Kirtland Jet Fuel Spill Delay and Walk Away

KIRTLAND JET FUEL SPILL STILL THREATENS ALBUQUERQUE

               STRATEGY – DELAY AND WALK AWAY

The massive multi-million gallon jet fuel spill at Kirtland Air Force Base continues to threaten the drinking water wells for Albuquerque and the Veterans Administration Hospital.  Governor Lujan Grisham did not respond to a March 9, 2021 Water Utility Authority letter requesting intervention with the Air Force.The unpublished letter obtained by Citizen Action cautions: “[M]any issues remain that place the cleanup’s timely and successful completion at risk.”

The Water Authority letter warns, “Cleanup at the site has slowed alarmingly. The Air Force has not provided an updated time line and has yet to complete the necessary prerequisites for implementation of a final remedy.” The Authority emphasizes that the “Air Force’s estimates of Ethylene Dibromide (EDB) removed by the pump-treat-system [is] potentially over-stating the success of the system and generating unreliable data…” 

Obstacles threatening cleanup include:

• Lack of a long overdue Facility Investigation Report necessary for evaluation of corrective remedies;
• Inadequate groundwater monitoring;
• discontinuation of interim mitigation measures for soil vapor extraction, bioventing
• Air Force reluctance to improve the pump-and-treat system.
• The cleanup budget reduction by 80 percent from the 2018 amount and no certain 2021 budget.

Complete cleanup of EDB in the aquifer is impossible as long as its full extent remains unknown. This is caused by a shortage of groundwater monitoring wells at the water table. Most monitoring wells are on the AF base near the source of the spill. There is the need for an additional deep monitoring well in the City at the northernmost extent of the contamination plume. The AF refuses to pay for the groundwater monitoring well.

The AF refuses to collect data or provide funding for critical data gaps without Pentagon review despite Environment Department Notices of Disapproval.  This obscures understanding of the amount and extent of soil vapor and jet fuel remaining in the ground.  The aquifer is further contaminated as the groundwater rises. The Authority asks the Governor’s support to gain compliance with the Notices of Disapproval.

AF reporting and stakeholder engagement by technical staff in the cleanup process -- from the Water Authority,  NMED,  City of Albuquerque,  U.S. Geological Survey, U.S. Environmental Protection Agency and AF staff and contractors -- has “degraded over the last three years … with little or no opportunity for stakeholder input … on key datasets and decisions in a timely manner.”

Citizen Action obtained another unpublished and unanswered 11/19/2020 Water Authority Technical Memo to the Environment Department. It starkly underscores the defective groundwater monitoring well network and sampling practices that were not authorized by the Department causing critical data gaps.

The  AF claims improper credit for lowering concentration levels of EDB.  The AF relies on groundwater monitoring wells that are submerged due to a rising water table.  Unless sufficient groundwater monitoring wells are at the water table, the data “almost certainly underestimates the concentrations within the plume … and are cause for great concern.”

The inaccuracy from the extensive, unauthorized use of passive bag samplers at 105 out of 161 sampling wells rather than using more accurate low-flow pumping methods “goes against technical recommendations.” The Environment Department authorized only use of 12 bag samplers.  The bags are used inappropriately where jet fuel was detected and also in submerged monitoring well shielding evidence of contaminant levels.

The AF excludes all detected concentrations for EDB and other chemicals not at maximum permissible levels. That defeats understanding of the width and depth of the plume migration. “Samples from some wells are as much as 40 feet below the water table.  That can make it appear that EDB concentrations are decreasing.  As a result, the effectiveness of the pump and treat system can be inaccurately stated.”

The minimal legal requirements for remediation are being ignored.  At this point, there is not a justifiable solution for remediation when groundwater monitoring is unreliable and the full scope of contamination is unknown. 

July 6, 2021

Dave McCoy, Director

Citizen Action

818 448 9981

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