[CPEO-MEF] FUEL: "SWM Alarming Water Authority Report: KAFB [Kirtland Air Force Base, NM] Contamination Greater than Reported by AF"

[Lenny Siegel]

> Begin forwarded message:
> 
> From: dave mccoy <dave at radfreenm.org>
> Subject: Fwd: SWM Alarming Water Authority Report: KAFB Contamination Greater than Reported by AF
> Date: March 12, 2020 at 5:21:46 PM PDT
> 
> Albuquerque Water Authority Finds 
> 
> Greater Contamination than in Air Force Report
> 
> Citizen Action New Mexico has obtained a January 2020 Albuquerque Water Authority technical memo that questions the conclusions in an Air Force (AF) report that there is “significant reduction” of jet fuel contamination between the ground surface and the groundwater (the vadose zone).  Among the Water Authority conclusions are that “fuel related compounds such as xylenes, EDB and ethylbenzene were detected above the reporting limit at KAFB [monitoring well] 106S9, indicating a much broader presence of fuel-related contamination than what is concluded in the Report.”
> 
> The Water Authority memo identifies serious problems with the AF collection of sampling data. The Water Authority states there are “likely biases … towards lower/reduced concentrations of fuel contaminants at the site.” Estimates of the Kirtland AFB jet fuel spill range from 6 to 24 million gallons.
> 
> The AF reported its findings in a source area characterization report that was supposed to resolve data gaps about the extent and concentration levels of fuel contamination necessary to develop a conceptual model to guide future remediation work.   The information was to come from soil corings drilled at various locations and depths.  The source area where the jet fuel spill occurred is particularly problematic because without cleanup it can continue releasing highly toxic chemicals such as benzene, toluene and ethylene dibromide (EDB) to Albuquerque’s drinking water aquifer.  No approved plan for the cleanup of the source material exists.
> 
> The AF did not follow the New Mexico Environment Department’s work plan for the investigation. 
> ·         The Air Force obtained biased lower readings for soil contamination because it allowed soil core temperatures to be too high from drilling speed vibration.  
> ·         Laboratory reports documented concerns they couldn’t quantify contamination because some corings were held too long before sampling.
> ·         Field sampling of the cores was not performed by a mandatory technique using a photoionization detector (PID).  Instead the AF used Ultraviolet (UV) screening that was not approved. 
> ·         The AF ignored sample data that showed contamination was above the required reporting limits. 
> ·         Some higher sample contamination levels were skipped while lower sample results were instead presented.
> The memo found a “Lack of consistent sampling depth across the boring locations thus requiring data interpolation and modeling instead of soil characterization data that was intended to fill the source area characterization data gap.” 
> ·         Decreased concentration claimed for off-base areas are not supported by statistical data.
> ·         The AF claimed remediation by natural processes but microbial analyses of the core samples were not reported.
> The Water Authority memo concludes with the following concerns:
> “Failure to delineate the extent of the remaining fuel contamination could result in a persistent  source to groundwater and increase the amount of time it will take to clean-up the impacted groundwater source.” 
> ·         Data collected and summarized in the Report does not address outstanding source data gaps.
> ·         The Report “lacks the robust analysis to revise/update the source area conceptual model.”
> ·         A statistical analysis of concentration trends is imperative.
> Using reduced concentrations and flawed data about the extent of contamination lead to erroneous conclusions about remediation.  The AF findings are compromised because of the:
> ·         biased data towards lower/reduced concentrations of fuel contaminants at the site
> ·         use of data reported that was outside core holding times and core temperatures that were too high
> ·         use of a limit of detection (LOD) greater than reported results. 
> ·         lack of consistent sampling across depth intervals
> ·         failure to collect core samples in accordance with photoionization (PID) recommendations
>  
> The Water Authority memo recommends that NMED and the AF should review the entirety of the laboratory reports to understand the scope of the data quality problems.  
> 
> As of this writing, neither NMED nor the AF have responded to the Water Authority Technical Memo alleged erroneous findings. 
>  
> March 12, 2020
> Dave McCoy, J.D., Executive Director
> Citizen Action New Mexico
> (818) 448-9981
>  dave mccoy <dave at radfreenm.org <mailto:dave at radfreenm.org>>
>                      -

--

Lenny Siegel
Executive Director
Center for Public Environmental Oversight
A project of the Pacific Studies Center
LSiegel at cpeo.org
P.O. Box 998, Mountain View, CA 94042
Voice/Fax: 650-961-8918
http://www.cpeo.org





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