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This report is an independent assessment of the potential for karst dissolution in evaporitic strata of the Rustler Formation at the Waste Isolation Pilot Plant (WIPP) site. Review of the available data suggests that the Rustler strata thicken and thin across the area in depositional patterns related to lateral variations in sedimentary accommodation space and normal facies changes. Most of the evidence that has been offered for the presence of karst in the subsurface has been used out of context, and the different pieces are not mutually supporting. Outside of Nash Draw, definitive evidence for the development of karst in the Rustler Formation near the WIPP site is limited to the horizon of the Magenta Member in drillhole WIPP-33. Most of the other evidence cited by the proponents of karst is more easily interpreted as primary sedimentary structures and the localized dissolution of evaporitic strata adjacent to the Magenta and Culebra water-bearing units. Some of the cited evidence is invalid, an inherited baggage from studies made prior to the widespread knowledge of modern evaporite depositional environments and prior to the existence of definitive exposures of the Rustler Formation in the WIPP shafts. Some of the evidence is spurious, has been taken out of context, or is misquoted. Lateral lithologic variations from halite to mudstone within the Rustler Formation under the WIPP site have been taken as evidence for the dissolution of halite such as that seen in Nash Draw, but are more rationally explained as sedimentary facies changes. Extrapolation of the known karst features in Nash Draw eastward to the WIPP site, where conditions are and have been significantly different for half a million years, is unwarranted. The volumes of insoluble material that would remain after dissolution of halite would be significantly less than the observed bed thicknesses, thus dissolution is an unlikely explanation for the lateral variations from halite to mudstone and siltstone. Several surficial depressions at WIPP, suggested to be sinkholes, do not have enough catchment area to form a sinkhole, and holes drilled to investigate the subsurface strata do not support a sinkhole interpretation. Surface drainage across the WIPP site is poorly developed because it has been disrupted by migrating sand dunes and because precipitation is not focused by defined catchment areas in this region of low precipitation and low-dip bedding, not because it has been captured by sinkholes. There are no known points of discharge from the Rustler Formation at WIPP that would indicate the presence of a subsurface karst drainage system. The existing drillholes across the WIPP site, though small in diameter, are sufficient to assess the probability of karst development along the horizontal fractures that are common in the Rustler Formation, and the area of investigation has been augmented significantly by the mapping of four large-diameter shafts excavated into the WIPP repository. The general absence of dissolution, karsting, and related conduits is corroborated by the pumping tests which have interrogated large volumes of the Rustler Formation between drillholes. Diffusion calculations suggest that separate isotopic signatures for the water found in the fractures and the water found in the pores of the matrix rock between fractures are unlikely, thus the isotopic evidence for ancient Rustler formation waters is valid. Geophysical techniques show a number of anomalies, but the anomalies do not overlap to portray consistent and mutually supporting patterns that can be definitively related to karst void space at any given location. The coincidence of the Culebra and Magenta potentiometric heads between Nash Draw and the WIPP site is the inevitable intersection of two non-parallel surfaces rather than an indication of karst-related hydraulic communication between the two units. The proponents of karst in the Rustler Formation at the WIPP site tend to mix data, to take data out of context, and to offer theory as fact. They do not analyze the data or synthesize it into a rigorous, mutually supporting framework. They assume that the existence of an anomaly rather than the specific characteristics of that anomaly proves the existence of intra-stratal karst in the Rustler Formation. In most cases, the interpretations of karst offered are non-unique interpretations of data for which more plausible interpretations exist

Assessment of the potential for karst in the Rustler Formation at the WIPP site.