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The Continuance of the Presentation by Citizens for Alternatives to Radioactive Dumping (CARD)
TESTIMONY OF DR. RICHARD HAYES PHILLIPS - March 17, 1999.
Dr. Phillips received a Ph.D. in Geomorphology,
University of Oregon, Eugene, 1987; a M.A. in History,
University of Oklahoma, Norman, 1983; a M.A. in Geography,
University of Oklahoma, Norman, 1982; and a B.A. in
Political Science and Geography, State University of New
York, Potsdam, 1979. Dr. Phillips wrote his Ph.D. thesis on
"The Prospects for Regional Groundwater Contamination Due to
Karst Landforms in Mescalero Caliche at the WIPP Site near
Carlsbad, New Mexico." Dr. Phillips has worked as an
adjunct professor and a graduate teaching fellow. Dr.
Phillips has also worked as a geologic consultant. He has
written many professional papers on the geology and
hydrology of the WIPP site. GEOMORPHOLOGY is the study of landforms and the processes
that create and destroy them. KARST refers to landscapes
that develop on soluble rocks (limestone, dolomite, gypsum,
anhydrite and halite). The most obvious karst surface
characteristic is a lack of surface runoff due to high
porosity. Rainwater infiltration is rapid through
sinkholes, disappearing streams and arroyos, and perforated
caprock. Drainage is almost entirely underground through
discrete solution-enlarged fractures, channels, and caverns.
The water emerges at a few large, irregular springs. The WIPP site is located in the Pecos River Valley, one
of the largest karstlands in the United States. The WIPP
site lies in the Mescalero Plain, which is capped by
Mescalero caliche and covered by windblown sand. To the
west, within 1 mile of the WIPP site, is Nash Draw, one of
the largest surface karst features in the world. The WIPP repository is located in the Salado Formation.
Directly overlying the Salado is the Rustler Formation, the
principal karstic aquifer in the area. The Rustler
Formation is divided into five members. Separate or
distinct types of rocks can differentiate a formation. The
Rustler Formation members are listed in descending order:
the Forty-Niner, the Magenta, the Tamarisk, the Culebra, and
the lower unnamed member. The Magenta and Culebra dolomites
are persistent marker beds and reliable aquifers, being
saturated in every WIPP test well east of the Nash Draw.
[WIPP is located in bedded salt. Layers of clay and
anhydrite are interspersed in the bedded salt. These layers
of clay and anhydrite are called MARKER BEDS. The WIPP
repository is located between Anhydrite b, Clay G Marker Bed
and Marker Bed 139.] Where the Rustler is unaltered by
solution (water eroding the sedimentary rock), its members
consist of alternating beds of anhydrite, halite, and
siltstone. Where there is circulating groundwater, however,
anhydrite converts to gypsum, and halite dissolves to
mudstone. At the WIPP-33 borehole (0.5 miles west of the
site), no halite remains in the Rustler and all anhydrite
has been converted to gypsum, indicating that water has
passed through this formation. There is a westward thinning
of the Rustler across the WIPP site, which is wholly
attributable to dissolution and removal of halite and
hydration of anhydrite to gypsum. Moving west across the
WIPP site, halite is missing from successively lower members
of the Rustler. The dissolution of halite in the Rustler
proceeds in a downward and eastward direction towards the
WIPP site. Virtually all scientists who have examined this
area recognize the extensive character of dissolution in the
Rustler Formation at the WIPP site. The work of two DOE
scientists does not "largely rule out this explanation," as
contended by the DOE. The Rustler Formation at WIPP is overlain by the Dewey
Lake Redbeds. In the eastern half of the WIPP site, the
Santa Rosa sandstone overlies the Rustler Formation. In the
case of this "covered karst," sandstone impedes but does not
prevent rainwater infiltration to the underlying karstic
aquifers. KARST AT THE WIPP SITE
Karst environments are the most vulnerable in the world to
groundwater contamination. The Nuclear Regulatory
Commission (NRC) has warned that "filtration, which acts in
porous media to remove many contaminants from the water, is
virtually absent in the karst environment." Larry Barrows,
when a geophysicist for Sandia National Laboratory,
identified 16 reports by 20 authors describing karstlands as
unreliable waste disposal environments. Nicholas Crawford,
a Professor of Karst Hydrology at Western Kentucky
University and one of the leading experts on karst
groundwater contamination, told the EPA, "One does not
locate a hazardous waste site in, below, or near karst
without an intensive karst hydrogeologic investigation."
The DOE states that surface collapse features are
characteristic of karst. To the contrary, Dr. Phillips
testified that karst need not involve surface collapse.
There can be sinkholes involving subsurface solution and
surface subsidence without collapse at the surface. The DOE claims to have employed surface mapping,
geophysical techniques, drilling, hydrologic testing, shaft
construction, and mining without finding evidence of karst.
Dr. Phillips addressed these claims one at a time. 1. Surface mapping can reveal the presence of closed
topographic depressions but cannot reveal whether they are
of karstic origin. 2. Geophysical techniques did find evidence of karst
at WIPP. The 1983 WIPP site gravity survey found negative
gravity anomalies beneath boreholes WIPP-14 and WIPP-33.
[WIPP-14 and WIPP-33 are sinkholes that were investigated by
drilling boreholes. The boreholes were never turned into
test wells.] The authors of the survey attributed the
anomalies to karst conduits. The 1976 WIPP site resistivity
survey identified the WIPP-14 borehole depression as a
"sinkhole due to solution caverning." The movement of water
causes both karst conduits and solution caverning.
[SOLUTION CAVERNING is caused when water soluble materials
are dissolved by solution.] There was also low resistivity
at borehole WIPP-33. Dr. Phillips found, when digging the
backhoe trenches as part of his thesis research, that there
was low resistivity at the eastern end of the karst valley
(within the southwest portion of the WIPP site). 3. Drillholes did reveal evidence of karst. Five
water-filled channels were found at borehole WIPP-33: 1 in
the Dewey Lake Redbeds, 2 in the Forty-Niner gypsum, and 2
in the Magenta dolomite. Mudfilled channels were found in
the Forty-Niner at test well H-3b2, in the Tamarisk at test
well H-6c, and in the unnamed lower member at test well H-6c
and borehole WIPP-14. In borehole WIPP-13, the Magenta
dolomite is leached, broken, and shattered. Collapsed
breccia was found in the underlying Tamarisk member.
[BRECCIA are composed of sharp rock fragments cemented in a
fine mineral network.] 4. Hydrologic testing has found hydraulic connections
and zones of high transmissivity along 2 flow paths from the
WIPP site to the accessible environment. [TRANSMISSIVITY is
the ability of an aquifer to transmit water.] The first
flow path is from test well H-3 to test well DOE-1 to test
well H-11 to test well P-17. The second flow path is from
the WIPP exhaust shaft to borehole WIPP-13 to borehole WIPP-
33 to borehole WIPP-25 (in Nash Draw). Borehole WIPP-14 and
borehole WIPP-33 were never converted to hydrologic test
wells, despite their potential for karst hydrogeologic
investigation. Therefore, the DOE's claim that hydrologic
testing revealed no evidence of karst is disingenuous. 5. Shaft construction resulted in deep washouts that
required the installation of 10-foot steel liner plates to
prevent further caving of the shaft walls. One of these
washouts, in a mudstone layer immediately beneath the
Culebra, was 6.7 feet from top to bottom and extended 2.5
feet into the shaft wall. Water seeps into the shaft at
this level. As much as 1 foot of water has collected in the
tunnel, now barricaded, leading north from the Waste
Handling Shaft. 6. Underground mining revealed no evidence of karst,
but one would not expect to find it in the Salado Formation
because water is not naturally running through the Salado.
The Salado Formation consists of Permian Age evaporites. The DOE does not address the results of methods such as
air photo interpretation, hand auguring, and backhoe
trenches. These methods did, however, produce evidence of
karst in the Mescalero Caliche within the WIPP site
boundary. MESCALERO CALICHE FORMATION
The DOE has stated to the EPA, and has stated in their
Comments, that the Mescalero Caliche is "extremely
impermeable" to rainwater infiltration and that the caliche
"is expected to be continuous over large areas." Evidence
shows, to the contrary, that the caliche is not a barrier to
infiltration. Up to 15% of the caliche has been dissolved
away, leaving surficial sands in direct contact with
fractured sandstone. Caliches are essentially limestones, composed of calcium
carbonate, a readily water soluble material. If there is
enough moisture, the caliches may develop karstic landforms
such as sinkholes, solution pipes, and discontinuous
drainage. Much of the cemented caliche caprock may be
practically impermeable. However, soil water reaching the
impermeable layer will migrate along the surface until it
finds an opening, perhaps a fracture or a hole caused by a
taproot, where water will again move downward, enlarging the
opening by solution. Soil water may also collect in
depressions on the caliche surface and initiate dissolution
there. The result is a perforated caprock that funnels
water into the karst formation in much the same way as do
sinkholes. Extending into the southwestern part of the WIPP site is
a karst valley 1 mile long, 200-10,000 feet wide, and nine
feet deep, consisting of troughs. These are solution-
subsidence troughs formed by the collapse of surface rocks
into underground caverns. With each collapse, the
underground streams establish new channels along nearby
fractures. The new troughs are not the result of the
collapse of a single cavern, but of several caverns. Trench exposures in the karst valley revealed 15 solution
pipes, 1 - 14 feet in diameter. Most of the solution pipes
pass entirely through the caliche caprock. Some of the
pipes are floored by caliche and hold water for a time.
Mesquite bushes grow in this area. The solution pipes are
appropriately called "flower-pot structures." In other
places in the karst valley, the caliche is mostly gone,
leaving widely separated caliche remnants exposed in the
trenches. Sometimes the carbonate has been leached, leaving
the caliche surface pockmarked with solution pits.
Sometimes all that remains of the caliche is a powdery
dissolution residue. In other cases, no carbonate remains
indicating solution processes are complete. A smooth,
continuous, impervious caliche surface cannot be expected in
buried caliche profiles. The effect is more like holes in
Swiss cheese. After heavy rainstorms, water runs along the
surface until it disappears into the solution pipes. Some
of the water finds its way through the joints and feeder
channels in the Dewey Lake Redbeds to solution channels in
the Rustler Formation. The DOE states that the caliche has not collapsed except
at the margins of Nash Draw (Comment No. 273-1-5). To the
contrary, Dr. Phillips testified that surface collapse is
visible in the caliche at the WIPP-33 sinkhole where a
caliche cliff stands 2 to 3 feet above the rim of the
depression and 30 feet above the floor. Moreover, the WIPP-
33 borehole revealed that 40 feet of waterborne fill had
collected in the sinkhole since the collapse. The actual
depth of the WIPP-33 sinkhole depression is 70 feet. Dr. Phillips dug backhoe trenches at the WIPP-14
sinkhole. The WIPP-14 sinkhole straddles the northern
boundary of the WIPP site and is 600 feet in diameter and 9
feet deep. There is no evidence of surface collapse
although such collapse could be obscured by up to 10 feet of
sand that has accumulated on the rim of the depression.
Hand auguring revealed a structural depression 6 feet deep
in the caliche surface. There were indications that the
depression had been filled with water in the past. The
caliche is extremely leached and degraded, leaving only
remnants pockmarked with solution features. The Santa Rosa
sandstone at sinkhole WIPP-14 is leached, broken, and
crumbled, presenting no barrier to rainwater
infiltration. SANTA ROSA SANDSTONE FORMATION
The DOE's Permit Application states that there is "little or
no water" in the Santa Rosa sandstone and that 11 of 12
observation wells completed in the Santa Rosa Formation were
dry. To the contrary, Dr. Phillips testified that the Santa
Rosa Formation was found to produce water in the exhaust
shaft, at 3 boreholes drilled in 1996 (within 215 feet of
the exhaust shaft), and in 11 of 12 monitoring wells located
within the fenced area of the WIPP site. [THE FENCED AREA
encloses the above ground structures.] Additional boreholes
would be necessary to define the extent of the water within
the Santa Rosa Formation. Because the Santa Rosa Formation
pinches out south and west of the WIPP shafts, such
boreholes would have to be drilled to the northeast where
there is evidence of fluid-bearing properties. In 1974
there was lost circulation of drilling fluids in the Santa
Rosa Formation at test well AEC-7, 3.8 miles northeast of
the WIPP site. In 1978 water was found in the Santa Rosa
Formation at test well H-5c in the northeast corner of the
WIPP site. In 1979 the United States Geological Survey
(USGS) proposed another test well at the H-5 hydropad to
evaluate the Santa Rosa Formation for fluid-bearing
properties, but that testing was never done. [A HYDROPAD
consists of several test wells for the purpose of conducting
hydraulic and tracer tests. The test wells are drilled to
obtain site-specific geophysical and geologic data.] The
DOE claims that the groundwater in the Santa Rosa Formation
is isolated, discontinuous, perched or semiperched.
Localized impenetrable layers sometimes provide impediments
to downward flow. Ponding may occur above these layers
producing a localized saturated zone known as a PERCHED
AQUIFER. This is not true. In fact, a continuously sloping
water table can be mapped in the Santa Rosa and Upper Dewey
Lake Formations. Dr. Phillips testified that there is not
enough data to definitively describe the fluid-bearing
properties of the Santa Rosa Formation or to model it as a
potential migration pathway. The DOE reports a hydraulic conductivity ranging from
0.44 ft./day to 15.5 ft./day at the 3 boreholes nearest the
exhaust shaft. By contrast, the highest reported
conductivity in the Culebra within the WIPP site is 3.8
ft./day at test well H-6. Therefore, it cannot be stated
unequivocally that the Culebra is the most transmissive
hydrologic unit above the repository. Finally, the DOE
states in its Comments that the Santa Rosa Formation is
"less than two feet thick." In fact, the formation is 16
feet thick at the exhaust shaft, 100 feet thick at test well
AEC-7, and 217 feet thick at test well H-5c. DEWEY LAKE REDBEDS FORMATION
The DOE believes the Dewey Lake Redbeds to be unsaturated
near the WIPP exhaust shafts and waste panels. In fact, Dr.
Phillips testified that the Dewey Lake Redbeds Formation has
produced water in the exhaust shaft (as seen in the video
shown by the Environmental Evaluation Group (EEG) at this
Hearing) and in 7 test wells very near the waste panels.
One of these test wells, H-1, is located directly above the
panels. In addition, lost circulation of drilling fluid in
the Dewey Lake Redbeds was reported at ERDA-9, P-1, DOE-2,
WIPP-33, WIPP-25, and H-7c. Water has been encountered in
the Dewey Lake Redbeds at 9 locations within the WIPP site,
including the shafts themselves. Water has also been
encountered at 6 locations within 2.5 miles of the WIPP
boundary. These wells are clustered in the south-central
part of the WIPP site and south of the site where the
Culebra water is freshest and the Santa Rosa Formation is
absent. The lost circulation of drilling fluids indicates
that the recharge area for the Dewey Lake Redbeds and the
Rustler Formations is within and near the site, everywhere
that the Santa Rosa Formation is not present. The DOE stated that the Dewey Lake "exhibits no flow at
the WIPP site." Dr. Phillips testified that the Dewey Lake
Redbeds produced 25 gallons per minute at test well P-9, 28
gallons per minute at test well WQSP-6, and 12 gallons per
minute at test well WQSP-6A, all within the WIPP site
boundary. Sandia National Laboratory has stated that the
transmissivity of the saturated fractured zone within this
formation (0.40 miles southwest of the waste panels) is 4
times greater than the highest reported transmissivity in
the Culebra within the WIPP site. [THE SATURATED FRACTURED
ZONE is the part of the Dewey Lake Redbeds consisting of
open fractures filled with water.] To Dr. Phillips'
knowledge, transmissivity has only been measured at WQSP-6A.
Dr. Phillips testified that it cannot be unequivocally
stated that the Culebra is the most transmissive unit above
the repository. Again, there is not enough data to model
the Dewey Lake Redbeds as a migration pathway. Photographs of the Dewey Lake Redbeds core samples from H-
3b3 (400 feet south of the waste panels) show that the upper
Dewey Lake Redbeds fractures are open. One hundred seventy
(170) feet below ground surface, most fractures are filled
with gypsum. This does not mean that the lower Dewey Lake
Redbeds is impermeable. There are feeder channels in this
formation right near the waste panels that transmit water
from the surface down to the Rustler Formation. The water in the Dewey Lake Redbeds is potable in all 6
wells where water quality was tested. Total dissolved
solids range from 390 mg./l to 4,238 mg./l, well within the
EPA criteria of 10,000 mg./l. At the Mills Ranch, 1 mile
from the WIPP site, water from a well (completed to the
Dewey Lake Redbeds) provides water for household and
livestock purposes. The DOE is incorrect in stating that
Mills Ranch is 3.5 miles from the WIPP site boundary. MAGENTA DOLOMITE
In its Comments, the DOE stated that the Magenta dolomite
"has low hydraulic conductivity through fractures." Yet the
transmissivity at test well H-3, 400 feet south of the waste
panels, is 330 sq. ft./day. At test well H-3b3 the
conductivity is 16.1 ft./day, or 1.1 mi./yr. The
photographs of the core also show 5 feet of the Magenta core
is broken and shattered. At borehole WIPP-13 the upper 11
feet of the Magenta is broken, shattered and leached to
mudstone. Borehole WIPP-13 was not converted to a Magenta
test well. At borehole WIPP-33, 2 water-filled caverns were
found in the Magenta. Similarly, borehole WIPP-33 was not
converted to a Magenta test well. At borehole WIPP-25
transmissivity was 375 sq. ft./day (compared to 270 sq.
ft./day in the Culebra). At borehole WIPP-25 the hydraulic
conductivity in the Magenta is 14.1 ft/day. In some
locations, Magenta hydraulic conductivity is high; in some
places its porosity is cavernous. Yet, again, there is not
enough data to model the Magenta as a potential migration
pathway. The DOE stated that the Magenta dolomite "contains
limited amounts of poor quality water" and "is not
considered a water source." Dr. Phillips testified that at
Magenta test wells within the WIPP site, total dissolved
solids range from 4,600 mg./l to 9,300 mg./l. Thus, the
Magenta groundwater, 400 feet from the waste panels, meets
both EPA criteria for drinking water: less than 10,000
mg./l of total dissolved solids and more than 5 gallons per
minute of water produced by the well. UNDISTURBED SCENARIO
The DOE stated that "any brine that may seep into the
facility É will be evaporated by the ventilation system so
that waste leachates cannot form." The DOE further stated
that "there is insufficient brine and pressure to drive
contaminants out of the disposal system and into nearby
groundwaters." The DOE concluded that, for these 2 reasons,
"contamination will not leave the disposal region," even
after closure of the repository. The DOE asserts that
"there are no credible pathways" that will result in
groundwater contamination and claims therefore that the
calculations of potential exposure to humans, domestic
animals, and wildlife are "not applicable to the WIPP."
The original premise of WIPP was that the salt beds would
be dry. But the Salado Formation contains clay seams and
anhydrite beds that produce brine, too much of which fatally
compromises containment. The brine migrates towards the
area of lowest pressure in the Salado Formation -- the WIPP
excavation. A ventilation system now evaporates the water,
but after WIPP closes, it will be a wet repository. The
brine would be able to corrode the steel drums and dissolve
the waste, creating a slurry of contaminated brine within
the WIPP repository. From the moment it became evident that
the WIPP repository would collect appreciable brine during
closure, the concept of nuclear waste disposal in salt has
remained indefensible. Brine is now "weeping" into the
repository at a slow but significant rate. Gases produced by waste corrosion will pressurize the
repository. Venting will occur by hydrofracturing weak clay
partings above the repository, opening a path for escape of
contaminated liquids. The sealed, undisturbed repository
will fail by sudden, runaway hydrofracture. At any
interruption of a clay bed or at an unsealed borehole, a
hydrofracture will jump to a higher stratum where
lithostatic pressure is lower. [LITHOSTATIC PRESSURE of any
given area is the weight of the column of rock overlying
that area in the earth's crust.] A single hydrofracture
following a succession of clay beds will breach to the
Rustler aquifer. After the gases have vented, contaminated
liquids will follow along the prepared pathway. BREACH SCENARIOS
The DOE believes that the water quality of the Pecos River
will not be impacted by WIPP because: (1) the Pecos River
is located 12 miles west of the WIPP site; (2) there are no
natural drainage features at the WIPP site; (3) no surface
release will occur at the WIPP; (4) there is no hydrologic
connection between surface water and the WIPP repository;
and (5) there is no driving mechanism that will allow
contaminates to migrate through the salt to a groundwater
unit that discharges to surface water. Dr. Phillips
examined the DOE's assertions, one at a time. 1. The Pecos River is indeed 12 miles west of the
WIPP site. 2. There are no natural drainage features at the WIPP
site because the WIPP site has almost no surface runoff.
The lack of evidence of surface runoff is not due to
inadequate precipitation, which averages 14.2 inches per
year in Nash Draw. Rather, the WIPP site is covered with
windblown sand in the form of deflation basins and partially
stabilized sand dunes. These sands are transmissive enough
to allow infiltration of even the largest storms. "Instead
of running off, the precipitation collects in small
topographic depressions and rapidly soaks into the ground.
The absence of surface runoff is characteristic of a
karstland." This is true even in semi-arid environments.
Apart from dune fields, deserts on impervious rocks rarely
lack stream courses, however ephemeral they may be. But
karst in semi-arid regions is usually without natural
drainage features. 3. Surface releases could occur at WIPP even before
closure by means of a blowout due to waterflooding and
hydrofracture at a well within 2 miles of the repository.
At one time the DOE retained a 2 mile buffer (Zones III and
IV) surrounding the WIPP repository in order to prevent
waterflooding and hydrofracture, to prevent solution mining
for potash, and to oversee the eventual plugging of oil and
gas drillholes. In 1983 the DOE relinquished Zone IV, thus
reducing the buffer to 1 mile. The rationale, according to
the DOE, was that "the minimal amount of crude oil likely to
exist within the WIPP site" made waterflooding adjacent to
WIPP unlikely [emphasis added]. There has since been an oil
and gas boom in the immediate vicinity of the WIPP site. As
of January 1998 there were 27 operating oil and gas wells
within the old Zone IV, 15 of them within 2 miles of the
waste panels. 4. There are hydrologic connections between the
repository and the land surface, namely, the waste-handling
shaft, the salt handling shaft, the air intake shaft, the
exhaust shaft and the ERDA-9 borehole. The 4 WIPP shafts
connect directly to the repository and the ERDA-9 borehole
is near enough to the repository footprint to be within the
disturbed rock zone (DRZ). Ultimately, containment at WIPP
depends on DOE's ability to seal the shafts and plug the
boreholes perfectly. There is no proven technology for plugging boreholes in
salt formations. In 1977 the DOE attempted to plug the ERDA-
10 borehole at the Gnome Site near Nash Draw. Four separate
plugs were emplaced for a total length of 4,430 feet. There
appears to be no record of the success or failure of the
attempt. 5. There is a driving mechanism that could push
contaminants through a less than perfectly sealed borehole
or shaft to overlying groundwater units. In 1981 a
pressurized brine reservoir associated with hydrogen sulfide
gas was encountered at the WIPP-12 borehole, about l.2 miles
north of the center of the WIPP site. The brine is located
in the upper Castile anhydrite, 240 feet below the Salado
Formation. The brine flowed to the land surface at a rate
of 1,500 barrels per day for 40 days. The total brine
outflow was 60,000 barrels, or 2.5 million gallons. The
total volume of the WIPP-12 brine reservoir was later
estimated at between 17 and 30 million gallons. By
comparison, about 63 million gallons would be necessary to
completely fill the WIPP repository. The WIPP-12 brine
reservoir is estimated to underlie as much as 60% of the
waste panels. The ERDA-9 borehole [one of the hydrologic
connections between the WIPP repository and the land
surface] penetrated 53 feet into the Castile formation. Two
hundred feet of vertically fractured anhydrite separates the
WIPP-12 highly pressurized brine reservoir from ERDA-9 and
the WIPP repository. It should be noted that as of January 1998 there were 177
operating oil and gas wells within 2 miles of the WIPP site
boundary, and 47 more had been planned and located. The DOE
plans to prevent any drilling at the WIPP site for 100 years
after closure, longer than the duration of a RCRA permit.
It seems inevitable, that after institutional controls are
lost, someone will drill through the karstic Rustler
aquifer, through a waste panel, and into the pressurized
brine reservoir, thereby breaching the WIPP repository
without ever reaching the underlying oil and gas
horizons. LAGUNA GRANDE DE LA SAL (or Salt Lake)
It is important to identify where contaminated water
escaping from the WIPP repository would reach the accessible
environment. There are 2 regional groundwater discharge
points in the WIPP area: Laguna Grande de la Sal in Nash
Draw and the brine springs at Malaga Bend on the Pecos
River. Dr. Phillips showed through evaporation analysis
that groundwater discharge to Laguna Grande de la Sal is
about 9 times the amount of groundwater discharge at Malaga
Bend. The DOE states correctly that "Nash Draw is the nearest
major geomorphic feature to the WIPP site. Nash Draw is one
of the largest karst features with surface expression in the
world. Bounded by cliffs, Nash Draw is a closed drainage
basin, 18 miles long, 5 to 10 miles wide, and 200 feet deep,
formed by the coalescence of thousands of sinkholes. The
DOE agrees that Nash Draw is an undrained physiographic
depression resulting from differential solution of the
Rustler and Upper Salado. The eastern rim of Nash Draw,
called Livingston Ridge, reaches within one mile of the WIPP
site boundary. The WIPP site lies within the Nash Draw drainage basin.
The lowest point in the basin is Laguna Grande de la Sal.
It is a salt lake with no outlet at the surface or
underground and loses water only by evaporation. The karst
springs that drain the Rustler Formation reach the surface
at Laguna Pequena, the largest inlet to Laguna Grande de la
Sal. There is no other apparent surface runoff into either
lake, so the regional water balance may be expressed as
follows: E - P = I E = evaporation from the lake surface
P = precipitation falling onto the lake surface
I = groundwater inflow to the lake Net evaporation from Laguna Grande de la Sal equals 5.84
x 10 exponent 8 cubic ft./yr. At least this amount of water
drains from the Rustler aquifer into Laguna Grande de la Sal
and an equal amount of infiltrating rainwater must reach the
Rustler Formation. In karst terrain like the Nash Draw watershed, there is
almost no surface runoff. Drainage is almost entirely
underground. Thus the regional water balance may also be
expressed this way: P - I = E P = precipitation
I = infiltration
E = evapotranspiration If precipitation equals 1.18 ft./yr., then precipitation
falling on the watershed is 1.16 x 10 exponent 10 cu.
ft./yr. The infiltration rate of 5.84 x 10 exponent 8 cu.
ft./yr. would equal about 5% of annual precipitation, and so
the rate of evapotranspiration would be about 95%. The DOE
claims that if more than 90% of precipitation is lost to
evapotranspiration, then "infiltration below the surface is
negligible." Dr. Phillips testified to the contrary that an
infiltration rate of only 5% results in a salt lake 2,120
acres in extent. It should be noted that Laguna Grande de
la Sal is only eight miles from the WIPP site, not the 10
miles the DOE suggests. RAINWATER RECHARGE
The DOE does admit that "intense local thunderstorms may
produce runoff and percolation." The EPA states that about
75% of total annual precipitation results from intense
thunderstorms between April and September. Dr. Phillips
observed one of these thunderstorms on September 18 and 19,
1985. Dr. Phillips observed 5 feet of standing water in the
WIPP-33 sinkhole, carried there by a disappearing arroyo.
The water sank into the sand within days, leaving behind a
"bathtub ring" of organic debris that recorded the high
water mark. Dr. Phillips also observed a new arroyo appear
on the landscape, only to disappear in another sinkhole
previously identified by hand auguring. These field
observations of rapid rainwater recharge are proof that
karst processes are active today. WIPP-33 is the
westernmost of a chain of 4 sinkholes, indicative of an
underground flow path beneath them. The easternmost
sinkhole is within 1,000 feet of the WIPP site boundary. There is evidence of rainwater recharge at the WIPP test
wells. A steady rise in water levels in 2 Magenta test
wells and 3 Culebra test wells, all located within the WIPP
site, was recorded between mid-1977 and mid-1981. This
occurred before the sinking of the first WIPP shaft in July
1981. The DOE says that this rise in hydraulic heads is
"unexplained." Dr. Phillips offers an explanation. During
this 4 year period, 68.55 inches of rain (17.14 inches per
year) was recorded in Carlsbad, New Mexico, compared to an
average of 10.85 inches of rain in the preceding 25 years.
While the water level rise in the Magenta and Culebra test
wells cannot be correlated with individual rainstorms, it
can be correlated with short-term trends of precipitation in
the area. The DOE's model of the Culebra dolomite as a confined
aquifer, receiving negligible rainwater recharge, is
inconsistent with groundwater geochemistry. If the Culebra
contained only "fossil" water left over from the ice ages,
it would be saturated, or nearly so, with total dissolved
solids (TDS). To the contrary, TDS in Culebra groundwater
within the WIPP site vary by a factor of 25 -- from 8,890
mg./l at test well H-2b to 230,000 mg./l at test well H-15.
These two test wells are only 1.66 miles apart. When the
Culebra test wells are plotted on a map, the contour lines
display a zone of high TDS in the northeastern part of the
WIPP site, where the Santa Rosa sandstone is present and
water is not found in the Dewey Lake Redbeds. In this zone,
TDS steadily decreases to the southwest, where the Santa
Rosa is absent and water is found in the Dewey Lake Redbeds.
This finding is consistent with the interpretation that the
Culebra groundwater becomes mixed with increasing amounts of
fresh water as it approaches Nash Draw because the
hydrologic regime is increasingly karstic. Freshwater recharge is occurring in the Rustler
Formation. Some test wells contain dissolved halite in
Culebra groundwater, but there is no halite in the Rustler
Formation. These wells are located to the west of the
Rustler Formation "dissolution front." There is halite in
the Rustler Formation only to the east, which indicates a
westerly component to groundwater flow. POTENTIAL PATHWAYS
Multi-well pump tests have revealed potential migration
pathways for contaminated water from the WIPP site. The
multi-well pump test procedure is to pump water from 1 test
well, monitor the water levels in other test wells, and to
determine if there was a response. If the wells are
hydraulically connected, the water level will drop in the
monitoring well. Likewise, the water level will rise in the
monitoring well after the pumping stops. Such multi-well
pump tests have revealed hydraulic connections between test
wells H-3, DOE-1, and H-11 in the southeastern part of the
WIPP site. There are also hydraulic connections between
test wells DOE-2, WIPP-13, and H-6 in the northwestern part
of the WIPP site. Cavernous zones were found at WIPP-33 in the Magenta and
higher strata. The WIPP-33 borehole was never converted to
a test well, despite promises to the USGS that WIPP-33 would
be available for hydrologic testing. A precipitous drop of
drilling equipment, lost circulation of drilling fluid, and
no core recovery indicated the presence of the WIPP-33
caverns. Unfortunately, an examination of the basic data
reports for other WIPP boreholes reveals that drilling time
and lost circulation are rarely noted so other criteria must
be used. For example, lost circulation, washout, loss of
core and/or dissolution residue must be used. Evidence of
these alternative criteria were found at 17 boreholes in the
Forty-Niner, 11 boreholes in the Tamarisk, and 22 boreholes
in the lower unnamed member, all inside or within 1 mile of
the WIPP site. Such consistent occurrences indicate that
these zones are poorly consolidated, probably transmissive,
and possibly cavernous. Water was observed seeping into the
WIPP ventilation shaft from the Forty-Niner member. Test
well H-1 yielded as much water in the Tamarisk member as in
the Magenta or in the Culebra. Test well H-3 yielded as
much water in the lower unnamed member as in the Magenta or
in the Culebra. These phenomena demonstrate that all of the
members of the Rustler Formation are at least water bearing
in places, and all Rustler Formation members are involved in
groundwater transport. The groundwater flow path from test well H-3 to test well
DOE-1 to test well H-11, primarily through the Culebra and
lower unnamed member, has been modeled by the DOE only as
far as the WIPP site boundary. The DOE has never conceded
that this groundwater flow path turns westward toward test
well H-7 in Nash Draw. There is another flow path from the WIPP repository to
Nash Draw that the DOE has not modeled. The multi-well pump
test centered at WIPP-13 has demonstrated a hydraulic
connection between the WIPP exhaust shaft and WIPP-25 in
Nash Draw, by way of WIPP-13. The response time between
WIPP-13 and WIPP-25 was extraordinarily rapid -- a delay in
maximum drawdown of only 26 hours between test wells nearly
4 miles apart. The apparent transmissivity between WIPP-13
and WIPP-25 is extremely high, 650 sq. ft./day, higher than
either WIPP-13 (72 sq. ft./day) or at WIPP-25 (270 sq.
ft./day). Located almost exactly midway between WIPP-13 and
WIPP-25 is the WIPP-33 sinkhole, which would explain the
extremely high transmissivity. The WIPP-13 multi-well pump test was centered in the
Culebra and all the monitoring wells were in the Culebra.
This is unfortunate because there is strong evidence that
this groundwater flow path is primarily through the Magenta
and higher strata. At H-3 the Magenta produced 6 gal./min.
[6 gal./min. = 360 gal./hr. = 8,640 gal./day] with a 6 foot
drawdown, compared to 25 gal./day in the Culebra.
Transmissivity in the Magenta at H-3 has been calculated at
330 sq. ft./day, compared to 19 sq. ft./day in the Culebra.
At WIPP-13 the Magenta is "broken and shattered," whereas
the Culebra is not. At WIPP-33 5 water-filled caverns were
found in the Magenta, Forty-Niner, and Dewey Lake Redbeds.
No water-filled caverns were found in the Culebra. At WIPP-
25 transmissivity in the Magenta was measured at 375 sq.
ft./day compared to 270 sq. ft./day in the Culebra. It is
wrong for the Detection Monitoring Program (DMP) to
disregard these potential pathways and to ignore the Magenta
altogether. GROUNDWATER MONITORING
The groundwater monitoring plan in the draft Permit treats
the Culebra as the only potential pathway for contaminants
in the Rustler Formation (as evidenced by the depths of the
test wells). The draft Permit also treats the Culebra as a
porous, homogeneous medium (as evidenced by the random
locations of the test wells). Permit Module V states that the DMP for groundwater
contamination shall consist of 7 wells -- 6 in the Culebra
dolomite and 1 in the Dewey Lake Redbeds. No other
geological strata are to be monitored, and no other test
well locations are contemplated. The 6 completed test wells to the Rustler aquifer are all
in the Culebra dolomite. The depth of the drilling reflects
the DOE's erroneous concept of the Culebra as a confined
aquifer, bounded above and below by impermeable anhydrite
beds. There is ample evidence that the Rustler is recharged
by rainwater and that all members of the Rustler are
involved in groundwater transport. The 6 Culebra test wells are located randomly, in a
hexagonal [6-sided] array, surrounding the WIPP repository.
The 6 monitoring wells, some of them hydraulically
upgradient from the WIPP site, might be considered
insufficient for an ordinary landfill and are surely
insufficient for our nation's defense transuranic waste
dump. The random locations of the test wells (a perfect
geometric pattern) might be appropriate if the Rustler
Formation were a porous, homogeneous, isotropic medium in
which groundwater flows predictably and uniformly
downgradient. The random locations of the test wells are
not appropriate in a fractured, heterogeneous, anisotropic
medium with solution-enhanced groundwater pathways, such as
the karstic Rustler aquifer. In karst, groundwater flows
through discrete channels comprising a very small fraction,
typically 0.1%, of the total rock volume. Test wells,
unless specifically located to intercept the groundwater
channels, are likely to miss them. There is ample evidence of karst in the Rustler at and
near the WIPP site. Potential groundwater pathways from the
WIPP repository to Nash Draw have been identified, and
groundwater travel times as short as ten years have been
calculated along the karst pathways. None of the WQSP test
wells are known to intercept these groundwater pathways, and
therefore these test wells cannot be relied upon to detect
groundwater contamination. Other locations, known to be in
or near these groundwater pathways, should also be
monitored: H-3, H-7, H-11, and DOE-1 in the Culebra; and H-
3, WIPP-13, WIPP-25, and WIPP-33 in the Magenta. If none of
these Magenta test wells are in operation, then the NMED
should require the DOE to drill them. The proposal to monitor only 1 test well in the Dewey
Lake Redbeds is a token gesture. At WQSP-6a the Dewey Lake
Redbeds produced 12 gal./min. of potable water, and so it is
a good monitoring choice. Because the Dewey Lake Redbeds
were more productive at other locations, monitoring should
take place at these other locations as well. The NMED states that the DMP "is necessary to demonstrate
compliance" with environmental standards. It is therefore
incumbent upon the NMED to require the DOE to monitor the
groundwater at the test wells mostly like to exhibit
contamination. Failure to do so would run the risk that a
breach of containment would remain undetected until much of
Nash Draw had become contaminated. IRREPARABLE HARM
The detection of groundwater contamination at the WIPP
monitoring wells would not constitute a preventive measure,
but a confirmation of failure. No remedial action would be
possible for a breach of containment at WIPP. The waste
could not be retrieval. The groundwater quality could not
be restored. The harm would be irreparable. The DOE plans to emplace waste in steel drums in direct
contact with salt, the most corrosive host rock imaginable.
Upon closure, WIPP will be a wet repository due to the
steady inflow of brine. The tunnels themselves are subject
to salt creep. The floors heave, the roofs collapse, the
walls cave in. Already a 1,500 ton slab of rock salt has
fallen from the ceiling in one of the WIPP experimental
rooms. These rooms have since been barricaded, with no
access for inspections. The roofs in Panel 1, the area
proposed for waste emplacement, have already experienced
failure, and are presently supported by 13 ft. roof bolts,
wire mesh, expanded metal, channel steel, and point-anchored
threaded rebar. There is a 220 ft. long open fracture, up
to 3 inches wide, in Room 7. There is a 180 foot-long
network of open fractures, up to 3 inches wide, in the
ceiling of Room 7. No one can say for certain that a roof
fall will not occur in Panel 1 during the time of waste
emplacement. Because of worker safety concerns, the NMED
should prohibit the use of Panel 1 for waste disposal in the
final Permit. An original premise of WIPP was that the salt would flow
like plastic, thus encapsulating the waste and isolating it
from the environment. Experience has shown otherwise. Even
if new waste panels are excavated, the roofs will eventually
collapse. Retrieval of waste would involve crushed drums
under tons of fractured salt, with contaminated brine
disbursed throughout. The volume of contaminated salt might
be many times greater than the volume of the original waste.
Because some of the waste is too hot to handle by humans
[remote-handled waste], retrieval would have to be attempted
by machines. The waste would have to be packaged and hauled
to another dumpsite. In short, retrieval of waste would be
impracticable. Dr. Phillips testified that if any miner
says it can be done, it is because he never expects to be so
required. Contamination at a monitoring well would suggest that the
entire groundwater pathway from the WIPP repository to the
test well had become contaminated. Corrective action would
require the pumping of contaminated water from a number of
test wells drilled directly into the groundwater pathway and
the injection of clean water into wells upgradient. Such
action would be futile because the source of contamination
would be continuous since the waste would be irretrievable.
What makes karst hydrology so relevant to RCRA
proceedings is the speed of groundwater transport. Dr.
Phillips and Dr. Snow have calculated groundwater travel
times as short as ten years from the WIPP repository to
Laguna Grande de la Sal. The DOE claims that contaminants
in groundwater would be retarded. However, the DOE's
conclusion is not based on sorbing tracer tests in the
field. Rather, the DOE has performed laboratory analysis
upon a few surviving blocks of dolomite taken from an
otherwise completely shattered interval of Culebra dolomite
at test well H-3b3. Clearly, the testing of the surviving
blocks of dolomite is not representative of conditions in
the field. Under karst conditions, the conservative assumptions are
that there is effectively no filtration and that the
contaminants will travel at the speed of water.
Contamination would arrive at Laguna Grande de la Sal as
soon as the groundwater could carry it there. Contaminants
would concentrate in the lake sediments until flushed out by
major flooding. There is a low, but discernable,
topographic divide between Laguna Grande de la Sal and the
Pecos River. This topographic divide is partly breached by
an irrigation canal, the elevation of which is 2,960 ft.
Field observations indicate that the evaporite crust of
Laguna Grande de la Sal has killed all vegetation up to an
elevation of 2,960 ft., the same elevation as the irrigation
canal. The top of the evaporite crust records the high
water level for the Laguna Grande de la Sal. Thus the
irrigation canal can be a conduit for overflow discharge
from Laguna Grande de la Sal to the Pecos River in times of
major flooding. The irrigation canal is 0.4 miles long and
reaches the Pecos River 3.25 miles east of the town of
Loving, New Mexico. The irrigation canal is known as the
"Loving Canal". If this canal should carry contamination
from the Laguna Grande de la Sal to the Pecos River, it is
here and downriver that actual victims would be
affected. A succession of reputable scientists over the years has
called for the following testing at the WIPP site. 1. Slant coring of Rustler Formation and Dewey Lake
Redbeds to characterize fractures, especially vertical
fractures; to determine if the 5 members of the Rustler
Formation are interconnected; and to determine if there are
feeder channels in the Dewey Lake Redbeds to karstic
channels. Vertical drill holes can easily miss karstic
features. 2. The conversion of boreholes WIPP-33 and WIPP-14
into test wells to measure groundwater flow under karst
conditions. 3. Dye tracer tests where dye is injected into
recharge areas like WIPP-33. The karst springs are then
monitored for arrival of the dye to check travel times. 4. Sorbing tracer tests to determine if there is
matrix diffusion and contaminant retardation. The DOE is charged with the burden of proof to show that
karst is not present at the WIPP site. HIGHLIGHTS OF CROSS-EXAMINATION OF DR. RICHARD PHILLIPS
In the EPA's Final Rule, the EPA addressed karst and
found no evidence of significant karst features in the
immediate WIPP area. The EPA also said the caliche was
continuous with no recharge. The EPA agreed with the
plausibility of the DOE's conceptualization of the WIPP site
geology. Dr. Phillips does not agree with the EPA's
conclusions. The EPA said if active dissolution was
occurring at the WIPP site, subsurface collapse features
would be evident. Dr. Phillips testified that collapse is
evident at WIPP, even though karst can occur without
evidence of surface collapse features. There are numerous WIPP test wells but boreholes WIPP-14
and WIPP-33 are not among them. The simplest explanation
for the lack of conversion from boreholes to test wells is
that the DOE is not interested in finding karst. The DOE
says there are more than 50 borings within the WIPP site and
that karst features in the Rustler Formation are not
encountered within the WIPP boundaries. Dr. Phillips does
not agree with the DOE's conclusion, but understands how
some people might be motivated to interpret the data that
way. Cavernous zones, washed out zones, and lost core or no
core results lead to evidence that karst may be present.
This evidence is the best available because the DOE often
did not record drilling times. Each result alone would not
necessarily indicate karst, but several results found
together would merit further investigation. The DOE's
failure to report drilling times has forced reviewers to
look at less definitive evidence to correlate possible
occurrences of karst across the WIPP site. The DOE's documentation of the construction of the
ventilation/waste handling shaft does not note washouts in
the Forty-Niner, Culebra, or unnamed lower member. If these
washouts had been found, they would have been noted in the
log, if the log were accurate. Dr. Phillips has no
information indicating that these logs are inaccurate. Dr.
Phillips has, however, seen other reports that he knows were
inaccurate. Washouts were encountered in the
ventilation/waste handling shaft before it was enlarged. WIPP-14 exhibited a 71-foot section of mud and fragments
of gypsum and anhydrite beneath the Culebra. Dr. Phillips
testified that this finding indicates a former flow channel.
The DOE says the surface depression at WIPP-14 was a
blowout. Dr. Phillips disagrees. Dr. Phillips has used an annual precipitation rate of
14.2 in./yr. at Nash Draw in his calculations. The DOE says
that the annual rainfall is approximately 12 in./yr. at the
WIPP site. The DOE claims that Dr. Phillips' water balance
calculation in his dissertation is wrong. The DOE stated
that if their annual rainfall amount is used in the water
balance calculation, there is no infiltration at the WIPP
site. Dr. Phillips disagrees with the DOE's annual rainfall
amount. Dr. Phillips testified that "approximately 12
inches" is not an accurate annual rainfall measurement. The Magenta and Culebra are not connected right at test
well H-6 but are connected in the general vicinity of test
well H-6. Fourteen wells, including the well farthest from
borehole WIPP-13 and the exhaust shaft, responded to the
multi-well pump test. Some responses were brief, some were
not so brief, and some took a long time. The DOE believes that there will not be enough brine in
the repository to form a leachate. Dr. Phillips disagrees
with the DOE's belief. The DOE/Sandia National Laboratory personnel said the
BARROWS BATHTUB was caused by a blowout from the wind.
Numerous people observed it. Some thought it was a small
doline or sinkhole. One person said it was a disturbed
site. Dr. Phillips trenched in the Barrows Bathtub during
his original research. He wanted to retrench it later but
was unable to do so. Some years, later two Citizens for
Alternatives to Radioactive Dumping (CARD) members dug a
trench by hand and found the Barrows Bathtub was a disturbed
site. They could not definitively describe the origins of
its features. The Barrows Bathtub appears in aerial
photographs from the 1950's. Because the Barrows Bathtub is
disturbed, no conclusions can be drawn about its
origins. Some sites that should be chosen for groundwater
monitoring wells in order to follow the karstic flow paths
are outside the WIPP site boundaries. There are karst features north of the WIPP site. Aerial
photographs show a chain of about 10 closed topographic
depressions with more vegetation than the surrounding
landscape. The closed topographic depressions are curved
around the northeast corner of the WIPP site and include
borehole WIPP-14. Borehole WIPP-14 was the only karstic
feature that was drilled or trenched. South of the WIPP
site is a vast karst area near the dune field at Mills
Ranch. Sinkholes can be clearly seen just south of the WIPP
boundary. One of the groundwater flow paths turns westward
there. West of the WIPP site there is a chain of sinkholes,
including borehole WIPP-33, leading to Nash Draw. Dr.
Phillips did not explore the area east of the WIPP site
because it is upgradient. Since the DOE has not characterized the geology above the
Culebra, the most transmissive flow paths could have easily
been missed. Karst channels may extend above the WIPP
repository. Test well H-3 is only 400 feet south of the
WIPP waste panels. Test well H-3 is of great concern
because the Magenta core in this location is broken and
shattered with high transmissivity. There is a scarcity of
data on the Magenta. Further investigation is needed to
define exactly the location of the karst conduits. There is
not enough characterization of the WIPP site at this time to
determine whether or not karst exists directly above the
repository. Dr. Phillips testified that karst is likely to
be found in the Rustler. It would be useful to conduct a multi-well pump test
centered in the Magenta. The test should explore the
interaction of borehole WIPP-33 with the other Magenta
wells. Injecting dye tracers and investigating discharge
points and wells along the routes would indicate the travel
times. The DOE has had 25 years to conduct these types of
tests. Many experts have requested such tests. The 1976 Resistivity Survey concluded that there was a
dissolution front on top of the Salado that extended into
the WIPP site. There are other water bearing members of the Rustler
Formation besides the Magenta and Culebra. At a February, 1999 technical exchange meeting in
Carlsbad, New Mexico, Al Lappin said that the DOE would not
perform any sorbing tracer tests. Dr. Phillips testified
that the sorbing tracer tests should be done.
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