Significance of water fluxes in a deep arid-region vadose zone to waste disposal strategies

Recently collected subsurface site characterization data have led to the development of a conceptual model of water movement beneath the Area 5 Radioactive Waste Management Site (RWMS) at the Nevada Test Site (NTS) that differs significantly from the conceptual model of water movement inherent in Resource Conservation and Recovery Act (RCRA) regulations. At the Area 5 RWMS, water fluxes in approximately the upper 75 m (250 ft) of the vadose zone point in the upward direction (rather than downward) which effectively isolates this region from the deep (approximately 250 m (820 ft)) uppermost aquifer. Standard RCRA approaches for detection and containment (groundwater monitoring and double liners/leachate collection/leak detection systems) are not able to fulfill their intended function in this rather unique hydrogeologic environment. In order to better fulfill the waste detection and containment intentions of RCRA for mixed waste disposal at the Area 5 RWMS, the Department of Energy, Nevada Operations Office (DOE/NV) is preparing a single petition for both a waiver from groundwater monitoring and an exemption from double liners with leachate collection/leak detection. DOE/NV proposes in this petition that the containment function of liners and leachate collection is better accomplished by the natural hydrogeologic processes operating in the upper vadose zone; and the detection function of groundwater monitoring and the leak detection system in liners is better fulfilled by an alternative vadose zone monitoring system. In addition, an alternative point of compliance is proposed that will aid in early detection, as well as limit the extent of potential contamination before detection. Finally, special cell design features and operation practices will be implemented to limit leachate formation, especially while the cell is open to the atmosphere during waste emplacement