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Regulatory Framework

Site investigation and cleanup activities of the jet fuel leak at KAFB follow a specific regulatory process known as “Corrective Action”. This process is spelled out in state and federal regulations, as well as in provisions in Part 6 of the KAFB Hazardous Waste Treatment Facility Operating Permit (RCRA permit). The RCRA process continues throughout corrective action and cleanup. The New Mexico Environment Department (NMED) was authorized by the U.S. Environmental Protection Agency (EPA) to administer and enforce this federal program.

Other laws and regulations that apply to this cleanup include:

  • The federal Safe Drinking Water Act (SDWA), which NMED is also authorized to administer by EPA. The SDWA requires that public water systems supply drinking water to consumers that complies with the EPA’s Primary (human health based) Maximum Contaminant Levels (MCLs);
  • The New Mexico Water Quality Act and associated regulations. Kirtland AFB has a Class V underground injection control (UIC) permit issued by NMED. Under these regulations treated groundwater is allowed to be returned to the aquifer;
  • The requirements in the New Mexico Air Quality Act as adopted and implemented by the Albuquerque Environmental Health Department through the Albuquerque-Bernalillo County Air Quality Control Board, and;
  • Permits from the Office of the State Engineer.

The RCRA corrective action process includes the following steps: initial site assessment, site characterization, interim cleanup measures, evaluation of cleanup alternatives, and remedy implementation.

Initial Site Assessment: This step involves collecting information about site conditions, releases, potential releases, and exposure pathways to determine if a cleanup is needed, and to identify areas of potential concern. Initial site assessment for this project began with identifying the fuel leak and conducting investigation activities from 1999 through 2007.

Site Characterization: This means to collect soil, groundwater, and soil vapor data to determine the nature and extent of contamination at a site, as well as the other information needed to support selection and implementation of appropriate cleanup remedies. The results of this process are presented in the RCRA Facility Investigation (RFI) Report.

The BFF RFI Report, which was submitted to NMED in January 2017 for review and comment, summarizes the results of the first 16 years of investigations and interim measures. An RFI Addendum will be submitted to summarize the results of investigation activities performed after Dec 2015.

The Risk Assessment Report, which was submitted to NMED for review and comment in July 2017, analyzes the potential for adverse impacts to human health or the environment as a result of contamination. This risk assessment found no adverse health or ecological affects from the fuel leak contamination based upon current land use. Depending upon the data collected in the RFI Addendum and the remedy, or remedies, recommended by the Air Force, the Risk Assessment may be updated as part of the Corrective Measures Evaluation Plan.

Interim Measures: Interim measures have been implemented and continue to be implemented under the RCRA Permit to reduce and/or prevent the migration of fuel constituents while the investigation phase is completed and long-term corrective action remedies are being evaluated and implemented. Interim measures conducted to date include:

  • Contaminated soil (4,822 tons) above screening levels was excavated in phases beginning in 1999, with the last excavation in 2015.
  • In 2003, the Air Force installed the first soil vapor extraction (SVE) system on-base. SVE and bioslurping systems together have removed approximately 550,000 gallons of fuel from 2003 until the system was taken out of service in 2015.
  • An additional 200,000 gallons of fuel and associated components have been removed through biodegradation (a process where naturally occurring bacteria breakdown contaminants into non-toxic products such as carbon dioxide, water, and ammonia).
  • The interim measure pump and treat system, or groundwater treatment system (GWTS), installed in 2015 is designed to capture and treat the ethylene dibromide (EDB) in groundwater that has migrated off-base. This system has three operational wells and is currently being expanded.
  • An in-situ (meaning in place) bioremediation pilot test is being conducted to identify the most effective treatment for EDB remaining in the source area. This pilot test includes stimulating native bacteria with nutrients and adding lab-grown bacterial cultures proven to degrade EDB. The results of this pilot test will help the project understand if this process would be effective in remediating EDB if it is implemented on a larger scale.

Results from interim measures are used to evaluate cleanup technologies for identification of final remedies. It is important to remember that interim measures are not end points of remediation, but are used to determine the final remedy approach.

Corrective Measures Evaluation (CME) Process: Once NMED has approved the RFI, the RFI Addendum, and Risk Assessment Reports, the Air Force will perform a CME to evaluate potential remedial alternatives for the source area and the EDB plume. The Air Force will present its selected remedies to NMED, who will review the report and propose its selected remedies. NMED’s remedy selection follows a public notice and comment process that is prescribed by state and federal law and includes the opportunity for a public hearing.

After the public meeting or hearing, and the Hearing Officer’s report is published, NMED will select a final remedy, or remedies, and issue a response to public comments. NMED will also direct the Air Force to prepare the Corrective Measures Implementation (CMI) Work Plan.

Corrective Measures Implementation: The CMI Work Plan includes design drawings, construction plans, an implementation schedule, an operation and maintenance plan, and performance monitoring plans for the selected remedies. Once NMED approves the CMI Work Plan, the Air Force will implement the final remedy, or remedies, in accordance with the CMI Work Plan and implementation schedule. The CMI Plan includes monitoring and other performance evaluation requirements to ensure that the remedies are functioning as designed.

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