until2009 at a depth of480 feet belowground surface (bgs)

LNAPL was continuously released for potentially decades as the water table lowered to the 2009 depth.

During that time, LNAPLwas migrating through the vadose zone and may have reached ground water much earlier than 2009 (Emphasis in original)

 The vadose zone CSM focuses on soil vapor and over simplifies residual LNAPL

 CSM inaccurately claims that “all contaminant mass” has been removed from the source area to a depth of 20 feet Conceptual Site Model

The vadose zone CSM focuses on soil vapor and over simplifies residual LNAPL

Contaminated pore water is a component of vadose zone contamination

Discussion does not address potential “lenses” of LNAPL throughout the vadose zone with the heterogeneous distribution of fine-grained units to depth

CSM inaccurately claims that “all contaminant mass” has been removed from the source area to a depth of20 feet

Soil removal to residential soil screening levels only

NMED Conclusions and Recommendations are:

Data gaps remain that must be addressed before moving  to Corrective Measures Evaluation:

Confirmation of EDB plume at water table

Delineation of LNAPL nature and extent both vadose zone and saturated zone, vertically and horizontally

Completion of robust degradation and concentration trend analysis

 

From:                        Agnew, Diane, NMENV

To:                             This email address is being protected from spambots. You need JavaScript enabled to view it.; This email address is being protected from spambots. You need JavaScript enabled to view it.; This email address is being protected from spambots. You need JavaScript enabled to view it.; This email address is being protected from spambots. You need JavaScript enabled to view it.

Cc:                             This email address is being protected from spambots. You need JavaScript enabled to view it.; This email address is being protected from spambots. You need JavaScript enabled to view it.

Subject:                    RFI Comments Letter

Date:                         Thursday, December 21, 2017 5:55:56 PM

Attachments:           DRAFT_RFI_Report_Comments.doc

Hello:

Attached is the draft letter with NMED comments on the RFI Report dated January 2017. This letter incorporates the comments received from Dennis, Mike Timmer, and Pat Longmire as well as my own comments. I included the EPA comments as an attachment to the letter as I thought that trying to incorporate them into the letter format could lose the impact of their comments. I instead added text stating that the Air Force must review and address their comments as part of the response.

Pat’s comments on the appendices were very well written as they were, so I opted to put those in as attachments as well.

 

There are 100 comments on the RFI Report, not counting the comments that Pat had on three of the appendices and the EPA comments. I have not called this letter an approval with conditions as I am not sure we can justify that classification given the quantity and nature of the comments on the report. There are some substantial technical errors that we have already raised in our August and NOD letters in addition to valid concerns and comments Mike raises on their conceptualization of LNAPL at the water table and use of the term “bioslurping.” My opinion is that we should call this a Notice of Disapproval.

 

As a reminder, the path forward we agreed to at the September working group meetings is that the Air Force will take our comments and generate a table that indicate which edits will be in the revised RFI Report and which will be captured in the RFI Addendum. We agreed to removing Appendix T altogether, waiting to do the thorough and robust degradation analysis during the CME process after all of the data gaps have been filled. They were also already looking into the CSIA appendix to start working on updating the appendix with the 2015 CSIA data.

 

I am out of the office Friday, December 22nd thru 26th because the pre-school is closed. I will keep my phone handy if anything comes up that we should discuss before next week.

Merry Christmas!

Diane

Diane Agnew

Hydrologist

New Mexico Environment Department 121 Tijeras Avenue, NE Ste 1000

Albuquerque, NM 87102

(505) 222-9555 (Direct)

(505) 660-3809 (Mobile)

https://www.env.nm.gov

 

January 19, 2018 DRAFT

NMED NOTICE OF DISAPPROVAL

RESOURCE CONSERVATION AND RECOVERY ACT INVESTIGATION REPORT

BULK FUELS FACILITY SPILL

SOLID WASTE MANAGEMENT UNIT ST-106/SS-111

KIRTLAND AIR FORCE BASE

EPA ID# NM9570024423, HWB-KAFB-MISC

 

As stated in NMED’s August 3, 2017 letter, there are three primary issues with the RFI Report as submitted on January 20, 2017:

1. Incomplete characterization of the dissolved-phase groundwater plume(s);
2. Technically incomplete and biased estimates of concentration trends and degradation rates; and
3. Incomplete delineation of the vertical and horizontal extent of light non-aqueous phase liquid (“LNAPL”).

 

NMED has completed a comprehensive review of the RFI Report and detailed comments are presented below. Due to the extensive outstanding data gaps in the characterization of dissolved-phase plumes and the LNAPL mass, the RFI Report is deemed incomplete and cannot be approved as submitted. The comments listed below must be corrected in either a revised RFI Report or in an addendum to the original RFI Report. NMED is open to meeting with the Permittee to discuss a path forward for resolution of comments on the RFI Report.

 

3.The RFI Report discusses vapor testing in soil and on-base industrial buildings, including the issue of vapor intrusion into industrial buildings. The Permittee’s discussion of the potential for groundwater contaminant diffusion and vapor transport, as it pertains to the potential for vapor intrusion both on-base and off-base, is piecemeal and does not compare off-base soil vapor and groundwater data with NMED risk-based screening levels. The Permittee shall provide a rigorous analysis of the potential for soil vapor contamination to migrate into homes and buildings located off-base and the findings integrated into the Conceptual Site Model presented in the RFI Report (Section 7).

 

4. … In particular, Q4 2015 water table levels in Figure 6-35 indicate a relatively flat gradient at the plume-scale with a component of groundwater flow towards the Veterans Administration (“VA”) Hospital water supply well.

 

10. Permittee’s Statement, p. ES-12, 1^st paragraph: “Dissolved-phase fuel-related contamination has been delineated.”

NMED Comment: The Permittee’s assertion that the dissolved-phase contamination has been delineated is no longer valid due to the continuing rising water table and the resulting submergence of groundwater monitoring well screens. The Permittee shall amend this statement to acknowledge the outstanding data gap at the water table and that NMED has required the Permittee to install additional water table groundwater monitoring wells.

 

24. NMED Comment, Section ES-6, Remaining data gaps: The Permittee shall add a bullet to state that additional information is required on locations of EDB partitioning out of the LNAPL and the rate(s) of partitioning under varying redox conditions. Additionally, a bullet is required to address the need for revising and updating the CISA that was conducted at the Site to obtain a more meaningful and robust analysis of residual and degraded fractions of EDB. The CSIA included in the RFI Report is not technically defensible due to coelution of benzene and other organic compounds with EDB, not using two-dimensional gas chromatography as the preferred analytical method, EDB concentrations at detection limits of analytical instruments, and lack of fresh LNAPL samples for carbon isotope analysis on EDB.

 

 

25. Permittee’s Statement, p. ES-24, 1^st list item: “Sufficient data were collected to characterize the nature and extent of fuel-related contamination at the Site with the exception of the data gaps listed below.”

NMED Comment: This statement is incorrect and overstates the conclusions that can be drawn from the data at the Site and is in conflict with the statement of “exception of data gaps listed below.” The Permittee must revise this statement to more clearly state that data gaps remain in the characterization of nature and extent of fuel-related contamination at the Site.

 

26. Permittee’s Statement, p. ES-24, 2^nd bullet: “Groundwater: The dissolved-phase EDB plume boundary is not fully defined in the northwestern most area of the plume in AOI 9.”

NMED Comment: The Permittee must revise this statement to clearly state the existing data gap for the dissolved-phase plumes at the water table, including EDB and benzene, due to submergence of groundwater monitoring well screens with the rising water table. Additionally, the Permittee must also incorporate data from the two newest well nests, KAFB-106235 and KAFB-106236, and determine if a data gap remains at the northwestern edge of the dissolved-phase EDB plume.

 

27. Permittee’s Statement, p. ES-25, 2^nd bullet, “Groundwater: Install at least one additional GWM well cluster north and west of KAFB-10626 in order to fully delineate the dissolved-phase EDB plume in AOI 9 and provide an additional sentinel well in that area.”

NMED Comment: A single GWM well cluster is not sufficient to address the dissolve-phase EDB plume data gap. The new groundwater monitoring wells scoped during the September 6-8, 2017 technical working group meetings, along with incorporation of existing monitoring well infrastructure, is the first phase of well installation and data collection to make progress towards addressing the data gap in the dissolve-phase plumes at the water table. The Permittee must revise this statement to include the additional wells that were scoped during the September 6-8, 2017 technical working groups as well as indicate the work plan to be submitted to complete well drilling, installation and sampling. Additionally, there is a reference to a “sentinel well” without defining the designation and purpose of a sentinel well. The Permittee must describe and consistently use the term sentinel well through the RFI Report, including the Executive Summary.

 

57. Permittee’s Statement, p. 5-6, 2^nd paragraph: “The disappearance of measurable floating LNAPL prior to the submergence of the GWM well screens indicates that no substantial amount of floating LNAPL exists.”

NMED Comment: See General Comment #6 above regarding the occurrence of LNAPL in groundwater. The statement that there is “no substantial amount of floating LNAPL” in monitoring wells at the Site is misleading. All groundwater monitoring wells in the source area, except for the two monitoring well nests installed for the In-Situ Bioremediation Pilot Test, are submerged and no longer have well screens at the water table. The lack of measurable LNAPL in monitoring wells at the Site may be due to the submergence of monitoring well screens by the rising water table. Moreover, an evaluation of the site-specific effective solubility values for constituents such as benzene, relative to detected groundwater concentrations, indicate that LNAPL persists in the source area. The Permittee must revise the cited text and RFI Report to acknowledge the existing data gap for characterization of LNAPL floating inside monitoring wells at the site. The Permittee must include a thorough evaluation of groundwater concentrations and effective solubility as a line of evidence for the presence of LNAPL in the source area. The Permittee shall discuss the existence of residual LNAPL at the Site submerged by groundwater.

 

59. NMED Comment, Section 5.3.5, LNAPL Data Gaps: The horizontal and vertical extent of LNAPL has not been adequately defined. The timing of the rising water table with the installation of groundwater monitoring wells at the water table resulted in a limited and too short period of monitoring to definitively determine extent of LNAPL at the Site. The Permittee leverages soil vapor data as the only other line of evidence for defining LNAPL but does not acknowledge the limitations of the soil vapor data set, including SVMP density on-base verses off-base and impact from poorly sealed SVMPs. Additionally, the discussion of LNAPL extent does not include an evaluation of effective solubility and groundwater concentrations for constituents such as benzene, an important tool for evaluating the occurrence of LNAPL in the subsurface.

 

 

88. Permittee’s Statement, p. 8-2, 2^nd paragraph: “As of Q4 2015, the nature and extent of groundwater contamination at the Site has been characterized with the exception of the northwestern most area of the dissolved-phase EDB plume, where concentrations at KAFB-10626 are below the MCL, but have been increasing.”

NMED Comment: This conclusion by the Permittee fails to acknowledge the loss of groundwater monitoring wells screened at the water table and the resulting critical data gap of dissolved-phase constituent concentration data at the water table. The Permittee must revise this conclusion.

 

95. NMED Comment, Appendix T, Trend Analysis of EDB and Benzene in Groundwater at Kirtland Air Force Base, Q4 2015: Please see Attachment C for NMED technical memorandum on errors, comments, and revisions required for Appendix T.

 

The EPA has also completed a review of the RFI Report and their comments are included as Attachment D to this letter. The Permittee must review, address, and make the necessary revisions in response to the EPA comments.

 

The Permittee must submit a revised RFI Report in addition to an RFI Addendum Report to address the deficiencies noted in this letter. NMED recognizes that the Permittee has submitted a work plan to collect data to address the existing data gaps in the characterization of LNAPL at the Site, and a work plan for the drilling and installation of water table groundwater monitoring wells. Any additional investigative work to address the data gaps in the RFI Report and noted in this letter will need to be done under a work plan that is submitted and approved by the NMED in accordance with the Permit. As part of the response to this letter, the Permittee must submit a timeline for deliverables to include submittal of a revised RFI Report and RFI Addendum Report.

 

Attachment B

Memo To:	John Kieling (HWB)
From:	Dr. Patrick Longmire
cc:	Diane Agnew (GWQB), Michelle Hunter (GWQB)
Date:	December 8, 2017

 

Re:	Review of Appendix R, Quant-ArrayTM-Chlor and Reduced Gases (Hydrogen/Methane/Ethene/Ethane) Study for the RCRA Facility Investigation Report, Bulk Fuels Facility, Kirtland Air Force Base

The Memo concludes as follows:

Concentration decreases of EDB under aerobic conditions downgradient from the LNAPL/dissolved phase interface may result from dilution/mixing along groundwater- flow paths. It is uncertain to what extent hydrolysis reactions play a role in controlling EDB degradation under aerobic conditions.

 

Attachment C [to NMED Draft NOD]

 

Memo To:	John Kieling (HWB)
From:	Dr. Patrick Longmire
cc:	Diane Agnew (GWQB), Michelle Hunter (GWQB)
Date:	December 8, 2017
Re:  Review of Appendix T, Trend Analysis of EDB and Benzene in Groundwater for the RCRA Facility Investigation Report, Bulk Fuels Facility, Kirtland Air Force Base    This appendix would greatly benefit by coupling the relevant and detailed trend-statistical analysis with aqueous geochemical, microbiological, and hydrological data and information collected at KAFB. A first order analysis should establish concise trends in contaminant chemistry, including scrutinizing field sampling protocols used at monitoring wells that can influence variability in groundwater analytical results and influence subsequent statistical and trend analysis. Consistent sampling protocols practiced at each monitoring well will limit some of the variability that occurs in groundwater chemistry under steady-state conditions. This may help in determining why some monitoring wells are not suitable or capable of providing a useful trend analysis. Consistent sampling protocols practiced at each monitoring well will improve statistical analysis of groundwater chemistry data. Evaluating equilibrium versus non-equilibrium conditions and solute residence time should be included in the trend analysis to identify and understand important hydraulic and biochemical processes influencing the fate and transport of EDB, benzene, and other contaminants present in groundwater at KAFB. Presence of LNAPL in monitoring wells should be addressed and its impact on trend analysis of contaminants ascertained.  (Emphasis supplied).

ATTACHMENT D [to NMED Draft NOD]

APRIL 11, 2017 USEPA REVIEW OF THE KAFB RFI FOR THE BULK FUELS FACILITY RELEASE SOLID WASTE MANAGEMENT UNIT ST-106/ST-111

 

Provided below are snippets from the EPA review of the 2017 RFI.

EPA reviewer’s concerns and comments are:

• Rising groundwater, submerged monitoring well screens and relation to EDB concentrations
• The extent of the vertical plume is still unknown
• The hydraulic connection of the deeper aquifer with the municipal production wells
• The need for discussion of rising water table and gradient changes towards the Ridgecrest well field.
• Limited utility of stratigraphy logs due to problems with logging instrument calibrations
• Regional stratigraphy not shown
• Unknowns about the plume shape and the effect of the Ridgecrest and Charles well fields on the plume movement
• Connections between shallower and deeper parts of the aquifer causing EDB to move toward the Ridgecrest wells.
• A worst case strategy should be considered for corrective action that EDB continues toward the Ridgecrest wells
• Giving the impression that the mass of LNAPL has been removed because pipelines were removed
• Contradictions in the RFI about plume movement to the northeast.
• Ignoring important factors in the RFI cited by the Water Utility Authority in their draft water future pumping forecast:

 

 

 

 

 

 

[Citizen Action Note:  The following emails, agenda and public notice led up to the cancellation of the July 27, 2017public meeting. Problems cited in the meeting agenda from July 13, 2017 differ substantially from the reasons given in the public announcement].

From: Agnew, Diane, NMENV

To: LYNNES, KATHRYN D HQE USAF AFGSC 377 MSG/SAF/IEE; BODOUR, ADRIA A CIV USAF HAF AFCEC/CZRX;

O"GRADY, HOLLY M GS-13 USAF AFCEC AFCEC/CZOW

Cc: Kieling, John, NMENV; Simpler, Trent SPA

Subject: Re: Meeting Requested - RFI Report

Date: Tuesday, July 11, 2017 4:02:02 PM

Hi Kate,

The driver is the need to discuss the RFI ahead of the upcoming public meeting which is a short two weeks away.

I will get an invite sent out for Thursday afternoon. Can you confirm who will attend from AF and AFCEC? I will

need an email address/contact information for Brian.

Diane

________________________________________

From: LYNNES, KATHRYN D HQE USAF AFGSC 377 MSG/SAF/IEE <This email address is being protected from spambots. You need JavaScript enabled to view it.>

Sent: Tuesday, July 11, 2017 3:57 PM

To: Agnew, Diane, NMENV; BODOUR, ADRIA A CIV USAF HAF AFCEC/CZRX; O'GRADY, HOLLY M GS-

13 USAF AFCEC AFCEC/CZOW

Cc: Kieling, John, NMENV; Simpler, Trent SPA

Subject: RE: Meeting Requested - RFI Report

I can do Thursday or Friday afternoon. It would be better for Adria and Brian to attend in person rather than by

phone and they will not here until the end of the month. What is driver for meeting this week?

1. KATHRYN D. LYNNES, HQE

Senior Advisor, SAF/IEE

Bulk Fuels Facility Project

2000 Wyoming Blvd. SE

Kirtland AFB, NM 87117

505-846-8703 DSN 246-8703

Mobile: 505-239-0584

This email address is being protected from spambots. You need JavaScript enabled to view it.

-----Original Message-----

From: Agnew, Diane, NMENV [mailto:This email address is being protected from spambots. You need JavaScript enabled to view it.]

Sent: Tuesday, July 11, 2017 3:49 PM

To: LYNNES, KATHRYN D HQE USAF AFGSC 377 MSG/SAF/IEE <This email address is being protected from spambots. You need JavaScript enabled to view it.>; BODOUR,

ADRIA A CIV USAF HAF AFCEC/CZRX <This email address is being protected from spambots. You need JavaScript enabled to view it.>; O'GRADY, HOLLY M GS-13 USAF

AFCEC AFCEC/CZOW <This email address is being protected from spambots. You need JavaScript enabled to view it.>

Cc: Kieling, John, NMENV <This email address is being protected from spambots. You need JavaScript enabled to view it.>; Simpler, Trent SPA <This email address is being protected from spambots. You need JavaScript enabled to view it.>

Subject: [Non-DoD Source] Meeting Requested - RFI Report

Importance: High

Hello:

NMED would like to meet with the Air Force and AFCEC to discuss the RFI Report submitted in January 2017. We

would like to schedule the meeting as soon as possible - please let me know your availability to meet Thursday, July

13th and Friday, July 14th. The meeting will be in Santa Fe at the Runnels Building. Please also provide a list of

attendees and I will get a calendar invite sent with details on the meeting.

Thanks in advance for your quick attention to this request.

Diane

Diane Agnew

Hydrologist

New Mexico Environment Department

121 Tijeras Avenue, NE Ste 1000

Albuquerque, NM 87102

(505) 222-9555 (Direct)

(505) 660-3809 (Mobile)

https://www.env.nm.gov <https://www.env.nm.gov

 

Kirtland Air Force Base Fuel Leak

RCRA Facility Investigation Report [Agenda for a meeting]

July 13, 2017 2 p.m. – 4 p.m.

1. General overview

 

2. Delineation and monitoring of groundwater plumes a. Submerged well screens – insufficient monitoring well network across water table for shallow plume definition
3. Capture zone analysis not representative
4. Projected water table rise à urgent need to address sentinel wells
5. Monitoring network and frequency i. Add in KAFB-106041 and KAFB-106231
6. Quarterly monitoring of complete network for EDB and BTEX
7. Degradation analysis in RFI Report a. Appendix T degradation analysis fundamentally flawed
8. Over-estimate of degradation rates
9. Delineation of LNAPL extent a. RFI fails to evaluate effective solubility concentrations in groundwater
10. Multiple lines of evidence point to existence of LNAPL at and near the groundwater
11. RFI Report Path Forward
12. Public Meeting Path Forward

 

From: 377 ABW/PA Administrative Mailbox

To: 377 ABW/PA Administrative Mailbox

Subject: Bulk Fuels Facility July 27 Meeting Cancellation Notice

Date: Wednesday, July 19, 2017 11:32:56 AM

Good morning. Please see the notice below.

Kirtland AFB Bulk Fuels Facility July 27 public information meeting cancelled

ALBUQUERQUE, N.M. - The Air Force and the New Mexico Environment Department, or NMED, announced today the cancellation of the public information meeting, poster session and technical deep dive seminar scheduled for Thursday, July 27 at the African American Performing Arts Center. The next scheduled public meeting for the project will be Nov. 14, 2017 from 6 to 8:30 p.m.

The July meeting is being cancelled to provide more time to review two major milestones on the project: the Resource Conservation and Recovery Act Facility Investigation Report characterizing the leak and the Risk Assessment Report delineating risk in support of future decision-making. Both of these documents present technical evaluation information about the Bulk Fuels Facility investigation activities conducted to determine nature and extent of fuel contamination; interim cleanup measures implemented as part of this project; and an evaluation of exposure risk associated with the fuel release.

Interim measures continue to advance fuel-contamination cleanup. The groundwater treatment system continues to extract and treat ethylene dibromide-contaminated groundwater with a fourth extraction well coming online in the fall. Work is also ongoing in the source area. The first phase of the biodegradation pilot test has begun and NMED is reviewing the work plan for soil coring.

For more information please contact 377th Air Base Wing Public Affairs at 505-846-5991, or This email address is being protected from spambots. You need JavaScript enabled to view it., or Air Force Civil Engineer Center Public Affairs at 866-725-7617, or by email, This email address is being protected from spambots. You need JavaScript enabled to view it..

- 30 -

Respectfully,

377th ABW, Kirtland AFB, Public Affairs

 

3/20/2018 MEMO to Dennis McQuillan (NMED) from Rick Shean (WUA)

Re; Water Authority Comment and Concerns on NMED’s 2018 Strategic Plan for the Kirtland Air Force Base, Bulk Fuels Facility Leak Site

 

“… In summary, the Water Authority is alarmed at the proposal of a strategy that allows for no active remediation given the proximity of water supply wells and the limited network of groundwater monitoring wells.  In addition, the strategies in the plan are disconnected from the stated goal of protecting drinking water and undermine Water Authority’s ability to ensure the safety and quality of drinking water.  Furthermore, the 2018 Plan no longer includes a strategy or emphasis on characterizing the remaining source at the site, a critical data gap for protecting drinking water and the aquifer. …

 

 “Inclusion of the Water Authority’s logo on the final page of the Plan implies our endorsement of the strategies and project timeline.  It also overstates our involvement in the development of the path forward for the BFF site.  … The Water Authority therefore requests that our logo be removed from the strategic plan.”

As stated in NMED’s August 3, 2017 letter, there are three primary issues with the RFI Report as submitted on January 20, 2017:

1. Incomplete characterization of the dissolved-phase groundwater plume(s);
2. Technically incomplete and biased estimates of concentration trends and degradation rates; and
3. Incomplete delineation of the vertical and horizontal extent of light non-aqueous phase liquid (“LNAPL”).

 

[Citizen Action Note: the following Email showing questionable results about Compound-Specific Isotope Analysis (CSIA) testing. No agenda or minutes of the meeting were furnished in the PRR response].

From: McQuillan, Dennis, NMENV

To: Julie McNeill; Majure, Allison, NMENV; Broom, Chuck; Clark, Scott; Dreeland, Linda; Duley, Megan; Eric Klingel;

Graves, Dustin; Hobbs, Rachel; Hunter, Michelle, NMENV; Jercinovic, Devon; Kieling, John, NMENV; Longmire,

Patrick, NMENV; Lynnes, Kate; Meyer, Brent; O"Grady, Holly; Phaneuf, Mark; Pullen, Steve, NMENV; RENAGHAN,

BRIAN J GS-13 USAF AFCEC AFCEC/CZRX; Rust, Colleen; Salazar, Carlos; Sanchez, Amy; SEGURA,

CHRISTOPHER G GS-13 USAF AFCEC/CZO; Snyder, Jay ; Timmer, Michael, NMENV; Simpler, Trent; Wortman,

Ryan; Yurdin, Bruce, NMENV; Kieling, John, NMENV; Salem, Brian, NMENV; Borrego, Juan Carlos, NMENV

Cc: Megan Duley

Subject: RE: KAFB BFF RFI Discussion

Date: Wednesday, February 7, 2018 10:07:36 AM

Attachments: image001.png

CSIA.EPA.Kirtland Air Force Base, New Mexico - 07.01.14 - Burden.pdf

Dear Colleagues,

Thanks to everyone for a terrific meeting yesterday.

As I discussed in our meeting, Dr. John Wilson’s review of the 2013 CSIA testing (copy attached) determined that is was unlikely that EDB was separated from the other fuel constituents by two dimensional gas chromatography. Therefore, we believe that the RFI should acknowledge that the 2013 CSIA testing was done, but the results should not be included in the RFI due to concerns about coelution of other fuel constituents with EDB, and that the resulting δ13C values represent the combination of constituents rather than just EDB. Any member of the public may nonetheless get a copy of the 2013 CSIA test results thru a U.S. FOIA or N.M. IPRA request, but there is no point of

including these questionable test results in the RFI.

Best regards,

Dennis McQuillan

Chief Scientist

New Mexico Environment Department

1190 St. Francis Dr.

PO Box 5469

Santa Fe, NM 87502

505-827-2140 desk

505-660-1592 cell

This email address is being protected from spambots. You need JavaScript enabled to view it.

 

Meeting Date: March 21, 2018 Staff Contact: Rick Shean, Water Rights Program Manager TITLE: OB-18-4 – Status Update [to the Water Utility Authority] for the Kirtland Air Force Base Bulk Fuels Facility Fuel Leak Cleanup

ACTION: Received the KAFB Cleanup Status Update

…The strategies include implementing a robust monitoring and wellhead protection program, collapsing the dissolved phase plume, and meet or exceed all public involvement requirements. In a shift from previous years, the NMED has revised Strategy 2 is now specific to monitoring natural attenuation of fuel contamination; this strategy was previously focused on characterization of light non-aqueous phase liquid (LNAPL) at the site. The Air Force has two work plans approved with conditions by the NMED that will collect data to address LNAPL at the site and take steps to address the reduction in the number and location of groundwater monitoring wells screened at the water table. The Air Force brought online a fourth groundwater extraction well in February 2018 and added pretreatment infrastructure at the groundwater treatment system. The pre-treatment addresses sediment and bacterial biofilm that may enter the system. The Air Force has treated over 350 million gallons of water contaminated by ethylene dibromide (EDB) since the extraction system began operation in June 2015. All four groundwater extraction wells are currently in operation and treated effluent is either used for irrigation at the KAFB golf course or is injected at former water supply well KAFB-7.

…

[Water Authority] STAFF COMMENTS: The NMED 2018 Strategic Plan includes a revised strategy for the site that focuses on monitoring natural attenuation (also known as “monitored natural attenuation” or “MNA”). This is a passive remediation approach that requires an extensive monitoring well network. Additionally, natural attenuation is typically applied at sites with decreasing concentrations, following a robust technical analysis of degradation rates. Currently, 85% of the monitoring well network is submerged and not viable for monitoring natural attenuation and increasing concentrations are observed in the source area. Water Authority staff are not supportive of an MNA approach for any site, particularly the BFF site, in the service area. The NMED strategic plan also reflects recent correspondence from the NMED to the Air Force that downplays the need for a revised plume capture analysis and no longer includes key stakeholder agreements such as RFI Addendum to address the numerous technical issues in the 2017 RFI Report. The Water Authority’s independent contractor, INTERA, Incorporated, provided their review of the RFI and the Water Authority’s concerns for the document at the Nov. 16, 2017, Water Authority Board Meeting. (Emphasis supplied).

Attachment:

Kirtland Air Force Base Fuel Leak Cleanup Status Update – 21 March 2018

Kate Lynnes Air Force Senior Advisor Scott Clark Restoration Program Manager

Updates:

• Notice of Deficiency (NOD) of 16 Nov has been resolved
• Overview of new Data Gap Monitoring Wells
• Upgrades to the GWTS
• New Extraction Well KAFB-106239 up and running

[Citizen Action Comment: Note that the many pages of technical comments in the Draft NMED NOD of January 19, 2018 are not addressed in the status report]. 

 

[Citizen Action Comment:  Excerpt p.6-7 from 2011 WPAB Annual Report re INTERA findings for KAFB jet fuel spill.[13]

… Intera suggested that the tests being performed to determine hydraulic parameters of the vadose zone and aquifer may also not be adequate for developing an accurate conceptual model for designing a final remediation system.”

 

In 2018, the WUA presented the following paper from INTERA that showed USEPA Guidance was not being followed for the modeling assessing capture wells for contamination in the aquifer]:

Uncertainty and Hydraulic Containment of the BFF EDB Plume, INTERA for the Water Utility Authority (2018)

 

[Citizen Action Note: There was no public posting regarding the technical issues that were raised by the Water Utility Authority for INTERA’s report on “Uncertainty Hydraulic Containment for the BFF EDB Plume;” papers on Monitoring Diffusion Bags, and; spotty operation of extraction wells.]

 

 

 

[1] The spill has been estimated to be as high as 24,000,000 gallons. (NMED, William Moats). https://www.manufacturing.net/news/2012/05/new-mexico-says-jet-fuel-spill-could-be-larger  The 2018 Phase I RCRA Facility Investigation Report, without evidence, estimates that it could be between 3 and 14 million gallons, but settles for 5.9 million gallons. P. 2-4

[2] For a history of the fuel spill see: http://www.radfreenm.org/mm-kafb/kafb-overview/kirtland-jet-fuel-spill-historical-summary

[3] Ethylene Dibromide (EDB), Benzene, Toluene, Ethylbenzene, Xylene, Methylene Chloride, Tetrachloroethene (PCE), and 1,2-Dichloroethane (1,2-DCA). EDB is the predominant contaminant of concern to the outmost edge of the plume. Maximum contaminant limit of EDB in drinking water is 50 parts per trillion.

 

[4] https://www.env.nm.gov/HWB/documents/KAFB_4-2-2010_Bulk_Fuel_Spill_HWB_Letter.pdf

[5] March 31, 2014 – KAFB RCRA Facility Investigation Report for Groundwater Zone and RCRA Facility Investigation Report for Vadose Zone

[6] August 27, 2014 – KAFB retraction of March 31, 2014 RFI Reports

… “Currently, NMED is reviewing the RCRA Facility Investigation (RFI) Vadose and Groundwater Zone reports submitted in March 2014. The Air Force wants to ensure the finest quality RFI reports are under review and include the most current data. NMED and the Air Force have identified additional analysis requirements, clerical errors, and data gaps that were addressed by the 01 August 2014 [Work Plan].  Correcting and including this data gap information will provide improved RFI reporting. In light of these events, the Air Force requests a retraction of:the RFI reports until this new data can be collected and incorporated. We will address the data gaps when we resubmit the RFI and expect it will be best postured to meet or exceed RCRA standards. Kirtland and the AF remain committed to an effective and timely clean-up and appreciate your support and collaboration.

[7] Kirtland AFB BFF March 2014 Groundwater Zone RFI Report ES-7 “There are no remaining data gaps for SWMU SS-111 based on the results of the RFI.” KAFB claimed (P. 2-7, Section 2.4) that it had completed: ·Characterization of NAPL and dissolved-phase contaminants in the groundwater. · Characterization of the vertical extent of the dissolved-phase contamination in the groundwater and the effects of vertical gradients. · Characterization of the geology of the aquifer. · Characterization of the leading edge and the eastern and western margins of the NAPL, benzene, and EDB plumes. · Characterization of the groundwater immediately underneath the NAPL. · Characterization of groundwater quality and distribution. · Identification of groundwater flow direction and velocity, and aquifer hydraulic parameters such as hydraulic conductivity and porosity. · Identification of COCs.

[8] Prepared by Sundance Consulting, Inc., 8210 Louisiana Blvd, Suite C, Albuquerque, NM 87113.

[9] August 29, 2018 – KAFB Phase I Resource Conservation and Recovery Act (RCRA) Facility Investigation (RFI) Report for the Bulk Fuels Facility Spill

[10] “This Phase I RF\ Report summarizes all investigation activities and interim measures performed between 2000 and December 31, 2015. Investigations and interim measures conducted after December 31, 2015, will be included in a Phase II RFI Report.” August 29,2018 Letter Colonel Richard W. Gibbs, USAF to John Kieling, Bureau Chief, NMED Hazardous Waste Bureau.

[11]http://www.abcwua.org/uploads/FileLinks/c54f4c01c9504b5b90a3f72a5c891b1b/WPAB_2011_Annual_Report.pdf

[12] Geophysical logs provide a continuous analog or digital record that can be used to interpret lithology, bed thickness, potential aquifers or confining units, permeability, porosity, bulk density, hydraulic resistivity, moisture content, and specific yield.

[13]http://www.abcwua.org/uploads/FileLinks/c54f4c01c9504b5b90a3f72a5c891b1b/WPAB_2011_Annual_Report.pdf

 

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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 realized.  https://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 1^st 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 1^st 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 1^st 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 1^st Quarter 2016 was not filed until July 25, 2016.  The subsequent reports for the 2d and 3^rd 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.

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Citizen Action Comments on the 2016 Strategic Plan for the Kirtland AFB Bulk Fuels Facility Contamination of Albuquerque’s Aquifer

1/15/2016

 

 

As part of the developing Conceptual Site Model the following must be included:

1. Total estimated mass of EDB in each zone, i.e. vadose, LNAPL, and leading EDB GW plumes.
2. Total volume of fuel spilled (estimate) for aviation gas and diesel fuel.
3. Please provide flow direction and velocity at leading edge of the EDB plume.
4. Present effect on plume movement cause by pumping well/wells.
5. Provide a summary of the various EDB remediation models.
6. Provide please the capital and annual operating cost for the remediation of the EDB.
7. Discuss the likelihood of EDB reaching the Ridge Crest or other municipal wells.
8. Provide a Remediation Advisory Board which includes stakeholders
9. Discuss the comprehensive total cleanup plan for the Kirtland BFF spill (vadose, NAPL, EDB).
10. There is no Environmental Impact Statement for KAFB. KAFB and NMED Are currently taking segmented actions that require an EIS. Segmented actions include commitment of major resources to monitoring, extraction wells and infrastructure and injection wells, and treatment facilities.
11. No Conceptual Site Plan, no RCRA Facility Investigation and Corrective Measures Study exist for the KAFB fuel spill despite the expenditure of $100,000,000 in taxpayer revenues. Yet, large scale activities are being put in place on a “temporary” basis through the use of Groundwater Protection Bureau discharge permits outside the RCRA process. This leads to forced commitment of remedies that may be ineffectual and not cost effective. There is no information given for the costs of the various segmented actions taking place. So called “interim measures” are a steamroller approach to ignore the public. The Pump and Treat remedy is extremely expensive and is questionable when extraction of 25,000,000 gallons of water has achieved only 6 grams of EDB removal. NMED and KAFB have not addressed the earlier studies by both EPA and the National Academies of Science regarding the lack of effectiveness and high cost of Pump and Treat. NMED and KAFB are not revealing the costs of the P&T project including the cost of infrastructure, granulated activated charcoal (GAC) and the location and cost of disposal of the GAC. There is no means to evaluate the cost or success in terms of the total quantity of EDB that is approaching municipal wells.
12. Potential contamination of the “waters of the United States” is being allowed without a Clean Water Act permit through the use of a temporary permit for the former KAFB supply well #7 to discharge into the Tijeras Arroyo which flows to the Rio Grande. The GWPB process does not include the RCRA public participation that is required under RCRA. The GWPB and KAFB play a game of submitting applications and then withdrawing them after public comment. Then the application is modified and resubmitted with inadequate notice to derail further public consideration or challenges. This wastes public time and resources and frustrates any transparency. The persons notified on the GWPB applications are far fewer than the persons required to be noticed under the RCRA process. The discharge permits are not discussed at the quarterly poster shows so as to keep the public in the dark about shortcomings and vagueness of the applications.
13. The management of the EDB plume is abysmal with high turnover in Air Force and NMED personnel. The level of expertise is far from effective considering that the New Mexico Legislature requested independent scientific oversight for the plume.
14. It is unknown if the extraction well is having any effect on the EDB plume.
15. There has been no release of modeling data from three different models being conducted.
16. Criticisms of the lack of monitoring between the municipal wells and the EDB plume that were raised in the earlier EPA Region 6 model have been ignored. There are still an insufficient number of monitoring wells to characterize the aquifer on a local let alone the more regional area that may be affected by the EDB over time.
17. There is the nondisclosure of information and the sanitizing of information before it is presented to the public. Poster presentations are no substitute for what should be a much more in depth dialog with the public. There is no Citizen Advisory Board or a Remediation Advisory Board. Public comments are limited, transcripts are not provided and there is no practice of preserving such comments and whether there are responses. The only information presented is that which makes it appear that the regulatory agencies are taking control and cleaning up the EDB plume. In reality, there is no mass balance, no known volume for the spill, defective groundwater monitoring well screens, no technical information as to whether the water will remain safe, no operating capital costs, and no modeling results. There is the pulling of the EDB plume toward the entire Albuquerque basin as pointed out by Geologist John Hawley.
18. The public assurance that the drinking water is safe come from monitoring the municipal wells and not from the use of groundwater monitoring wells placed near to the municipal wells. As has been stated many times and ignored by NMED and KAFB, the municipal wells are pumping high volumes of water with a high dilution factor that precludes knowledge of the proximity of the EDB plume. Employees and the public using water at the Veterans Hospital are less than convinced of the reliability of testing, especially since the upper screen of the nearest monitoring well to the VA is defective. But NMED and KAFB keep on avoiding the realities of the inadequate monitoring situation.
19. Due to the lack of comprehensive planning and lack of independent and qualified oversight, there have been constant and costly errors made by NMED and KAFB as well as a round robin of reports and Notices of Violations. The managers at NMED and KAFB are/were clearly not qualified. Air Force commanders come and go as do NMED personnel. The latest change in the “A Team” has been the substitution of a “Highly Qualified Expert” for a microbiologist. A professional ongoing monitoring oversight board is needed.
20. There is no posting of comments from the public as that might indicate that the Emperor has no clothes. The public is treated as if it has no right to full access of information even though it is public taxpayer funds that are being squandered. For example, why aren’t the discharge permit applications and comments by the GWPB posted? Why are there no members of the public allowed to listen to the technical group discussions? All this is an intolerable arrogance on the part of NMED, EPA, the GWPB, the WUA, KAFB and its contractors. The current 60 day Notice of Intent to Sue under RCRA is an indication of public frustration with a process that is disingenuous and largely designed to make regulators “look good.”
21. Credit is taken for the Soil Vapor Extraction system removal of 500,000+ gallons of soil vapor. Not mentioned is the fact that 400,000 gallons of that removal was accomplished by the earlier SVE system and not the new and flawed SVE system that is not being operated at present.

 

 

David B. McCoy
Executive Director
Citizen Action New Mexico
POB 4276
Albuquerque, NM 87196-4276
505 262-1862
This email address is being protected from spambots. You need JavaScript enabled to view it.

 

Dr. Eric Nuttall, Ph.D.
1445 Honeysuckle Drive NE
Albuquerque, NM 87122
505 269-7840

 

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