EBTAG Annual Workshop and Field Trip
May 16-17, 2012

¹Registered Geologist, 7220 Central Avenue SE, Unit 1043, Albuquerque, NM, 87108, rhgilkeson@aol.com

²Concerned Citizens for Nuclear Safety, 107 Cienega Street, Santa Fe, NM, 87501

The necessary networks of monitoring wells to detect groundwater contamination from the LANL waste dumps do not exist. Practically all of the wells installed since 1997 are unreliable and require replacement. In 2007, the National Academy of Sciences (NAS) stated, “Many if not all of the [33] wells drilled into the regional aquifer under the Hydrogeologic Workplan appear to be compromised in their ability to produce water samples that are representative of ambient groundwater for the purpose of monitoring.” Plans and Practices for Groundwater Protection at the Los Alamos National Laboratory – Final Report (2007), p. 49. http://www.nap.edu/catalog.php?record_id=11883 

Further, in 2010, the New Mexico Environment Department (NMED) stated, “The NAS report references wells that were installed as part of LANL’s groundwater characterization efforts that were conducted in accordance with their Hydrogeologic Work Plan (1998)… These wells were not installed for contaminant detection or groundwater monitoring. Therefore, these wells have limited relevance to groundwater protection goals set forth by the March 1, 2005 Consent [Cleanup] Order.” LANL Renewal Permit (November 2010) General Response to Comments, p. 31. http://www.nmenv.state.nm.us/HWB/Permit.htm

Nevertheless, the unreliable characterization wells are now used as reliable monitoring wells for remedy decisions in the NMED "Cleanup" Order. The attempt to rehabilitate some of the characterization wells was not successful.  Replacement of the characterization wells and the new monitoring wells drilled under the “Cleanup” Order is needed because: (1) the screened zones were contaminated with large amounts of organic and bentonite clay drilling additives, (2) the wells were not installed along groundwater flow paths from the dumps, (3) the wells were not installed at locations close to the dumps, and (4) the wells were installed in “tight zones” and not in the permeable aquifer zones where the groundwater contamination is expected.

As a result, there is inadequate knowledge of the direction and speed of groundwater travel at the waste dumps because the careless drilling operations did not locate the water table or correctly locate and install the monitoring wells.

For example, the LANL September 2011 Corrective Measures Evaluation, Rev. 3 report for Material Disposal Area (MDA) G, a 63-acre dump for large inventories of radioactive, toxic and hazardous waste, admits there is inadequate knowledge of the direction of groundwater travel. LANL states, “In the area downgradient from MDA G, the direction of the regional aquifer flow is believed to be dominantly towards the southeast based on regional water-table levels and maps.” [Emphasis added.] LA-UR-11-4910, p. E-21. http://content.govdelivery.com/bulletins/gd/USLANL-12ce13 But the data and flow maps clearly demonstrate the direction of flow is to the northeast to the Pueblo de San Ildefonso and further to the Santa Fe Buckman drinking water wells. There are no reliable monitoring wells for groundwater contamination from MDA G.

LANL and NMED continue the mistake to use water quality data alone to determine that the monitoring wells damaged by drilling additives have “cleaned up” to produce representative water samples. However, the NAS and reports by the Environmental Protection Agency Kerr Research Laboratory explain that water quality data alone cannot be used for this purpose.