On June 10, the ABQ Journal published a front page article titled: State rejects plan to clean up KAFB fuel spill.  This article, written by John Fleck, described NMED's denial of Kirtland's latest proposal to prevent EDB from hitting municipal wells.  Mr. Fleck quotes NMED's Hazardous Waste Bureau chief Tom Blaine who is in charge of oversight for the jet fuel cleanup:

“The proposed strategy would actively enhance the spread of contamination into the very resource NMED seeks to protect, Albuquerque’s drinking water supply.”

Mr. Blaine's written statement can be read in it's entirety here.  

Mr. Fleck also quotes John Stigda, a senior hydrologist with Intera Geo Science & Engineering Solutions in Albuquerque.  Intera and Mr. Stigda have been frequent advisors to the Water Utility Authority for independent technical advice on the jet fuel spill.  Mr. Fleck writes:

Blaine’s comments echo a technical evaluation done by groundwater scientist John Sigda of the consulting firm INTERA for the Water Authority. Sigda found the proposed pumping “would spread, not contain” the spilled fuel.

Sigda argued that the Air Force plan is doomed to failure because the Air Force’s proposed pump-and-treat well is so much smaller than the big supply wells run by the water utility. The Air Force hopes to divert the flow of contamination by pumping 500 gallons of water per minute. But the water utility wells already pump “many thousands” of gallons per minute, suggesting the Air Force proposal is too small to divert the main flow of contamination.

And even if it works, Sigda concluded, the Air Force plan would take “decades” for it to begin removing contamination from the groundwater.

The full text of Mr. Sigda's evaluation of the Kirtland proposal, written on May 1, 2014, can be read here.  Key quotes from this Intera document:

1. "Hydraulic capture and treatment is in general a feasible approach for achieving removal or containment of the migrating EDB plume, but the proposed design does 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."

2. (...) "the modeling conducted is far from adequate and cannot serve as a defensible foundation for designing an interim measure of hydraulic capture."

4. "The IM proposed design does not address how it will affect contaminants migrating away from the KAFB source area, especially whether the proposed design will increase spreading of the EDB plume “core” across other volumes of clean aquifer without active control in the source area."

5. "The proposed IM design does not demonstrate that it will not split the existing EDB plume nor does it demonstrate how much of the known EDB plume mass it will capture."

6. "The proposed design contains inconsistencies that must be resolved and makes assumptions that contradict available data."

This document continues with a section: Detailed Comments (1 - 7).  Comment 7 states:

The following inconsistencies must be resolved.

7.1. Page 1, 2nd paragraph: Additionally, 10-year pumping averages (2003 through 2013).

This statement is incorrect because the period from 2003 through 2013 constitutes 11 years.

7.2. Page 2, 1st regular paragraph: The final simulation, 500_South, indicates the lowest EDB concentrations over time. The lower concentrations at KAFB-3 are due to increased EDB plume capture by conceptual well, KAFB-3_South. 

For 500_South scenario, KAFB-3_South is the pumping well but the breakthrough curve is for KAFB-3, whereas, for other 3 scenarios, KAFB-3 is both the pumping well and monitoring well. As a result, comparison of the breakthrough curve for 500_South scenario to the curves for the other scenarios is not valid.

7.3. Page 2, next to last paragraph: Based on the groundwater model, increasing the pumping rate at KAFB-3 from its current 10 year average of 79 to 90 million gallons per year (150 to 170 gpm) to roughly 263 million gallons per year (500 gpm) will contain the EDB dissolved phase plume.

Figure 3 shows that none of the pumping scenarios ‘contain’ the EDB plume.

7.4. Page 3, 1st paragraph: The lead adsorber removes all of the EDB and the lag or second unit is essentially a backup unit that will pick up any EDB that makes it through the first bed.

Reword this sentence to: The lead adsorber is intended to remove all of the EDB...

7.5. Page 3, 2nd paragraph: The carbon system will be designed for 600 gpm. This is needed to account for downtime in operation of the treatment system.

How does a 600-gpm carbon system account for downtime? Is the capture well pumped at 600 gpm but its expected average is 500 gpm? What if both carbon tanks must be brought off-line?

7.6. Page 3, last paragraph: The carbon system feed pumps are two identical 500 gpm centrifugal pumps, where one pump will be in operation and the other is an online spare.

Page 3, 2nd paragraph states that pumps will be designed to 600 gpm to account for downtime, yet carbon system feed pumps are only designed to 500 gpm. 

These observations and comments have been publicly raised and written by Citizen Action for a very long time.  Citizen Action requested EPA to intervene in late 2012, citing many of these same issues over 2 years ago.

John Fleck's article also mentioned 2 letters sent June 4 and signed by Sen(s) Udall, Heinrich and Rep. Lujan Grisham:

"Last week, Sens. Tom Udall and Martin Heinrich, D-N.M., and Rep. Michelle Lujan Grisham, D-N.M., requested that the Air Force commission an independent review of Kirtland’s problems by the National Academy of Sciences."

The letter requesting NAS' commission for an independent review of the cleanup effort follows Citizen Action's efforts early this year working the passage of House Joint Memorial (HJM 13) through the New Mexico legislature.  HJM 13 asked our congressional delegation to create an independent panel of experts, and we have been advocating NAS lead this panel.  Sen. Udall's letter is the first action taken to make this independent panel a reality.  

This letter and Citizen Action's work passing HJM 13 and getting it implemented is detailed here.