Dr. Richard Phillips
University of Oregon
In 1999, the New Mexico Environment Department (NMED) held hearings to determine if they should issue an operating permit for WIPP. Under the Resource Conservation and Recovery Act (RCRA) the State is authorized to permit and regulate hazardous and mixed waste treatment, storage and disposal facilities in New Mexico. (Mixed waste is waste that is both radioactive and hazardous.) After the hearing WIPP was permitted to operate as a mixed waste storage and disposal facility. The State operating permit is the only permit issued to the WIPP facility and allows the state to regulate only the hazardous component of the waste. Regulation of the radioactive component is legally reserved for the Department of Energy (DOE) under the Atomic Energy Act. DOE effectively self-regulates that portion of the waste.
Doe is continuously modifying or attempting to modify WIPP's permit--sometimes trying to include waste treatment in the permit. So far they have not been allowed to add hazardous waste treatment at WIPP.
Dr. Phillips testified on many aspects of the geology and hydrology at WIPP during these hearings as a witness for CARD. Exhibits referred to in this paper were slides and overhead projections shown during his testimony and can be seen in the WIPP public record at NMED in Santa Fe, New Mexico. Some of these exhibits are also shown here.
My name is Richard Hayes Phillips. I hold a doctorate in karst geomorphology and hydrology from the University of Oregon. These are my fields of formal training and expertise. For purposes of these hearings, I claim no others.
Geomorphology is the study of landforms and the processes that create them and destroy them. Karst refers to landscapes that develop on soluble rocks such as limestone, dolomite, gypsum, anhydrite and halite. The most obvious surface characteristic is a lack of surface runoff. Rainwater infiltration is rapid and substantial, through sinkholes and disappearing streams and, in semi-arid climates, disappearing arroyos and perforated caprock. Drainage is almost entirely underground, through solution-enlarged fractures, channels, and caverns. Instead of seeping through innumerable pores as in sandstone, groundwater flows preferentially through discrete underground pathways, enlarging them by solution as it does so, and emerging at a few large, irregular springs (Phillips, 1987, pp. 34-41) (Phillips and Snow, 1998, 1-8).
The WIPP site is located in the Pecos River Valley, one of the largest karstlands in the United States (LeGrand et al., 1976, Figure 1) [Exhibit 1]. The Pecos River Valley is famous for Santa Rosa sinks, Bottomless Lakes, and Carlsbad Caverns. East of the Pecos River lies the Mescalero Plain, a gently rolling landscape capped by Mescalero caliche and covered by a mantle of windblown sand (Phillips, 1987, Figure 1) [Exhibit 2]. Near the WIPP, the edge of the Mescalero Plain is marked by Livingston Ridge, an eastward-retreating escarpment (USGS memo, George O. Bachman to William P. Armstrong, 10/26/79). To the west, within one mile of the WIPP site, is Nash Draw, one of the largest surface karst features in the world (Phillips, 1987, Figure 2) [Exhibit 3].
The WIPP repository is located 2150 feet below the surface in the Salado salt formation. Directly overlying the Salado is the Rustler Formation, the principal karstic aquifer in the vicinity. The Rustler is divided into five members, in descending order: the Forty-Niner, Magenta, Tamarisk, Culebra, and lower unnamed members (Phillips, 1997a, Figure 1) [Exhibit 4]. The Magenta dolomite and Culebra dolomite are persistent marker beds and reliable aquifers, being saturated in every WIPP test well east of Nash Draw (Phillips and Snow, 1997, Table 2). Where the Rustler is unaltered by solution, (for example, at test well P-18, considered to be a complete Rustler section), the Forty-Niner, Tamarisk, and lower unnamed members consist of alternating beds of anhydrite, halite and siltstone. However, in the presence of circulating groundwater, anhydrite converts to gypsum, and halite dissolves to mudstone. At the WIPP-33 borehole, no halite remains in the Rustler, and all anhydrite has been converted to gypsum (SAND 80-2011, pp. 15-21).
Isopach maps (SAND 82-1069, Figure 2.25) [Exhibit 5] show a westward thinning of the Rustler, from 440 feet thick at P-18, one mile east of the WIPP site, to 276 feet thick at WIPP- 33, one-half mile west of the WIPP site. The reduction in thickness is wholly attributable to dissolution and removal of halite, and hydration of anhydrite to gypsum. As one moves westward across the WIPP site, halite is missing from successively lower members of the Rustler Formation (Phillips and Snow, 1997, Figure 2) [Exhibit 6]. This is consistent with the interpretation that dissolution of halite in the Rustler proceeds in a downward and eastward direction. Phillips and Snow (1997, p. 4) cite 15 reports by 21 authors who support this interpretation (see also Jones et al., attachment to USGS memo from Twenhofel to Schueler, 07/18/78). The extensive character of dissolution in the Rustler at WIPP is recognized by virtually all scientists who have examined this area (Anderson, 1996, p. 2) The works of two scientists on the DOE payroll does not largely rule out this explanation, as contended by DOE (CCA, p. 2-38) (Phillips, 1998a, p. 18)
The Rustler Formation at the WIPP site is overlain by the Dewey Lake Redbeds and, in the eastern half of the site, by the Santa Rosa sandstone [Exhibit 4]. This is known as a covered karst, the classic example in North America, where sandstone cover rocks impede but do not prevent rainwater infiltration to the underlying karstic aquifers (Phillips, 1987, p. 18) (Phillips and Snow, 1998, p. 8) (Sweeting, 1973, p. 59)
Karst at WIPP
DOE claims that, in selecting a location for a hazardous waste facility, certain environmentally sensitive environments, such as karst, should be considered (Comment No. 273-I-5, p. 5). To the contrary, karst enviroments are the most vulnerable in the world to groundwater contamination (Crawford, Nicholas, EPA Docket # A-93-02, Item # IV-G-42). The geologic literature is replete with reports of contaminated groundwater discharging rapidly and unexpectedly at karst springs. While it is true that some karstlands, including the Pecos River Valley [Exhibit 1], are so extensive that some local or regional landfills will inevitably be located within them, it is wholly inappropriate even to consider locating the national waste dump in or near a karstland.
The United States Nuclear Regulatory Commission (NRC) published an entire report on the subject. The report is entitled: Foundation Considerations in Siting of Nuclear Facilities in Karst Terrains and Other Areas Subject to Ground Collapse. The authors warned that filtration, which acts in porous media to remove many contaminants from the water, is virtually absent in the karst environment. (Franklin et al., 1981, p. 57). Larry Barrows, when he was a geophysicist for Sandia National Laboratories, identified 16 reports by 20 authors who described karstlands as unreliable waste disposal environments. (Barrows, 1982, p. 17, reprinted as EEG-32, Appendix A). Nicholas Crawford, who is a Professor of Karst Hydrology at Western Kentucky University and is one of the leading experts on the subject of 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. (EPA Docket # A-93-02, Item # IV-G-42).
DOE states that surface collapse features are characteristic of karst. (Comment No. 273-I-5, p. 5). To the contrary, karst need not involve surface collapse. Phillips (1987, p. 193) cites 14 reports by 19 authors who describe sinkholes involving subsurface solution and surface subsidence without collapse at the surface.J. N. Jennings (1985, pp. 107, 111-112, cited by Phillips and Snow, 1998, p. A-10) calls them subsidence dolines. These are his words:
Where thick soils or superficial deposits cover karst rocks, dolines can develop through spasmodic subsidence and more continuous piping of these materials into widened joints and solution pipes in the bedrock beneath. They vary much in size and shape. A quick movement of subsidence may temporarily produce a cylindrical hole, which rapidly weathers into a gentler conical or bowl shape. The latter shape, however, can also be the consequence of more or less continuous small-scale movements only.
DOE claims to have employed surface mapping, geophysical techniques, drilling, hydrologic testing, shaft construction, and underground mining, without finding evidence of karst at the WIPP site. (Comment No. 273-I-5, p. 5). Let us examine these claims one at a time.