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SpicaBooks.Com/Nuke_Wipp.html Stop WIPP
* Nuclear Waste Isolation Pilot Plant near Carlsbad, New Mexico * Karst terrain is only one-mile away * Plutonium only stored in steel barrels * There's drilling less than two-miles away * Dry salt today can become brine tomorrow
Closing Arguments on EPA's Proposed Decision to Open WIPP Copyright 1998 by Richard Hayes Phillips, Ph.D. My name is Richard Hayes Phillips. As you know, I am a doctor of karst geomorphology. I have studied the WIPP site for 19 years, and I conducted eight months of field work at the WIPP site. I have already presented to you a cogent description of the regional hydrology of the WIPP site and the Nash Draw watershed, based upon measured data and field observations.
My concerns are not imaginery; they are real. I address you, today, as if I were an attorney, making closing arguments to the jury, on appeal. I will specifically address the Technical Support Document for the EPA's proposed decision, which is what these hearings are supposed to be about. I will point out some of the false statements made by the DOE to the EPA, and relied upon by the EPA, in arriving at its proposed decision.
Searching for a presumed barrier to rainwater recharge and karst hydrology at the WIPP site, DOE indicated that the Mescalero caliche is typically present beneath the sand. DOE told EPA that the Mescalero caliche covers the WIPP area as a hard, caliche crust up to ten feet thick, which led EPA to conclude that karst development is not a threat to waste containment at WIPP.
DOE, also, said that the Mescalero caliche is expected to be continuous over large areas, and that WIPP data are limited mainly to boreholes. EPA is referred once again to my doctoral dissertation. EPA has three copies, including one with color photographs submitted at public hearings in Albuquerque in 1990. My dissertation contains site-specific maps and photographs of the Mescalero caliche surface, based on 1000 augur holes and ten hackhoe trenches which I dug at the WIPP site and vicinity.
Four of these trenches were located in the eastern end of a karst valley, within the WIPP site, within the rainwater recharge area, where Mescalero caliche is in direct contact with the Dewey Lake Redbeds.
The karst valley, one mile long, is plainly visible in the WIPP site air photos. Trench exposures in the karst valley revealed 15 solution pipes, 1 to 14 feet in diameter, most of them passing entirely through the caliche, the largest of them displaying surface collapse in the Dewey Lake Redbeds. A smooth, continuous caliche surface cannot be expected; the effect is more like Swiss cheese. After heavy rainstorms, water runs along the caliche surface until it disappears into the solution pipes and infiltrates into the Dewey Lake Redbeds. DOE knows this. DOE videotaped the trenches. Larry Barrows, Al Lappin, Steve Lambert and George Bachman all viewed the trenches, as did a number of other scientists affiliated with New Mexico Tech, Texas Tech, EEG (?) and EPA.
DOE stated that the Dewey Lake Redbeds have not produced water within the WIPP shafts, or in boreholes int the immediate vicinity of the waste panels, and that the Dewey Lake exhibits no flow at the WIPP site. These statements are false, and here is why:
The Dewey Lake Redbeds have produced water in the WIPP exhaust shaft at approximately 100 feet below the surface, which EEG says can be traced to recharge. The Dewey Lake produced water in the air intake shaft as well. The Dewey Lake Redbeds have produced water in four test wells in the immediate vicinity of the waste panels (H-1, H-2, H-3, and WQSP-6).
One of these wells, H-1, is located directly above the waste panels. The Dewey Lake Redbeds do exhibit flow at the WIPP site. According to the neutron log for H3-b4, a down-hole camera recorded water streaming from a fracture only 35 feet above the Rustler Formation, which leads to the inescapable conclusion that, in the immediate vicinity of the waste panels, the Dewey Lake Redbeds contain feeder channels which readily transmit water to the Rustler Formation.
DOE's fallback position is that the Rustler anhydrites, siltsones and claystones are confining layers, barriers to rainwater infiltration. In performance assessment, the forty-niner, Tamarisk, and lower unnamed members of the Rustler Formation are assigned a permeability of zero, despite occasional reports of Rustler claystones producing water at rates equivalent to the Culebra or Magenta dolomites.
CARD (?) has correlated and presented borehole data showing wahouts and sonsistent loss of core in two distinct horizons of Rustler mudstone: in the Forty-Niner member about 20 feet above the Magenta, and in the lower unnamed member immediately beneath the Culebra. These are not occasional occurrences.
CARD succinctly summarizes 12 such encounters above the Magenta and 14 beneath the Culebra, all of them at or near the WIPP site. CARD describes a similar horizon in the Tamarisk member, with washouts of loss of core in 5 locations and reports of dissolution residue in 7 others. Evaporite rocks are not typically fractured, and a consistent lack of core recovery in horizons identified by the actual drillers as being dissolution residues is a clear indication of unconsolidated or cavernous zones capable of transmitting water with little resistance. When these occurrences are correlated and mapped, as CARD has done, it is shown that these zones snake across the WIPP site, penetrating its heart at the ventilation shaft.
DOE claimed that the Magenta dolomite is unfractured at WIPP. This claim was later modified to read that the Magenta has no hydraulically significant fractures at WIPP. The Peer Review Panel was unconvinced. DOE, in response, stated that the only location on the WIPP site at which open fractures have been observed in the Magenta is WIPP-13. At WIPP-13, according to the lithologic log, the Magenta dolomite is broken and shattered by numerous fractures dipping 60 to 80 degress and displacing bedding planes. At WIPP-19, open fractures were found in Magenta core; and in the WIPP ventilation shaft, eleven fractures in the Magenta, all of them vertical to subvertical, all of them open, were observed and mapped.
DOE told EPA that it does not appear that the Culebra dolomite is extensively fractured in the vicinity of the WIPP shafts. The truth is that in the WIPP air intake shaft, much of the Culebra dolomite exhibits extensive subvertical to vertical fracturing. About half of the fractures are filled with gypsum, and the rest are open. The lower six inches consists of brecciated dolomite. At H3-b2 the Culebra is totally fragmented. Only three core samples totaling 4 feet were recovered; 18 feet of Culebra core was lost, and another 5 feet of core was lost in black clay (not claystone - - clay) immediately beneath the Culebra.
At H3-b3 the whole Culebra interval was broken into pieces less than one foot in length; where pieces were preserved, the core was very porous; some fractures were open, some were filled with gypsum; 14.5 feet of Culebra core was lost, and another 4 feet of core was lost in the black clay beneath the Culebra. This is entirely consistent with a cavernous groundwater flow path through the Culebra dolomite and the claystone of the lower unnamed member of the Rustler.
DOE says that Culebra groundwater is saturated with respect to gypsum. DOE made this statement in response to EPA's concerns about the potential for dissolution of gypsum fillings in fractures in the Culebra dolomite. DOE convinced EPA that dissolution processes are not presently occurring in the Rustler Formation, and that conditions are not expected to change during the regulatory period, that is, in the next 10,000 years.
DOE's argument is that infiltrating waters that would cause the dissolution would become saturated with respect to gypsum and therefore would be unable to dissolve anhydrite or gypsum. The truth is that infiltrating groundwater will not be saturated with gypsum until it has dissolved enough gypsum to become saturated.
Presently, some Rustler groundwater is saturated with respect to gypsum, and some is not; concentrations of dissolved calcium and sulfate vary not only from well to well, but also from time to time -- for example, along the entire southeastern flow path from the WIPP site to Nash Draw, at test wells H-3, DOE-1, H-11 and P-17. Dissolution of gypsum fillings in Culebra fractures is presently occurring.
DOE states that there is no evidence from hydraulic conductivities that the karst development found at WIPP-33 extends into the WIPP site. The truth is that WIPP-33 extends into the WIPP site. The truth is that WIPP-33 was never converted to a hydrologic test well, and so there are no multiwell pump tests designed to determine whether or not the five water-filled caverns found at WIPP-33 -- two in Magenta dolomite, two in Forty-Niner gypsum, and one in Dewey Lake siltstone -- are hydraulically connected to the WIPP site. If there is no evidence, this is because DOE has not done the necessary testing. Absence of evidence is not evidence of absence.
However, a multiwell pump test centered in the Culebra at WIPP-13, located within the WIPP site, did show a hydraulic connection to WIPP-25, located 4 miles away in Nash Draw, which DOE admits is a karst valley. The response was extraordinary rapid; the delay in maximum drawdown at WIPP-25 was only 26 hours. The transmissivity between WIPP-13 and WIPP-25 was calculated at 650 square feet per day, which works out to a hydraulic conductivity of 27 feet per day.
WIPP-33 is located almost exactly midway between WIPP-13 and WIPP-25. WIPP-33 is the westernmost of a chain of four sinkholes; they are almost perfectly aligned with WIPP-13. There was, also, a measurable response at the WIPP exhaust shaft, 1.5 miles southeast of WIPP-13, which suggests an existent northwesterly flow path from the WIPP repository all the way to Nash Draw, by way of WIPP-33.
Ladies and gentlemen of the EPA, you have been deceived, through no fault of your own. You have a duty to overturn the proposed decision to open WIPP, because it was based upon false testimony. To change your mind, now, would not be an embarrassment. It would be an act of courage.
You can reach Richard Hayes Phillips, Ph.D., by telephone at (315) 379-0820, by snail mail at 4 Fisher Street, Canton, NY 13617, or by e-mail @ richardhayesphillips@yahoo.com.
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