Water

Environmental Education 501(c) 3
La Cienega Valley Citizens for Environmental Safeguards

Water Last update 3/25/2011

Our Educational Platform

On Water Issues

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Team: EPA underreports radiation in America’s drinking water

http://www.khou.com/news/I-Team-EPA-under-reports-radiation-in-Americas-drinking-water-.html

Radio Interview On KIVA 1550PNM January 9 2010

Progressive Radio interview with Elaine Cimino MP3s

What Homeland Security and ABCWUA doesn't want you to see Map

CES Meeting on from Jet Fuel Plume

CES is planning will be meeting with City Councilors and County commissioners in the next few weeks. If you would like to ask questions on your local representatives please contact Elaine Cimino ecimino10 at gmail.com

Coming Soon Monthly Newsletter Sign up

Education Platform on

Jet Fuel Aquifer Contamination

According to Albuquerque Journal Reporter John Fleck, This is the largest contamination of water in New Mexico on the order of the Exxon Valdez Oil Spill in Prince William Sound. Imagine 17 olympic-sized swimming pools filled with jet fuel floating in the Aquifer.

CES would like to post maps of the Jet Fuel plume in relationship to the Water Wells in that is delivering water to thousands of Albuquerque residents in including hospitals, schools and the universities. However, the is a policy and practice of the ABCWUA that states because iof national Secuirty, due to 9-11, they will not releases that infornation.

CES is of the opinion that the ABCWUA policy does not trump the NMSA 1979 Chapter 14 Request for Public documents Act.

The question is whether this policy of the Water Authority under the mandate of the Homeland Secuirty should be enforced when a serious public health threat is pending regarding drinking water supply delivered to ratepayers. Citizens should be able to see for themselves on a map where the plume is in relationship to those wells that are being pumped.

Our third question is; whether the United States Government who is responsible for the pollution, (KAFB) have the right to then mandate (Dept. of Homeland Security) to the citizens that do not have the right to see information on the pollution plume that is threatening their drinking water supply [and its proximity to the cone of depression(s) well pumping, including horizontal and vertical boundaries of the leading edges under the auspices of Homeland Security] for which they pay taxes for?

pipeline hole

Letter of Denial of Public informaiton by ABCWUA ABCWUA_response_to_request

Ridge Crest Wells Water Quality Test Results

Ridge Crest Wells #1 - 5 Posted test results are samplings becuase of the cost of copies are beyond our ability to provide all results. This is why we need to push for these test results to be published on the ABCWUA Website.

Legend of water quality well Parameters and Sampling records 3 years Samples and Legend

Ridge Crest Well #1 rcwell1

Ridge Crest Well #2 RCwell2

RidgeCrest Well #3 rcwell3

Ridge Crest Well #4.rcwell4

Ridge Crest Well #5 rcwell5

We did not receive much of the information we requested nor did we have the questions answered to know the extent of the egregious crimes that have been committed. ABCWUA refuses to answer questions or give requested information and referred me to the polluter for further information.

CES is looking for volunteers to help with survey, gathering lists of names and contact info of people in attendance at meetings, helping with video taping, editing and website, tabling, petitions, and developing environmental justice survey and neighborhood walking door-to-door educational updates to people living and working on the plume. WE need 15 people dedicated to making the effort to reach 10 homes of people that are living on the plume. We estimate that there are 150 home and/or businesses on the plume.

CES is an environmental educational platform on the permanently damaged aquifer.

TheAuga es Vidas Action Team (AVAT) Library of documents on water quality of source and drinking water .

Spread Sheet on Radionuclide Testing of the Rio

USGS SpreadSheet on Testing the RIO at the Alameda St. Bridge Albuquerque, NM

Amigos Bravos Press Advisory MRGBI

Plutonium Argonne Press Release Risk of Nano Cluster Spreading Contaminants

B Gastian Presentation 1-27-10 PdfABCWUA

AVAT COOP Article 2010

PPCPS sampling results 09 - py amigos bravos

Trihalomethane Formation Due to Aquifer Recharge of Cholrinated Water

AVAT Accomplishments

Questions for Mr Sanchez of the ABCWUA

AVAT Presentation April 2009 PPCPs and the Rio

Testing Results by the State of NM of Radionuclides

2007 all rad results 011207x

Joe Wexler Proposal to the Review BoardSept 8th, 2009

State Lab Reports on Heavy metals

Letter to Susanna Martinez on NMED Dissolution

Read into the record at the ABCWUA 11/2008

Chemical list on pilot plant 2008

Groups seeks new Water Analysis By John Fleck ABQ Journal

Lesile Weinstock ABCWUA Presentation on Water Analysis 2010

USGS Potential Chemical Effects of Changes in the Source of Water Supply for the Albuquerque Bernalillo County Water Utility Authority PDF

When Jet Fuel Becomes Drinking Water, who will be charged?

Part One
Should KAFB be investigated and charged for the egregious crime of known endangerment?

This is a sad story of negligence, and outright lying by the Untied States Air Force that covered up jet fuel leaking into the aquifer, poisoning the drinking water supply for the City of Albuquerque, while those who were to protect the public interest were asleep at the wheel.

The first question arises, should the US Air Force be investigated and charged for the egregious crime of knowing endangerment for neglecting the polluting jet fuel system and poisoning the city water supply?

The second question is one as to what does the public have a right to know about their drinking water. Does the ABCWUA policy and practices trump the NMSA 1979 Chapter 14 Request of the Public Documents?

The third question is whether the United States Government who is responsible for the pollution, (KAFB) have the right to then mandate (Dept. of Homeland Security) to the citizens that they do not have the right to information on the pollution plume [and its proximity to the cone of depression and including horizontal and vertical boundaries of the leading edges under the auspices of Homeland Security] for which they pay taxes?

In 1999, the New Mexico Environment Department investigated a spill and found that the pipeline was leaking. The Air Force at the request of NMED sampled the vadose zone through soil samplings and told the NMED and the public that the problem was confined to a small area around the fuel-loading platform.

Nothing was done about the problem until 2007 when the ABCWUA nudged NMED to look at this problem. There was a person at the Base who also suggested that the sampling expand to include areas outside the Kirtland Air Force Base. We would like to know who that person is.

In 2008 and 2009, the NMED had to be nudged again. But this time the NMED Ground Water Division turned the investigation and testing over to the Hazardous Waste Division because they had more of jurisdiction under RCRA and could warn the Base to get on with the clean up.

Some people believed the Air Force when they said it wasn’t a problem back in 2000 and that they would take care of it. At the time of that finding NMED is quoted as saying that this was a problem that would take 10 years to clean up and at that time this was deemed not an accident. The truth is everyone dropped the ball. Only recently, in the last 2 months, they found that the storage tanks were leaking, as well. James Bearzi, NMED Hazardous Waste chief said that the “There was a finding of 3 leaks in the storage tanks when they were disassembled.”

Most of the testing and sampling performed by the Air Force has been deemed unreliable and is the reason for a consent order mandating that the air install 100 monitoring wells.

There have been several well-written reports in the Albuquerque Journal by John Fleck that has characterized the plume of jet fuel in the aquifer comparison of the size of the Exxon Valdez Oil Spill.

There is a inherit problem with jet fuel that it loses it potency after two weeks or so, then there is the problem of temperature change causing expanding and contracting fuel storage tanks and condensation. Jet fuel has to be replaced and it is highly likely that a fuel storage leak take care of that problem. It is easier to let the fuel soak into the ground then to mitigate the problem. It appears that this is what Kirtland Air Force Base did.

Others say there is no such problem with jet fuel and the fuel was accounted for.
If so then how did 8 million gallons soak into the aquifer?

CES now has a petition to request that the US Federal Prosecutor and the State of NM Attorney General investigate and charge Kirtland Air Force Base with the egregious crime of Know Endangerment. See this link to sign on to the Petition.

We encourage you to think about this problem and sign on to the petition.

The groundwater on the ridge of Nob Hill area of town is some of the best water around the city, lower in Arsenic and a better pH than the area of the foothills.
Most people should have a water purification system on the water lines coming into the their homes and businesses, not just on their kitchen sink. But at least one on the kitchen sink should be mandatory.

Beware of "Performance Contracts" where mlitary contractors get paid for early closure, it is pattern and practice of the Air Force to 'Hit and Run' and now there is a potential for this to happen at this cleanup.

ONWR Public comment PDF

Rain barrels In the Albuquerque program

WATER RESOURCES PROGRAM

The one thing that the ABCWUA got Right!

Bernalillo County Rain Barrel Program

Property owners in the unincorporated area who are NOT water customers of the Albuquerque Bernalillo County Water Utility Authority (ABCWUA) can qualify to receive one rain barrel per occupied address. To participate and qualify for the Rain Barrel Program, just sign up for a Home Water Conservation Survey. We will verify that there is a way for the rain barrel to be utilized on the site and you will pay only $40 for a 100 gallon rain barrel. We will also provide water saving tips for the outdoors and can provide low-flow aerators and shower heads for inside your home. To sign up, just complete an application or call 848-1500.

Our land of little rain

As the Earth becomes more inhospitable and difficult to survive in, perhaps we may find oursselves on a path to sweet water then again, might not.
This is a place where marginalized Indians, Mexicans, and women struggle to speak their voices,
yet only the howls of coyotes can be heard.
Cackling and vying for alpha positions. It is there where the voices that held knowledge spoke and it is where grandmothers lived.
It is a land where water flows in a ditch or it doesn't.
Where the water is in the plants,
trees and the rocks,
and it is brokered, brokered like our relationship to Earth and Sky so familiar in the West.
Our land of little rain where clouds fly by yet keeps their gifts for others. It rains so hard with never touching the ground or pours so violent it drowns with the deluge of mud, turbid and rank. Taste the salty sweat bead as it passes over lips all the while longing for sweet water.
It carries with it the snow, the ice or the fire and heat it is that which flows, blood, water and life.

Our land of little rain. Must we move or stay, without rain, there is no life.-Elaine Cimino

RAIN GARDENS

Fact Sheet: A 'Rain Garden'

John builds a rain garden

Related Fact Sheets

By John Patrick
Prolonged droughts in southern Australia has meant there is less water available for home gardeners, both in terms of natural rainfall and because of water restrictions. Gardeners are looking at different ways to overcome this dire situation and to prevent their gardens from becoming a wasteland. One method is to build a rain garden.

A rain garden is a system that collects water from paving, hard surfaces, roofs, and puts it through a filtering mechanism that removes nutrients and pollutants. The water can then be used to irrigate the garden or, can pass through the filtering system and be released into the drainage system.

Our rain garden:

• The rain garden we are building will collect rain from the roof and direct it into a planter box through a pipe system.

• The planter box will contain a layer of sand, and the water will run into that sand and some of it will be held, but excess will run through.

• Plants will use much of the water. But excess water runs into the sand, and into a layer of gravel at the bottom.

• Use a PVC pipe, with slots, or aggie pipe in the gravel layer at the bottom. This will help drain excess water into the drainage system, leaving the plants at the top to thrive and give you a wonderful green garden.

• But remember, any work done on the stormwater system, must be performed by a licensed plumber.

To make a rain garden:

• A timber container, or planter box, is lined with a sheet of plastic - to prevent water spreading laterally through the joints in the timber.

• At the bottom we have laid 20mm of gravel (we used 10 to 14 mm gravel) below the pipe but it will eventually be filled up above the pipe.

• The pipe should be laid so that it flows, down to the lowest point in the container.

• Then place gravel around the pipe to prevent sand entering it.

• The next layer is sand. Fill the planter box up – it should be about 100mm from the top, but leave enough room for a good layer of large pebbles as mulch.

• An extra overflow pipe means that in a really heavy downpour, the excess water will go down into the garden and won’t flood the whole garden.

• When choosing plants for the rain garden, select those that will tolerate occasional water logging when it floods, but extended periods of dryness when there’s no rainfall.

• Remove as much soil as possible from the roots before planting because the potting mix will reduce the porosity of the sandy soil.

• Choose fibrous rooted plants which make use of the sandy medium they’re growing in, but allow water to percolate through. There are many native and indigenous plants that fit that bill.

• We planted Lomandra along the back. In the foreground we planted Carex testacea; in the centre we planted a green form of kangaroo paw – known to love sandy, open soils and full sun so it should do well in the centre; and on each side a variegated Dianella.

• Once the garden is planted just top it off with about 50mm of pebbles.

• The stones act as good mulch and they’re heavy enough not to float away if they get flooded. The air gaps between them allow ponding so only in a really big downpour will the overflow be needed.

• Once the plants are in and the mulch is on, just water the plants in.

Now the great thing about a rain garden is that it maximises the amount of water that would otherwise just run off. It removes nutrients and pollutants so it makes our streams and creeks much cleaner, ancleaner, and what’s more, it brings a wonderful splash of colour to an area of the garden that was otherwise really pretty dull.

Letter to EPA and NMED

on KAFB Jet Fuel Plume

CES wrote a letter to EPA and the New Mexico Environment Department (NMED) on Feb 24, 2011, we have not heard from them. Now you can read what we asked and what they have not respond to.

February 24, 2011

EPA, Region 6 Compliance Assurance and Enforcement Division
John Blevins, Director mailto:blevins.john@epa.gov

EPA Region 6 Multimedia Planning and Permitting Division (6PD)
Federal Facilities Section
Susan Spalding, Associate Director for RCRA Programs mailto:spalding.susan@epa.gov
1445 Ross Ave, Ste 1200
Dallas, TX 75202

Tara Hubner RCRA Environmental Scientist mailto:Hubner.Tara@epamail.epa.gov
EPA Region 6
1445 Ross Avenue Suite 1200 Dallas, Texas 75202-2733

NMED Interim Department Secretary David Martin mailto:david.martin@state.nm.us
PO BOX 26110,
Santa Fe, New Mexico 87502

Mr. James Bearzi NMED HW Bureau Chief mailto:james.bearzi@state.nm.us
2905 Rodeo Park Drive East, Building 1
Santa Fe, New Mexico 87505-6303

Bill Olsen NMED Groundwater Chief mailto:bill.olsen@state.nm.us
1190 Saint Francis Drive
PO Box 5469
Santa Fe, NM 87502

KAFB Colonel Robert L Maness Commander
2000 Wyoming Blvd SE
Kirtland AFB NM 87117-5000 mailto:377ABW.PA@kirtland.af.mil

Request for EPA Region 6 Oversight for Public Participation and Technical Concerns for the Kirtland Air Force Base (KAFB)
Bulk Fuel Facility Jet Fuel Plume

The undersigned groups and individuals are requesting that EPA Region 6 exercise its oversight authority to ensure that the appropriate permits and public participatory requirements of Resource Conservation and Recovery Act (RCRA) and the Safe Drinking Water Act (SDWA) are met by the New Mexico Environment Department (NMED). The reasons for the request are described below.

Significant public concern is present for a jet fuel leakage plume at KAFB that is estimated to be 8,000,000 gallons. The size of the plume and the presence of contaminants that have reached the aquifer at KAFB and have traveled offsite beneath residential neighborhoods are of concern to the Albuquerque community. The plume of contamination may threaten municipal production wells and the health of residents. The plume was discovered in 1999 by an NMED hydrologist in the groundwater bureau. No further investigation was pursued until in or about 2007.

Under Resource Conservation and Recovery Act (RCRA)
We appreciate the public informational meetings given the New Mexico Environmental Depart Hazardous Waste Bureau (NMED HWB) on the Kirtland Air Force Base (KAFB) Jet Fuel Plume. Investigation Plans and Interim Measures have been required. However, there are proposals for remediation that include vapor extraction with injection of wastewater back into the aquifer through an underground injection control (UIC) Class IV well. The KAFB Permit was presented to the public in 2007. No extension of the public comment period was granted to the public.

The Permit was originally captioned for the Open Burn and Open Detonation Units. Although major modifications were subsequently made to the Permit before its approval in July 15, 2010, public requests to reopen the public comment period were denied. Additionally, despite the realization in or about 2007 that extensive contamination existed at the Bulk Fuel Facility the public was precluded from participating in that portion of the Permit related to Corrective Action needed for the Bulk Fuel Facility. The Bulk Fuels Facility was only listed in Permit Part 6.4.1.3 (#8) Areas with Groundwater Contamination and Table I-3, requiring a CME Report due 180 days after NMED approves site characterization. No further characterization of the Bulk Fuel Facility was provided to the public during the Permit approval process.

Characterization of the site is required previous to the implementation of remedies. However, KAFB is proposing the implementation of remedies prior to the completion of any CME Report. A CME Report is required subsequent to full site characterization, which has not yet been performed. The public is entitled to a review, comment period and public hearing previous to the selection of any remedies that would be proposed in a CME Report.

Work Plans that have been approved or partially approved by NMED include substantial modifications to groundwater monitoring for number, location of downgradient and upgradient monitoring wells. The work plans have not been previously submitted to the public for any review and comment. 40 CFR 270.42 Appendix I, C Groundwater Monitoring. Modifications are being made to the permit under the Resource Conservation and Recovery Act (RCRA) that are class 2 or class 3 modifications. The limited corrective action measures described for the Bulk Fuel Facility do not include what is currently being undertaken at KAFB and offsite in the surrounding community. The need for extensive changes to groundwater monitoring and soil vapor monitoring were not contemplated or presented to the public in the permit.

Given the high level of public interest in the Jet Fuel Plume in Albuquerque’s aquifer, and its proximity to City of Albuquerque municipal, KAFB and other public drinking water wells, the Class 2 modifications rise to Class 3 modifications. These modifications have been made without public opportunity for full public participation to include review, comment and opportunity for public hearing, if requested, as provided for by RCRA.

“Since Class 3 modifications involve substantial changes to facility operating conditions or waste management practices they should be subject to the same review and public participation procedures as permit applications. The specific procedures for Class 3 modifications are at 40 CFR 270.42(c).”
Federal Register/Vol. 53. No. 188 Rules and Regulations
28th Sept 1988 pg. 37919

Substantial public interest exists under NMAC also that provides for Class 2 modifications to be treated as Class 3 modifications.

The substantial changes to the permit that include plans that are being implemented without opportunity for review and comment and remedies being proposed without presentation in a Corrective Measures Report include the following:
1. IM Plan – excavates former Fuel Offloading Excavation Plan- Rack area, complete shallow boreholes along ancillary piping, and conducts various tests.
2. Vadose Zone Investigation Plan – complete soil borings and soil-vapor wells.
3. Groundwater Investigation Plan – install groundwater monitoring wells
4. The LNAPL Containment Plan and injection well remedy were approved by NMED on December 10, 2010 with no presentation of a permit to the public. The public is uninformed as to whether a Class IV or Class V injection well is planned for use. Class IV injection wells require a UIC permit. Air quality concerns have not been addressed. Minimum construction and siting requirements have not been presented to the public. Injection of treated wastewater has not been investigated for potential to spread contamination that may exist near injection sites. Injection of fluids is not assured to be accomplished in an environmentally safe manner. The location to receive waste from the LNAPL Storage Tank and the details of transportation and disposal location has not been provided. Disposal of activated carbon filters has not been determined. The location of injection wells to receive the pump and treat wastewater has not been provided.
The need for a UIC permit has not been addressed. A UIC permit requires public notification, opportunity for comment and review. See,
“40 CFR Section 145.11 referring to Sections 124.10 (a)(1)(ii), (a)(1)(iii), (a)(1)(v), (b), (c), (d), and (e)—(Public notice); Section 124.11—(Public comments and requests for hearings); Section 124.12(a)—(Public hearings); Section 124.17 (a) and (c)—(Response to comments).”
Technical concerns that have not been addressed because NMED has not required a UIC RCRA permit are the following:

Underground Injection Control (UIC) Wells –The State has discretion to permit the UIC wells under RCRA and/or Safe Drinking Water Act. Neither RCRA nor the SWDA has been addressed.
Whether the injection wells would be protective given reinjection of contaminated water into Albuquerque’s drinking water aquifer has not been determined. We are requesting that NMED require a permit under both RCRA and SWDA in order to ensure that the drinking water supply is adequately protected. The permit process must follow public review, comment and public hearing procedures outlined above. The Environmental Protection Agency established minimum requirements necessary to meet the objective of adequate protection of drinking water. Those include:
1. All injection wells must be either authorized by permit or rule.
2. Minimum construction and siting requirements.
3. 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 KAFB LNAPL Containment Plan site has an elaborate pump and treat system for which many questions remain. The characterization of the aquifer has not been adequately investigated with contour maps provided. The hydrological studies of the aquifer injection have not been made and evaluated as to what impacts on seeps and springs are located within the hydrological area of influence for the plan. 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 to identify the number of known contaminant plumes within area that could be affected by the infiltration and injection systems plan. The permit itself recognizes 9 areas of groundwater contamination but does not identify previous areas that remain contaminated.
The full extent of surrounding contamination is not identified in the permit or plans. Other plumes of contaminants that exist in the area should be identified and mapped in relation to the Jet Fuel Plume. According to NMED Website the Permit that was issued in 7/15/2010. ???? In the permit the groundwater contamination sites are listed that show 8 other sites. Many sites were designated in the past for “no further action” but may still contain contamination that is present at some level that would be released by the pump and treat and injection.

The permit identifies the following areas for groundwater contamination:

Permit Part 6.4.1.3. 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
Contamination;
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.

An issue arises as to whether monitoring of the injection well site is provided for.
Monitoring wells across KAFB and Sandia National Laboratories are known to be defective in many respects due to incorrect location, improper construction, corroded well screens, cross contamination of different saturation zones and improper sampling procedures. Wells that currently exist in the Bulk Facility plume gave unreliable data according to HWB Chief James Bearzi during the November 30, 2010 informational presentation. At the January 12, 2011 informational presentation, NMED announced that 29 of the existing wells had been approved. No assurance that the approval was based on reliable factors was presented.
Consideration of pH, water temperature differences in relation to the natural conditions of groundwater or impacts on surface water and other water rights holders regarding their beneficial use, have not been provided for public review prior to approval of the LNAPL injection plan and associated aquifer Underground Controlled Injection.
Additional technical concerns are as follow:
1. There has been no study on the affects of hydrocarbons and EDB on the treatment system and what type of filtration system that may be most effective.
2. The compatibility is unknown for the LNAPL treated water in relation to the groundwater or whether the chemical analysis of the treated water includes an analysis for mineral balance. Mineral balance is needed for determination of ion balance in the water, the scaling tendency of the water or the sodium adsorption ratio. The quantity of the pump and treat water output that can affect water quality in the aquifer has not been described for the period of time over which operations will continue.
3. Bromide concentration in the groundwater has not been considered in the treatment process. The types of chemical analyses that are necessary to perform have not been presented. Modest concentrations of bromide in the water to be treated feed water can significantly promote the formation of Disinfectant By Products (DBPs). Treatment methods must be adequately described to ensure that various chemicals and compounds are identified and do not mask the presence of other chemicals and contaminants. This masking process can result if the appropriate testing and treating methods are not utilized. Such technologies may necessarily include mass spectrometry, dual-column dual-detector analysis where ethylene dibromide (EDB) and hydrocarbons are simultaneously present. Without such varied testing the EDB and hydrocarbons may mask the presence of the other.
5. Partial Approval of the 3 KAFB Work Plans December 10, 2010, NMED issued partial approval of the 3 Work Plans with direction to:
• Install 78 additional groundwater wells
• Install 35 additional soil-gas wells
• Develop all groundwater wells
• Conduct borehole geophysical logging, existing and new wells
• Complete soil sampling at 27 deep borings
• Complete soil sampling at former fuel offloading rack and along pipeline to tanks.

The addition of the large number of 78 groundwater wells may be excessive and could lead to further aquifer contamination. No plan has been presented for review and comment by the public for the monitoring wells and whether the aquifer has been adequately characterized for flow direction and hydraulic head. The GIS modeling for flow direction has not performed from a reliable network of monitoring No GIS investigation using topography has been provided to determine flows direction. The public has not been presented with information that the monitoring well network is reliable to make such a determination.

The January 12, 2011, Power Point presentation of HWB Chief Bearzi identified the July sampling event may have been from wells that were not properly developed. NMED has a duty to determine if data provided is full, accurate and complete. Nevertheless, NMED purports there is no change in the size of the plume based on the same data that NMED deems unreliable.

6. Vapor Extraction Units were previously utilized to an approved plan and did not include air quality concerns. The ABCWUA and City and County governments requested a Vapor Extraction plan for a permit of the NMED HWB, and there has been no mention of this matter in the public informational meetings.

Additionally, the wide scope of proposed of changes and commitment of federal resources have not been addressed or supplemented by any environmental analysis under the KAFB Environmental Impact Statement.

The relation between corrective action procedures and permit modification is not clear. The relationship between plans and remedies seems to have blurred. The public is uninformed as to the classification levels of the ongoing permit modifications and what is to be the KAFB corrective action compliance period with specific deliverables. NMED should clarify what process it is approving these plans under and what the classifications of the modifications are. Public Participation as provided for by RCRA is not being fulfilled. NMED should identify the planning process in relation to the remedy process.

Through public information requests we have found there has not been a Corrective Action Order with overall specifics. In the 40 years of jet fuel leakage, the slow response and lack of enforcement measures by NMED is disappointing.

Investigation is needed under the Safe Drinking Water Act as to whether the public utility wells closest to the contamination were developed properly so that the contamination will not enter the well screens. Documentation needs to be provided when a plume of contamination could arrive at municipal wells. NMED has rejected without explanation CH2MHill analyses for the plume to arrive at municipal and KAFB wells under worst and best case scenarios. There is a lack of agency coordination between ABCWUA and NMED HWB as to whether the municipal wells should be replaced.

Whether the contaminants would be blocked from being delivered into the ABCWUA drinking water distribution system and piped to our homes, schools, hospitals, churches and businesses, is a major issue. This is a bigger concern since the recent discovery of EDB. The older municipal wells may be somewhat shallow in relation to the water table and lack the annular casing rings, as do more modern wells. One may question why a huge expenditure for 78 monitoring wells is required but not a single municipal well is under consideration for replacement.

NMED has stated that they will NOT implement precautionary measures to shut down Ridge Crest and Burton Wells #5, which are respectively 4-8 city blocks from the plume. NMED is regulating under RCRA and the need for the application of the SWDA is necessary to address the problem of the municipal production wells. There has not been a groundwater characterization report on the cone of the depression, calculating the current pump rate, direction and rate of flow considering the cone of influence nor has there been a public discussion of the map boundaries set by the SWDA, determination of susceptibility of the water supply to the contamination or allowing the public to formally comment on what will happen to the aquifer with a injection system that will be used.

We request that EPA exercise its oversight capacity to review and clarify these above issues.

Respectfully,

Elaine Cimino
Citizens for Environmental Safeguards (CES)
1132 Stanford Dr NE Albuquerque, NM 87106
mailto:ecimino10@gmail.com
Cliff Bain
Peaceful Skies Coalition (PSC)
mailto:bain@newmex.com?subject=EPA oversight for public participation on Jet Fuel Plume

Kathy Wanpovi Sanchez,
Tewa Women United
mailto:tewawu@msn.com?subject=EPA oversight for public participation on jet fuel plume

Robert Anderson "Bob Anderson" <mailto:citizen@comcast.net?subject=EPA oversight for public participation on Jet fuel plume>,
Jeanne Pahls "Jeanne Pahls" <mailto:jeannepahls@comcast.net?subject=EPA oversight for public participation on Jet fuel plume>,
Stop the War Machine (SWM)

Charles Bennett
mailto:nmbcb4@gmail.com?subject=EPA overight for public particpation on jet fuel plumeLa Mesa Community Improvement Association

CC: EPA, Region 6,
Compliance Assurance and Enforcement Division
John Blevins, Director

EPA Region 6 Multimedia Planning and Permitting Division (6PD)
Federal Facilities Section
Susan Spalding, Associate Director for RCRA Programs

Tara Hubner RCRA Environmental Scientist
EPA REGION 6
1445 Ross Avenue Suite 1200
Dallas, Texas 75202-2733

David Martin, NMED Interim Cabinet Secretary
Harold L. Runnels Building
1190 St. Francis Drive
Suite N4050
Santa Fe, New Mexico 87505

Mr. James Bearzi NMED Hazardous Waste Bureau Chief
2905 Rodeo Park Drive East, Building 1
Santa Fe, New Mexico 87505-6303

Bill Olsen NMED Groundwater Chief

John D’Antonio
Office of the State Engineer
In Care of Kristina Eckhart mailto:kristina.eckhart@state.nm.gov
130 South Capitol Street Concha Ortiz y Pino Building
P.O. Box 25102
Santa Fe, NM 87504-5102

The Office of Inspector General (OIG) of the U.S. Environmental Protection Agency (EPA)
WASHINGTON, D.C. 20460
Najjum Wade
najjum.wade@epa.gov,
Eric Lewis
lewis.eric@epa.gov

Albuquerque City Councilor Isaac Benton <mailto:ibenton@cabq.gov>
City Hall One Civic Plaza Albuquerque NM 87101

Albuquerque City Councilor Rey Garduno <mailto:reygarduno@cabq.gov>
City Hall One Civic Plaza Albuquerque NM 87101

State Senator Cisco McSorley mailto:cisco.mcsorley@nmlegis.gov

Senator Linda Lopez mailto:linda.lopez@nmlegis.gov

Senator Jerry Ortiz Y Pino mailto:jortizyp@msn.com

KAFB Colonel Robert L Maness Commander
2000 Wyoming Blvd SE
Kirtland AFB NM 87117-5000

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Conflicting reports

In a study of chromium-6, whose results were published in mid-December, a Washington D.C.-based environmental advocacy group, the Environmental Working Group, found that the Río Grande water at Albuquerque contains chromium-6 at levels 17 times higher than the Environmental Protection Agency standard for drinking water. This form of chromium is a known human carcinogen.

Yet the private research company, ChemRisk, that was hired by the Buckman Direct Diversion Board to perform an independent peer review of data provided by the Los Alamos National Laboratory, pronounced the Río Grande water safe for drinking. In the face of these contradictory results, it is clear that the best way to ensure a safe water supply for Santa Fe is to press LANL to clean up its high-priority waste dumps in the canyons above the Buckman pipeline well before the Buckman project goes on line.

As far as Albuquerque is concerned pushing for testing of contaminants not yet regulated is imperativel How long do we drink toxins in water before we get the contmainates regulated and then enforced? Read the following reports on the problem.

Charge to EPA on Chromium VI Toxicological Review Sept 2010

Toxicological Review Of Hexvalent ChromiumVI (Cas No. 18540-29-9)

What you can do to help on jet fuel plume?

1. Write the ABWUA? Ask for the following:

Ask them to Shut down wells #5 of the Ridgecrest and burton Well fields due to the jet fuel plume.

Post on the ABCWUA website water qulaity Report specific to Wels #5 of the Ridge Crest and Burton Well fields.

Ask them specifically for rwater quality tests for wells # of Burton and Ridge Crest Wells

Demand that they test and raise the standard to what they anticipate the EPA regualtions to be raised for Chromium 6 and tell us what they are going to do about these carcinogens in our drinking water now. It may meet current standards, however, those are out of date with what they know now about the contaminant. (See above report on Chromuin plus go tothe EWG.org website They will eventually be mandated to upgrade the systems to rid it. http://static.ewg.org/reports/2010/chrome6/html/home.html

Test for Percholrates in all the municipal productions wells city and county wide,

Ask them why they dropped the ball on protecting the public health.

If they refuse to do the above request tell them we will work to abolish the ABCWUA within the state legislature.

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