TESTIMONY OF ROBERT KEHRMAN - February 22, 1999.
Mr. Kehrman received a M.S. in Geology with a Geophysics
of Missouri, 1968 and a B.S. in Geology with a Geophysics
option, University of Missouri, 1967.
ROBERT KEHRMAN has been the regulatory advisor to WIPP
since 1994 and was the primary preparer of the Permit
Application and the DOE's Comments. He stated that the
hazardous waste at WIPP was mostly hazardous metals and
solvents. Most of this waste will be coming from more than 20
generator sites. WIPP itself will generate both derived
(mixed) waste which will be buried in the repository and
hazardous waste which will be shipped off-site.
The WIPP facility is sited in an isolated area where the
main activities are grazing, mining for potash, and oil and
gas exploration. No drilling or mining will be allowed within
the site boundary. Mr. Kehrman stated that the SALADO
formation was an impermeable, stable salt formation, which was
isolated from groundwater by impermeable formations above and
below the Salado. Although there is a small amount of water
(or brine) trapped in the salt, in the undisturbed case water
does not move in the salt. Mining has caused a disturbed rock
zone to extend out about six feet from the excavations, and
water from those fractures is drawn into the repository.
Cracks across anhydrite and clay seams in the salt can allow
water from areas beyond 6 feet to also enter the repository.
Below the Salado is the CASTILE FORMATION. Above the Salado
is the RUSTLER FORMATION which includes 2 water-bearing zones,
the CULEBRA and the MAGENTA. The Culebra is the first
regionally transmissive region above the site and the flowpath
of greatest significance, but it is separated from the Salado.
The DEWEY LAKE REDBEDS FORMATION is above the Rustler and has
no water directly over the WIPP site. THE SANTA ROSA
FORMATION is above the Dewey Lake Formation. Brine has been
found over the WIPP site recharged from ponds built at the
site for fire control.
The surface facilities were described, including the WASTE
HANDLING BUILDING (WHB) and the 4 shafts into the underground.
Then the underground Panels or Hazardous Waste Disposal Units
(HWDUs) were described. To date only the 7 rooms of Panel 1
have been mined. The main strategy to prevent contamination
at WIPP is never to open any waste containers at the facility.
The ventilation system underground is very important, and air
can be channeled through filters if there is any release.
Flow can also be reversed in case of underground fire. Air is
the most viable release pathway and the only way hazardous
materials could leave the facility. Volatile Organic Compounds
(VOCs) are continuously released from the waste. The VOCs are
monitored in the underground. Room limits have been
established for the amount of VOCs that may be released into
Closure activities: As each Panel is filled it will be
closed with PANEL CLOSURES. These panel closures will include
an explosion isolation wall and a concrete barrier. This
barrier will be built into the panel tunnels to the interbeds
above and below the excavation. When the facility is closed,
shaft seals will return the shafts to permeability almost like
the original state. Shafts will have some materials to render
them impermeable immediately and then natural materials for
long-term sealing. Groundwater monitoring around WIPP will
start with the Disposal Phase and will continue for 30 years
HIGHLIGHTS OF CROSS EXAMINATION OF ROBERT KEHRMAN:
Lead-contaminated water has been leaking down the exhaust
shaft. This is mainly from precipitation from the ventilation
there is a small leak in the Dewey Lake Redbeds/Santa Rosa
horizon from ponding on the
surface. This water is considered hazardous waste and is
shipped offsite for disposal.
DOE does not want the requirement for Magnesium Oxide
backfill totally removed from the Permit (although their
written Comments deleted this requirement) but only want more
flexibility on the amount used, size of containers, etc.
The purpose of WIPP is to be a Hazardous Waste Disposal
Facility (among other things).
Brine that may exist under the repository in the Castile
Formation is not a problem for WIPP because there are not any
pathways between the two locations.
Panel Closures are not seals because VOCs will continue to
seep out of the closed panels. However, particulate waste
will not come out. Closures
will employ commonly used materials, but the design and
materials have never been used under these exact conditions
before. Some shaftsealing design materials, like compacted
salt, have never been used for sealing shafts before.
Financial assurance: Proper closure is dependent on proper
The first waste stream to go to WIPP, Panel 1 would be non-
mixed waste from Los Alamos National Laboratory (LANL). This
waste would come before the Permit was issued. The DOE did
not consider the impact of this waste on
the Permit Application when they made the decision to ship
The only possible transport mechanism into the Culebra is
up the shafts. There are no monitoring wells planned for the
Magenta because the Culebra is so much more transmissive.
There is also no evidence of KARST within the WIPP site
boundaries, and within the site all 5 members of the Rustler
Formation are discrete. The possibility of karst at the site
thoroughly investigated by drilling 3 or 4 test wells into
"anomalies." Only borehole WIPP-33 to the west of
the site showed caverns and evidence
of karst. Other agencies, including regulatory agencies,
have reviewed the data and agreed that there is no karstic
flow at the site. Groundwater mostly infiltrates into the
surface and evapotranspires back into the atmosphere. There
is no connection between WIPP and flow in Nash Draw, and
water in the Culebra is not from rainwater recharge but is
about 12,000 years old.