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