Kirtland Jet Fuel Spill and Sandia Labs’ Radioactive Waste Dumps

Homeowners and Buyers Beware the Nuclear Military Industrial Complex

Comments on the July 22, 2014 Citizen Advisory Board (CAB) meeting

The Albuquerque community was assured by Kirtland AFB newly arrived Col. Dennis A Haught that the jet fuel contamination of the drinking water aquifer will “receive a new sense of urgency.” According to Dr. Adria Bodour, from the Air Force Civil Engineering Center (AFCEC), the “A-team has arrived.” The community is cautiously optimistic once again and willing to support. Proving that this new enthusiasm and thinking will show cleanup results may be difficult given the past history of a bumbling Air Force strategy to minimize the problem, delay and do little.

In 2008 Kirtland AFB made a showboat promise to clean up the jet fuel spill, then estimated at 1-2 million gallons.  The Air Force delayed telling the public for two years that skimmer wells installed in 2006 demonstrated that the jet fuel had already left the base property.

Four years ago in May 2010, the Environment Department and public were informed by a high ranking Air Force official that it “has assigned top priority to the cleanup.”  But despite that promise, there still is no plan in place or program for cleanup of the dissolved, mobile Ethylene Dibromide (EDB) plume that is destroying drinking water supplies over a 1000 by 6000 ft long area. 

To their credit, the A-team realizes that no site conceptual plan exists to plan for characterization of the EDB plume. The A-team has obtained money for additional monitoring wells. However, the plans for the additional monitoring wells were not offered for prior public review as is required by federal law. Sixteen new monitoring wells are being installed to attempt to determine the northeast extent of the EDB plume.  According to Registered Geologist Robert Gilkeson, "Those monitoring wells use the Air Rotary Casing Hammer (ARCH) technique known to compress the formation surrounding the well screen and that gives less reliable sampling results.  Unfortunately, additional USGS sentinel monitoring wells are installed using a mud rotary well drilling technique that is known to mask evidence of contamination. More reliable drilling methods are available but would be more expensive. The Air Rotary Underreamer Casing Advanced drilling technique should be used."

Without performing adequate characterization, the proposed cleanup remedies, their effectiveness and costs cannot be evaluated.

NMED has a new technical director: Dennis McQuillan, for the jet fuel contamination. McQuillan was the first to recognize the fuel spill as “significant” in 2000, although the size of release was grossly underestimated as 96,000 gallons because there were no accurate inventory records available.  

Hopefully, NMED will reject the Kirtland Vadose and Groundwater Facility Investigations that assert that there are “no more data gaps.” EPA, Interra and the Water Authority have all cited glaring data gaps. An insufficient number of groundwater monitoring wells has been an ongoing problem so that the leading edge of the EDB plume has not been identified. There are air bubbles in groundwater monitoring samples that destroy evidence of contamination.  A low bias for the presence of EDB and volatile organic compounds can result in underestimation of the size of the plume and the timeframe for arrival to municipal wells. Additionally, NMED has not required replacement of shallow groundwater monitoring wells that can no longer monitor at the water table because their well screens have been covered by rising groundwater.

A significant issue for homeowners was raised by homeowner Steve Pierce at the July 22nd CAB meeting. FHA and VA mortgage appraisers are required to look for “adverse conditions” before lending to a buyer (pg. D-8):

“The hazards include toxic chemicals, radioactive materials, other pollution, hazardous activities, potential damage from soil or other differential ground movements, ground water, inadequate surface drainage, flood, erosion, excessive noise, defective lead base paint (24 CFR Part 35) and other hazards on or off site.”

The jet fuel spill, estimated (NMED 2012) at up to 24,000,000 hazardous gallons, is contaminating billions of gallons of drinking water supplies beneath homes and businesses. Honest or dishonest disclosure of problems can result in loan denial by VA or the FHA mortgage lenders. A seller or realtor who deliberately does not truthfully disclose facts that could be sued by the unsuspecting buyer for fraud.

It’s time for realtors to support community demands for clean-up of the Kirtland jet fuel spill and Sandia Lab’s toxic dumps. Realtors have an ethical duty to report dangers to potential property buyers but have remained silent for too long. Under the Realtors Code of Ethics, Duties to Clients and Customers include: “Article 1 to protect and promote their clients’ interests while treating all parties honestly. Article 2 refrain from exaggeration, misrepresentation, or concealment of pertinent facts related to property or transactions.” 

Prospective buyers for Mesa del Sol and other Albuquerque neighborhoods may be unaware of the Kirtland Air Force Base (KAFB) fuel spill and radioactive and hazardous waste dumps existing at Sandia Labs such as the Mixed Waste Landfill (MWL). The MWL contains mixed waste and high level radioactive waste from radioactive fuel destruction experiments that remains leaking into groundwater from shallow pits and trenches. Sandia Labs has covered up the information regarding high level waste disposal in the MWL for over forty years. The High Level Waste came from some of the fuel meltdown experiments Sandia Labs performed from 1977 into the 1980s.

Citizen Action is suing the NMED for its failure to enforce Sandia Labs performance of the five year reviews for excavation of the MWL wastes. Add to the homeowner mortgage disclosure list that Sandia Labs also plans to openly burn 10,000 pounds a year of explosive wastes that can release chemicals such as dioxin and hydrogen cyanide to our breathing air. 

Groundwater at Kirtland is also contaminated with cancer-causing trichloroethylene (TCE) at Tijeras Arroyo Groundwater Area, Landfills #4, #5, and #6, and the Manzano landfill.

The public must continue to demand real cleanup and containment of the Kirtland EDB plume and for the Sandia sites. So far there is a history of pacifying statements made to the public from biased modeling, misinformation and, irrelevant pilot projects that are spun to the media to appear as action. The A team has its work cut out at Kirtland.

DATA GAPS

Primary stakeholders tasked with protecting Albuquerque's public from toxic jet fuel in our drinking water have made explicit and official statements identifying "data gaps".  Kirtland and their remediation contractor (CB&I) have said these data gaps are largely minor or inconsequential.  Citizen Action is confident these data gaps are not satisfied.  Work must be done to acquire reliable data if we are to have drinking water free from jet fuel contaminants.

Below are statements made by stakeholders supporting the unavoidable assertion resources must be allocated immediately to accurately fill these "data gaps".

• Presentation before the Water Utility Authority (WUA) on May 21 2014 by WUA's Water Quality Hydrologist Rick Shean and Intera Inc.'s Eileen Marcillo (Page 5):

Identified Data Gaps 
- LNAPL in vadose zone 
- - Limited LNAPL saturation and chemical data for soil 
- - - Migrating LNAPL  - - - Mass of LNAPL and EDB above the water table 
- LNAPL below the water table 
- - Mass below the current water table 
- - Mass below the water table in the future 
- - - 2-3 feet rise per year 

Page 7:

Additional Data Gaps
- Dissolved contamination 
- - EDB plume extent still not fully delineated 
- - Deep monitoring well network is insufficient 
- Dissolved plumes are not stable 
- - Source mass is likely increasing 
- - Long-term monitoring required to show plume changes 
- Rising water table moves the plume up away from the existing well screens 
- - Some shallow wells no longer monitor the higher concentration plume 
- No aquifer test near downgradient edge of plume 

• EPA Region 6 Ellinger Draft Report, 3-d model of the jet fuel plume (Page 63): 

     "Like many groundwater models, this model uses monitoring wells clustered in the area of concern. Clustered data points in modeling are common because field investigations are not typically designed at the outset to support modeling efforts. Ideally, groundwater monitoring wells should be distributed throughout a model domain. Although the flow model achieved acceptable matching between calculated and observed heads, there are areas of the model domain where no monitoring wells exist so it was not possible to calibrate heads in those areas. The significance is that simulated flow directions are potentially less reliable at distances away from existing groundwater monitoring wells."

     "A related reason for having monitoring well data gaps is that the scale of the model had to encompass an area larger than the EDB plume. The larger area was necessary to include the Ridgecrest well field and other pumping wells in southeast Albuquerque. These pumping wells had to be included to create the appropriate flow field and to assess the movement of the EDB plume towards pumping wells. Additional groundwater monitoring wells or piezometers placed north and northeast of the Ridgecrest well field would improve flow model accuracy."

• Intera Inc.'s review of CH2MHill's 3-d model (Page 2):

     "The particle tracking analysis does not provide the time when the EDB plume will be captured by the supply wells. (...) The arrival years listed in Section 3.5 and Table 3.2 are the travel times for the particles to flow past the supply wells to some arbitrary point, such as the end of the simulation period in 2054."

     "Results from the analysis should not be used to estimate the time when the supply wells will capture the EDB plume." (...)

     "The particle tracking analysis uses a set of hydraulic properties for the EDB plume area that is not consistent with the properties used for the groundwaterflow simulations and, possibly, the calibration."

The modified model, as presently configured, cannot simulate capture of the EDB plume by the downgradient supply wells."

(Page 4):

"Given the lack of capture by the wells, the estimated travel times are very uncertain and are likely to be significantly larger than travel times calculated using a finer spatial discretization."

(Page 7):

A second concern identified by INTERA was the approximately factor of two difference between the groundwater velocity used in the flow model and the velocities employed in the particle tracking analysis. The particle tracking velocities were increased by about a factor of two because the velocities simulated by the groundwater model “generated particles with insufficient migration distance to match the current EDB 3-D distribution” (Appendix B of HILL (2013)). That is, particle tracks generated with the velocities produced by the groundwater flow model were not consistent with known EDB concentrations. The inconsistent velocities indicate that the groundwater model requires modification for predicting transport of the EDB plume. For example, the hydraulic conductivity could be locally increased by roughly a factor of two to generate higher velocities near the location of the EDB plume.

Dave McCoy, Esq., Executive Director
Citizen Action New Mexico