In a letter to EPA Region 6 and the NMED HWB, environmental and social justice groups and individual citizens are asking for a public commenting and public hearing as it is their right under state and federal statutes’ regarding the KAFB Bulk Facility Fuel Leak.
The Bulk Facility Jet Fuel Leakage at Kirtland Air Force Base (KAFB) is one of a series of environmental disasters perpetrated on their federal reservation. The leakage is one of the most massive in environmental spills in this state’s history leaking jet fuel into the aquifer since the 1970”s when leaded fuel was still used. EDB (ethylene dibromide), a component of leaded gas, and hydrocarbons (JP-4, which is essentially diesel for jet planes) are the very compounds that are now being monitored through water quality testing. The 8 M gallon spill (or more) is large enough to fill 15 olympic-size swimming pools of fuel floating in the aquifer, the primary source of drinking water.
The Issue at Hand
At this time the plume is not affecting any of the water production wells. However, two drinking water production wells; the number 5 wells of the both the Ridgecrest and possibly the Burton Well fields could be affected. As the crow flies, the plume’s suspected migration path location down gradient is closest to the Ridge Crest Well number 5 is only 4 city blocks. There has not been any groundwater modeling to precisely know where the plume is migrating. In the 11 years the known plume has existed there were only 3 monitoring wells and one of those wells were up gradients meaning it was drilled out side of the migrating pat of the plume and would never detect a problem. The other wells were made of stainless steel and have corroded thereby rendering the sampling useless unable to measure the full impact of contaminates. Many other KAFB monitoring wells have screen installed improperly as well.
The saturation of the plume covers nearly 1 mile to the north-northeast of the former KAFB Bulk Fuel Facility site. This area has a LNAPL area defined in the Plume that has vapors that are in desperate need of mitigation. To put the vapor extraction issue into context, in California a spill 100 times smaller than this one would have nearly 15 vapor extraction burners. This spill has one. The California fuel spills have nearly one billion dollars thrown at it and it will never be able to be fully cleaned up.
The current substantial modifications to the KAFB permit will allow 78 monitoring wells. These are not cheap, costing hundred of thousands of dollars. In other areas of the KAFB and other federal reservations upwards of 2 million dollar have been spent on monitoring wells. Many of the well have been drilled, installed improperly and will show false sampling data. Meaning a vapor extractor in every yard in the neighborhood running 24/7. As seen from Google Earth there are over150 properties buildings that are affected by this disaster. However, the water delivery system itself is threatened and poses a severe public heath risk and severe water delivery shortage if the current sampling is only done once a month and the plume hit the wells the day after it was sampled. The public could be drinking jet fuel for 35 days before a problem is detected.
Under the Resource Conservation and Recovery Act (RCRA), a.k.a the Hazardous Waste Act, facilities that create hazardous waste must be permitted under federal and state statutes’. When the NMED Groundwater Bureau who was investigating a reported jet fuel spill around the fueling docks discovered the extent of the leakage in 1999. At that time NMED realized the spill was massive and it was reported in the Albuquerque Journal the is would take 10 years to clean up. The proverbial ball was dropped. After a constant nudging by the Albuquerque Bernalillo County Water Utility Authority (ABCWUA) the NMED HWB finally put the ball back into play within the federal oversight under RCRA because of Kirtland Air Force Base is a federal reservation and jurisdictional issues affects the oversight.
Despite the informational meetings offered by the New Mexico Environment Department Hazardous Waste Bureau [(NMED) (HWB)] their presentations have queried far more questions than have satisfied answers. Regarding NMED’s Jan 12th, 2011, 20-page Power Point presentation I have listed 40 questions that have not been answered satisfactorily. (See attached list of Questions. also at http://www.environmentalsafeguards.org/water.html)
In the informational meetings citizens who are being impacted directly or indirectly are only allowed to field a couple of questions and most of the time do not know enough about the law to understand what their rights are under the law. This truncated view of the problem is disingenuous to public when in fact they are entitled to a full commenting period and a public hearing. Answers to questions are over-simplified and vague with presenter lionizing the strong hand of the Environment Department while the full picture has not been painted for the public.
The facts are the NMED has substantially modified the RCRA Permit, which has changed the classification of the permit from classification level 2 that allows for a public commenting period to a modification classification Model 3, which entitles the public to have a public hearing. In fact I specifically asked in the Jan 12th meeting, “when do we the public get to comment on the record.” The question was glossed over.
The more I study the problem the more I see things slip through the cracks
This will allow people to comment on the planned Aquifer/Underground Injection Control (UIC) and the possible impacts on that to the drinking water ground water.
Aquifer Injection Pump and Treat and ARS
The hydrological studies on Aquifer Storage and Recovery (ASR) that the ABCWUA as the permittee from the Office of the State Engineer (OSE) and the New Mexico Environment Department (NMED) have not proved the impacts on seeps and springs within the hydrological area of influence nor has it proved that the pH, water temperature difference in order to preserve the natural conditions of groundwater or impacts on surface water and other water rights holders through their beneficial use, and
- The chemical analysis of river water does not include calcium and magnesium, which prevents determination of an ion balance in the water, the scaling tendency of the water or the sodium adsorption ration. The scaling tendency indicates the probability of forming (or Removing) a calcium carbonate layer of the downstream distribution system. It also indicates the compatibility with other waters, which the product water may be mixed with.
- Consideration should also be given to understanding the effects of mixing pumped groundwater with treated river water, Chemical analysis of proposed well field groundwater source will provide invaluable information for understanding and predicting potential adverse conditions.
- Bromide concentration in the water had not been specified; even the modest concentrations of bromide in the feed water can be significantly promoting the formation of Disinfectant By Products (DBPs). It is not clear what the Total Organic Carbon (TOC) consists of. The TOC of the river water is high enough that one must worry about the formation of DBPs. Some of the organic carbon will be removed during the coagulation process, but not all.
- It is not clear what residence time would exist between the addition of chlorine and addition of ammonia to convert the chlorine to monochloramine. One of the advantages of using chloramines for disinfection is the lowered tendency to form DPBs. However, if the period of time that the water is exposed to chlorine is too long, this advantage is dissipated. Reference is made to the hazards of use of chlorine gas as disinfectant. Further investigation and study is needed to prove the viability of these ABCWUA ASR projects and whether they have the ability to provide safe and verifiable water source is require and that any permit already issued without these considerations should be pulled.
Under New Mexico Aquifer Storage and Recovery Act the permittee must show other contaminants or other known plumes of contamination in the area. NMED has a Letter of Understanding (LOU) from the Office of the State Engineer regarding the Water Quality on aquifer injection. Yet there are no regulations on the books requiring NMED to oversee permitting of an injections project. Under the current law:
Aquifer Storage and Recovery Act and its rules and regulations, NMSA1978, 72-5A-1 through 72-5A-17 (1999 Supp.) Title 19 Chapter 25 Part 8.
The permittee must prove that their actions of the injection process will not affect the sphere of influence of those identified plumes or known contaminants by the potential turbulence of the injection plume and migrating water flows or other actions practiced by the permittee in this case. This has not been acknowledged or talked about.
Underground Injection Control Wells- It has come to our attention that it is up to the State’s discretion to permit the wells under RCRA and/or Safe Drinking Water Act. Whether these injection wells will be a Class IV or Class Five (under 40 CFR 144) and would need to be positive that such reinjection of contaminated water would not endanger underground sources of drinking water. We are requesting that NMED require a permit in order to ensure that the ABCWUA drinking water supply from this very groundwater source is adequately protected and that this permit process is subject to a formal public commenting period and public hearing. In order to delegate the UIC state program:
According to the UIC federal statues
The Underground Injection Control Program is authorized under the Safe Drinking Water Act. The program is to assure that injection of fluids underground is accomplished in an environmentally safe manner. The Environmental Protection Agency established minimum requirements necessary to meet that objective. Those include:
- All injection wells must be either authorized by permit or rule.
- Minimum construction and siting requirements.
- Requirements for permit applications and processes which must be followed for permit evaluation.
Enforcement of program requirements. —http://www.epa.gov/region6/6en/w/sdwauic.htm
The EPA retains enforcement authority where the states were unable to demonstrate jurisdiction or if a state does not adequately enforce program requirements.
This plume’s footprint is large and has an elaborate pump and treat system that has people asking several questions to which there are no answers. The hydrological studies of the aquifer injection have not been proven or has it been studied and evaluated as to what impacts on seeps and springs within the hydrological area of influence; nor has it proved that the pH, water temperature difference in order to preserve the natural conditions of groundwater or impacts on surface water and other water rights holders regarding their beneficial use, and the following concerning regarding aquifer/underground Controlled injection. The case of the Bulk Facility Fuel Spill it is not an empty borehole that they are plugging. It is injection back into the drinking water aquifer.
The attempt to explain how the aquifer injection is going to work has raised other questions that have not been answered. The concerns of what type of process is going to clean this water have not been addressed. The must be explained in a written report. The public deserves get the explanation and assurance in writing it is the public health risk at stake.
No formal studies have been done to insure that the injection well will not cause turbulence and disperse contaminants over a wider area, thereby raising the maximum contaminant levels in the aquifer. Nor has there been a report submitted by KAFB on the number of known plumes within a 3 miles radius that could be affected by the infiltration and injection systems plan. The permit itself recognizes 9 areas of groundwater contamination but the full extent of this contamination is left out of the permit, such as the placement of well, condition of well and screens, construction of the monitoring wells.
Furthermore how the water will be tested and the ultimately treated is another concern. According to the permit issued 7-15-10, Bureau Chief James Bearzi referred to in his response to the Citizens for Environmental Safeguards (CES) Request for Public Information of January 20 & 26M NMED only requires testing for perchlorates for a period of one years. Yet there is no mention of perchlorates testing being done on the Bulk Fuel Facility JP4 and 8!
188.8.131.52. Perchlorate Screening in Groundwater
Monitoring for perchlorate is required for eight consecutive quarters in groundwater monitoring wells installed at the Facility after the effective date of this Permit and in the following existing wells or their replacements: KAFB-1001 through KAFB-1007 (McCormick Ranch/Range wells), KAFB-1901 through KAFB-1904 (Lake Christian wells), and EOD Hill well. The Department reserves the right to include additional wells for perchlorate monitoring. The Permittee shall report all monitoring results on January 31, April 30, July 31, and October 31 of each year for at least 8 consecutive quarters to the Department, unless the Department agrees in writing to a longer reporting period.
The Permittee shall determine the nature, extent, and rate of migration of any perchlorate contamination in groundwater at the Facility and, if necessary, down gradient of the Facility. The detection limit for the monitoring of perchlorate in groundwater shall not exceed 1 ug/L.
If perchlorate is detected in a groundwater at a concentration greater than or equal to 1 ug/L in a groundwater monitoring well, monitoring of perchlorates in such well must continue at a frequency determined by the Department. The frequency shall not exceed one year.
In this case the KAFB only has to test for 1 year out of a 10-year permit!
Other plumes of contaminants that exist in the area should identify and mapped in relation to the Bulk Fuel Facility Jet Fuel Plume. According to NMED web site the permit that was issued in 7/15/2010, there are groundwater contamination sites are listed that show 8 other sites. Over 268 sites that have been rated “no further action” which doesn’t mean that they are cleaned up it could mean that the contamination is too costly to clean up.
Other issue with KAFB
According to NMED Website the RCRA Permit that was issued in 7/15/2010. In the permit the groundwater contamination sites are listed that show 8 other sites. Over 268 sites that have been rated “no further action” which doesn’t mean that they are cleaned up it could mean that the contamination is too costly to clean up.
- Permit Part 184.108.40.206. Areas with Groundwater Contamination
- Groundwater contamination or the potential for groundwater contamination has been identified at the following areas:
- 1. Tijeras Arroyo Groundwater (TAG) Area – trichloroethylene (TCE) and nitrate;
- 2. Landfills #4, #5, and #6, LF-008 (SWMU 6-4)–potential for contamination by selenium and TCE;
- 3. Manzano Base Groundwater – TCE;
- 4. Sewage Lagoons and Golf Course Pond, WP-026 – TCE, nitrate;
- 5. Manzano Sewage Treatment Facility, WP-16 (SWMU 6-24) – potential for
- 6. Monitoring well WYO-4 area – TCE;
- 7. McCormick Ranch — Nitrate;
- 8. Bulk Fuels Facility, ST-106 and SS-111 — Fuel (JP-4, JP-8, and Aviation Gas) Contamination; and
- 9. EOD Hill – Perchlorate contamination.
- The Permittee shall complete an Investigation Work Plan, Investigation Report, or CME Report
New Mexico Environment Department Kirtland Air Force Base
July 2010 Hazardous Waste Facility Permit No.NM9570024423
- PERMIT PART 6 for each of the nine areas of groundwater contamination in accordance with the compliance schedules in Table I-3 of Permit Attachment I. The Permittee shall complete a CME Report for each area of groundwater contamination that requires remediation, as determined by the Department. In addition, Permittee shall investigate other areas of the Facility, in addition to those listed above, where the Department determines that either groundwater is contaminated or there is potential for groundwater contamination.
Who lives down gradient? Nearly 80,000 to 100,000 people in the Mesa Del Sol community, the village of Mountain View the South Valley Agricultural Community and directly south the Pueblo of Isleta.
What is reported here is not the worse of it. The radionuclide’s for bomb making manufacturing and the Sandia National Laboratory nuclear reactor that has no containment building and government contractors throwing deadly toxic waste in boxes, plastic bags, and steel drums that are decomposing and leaks in into the aquifer. All of this sits upon the crossroads of three major faults; just south of the facility is the Seismic Facility for USGS, yesterday there was a reported earthquake measuring. 2.9 on the Richter Scale on the Los Alamos National Laboratory reservation along the Jemez Caldera Rim New Mexico’s Super Volcano.
To have these facilities in a metropolitan area is not smart, puts at risks the lives of hundreds of thousands of people along the Rio Grande, destroying our biosphere and there holds out little promise that our children will know the Earth as we did as children. We are the last generation to do anything about the problems at hand. Join us in our challenge to tell the stories of who we are and how we are going to transform this world despite the realities we face.