HomeMy WebLinkAboutMLA08-00509 AQUIFER RECHARGE AREA REPORT December 23,2008
CBENDER
CONSULTING, LLC
Applied Groundwater Solo lions
Mr. Brandon Bird p.16 154
1992 South Elgcr Bay Road
Olympic Property Group Camauo Island,WA yti2142
19245 Tenth Ave.NE ph:360.6315600
cell:4?i.n94 n943
Poulsbo, WA 98370 ,corgi hamdcrl/c corn
own,hooded&cam
RE: AQUIFER RECHARGE AREA REPORT,TALA POINT PLANNED RURAL
RESIDENTAIL DEVELOPMENT,PORT LUDLOWWASHINGTON
Dear Brandon:
This letter presents our evaluation of the aquifer system beneath the proposed Tala Point
residential development and our opinion on the potential for groundwater impacts of the
development. This letter has been prepared to conform with the requirements of JCC
18.22.400(2) Aquifer Recharge Area Report. This letter presents our opinions on the nature
and impacts to the groundwater system based on data and development plans made available
to us and our independent research. Should new geologic,groundwater,and operation data be
available we request to review these so we may revise our opinion as necessary.
Our analyses and opinions are formatted per paragraph(2)of JCC 18.22.400.
(2)(a)Project Description
The Tala Point residential development is proposing to develop approximately 54
single-family residential lots on 251 acres of property. The Tala Point Property is located
north of Paradise Bay Road and west of the town of Port Ludlow in Jefferson County.
The site plan is shown in Figure 1. The property is located on the northern portion of
Tala Point. The development parcels consist of a U-shaped tract that surrounds
Department of Natural Resources property in the central part of the point.
The project will consist of developing 54 residential lots in a clustered development style.
14 lots will be located in the southeast part of the property, 8 lots will be located in the
southwest portion, 29 lots will be located in the north central part, and 2 lots will be
located on the waterfront on the northwest part of the property.
The majority of the area will be left as reserve undeveloped property with the exception
of select timber harvesting. This will consist of existing second and possible third-
growth forest areas. There are no existing structures on the site. The reserve areas and
wetlands are shown on Figure 1.
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December 23,2008
Page 2 of 12
Impervious Surfaces
The lots will be about one-acre in size. D.R. Strong Consulting Engineers (DRS) has
conservatively estimated about 8,000 square feet of impervious area per lot, or about 9.9
acres of roof top and driveways for the area. The residents will be served by the existing
Tala Point Drive and two new roads that will add about 5.4 acres of impervious surfaces.
In total, about 15.4 acres of impervious surfaces will be added to the area.
Drainage from the roof tops and roadways will mostly be infiltrated on site. Runoff from
the homes in the southeast cluster will be routed to dispersal trenches located on each
property to the east of the home sites. Roadway runoff will be drained to the open space
between the main access road and home sites.
In the northern cluster, lots 3 though 5 and 29 through 32 will disperse runoff in trenches
on the west and east sides of the properties, respectively. The runoff from lots 1, 2, 6
through 28, and the roadway will be conveyed by a pipeline to the sound for direct
discharge.
Runoff from the homes in the southwest cluster of 8 homes will be tight-lined to the east
of the access road and infiltrated using dispersal trenches.
Water Supply
Water supply for the development will be from one or more existing groundwater wells
located off of the point about one mile to the south of the site. As such water will be
imported into the area. The water supply system is designed for four bedroom homes
using the Department of Health requirements of 120 gallons per day per bedroom.
Wastewater
There is no regional sewer service for the development. The development wastewater
will be served by a community on-site drainfield located in the northern portion of the
property as shown in Figure 1. All of the homes in the southeast and northern clusters (a
total of 44) will utilize the drainfield. The two waterfront properties and the 8 homes
located in the southwest cluster will have individual septic systems.
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December 23,2008
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(2)(b)HYDROGEOLOGIC EVALUATION
(b)(i) Hydrogeologic Setting
The site lies on a north-south oriented point surrounded on three sides by Puget Sound. The
site soils exhibit Puget Sound glacial stratigraphy where recessional outwash overlies glacial
till. Advance outwash and pre-Vashon-aged soils lie below the till.
The uppermost aquifer is the sea level aquifer. This typically lies 80 to 300 feet below ground
surface. Most of the local wells appear to be completed just below sea level. Deeper aquifers
are also likely present. Bedrock underlies the glacial soils at depths likely less than 100 feet
below sea level.
Based on site reconnaissance and existing reports, there do not appear to be any perched
aquifers above sea level.
The site climate is temperate with wet, cool winters and dry warm summers. The climate
plays an important part of the hydrogeology at the site since the peninsula is surrounded by
salt water;precipitation is the only means of aquifer recharge.
The wet season is when the aquifer system receives most of the recharge on an annual basis.
Precipitation falls on the forest canopy;a large part of that water is consumed by the plants or
lost through evaporation. Water that passes the vegetative cover infiltrates and replenishes
soil moisture that was lost during the last dry summer season. Once the soil moisture budget
has been satisfied,water percolates into the deeper soil system.
At this site there is typically less than 5 feet of soil above till. As such, once this soil achieves
saturation, the majority of water will emanate from seeps in the slopes and discharge toward
the sound in small seasonal streams. Water will reside in the recessional outwash soil cover
and some of this will percolate into the till subject to the unit's vertical permeability and the
number of fractures or sandier zones in the till. Some of this water only locally recharge and
may then be exposed and possibly evaporate on the hillside or bluffs, the remainder of this
water will slowly recharge the groundwater system.
The principle governing feature for groundwater recharge at this site is the presence of till.
Since the till will only percolate small quantities of water, it limits the amount of recharge the
groundwater system will take. The remaining water is discharged to the sound as seasonal
surface water.
This site is designated as a critical aquifer recharge area because it is bordered by salt water.
Sea water intrusion is typically caused by withdrawing groundwater at rates greater than the
recharge rate. It is a serious condition that will damage the quality of the water in the aquifer,
and is an effect that takes many years or decades to resolve.
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This project has the advantage that the source of domestic water comes from a distant site
located in a more protected aquifer area. As such aquifer impact can be addressed by
assessing if the presence of impervious surfaces and drainage limits aquifer recharge more
than the limitations of the till.
(2)(b)(ii) Site Location, Topography, Drainage, and Surface Water Bodies.
The site is located in the eastern portion of Jefferson County. The site is located in section 15,
Township 28N, range 1 E (a small section of the site is also located in section 22). Tala Point
is located on the east side of Port Ludlow; the west side of the point is located in Admiralty
Inlet and the entrance to Hood Canal.
The site is largely located on the upper elevation areas of Tala Point. Most of the property
bordering the water has previously been developed with residential homes. No commercial
facilities are present on the point. Site ground surface elevations range from sea level on the
northwest corner of the property to over elevation 315 feet at the center of the peninsula. The
higher elevation part of the property is roughly in the center of the peninsula and property; as
such,the property drains to the east,west,and north.
There are no perennial streams on the property or in the vicinity of the property. Small
seasonal streams drain the soil in the wet season. A few wetlands are present on the upper part
of the eastern facing slope. These are formed by groundwater seeps and discharges above the
till soil(Wiltermood Associates,2008).
The closest surface water body is Teal Lake. The lake is located on the mainland proper about
one mile south of the site. This is also the general area of the water supply wells that will
serve the site.
(2)(b)(iii) Soils and Geologic Units Underlying the Site
The project site lies on the boundary of the Physiographic province of the Olympic Mountains
and the Puget Sound Lowland which has a complex history of orogeny (mountain building),
volcanism, faulting, erosion, deposition of sedimentary rocks, and several periods of
glaciations.
During the Pleistocene (10,000 to 200,000 years ago), continental glaciation advanced in the
Puget Sound Lowland and the Olympic Mountains at least four times. The Fraser Glaciation,
particularly the Vashon Stade (last glacial advance about 13,000 to 19,000 years ago) has
modified the project area to its present topography. As the glacial ice advanced into the
project area, meltwater streams began depositing advance outwash deposits of silt, sand,
gravel and cobbles over ancestral topography.
Portions of the Puget lobe blocked the drainages of the outwash meltwater streams producing
ice dammed impoundments such as glacial Lake Leland. In the relatively quiet waters of the
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glacial lake, glacio-lacustrine deposits of sandy silts, silts, and clays were deposited at the
bottom the glacial Lake Leland. As the Puget Lobe advanced into project area glacio-
lacustrine and outwash deposits were overrun by the advancing ice and a heterogeneous
mixture of silts, sands, gravel, cobbles and boulders known as Vashon glacial till was
deposited in and under the advancing glacial ice.
As the glacial ice retreated,the project site experienced active runoff from the melting glacier
and deposition of sands and gravels, with some areas of clay and silt referred to as recessional
outwash. These are often pervious sands and gravel that mantle the hill slopes. In places,
erosion from the meltwater streams removed outwash,till,and even older deposits.
Site specific geologic information was largely provided by ZZA-Terracon in their June 2008
Geotechnical Pre-Design Evaluation report prepared for you. The site investigation included
19 exploratory test pits and 2 borings drilled to depths of about 50 feet below grade. The test
pit and boring information indicate that the majority of the site is underlain by about 6-to 9-
inches of organic duff and topsoil. The topsoil is underlain by a thin veneer of recessional
outwash soils above weathered till and till. The recessional outwash appears to consist
primarily of silty sand and silty gravelly sand with a thickness typically less than 5 feet. Based
on the soil description,the recessional outwash likely only exhibits moderate permeability.
Till underlies the majority of the site. The till thickness was between about 20 and 30 feet,
though boring B-2 did not penetrate through the till unit. Till is composed primarily of silty
gravelly sand. Till exhibits low permeability and is often a perching layer to groundwater
flow. Based on geologic mapping by Yount and Minard(1993),the till has been eroded from
much of the west side of the site.
Advance outwash underlies the till and is exposed on the west side of the site. Advance
outwash is a pervious soil unit consisting of fine to medium sand with relatively low silt
percentages. Advance outwash is one of the most prolific aquifers in the Puget Sound region.
It is difficult to estimate the thickness of the advance outwash based on boring log B-1 from
the geotechnical evaluation and the boring logs from water wells drilled on the site. B-1
indicates the presence of a sandy silt beneath the advance outwash;we interpret these soils to
be non-glacial transitional beds underlying the Vashon glacial sequence. Given this the
advance outwash may be only 10 feet thick on the margins of the peninsula. The boring did
not encounter saturated advance outwash soils. Springs or seeps were not observed, nor have
been mapped, emanating from the exposed face of the outwash soils on the west side of the
point.
Water well logs from the few wells on the point indicate that the uppermost water-bearing
zone and aquifer resides at sea level. This is relatively common for bluffs and peninsulas
adjacent to Puget Sound. It is difficult to classify the aquifer soil origin merely from
evaluation of the well logs, but based on the log for the Tala Point Community well there
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appears to be two if not three till units and/or aquitards between ground surface and the sea
level aquifer.
Bedrock likely underlies the point at depth. Bedrock consists of Crescent formation basalt:
slightly weathered fine grained, hard, slightly weathered. Generally the basalt is not friable
(sound bedrock)and has widely to very widely-spaced fractures. Though the bedrock surface
likely undulates across the region, it was encountered at about elevation-87 feet in one of the
Port Ludlow wells about one mile south of the site.
(2)(b)(iv) Groundwater Characteristics of the Area
The groundwater system in the Tala Point and Port Ludlow areas has been monitored by
Robinson, Noble, and Saltbrush for a period over 15 years. The program has monitored
groundwater levels and production rates in supply wells, and water levels in select monitoring
and domestic wells. The project and Tala Point are located in the South Aquifer of the study;
the South Aquifer roughly extends from the north end of Tala Point south to Squamish Bay as
shown in Figure 2.
Two of the wells in the monitoring program are in the vicinity of Tala Point; these indicate
that groundwater level elevations are between about 11 and 37 feet in the vicinity of the
shoreline. Groundwater levels have remained relatively constant, if not slightly higher,for the
two wells since 1994. Considering the position of these wells near the shoreline, where
groundwater levels should approach sea level, the aquifer has a high groundwater head and
does not appear to have a sea water intrusion issue based on groundwater elevation.
Groundwater elevations in the center of the point are higher than those mentioned above.
The boring logs and a number of the hydrographs for the wells in the south aquifer indicate
that the aquifer is under confined conditions. This indicates that there is a low permeability
confining unit above the aquifer.
There are not a sufficient number of wells in the area or on the peninsula to define
groundwater flow patterns. In the vicinity of Tala Point, typical groundwater flow patterns
would suggest that there is a predominant south to north groundwater flow pattern from the
south aquifer. More local flow patterns would consist of groundwater flowing radially from
the center of the point towards the saltwater bodies. All of the shoreline areas are likely
groundwater discharge areas. The presence of a confining unit at or below sea level suggests
that a portion of the groundwater recharge will perch on the deeper aquitard(s) and flow
laterally to discharge to bluff or beach areas; deeper percolation to the sea level and deeper
aquifer then occurs.
Water quality has been measured in a number of wells over the study period. Chloride
concentrations were 5.7 mg/I in the Neault Well(23)and were not detected in the Devine well
at the time of the latest measurements(2007 and 2003 respectively). Conductivity levels were
less than 230 micromohs per centimeter. These data indicate that the groundwater quality on
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Tala Point is very good. While it is conceivable that there may be a well on the point with
poor water quality; the aquifer and groundwater conditions of Tala Point and vicinity indicate
that the potential for this is low.
(2)(b)(vi) Wells and Springs within 1,000 feet of the Site.
Domestic and public supply wells are located in the south aquifer. A search of the
Washington State Department of Ecology's web site indicates that there are 52 wells in
sections 10, 15, and 16 in the vicinity of the site. All of the wells in this group withdraw
groundwater from the sea level or deeper aquifers. The majority, if not all, appear to have
confining units overlying the sea level aquifer.
There are no documented springs in the area. The wetland and other studies for this project
have shown that there are seasonal seeps in the area; other seeps are likely present on the
point. These reflect seepage from perched water on a seasonal basis. The volumes of water
are too low and too diffuse to be used for domestic purposes.
(2)(b)(vi) Existing Groundwater Recharge
As discussed,there are no sources of recharge to the aquifer other than precipitation. As such,
climatic conditions govern aquifer recharge and the amount of water that can be directly
collected for water supply. An understanding of local climatic conditions is necessary to
provide an understanding of groundwater recharge at the site.
The site lies in southeastern Jefferson County adjacent to Hood Canal. The site lies on the lee
side of the Olympic Mountains and is buffered from large offshore storms. Low pressure off-
shore weather systems encounter the Olympic Mountains and are forced upward and over the
mountains, releasing a large percentage of the moisture on the west side of the mountains due
to orographic effects. As the systems move east over the crest of the mountains, temperatures
increase and there is less precipitation. This is locally referred to as the rain shadow effect of
the Olympic Mountains. The rain shadow effects in Jefferson County are strongest in the Port
Townsend area;where less than 20-inches of rainfall occur on average,precipitation increases
toward the southern portion of the County. Just over 55 inches of precipitation fall in
Quilcene to the south of the site. Most of the precipitation events in the site area are generated
from southerly storms that move north up the canal. The climate is marine;winter months are
typically moderate and wet,while summer months are typically mild and dry.
The measured differences in precipitation at stations along the east side of the County occur
primarily in the winter months and are related to rain shadow effects; most stations have
similar summer month rainfall characteristics. The climatic data used for the site analyses
were from the Chimicum 4S weather station (No. 451414), located about 6 miles west of the
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site. The period of record for this station provides over 82 years of precipitation data. The
average precipitation at Chimicum over the period of record was 27.87 inches. Only two
other long-term weather stations are in the region: Port Townsend and Quilcene. Table 1
compares climatic conditions at these stations. These stations were unsuitable for climatic
uses because of their distance from the site and because of the large differences in
precipitation. However, the temperature data from these and other stations in the area are
valuable for the Chimicum station does not collect temperature data. Analysis of a number of
stations in the area shows that while precipitation data vary considerably,the temperature data
is similar.
Average daily weather precipitation data were downloaded from the Western Regional
Climate Center for the Chimicum gage. Average daily temperature data were downloaded for
the Quilcene gage. The available data of interest to this evaluation are average daily
precipitation and average daily maximum and minimum temperatures.
Evapotranspiration is a calculated value that describes the combined loss of water through
evaporation from site soils, plant transpiration, and evaporation of intercepted water from
foliage. Evapotranspiration is an important variable when calculating recharge for a large
percentage of the water budget is consumed by this process. Potential evapotranspiration
describes the amount of water that can evaporate from an area under given climatic
conditions;actual evapotranspiration describes the amount of water that can actually evaporate
given the amount of water in storage in the soils and plants. Actual evapotranspiration is
always less than potential evaporation in the Pacific Northwest because of a moisture deficit in
the summer months. The deficit is due to low precipitation and soil moisture that has been
consumed due to transpiration and evaporation processes. This is an important variable when
describing groundwater recharge conditions.
Potential evapotranspiration was calculated using the FAO Penman-Monteith (1998) method
on a daily basis from the Qulicene data set. This method is considered the international
standard for calculation evapotranspiration. For comparison, evapotranspiration values were
obtained from Geology and Ground-Water Resources of Eastern Jefferson County, Water
Supply Bulletin No. 54 (1981). Figure 3 shows a comparison of precipitation and potential
evapotranspiration on an average daily basis for the year. The calculated annual potential
evaporation was 24.1 inches per year using the Penman-Monteith method,and 24.2 inches per
year using the Thornthwaite method in WSB No. 54.
Water balance calculations were performed to evaluate the recharge conditions at the site. A
typical water balance calculation is performed by subtracting hydrologic process from the total
precipitation similar to the following equation:
Recharge=Precipitation—actual evapotranspiration—runoff—change in soil moisture storage
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Actual recharge at the site cannot be quantified because runoff at the site cannot be quantified.
There are numerous seeps at the site and there are no available data to document the amount of
runoff. Measurement of runoff would require installation and monitoring of a number of
gages at the small drainages over a period of at least one year. This type of monitoring may
not be sufficient because there are likely a number of small seeps that could not be measured.
Based on our calculations about 15 inches of rainfall are available for evapotranspiration,
runoff, soil moisture replenishment,and recharge.
For this site, groundwater recharge occurs once soil moisture is replenished. In a typical year,
precipitation will be partially consumed by evapotranspiration processes as rainfall is
intercepted by plants and evaporated from the foliage and is consumed by the plants.
Remaining water then infiltrates into the ground and replenishes soil moisture that has
evaporated from the soil or has been consumed by the plants during the dry season. Once the
soil moisture deficit has been replenished, water will percolate deeper. The soil moisture
capacity was assumed to equal 4-inches,as presented in Water Supply Bulletin 54,and by our
understanding of the site soil conditions.
At this site, there is only a shallow cover of topsoil and recessional outwash, once the soil is
saturated, water will perch on the underlying till. The majority of this water will then flow
laterally and form at seeps. A small component of this water will infiltrate down through
fractures in the till and sandier zones in the till. This is the period of groundwater recharge.
The seeps at the site will dry soon after the end of the wet season. Recharge will continue for
a period until the soil moisture is consumed again by the plants and evaporation.
Recharge in northern Puget Sound environments with a thin soil cover underlain by till has
been studied by the U.S. Geological Survey(Orr et al, 2002) in a number of areas. Recharge
ranged between 2-and 4-inches in the studies. Based on this publication,we utilize a recharge
of 4-inches for the site. For a 251 acre parcel, the calculated recharge below the till layer
would be about 84 acre feet.
(2)(b)(vii) Potential Impact of the Proposal Upon Groundwater Recharge
As stated above, actual calculations of recharge, and therefore the impacts of the proposal on
groundwater recharge cannot be calculated because the amount of surface water runoff cannot
be calculated. As such, the impact of the proposed development on recharge can only be
evaluated by calculating the changes in runoff and soil moisture; recharge will be affected
only if the proposal limits the amount of soil moisture replenishment.
The surface water components of the site were calculated utilizing the daily weather data and
evapotranspiration estimates discussed above. Precipitation events less than or equal to 0.01
inch were not allowed to contribute to the budget. Evapotranspiration was allowed to reduce
the amount of precipitation before runoff
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The proposal will place about 15 acres of impervious surfaces at the site,or about 6 percent of
the existing site. The water from all of that area but 3 acres will be dispersed back on site.
The water from the 3 acres will be discharged to the sound. Based on calculations using the
daily data this water loss equates to about 4 acre feet. The dispersed runoff water will be
infiltrated back into the ground on each individual property proximate to where water
naturally infiltrated. For the roadway water that is dispersed on site, the water will also be
infiltrated proximate to the original location. The total amount of water infiltrated from the
impervious surfaces is about 0.8 inches or 16 acre feet. Based on this development approach,
the only loss to the system from runoff will be about 4 acre feet.
The project will import water to the site for domestic uses. The design rate will be 25,920
gallons per day. We note that this is the design rate which will be higher than actual use.
Given the design amount, up to 1.5 inches or 29 acre feet of water will be imported to the site
and discharged to individual drain fields or the community drain field located in the north
central portion of the property. Given the importation of water to the site the system will
actually realize an increase in water of 25 acre-feet (29 ac-ft minus 4 ac-ft). The majority of
this water will result in an increase in runoff;the amount of increase in recharge will likely not
be great. These calculations indicate that there should be no loss of groundwater recharge due
to the proposed development because the same or more water is available to replenish the soil
moisture deficit. This no impact (to possible increase) in recharge is due to the large acreage
of open area that will remain at the site and due to infiltration of the majority of surface water.
(2)(c) CONTAMINANT TRANSPORT ANALYSIS
Since this site will be solely residential, there is only small potential for the introduction of
contaminants into the system. We understand that the surface water runoff will be treated
according to state and county guidelines for contaminants from roadways. The other potential
release of a contaminant would be from a spill of fuel or chemical at a residence,these would
likely be small. In the case of a fuel spill and subsequent infiltration, much of the fuel could
evaporate from the shallow soil system depending on the time of the year. Because the till is
so shallow at the site, the contaminant would then perch on the till surface and possibly flow
laterally to a local seep. Many residential contaminants have chemical properties that tend to
attached to soil or retard the movement of the contaminant,the high silt content of the surficial
soils and till will likely prevent large lateral movement. The thickness and nature of the till
will significantly if not completely retard the vertical downward migration of a contaminant
into the aquifer system.
(2)(d) ON-SITE SPILL RESPONSE
On-site spill response programs are not typically performed in a residential area. Individual
property owners must be responsible for containment and reporting of contaminant spills.
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(2)(e) BEST MANAGEMENT PRACTICES TO MINIMIZE EXPOSURE OF
PERMEABLE SURFACES TO POTENTIAL POLLUTANTS
Based on our understanding of the design of the development, appropriate levels of design are
being implemented to route all surface water to treatment systems. The development design
has left large undeveloped areas that will have no potential for contaminant introduction.
(2)(f) MONITORING PROGRAM
Residents will need to self monitor their own practices as is customary in residential
developments
Thank you for the opportunity to be of service. Please call me at (360) 631-5600 if you have
any questions or comments.
Sincerely,
Wa$,,o;'�
1'."IYlh:ny'rsJlaC ...
5CUTT F
BENDER
Scott F. Bender R.P.G., C.G.W.P.
Enclosures: Figure 1. Site Plan
Figure 2. South Aquifer Area and Monitoring Wells
Figure 3. Comparison of Precipitation and Potential Evapotranspiration
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References:
• Anchor Environmental, Inc. January 2007. Draft Water Service Feasibility Study—
Phase 1,Tala Point.
• D.R. Strong Consulting Engineers,Inc.2008. Site Plan
• Geology and Ground-Water Resources of Eastern Jefferson County, Water Supply
Bulletin No. 54, Washington Department of Natural Resources and Jefferson County
Public Utility District No. 1 (1981).
• Orr, L.A., Bauer, H.H., and Wayenburg, J.A. 2002. Estimates of Ground-Water
Recharge from Glacial-Deposit and Bedrock Aquifers on Lopez, San Juan, Orcas,and
Shaw Island, San Juan County, Washington. U.S. Geological Survey Water
Resources Investigations Report 02-4114.
• Robinson, Noble, and Saltbush. February 2008. 2007 Annual Report on the Port
Ludlow Area Groundwater Monitoring Program for Port Ludlow Associates,LLC
• Western Regional Climate Center
• Wiltermood Associates, Inc. July 11, 2008. Wetland Analysis Report for the East
Side of a 262 Acre Parcel along East Ludlow Ridge Road,Port Ludlow,Washington.
• Yount, J.C., Minard, J.P., and Dembroff, G.R. 1993 Geologic Map of the Surficial
Deposits in the Seattle 30x60 Quadrangle, Washington
• ZZA-Terracon. June 4, 2008. Geotechnical Pre-Design Evaluation. Tala Point
Development,Port Ludlow Area,Jefferson County,Washington
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Aquifer Recharge Area Report Project Number
BENDER Tala Point Planned residential 0826-01
Site Plan
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