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APPENDIX F - DISSENTING STATEMENT ON ISSUE 1 AND 7
Pages 227-238

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From page 227...
... Further, a history of both chemical and radioactive leachate at the water table at the Beatty facility, an analog of the Ward Valley Site, suggests inadequate documentation/understanding of the hydrologic processes in the thick vadose zones at both sit - . Arid-climate vadose zones are the least wed-documented hydrologic systems of te~restial environments Carol may prove to be the most deceptive as welI)
From page 228...
... Soil moisture and chIonde profiles indicate dry conditions and no percolation to below the root zone. Other Ward Valley site datasets also may be interpreted to permit some deep percolation by preferred or local paths, such as periodic water-level fluctuations, water-chemistry variations, high infiltration rates at the pit percolation test, high densities of norrnaDy deep-rooted plants, numerous small wash channels in the site area' a higher concentration of modem carbon In the longer-term pumped sample from MOO-WV-l, the order of magnitude larger heat dissipation probe potentials than would be determined Tom the thermocouple psychrometers and soil moisture content data, and so forth.
From page 229...
... Ecology Beattv Nevada radioactive and hazardous waste disposal tac~ty, the climate, vegetation zone, hydrogeology, and basin setting are similar to the Ward Valley site. The general design for the proposed Ward Valley disposal facility is closely based on the Beatty disposal facility, arid similarites are pointed out throughout the license application documentation.
From page 230...
... Ward Valley has, perhaps, about twice as much mean annual precipitation arid double the thickness of the vadose zone as the Beatty facility. The modeled retention appears to not have occurred at the Beatty facility, as the first documented evidence for leachate in the saturated zone was In 1982, 20 years after disposal operations began, and apparent occasional breakthroughs of leachate continue to occur through 1993.
From page 231...
... , whereas other databases from six boreholes suggest little or no deep percolation at the borehole sites. The Beady facility monitoring record and the significant tr~tium profile at the Ward Valley site combine to suggest the vados~zone hydrology Is not understood at either site.
From page 232...
... The dual wad reverse circulation rotary technique is cost-e~ective and useful for vertically controlled sampling In the 300 meter thick vadose zone and uppermost saturated zone. The methodology wiD produce cuttings in the vadose zone useful for the fodow~ng analyses: CI-36, soil moisture contents, water extractions for tr~tium (later gas extractions for tr~tium arid C-14 are possible)
From page 233...
... Therefore, timely revegetation to high densities is of paramount importance to assure little or no percolation of water to the emplaced waste. A preliminary review of the trench cover and water balance literature suggests there is little or no documentation of the time and moisture required to reestablish the existing high-density vegetation and root-zone barrier on the raised trench covers in the Mojave Desert climate.
From page 234...
... Sediment properties and water movement through shallow unsaturated alluvium at an arid site for disposal of low-level radioactive waste near Beatty, Nye County, Nevada, U.S. Geological Survey, Water Resources Investigations Report 92(4032)
From page 235...
... Geohydrology of the unsaturated zone at the burial site for low-level radioactive waste near Beatty, Nye County, Nevada, U.S. Geological Surrey, Water Supply Paper 23 12, p.
From page 236...
... Trench cover systems for manipulating water balance on low-level radioactive waste sites, in Bedinger, M.S.
From page 237...
... Hakonson, 1984. Water balance calculations and net production of perennial vegetation in the northern Mojave Desert, I
From page 238...
... Some characteristics of soil and perennial vegetation in northern Mojave Desert areas of the Nevada Test Site, University of California, Laboratory of Nuclear Medicine and Rad. Biology, Los Angeles, California, UCLA No.


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