KAFB Jet Fuel Spill 3 Times Larger at 24,000,000 Gallons? by David McCoy

Photo above from Save the Water website.

From David McCoy, Executive Director of Citizen Action New Mexico wrote on Thursday, May 17, 2012;

Thanks for your continuing interest in the KAFB jet fuel crisis. I've attached an affadavit to what I heard Mr. William Moats, a geologist from the New Mexico Environment Department say. I received information that Dr. Davis (NMED) confirmed hearing Mr. William Moats' statement to me, but says nobody really knows the size and they don't know Mr. Moats' basis...

At 8,000,000 gallons the spill is still the largest, deepest and greatest threat to any City's drinking water aquifer in the history of the nation. 24,000,000 gallons may represent Armageddon for Albuquerque's Aquifer. I am hoping the Water Utility Authority seriously gets on top of the need for saving the Ridgecrest wells by 1.) demanding a plan for water treatment now from the Air Force and 2.) demanding that the LNAPL plume be stopped. If water treatment is not installed at Ridgecrest and the wells are simply shut off, the plume may travel to 40 city wells to the north. Surely, the economic benefit brought to ABQ by the Air Force cannot be greater than the value of our drinking water for homes, businesses, health and a future.

There is a WUA meeting next Wednesday May, 23 in the City Council chambers. The public can speak although the limit is usually 2 minutes. It would be good to turn out a lot of people.

The WUA should demand that the Air Force state NOW how it will treat the Ridgecrest wells. Shutting down Ridgecrest is not an option because the plume may continue to be drawn to the north to 40 other wells. Water treatment needs to be put at Ridgecrest starting immediately. If the LNAPL plume is not stopped, the water will be worthless, unless no one minds the taste of diesel fuel.

Inaccurate statements were made to the WUA at the last presentation by KAFB.
First, the movement of the LNAPL plume will not be stopped by the SVE equipment since it is not volatile. SVE is not recommended for dealing with diesel fuel. (US EPA Office of Underground Storage Tanks EPA 510-B-95-007). EPA also states: "Injection of heated air can be used to enhance the volatility of these heavier petroleum products because vapor pressure generally increases with temperature. However, energy requirements for volatility enhancement may be so large as to be economically prohibitive."

Second, there is no plan for the LNAPL containment. On April 2, 2010 the NMED ordered an Interim Measures Plan to be produced by KAFB. Three additional letters followed up that order.
From April 2, 2010:
"Therefore, on or before June 7, 2010, the permittee must submit to the Department for its review and approval an Interim Measures ("IM") Plan that describes what immediate actions it will take to remediate and stop the migration of the LNAPL plume. ... The IM Plan must also include an implementation schedule showing that remediation of the LNAPL plume will be completed within five years of the Department's approval of the IM Plan."

At the June 23, 2010 NMED presentation to the ABCWUA, Mr. Bearzi's handout stated:
"CURRENT REMEDIATION EFFORTS ARE INADEQUATE; Without doing something different, could take over 50 years to remove fuel from vadose zone and LNAPL plume."

Two years after NMED's order and there is still no approved IM Plan! There is also no enforcement of the 4/2/2010 Order.

Third, given the mass of liquid jet fuel floating on the aquifer, there is no evidence that using SVE equipment will keep the liquid from dissolving into the ground water or keep the LNAPL plume from moving. The bulk of the fuel on the aquifer is not aviation gas. It is JP-4 and JP-8 that are non-volatile fuels. So SVE won't stop the floating liquid plume's migration north. SVE will only remove whatever aviation gas is left down there and will not recover any of the JP4 and JP8 or keep it from moving. The LNAPL plume will reach a tipping point ust as the dissolved plume did. The vacuum for the SVE is 3 ft above the floating plume and cannot be put into the water.

The Colonel is not an environmental expert and the vacuum cannot come in contact with the 3 ft thick layer of the Jet Fuel. Moreover, the vacuum is only being applied on the Base and the leading edge of the dissolved plume is already 3/4 into the City and the LNAPL is 1/2 into the City. KAFB has let the plume leave the base which is 12 years of failed policy of both NMED and the AF. The two plumes in the City must be dealt with immediately. The liquid plume is 3 ft thick, one-half mile wide and one mile long. The dissolved plume with 100s of millions of gallons of aviation gas is three times the size of the LNAPL plume, 85 ft thick and contains Ethylene Dibromide (EDB), a potent carcinogen. The dissolved plume cannot be stopped from arriving at the Ridgecrest wells. Every gallon of aviation gas has 1/2 teaspoon of EDB. Every gallon of aviation gas is capable of contaminating millions of gallons of water.

Colonel Conley just doesn't understand that the vacuum which is only operating on the AF Base will only have a radius 100 ft. That is far distant from the leading edge of the plume and there are no remediation wells in the City. There will be zero effect on stopping the LNAPL because the vacuum can't touch the top of the water. There will no effect on the leading edge of the LNAPL plume heading for KAFB #3 well. Adding monitoring wells and vacuum will not stop the plume.

Citizens and the WUA should ask when the 1st gallon of jet fuel will be pumped. Otherwise, the only thing is that there will be more years of studies and we've already had 15 years of delay with no clean up. The thermal oxidizer is only a burner and doesn't pull vacuum. But again that will only be used on the AF Base. There is nothing stopping movement of the front end of the dissolved or liquid edge of the plume that is already far off the AF Base. The dissolved plume will hit the wells and we need water treatment. We need a plan for stopping the LNAPL movement.

One last item: Automatic federal budget cuts will go into effect on January 1, 2013 across all agencies. WUA needs to assure how this expensive problem of water treatment will be paid for.

Sincerely,
David B. McCoy, Executive Director, Citizen Action New Mexico
POB 4276, Albuquerque, NM 87196-4276
505 262-1862  dave@radfreenm.org    www.radfreenm.org