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Water Report - Status Update for the Kirtland Air Force Base Bulk Fuels Facility Fuel Leak Corrective Action Activities
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The Albuquerque Bernalillo County Water Utility Authority (Water Authority) staff and their independent contractor, Intera, Incorporated (Intera), reviewed the recently submitted Resource Conservation and Recovery Act (RCRA) Investigation Report (RFI), and has provided comments to the New Mexico Environment Department (NMED), Kirtland AFB, the Air Force Civil Engineering Center, the U.S. Army Corps of Engineers, and their respective contractors.
In their technical review, Intera pointed out some of the following insufficiencies in the RFI:
1. Data gaps for vadose zone (or soil) contamination characterization; and
2. Inaccurate descriptions of the light nonaqueous phase liquid (LNAPL) plume; and
3. A lack of a description of how much contamination in the soil continues to move down towards the aquifer, or be coming into contact with the rising aquifer; and
4. An inadequate definition of the vertical extent of the dissolved phase ethylene dibromide (EDB).
When the Air Force submitted the RFI earlier this year, they did acknowledge there are existing data gaps that need to be addressed before the project moves to the next RCRA Corrective Action phase. Water Authority staff encourages the Air Force and their contractors to fill the data gaps and address the concerns provided in Intera's technical review of the RFI document.
In addition to the Water Authority's comments, the NMED responded to the document with their own comments regarding the RFI similar to the Water Authority's, which included that the document provided incomplete characterization of the EDB plume, incomplete and biased estimates of concentration trends and degradation, and incomplete delineation of the LNAPL plume. NMED requested that the Air Force participate in technical meetings with the key stakeholders and to submit a work plan addressing the identified data...
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