The Continuance of the Presentation by Citizens for Alternatives to Radioactive Dumping (CARD)


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 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.


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.

A number of scientists who disagreed with the DOE's "party line" about the geology of the WIPP site were taken off the project or lost their jobs altogether when they raised question about the suitability of the site.

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