HomeMy WebLinkAbout052David W. Johnson
From: Eric and Joan Hendricks [overbrookfarm@embargmail.com]
Sent: Sunday, November 22, 2009 9:06 AM
To: David W. Johnson
Subject: Pleasan Harbor Resort
To: David Wayne Johnson, Project Lead Planner
dwjohnson _co.jefferson.wa.us
Jefferson County Department of Community Development
Thank you for the opportunity to comment on the scoping process now taking place.
Statesman has used different numbers in different planning documents for the amount of
water that will be needed for the proposed resort. However, none of the planning
documents defines the aquifer from which the water will be taken. It appears that no one
has defined this aquifer. There are already wells with existing water rights of 5000 gallons
per day. Before any water can be claimed by Statesman, there must be a scientific
definition of the capacity of the entire aquifer, minus existing water rights. Then we can
begin to define what water Statesman might be able to use.
To define the aquifer, various tests need to be done for the next year. Wells on Black
Point need to be tested at different times of the year for their capacity and, also, for salt
water intrusion. Detailed recommendations by Waterworks Consultants have been
submitted to you during this scoping process and are on the Brinnon Group website. We
support those testing recommendations.
Sincerely,
Joan, Eric, Forrest, and Jasper Hendricks
David W. Johnson
From:
Roger & Vicki Foszcz [rvfoz@olypen.com]
Sent:
Saturday, November 21, 2009 6:51 PM
To:
David W. Johnson
Cc:
Brinnon Group
Subject:
Black Point Resort
To: David Wayne Johnson, Project Lead Planner
dwiohnson(c-b-co.jefferson.wa.us
Jefferson County Department of Community Development
Thank you for the opportunity to comment on the scoping process now taking place.
Statesman has used different numbers in different planning documents for the amount of
water that will be needed for the proposed resort. However, none of the planning
documents defines the aquifer from which the water will be taken. It appears that no one
has defined this aquifer. There are already wells with existing water rights of 5000 gallons
per day. Before any water can be claimed by Statesman, there must be a scientific
definition of the capacity of the entire aquifer, minus existing water rights. Then we can
begin to define what water Statesman might be able to use.
To define the aquifer, various tests need to be done for the next year. Wells on Black
Point need to be tested at different times of the year for their capacity and, also, for salt
water intrusion. Detailed recommendations by Waterworks Consultants have been
submitted to you during this scoping process and are on the Brinnon Group website. I
support those testing recommendations.
Sincerely,
Roger M. Foszcz
910 W. 11 th St.
Port Angeles, WA 98363
(360) 457-8330
1
David W. Johnson
From: Laurie Lewis Deramysmom@hotmail.comj
Sent: Friday, November 20, 2009 7:12 AM
To: David W. Johnson; brinnongroup@embarqmail.com
To: David Wayne Johnson, Project Lead Planner
dwiohnson(a.co jefferson.wa.us
Jefferson County Department of Community Development
Thank you for the opportunity to comment on the scoping process now taking place.
Statesman has used different numbers in different planning documents for the amount of
water that will be needed for the proposed resort. However, none of the planning
documents defines the aquifer from which the water will be taken. It appears that no one
has defined this aquifer. There are already wells with existing water rights of 5000 gallons
per day. Before any water can be claimed by Statesman, there must be a scientific
definition of the capacity of the entire aquifer, minus existing water rights. Then we can
begin to define what water Statesman might be able to use.
To define the aquifer, various tests need to be done for the next year. Wells on Black
Point need to be tested at different times of the year for their capacity and, also, for salt
water intrusion. Detailed recommendations by Waterworks Consultants have been
submitted to you during this scoping process and are on the Brinnon Group website. I
support those testing recommendations.
Sincerely, Laurie Lewis
Laurie
Bing brings you maps, menus, and reviews organized in one place. Tr rLit now.
David W. Johnson
From: Miriam Murdoch [miriamclaire@embargmail.coml
Sent: Thursday, November 19, 2009 8:52 PM
To: David W. Johnson
Subject: Statesman project
To: David Wayne Johnson, Project Lead Planner
dwjohnson[c).co.jefferson.wa.us
Jefferson County Department of Community Development
Thank you for the opportunity to comment on the scoping process now taking place.
Statesman has used different numbers in different planning documents for the amount of
water that will be needed for the proposed resort. However, none of the planning
documents defines the aquifer from which the water will be taken. It appears that no one
has defined this aquifer. There are already wells with existing water rights of 5000 gallons
per day. Before any water can be claimed by Statesman, there must be a scientific
definition of the capacity of the entire aquifer, minus existing water rights. Then we can
begin to define what water Statesman might be able to use.
To define the aquifer, various tests need to be done for the next year. Wells on Black
Point need to be tested at different times of the year for their capacity and, also, for salt
water intrusion. Detailed recommendations by Waterworks Consultants have been
submitted to you during this scoping process and are on the Brinnon Group website.
support those testing recommendations.
Sincerely, Miriam Murdoch
Brinnon, WA.
1
David W. Johnson
From: Barbara Moore -Lewis [brinnongroup@gmail.com]
Sent: Thursday, November 19, 2009 6:29 PM
To: David W. Johnson
Cc: Jimi Couture
Subject: Brinnon Group comments on scoping process
Attachments: Comments to DCD for Scoping Process 11-30-09.pdf;
waterworksConsultantsWaterReview.pdf; seawaterintrusion.pdf
Attached are 1) the letter from the Brinnon Group on the scoping process, 2) the report from Waterworks
Consultants referred to in the letter, and 3) the seawater intrusion policy of Island County, referred to in the
report.
Please respond to this email to let me know you received everything.
Thank you. Barbara Moore -Lewis
Brinnon Group
Comments for Scoping Process
November 30, 2009
Emailed to DCD November 30, 2009
Thank you for the opportunity to give input to the scoping process.
The Brinnon Group is concerned about both the quality and the quantity of water on
Black Point. There seems to be no clear idea of the extent of the existing aquifer or the
current or potential salt water intrusion.
In fact, it seems the development process has been backwards. Should we not fust
determine the resources available and base the development allowed on this data?
Statesman has proposed a development that they deem to be financially viable. The
developer has based its determination on potentially disastrous "snap shot" data" that the
resources will support the development. They project their water usage to be 39 million
gallons per year. How do we know the aquifer will support this? Their development
plans include cutting and filling 2 million cubic yards of soil. What effect will this, along
with drastically reducing the permeable surface area, altering the kettles, and removing
most, if not all, of the existing vegetation have on the hydrologic cycle? The answers to
these and many other questions can only be obtained from analyzing cyclic data.
We request that you implement the recommendations of Waterworks Consultants, which
is attached. Below is a summary of these recommendations.
Summary of Recommendations for Additional Testing
To better understand the hydrogeologic response to the proposed water supply
management scheme in this relatively sensitive groundwater environment, each
of the components of the hydrologic cycle should be more accurately quantified.
In addition, the aquifer properties must be better defined to design a supply
system that does not overstress the aquifer. The following tests are
recommended in order to gather that information.
Aquifer properties
Aquifer testing — pump tests should be conducted for a minimum of 72 hours in
any wells that might be proposed for water supply purposes (American
Campground We]I, Pleasant Tides Coop Well (Sam Boling Water System/Black
Point Water Company) and MW -2). Pump tests should be conducted for long
enough to generate a measurable drawdown in at least two monitoring wells in
the vicinity. Pumping rate at the Pleasant Tides Coop Well should include the
300 gpm for existing water rights plus the proposed new withdrawal.
Q Pump testing at MW -2 should include installation of a monitoring well, at a
location that is as close as existing wells are to the eastern shoreline, in
Brinnon Group
Comments for Scoping Process
November 30, 2009
Emailed to DCD November 30, 2009
line with the MW -2 well. Chloride testing of water pumped from the
aquifer should be done when the MW -2 is pump tested.
A Pump testing at the Pleasant Times Coop Well should include
monitoring for water level drawdown and for chloride at the other
Black Point Water Company wells, the Babare well, the Tudor well
and the other Pleasant Harbor Beach Tract Owners wells.
Seawater intrusion
Chloride content in groundwater should be determined in samples collected from
wells pumped adjacent to the marine shoreline over the duration of the pump
tests. At a minimum one sample should be collected prior to initiation of
pumping, another after at least 12 hours of pumping and a third shortly before
pumping is stopped. More samples provide more confidence in the data collected,
and the interpretations derived from that data. Chloride concentrations
between 100 and 200 mg/1 indicate wells at moderate risk for seawater intrusion,
with 200 mg/l being the trigger for high risk, according to Island County's
Seawater Intrusion Policy (a copy is included with these continents as an
Attachment).
Groundwater movement
Groundwater levels should be measured in every accessible well on the same
date, so that a groundwater elevation contour level map can be constructed that
is reliable for interpreting the direction(s) of groundwater movement. A better
understanding of the direction of groundwater movement will support a better
interpretation of the groundwater withdrawal impacts to private wells on the
Black
Point Peninsula and seawater intrusion risk.
Water Budget
The presentation of the water budget in the Report makes it impossible to assess
the individual components of the water budget, their relationship to each other,
and what data was used to derive them. A comprehensive explanation of the
water balance calculations must be provided. This should include:
9 water budget equation used
Values for each component the equation
:- data, calculations and assumptions used to derive each value
2
Brinnon Group
Comments for Scoping Process
November 30, 2009
Emailed to DCD November 30, 2009
In particular the following components need better delineation.
Precipitation
Precipitation should be monitored on the Black Point Peninsula site for the
duration of a year (concurrent with other monitoring data collection).
Recharge
Groundwater levels should be monitored with continuous electronic logs in the
three monitoring wells, and reported for the duration of a year to assess the
range of groundwater level variation, and the recharge resulting from
precipitation events. Precipitation monitoring should coincide with groundwater
level monitoring periods. Precipitation should be used to evaluate the changes in
groundwater levels associated with precipitation events (i.e. recharge)
Evapotranspiration
Evapotranspiration calculations, and the data and assumptions used in those
calculations needs to be presented in report form.
Streamflotiv
Stream flow emitting from the lake on the eastern margin of the Peninsula, and
flowing to the east shoreline should be monitored to assess the rate of surface
water runoff from the Peninsula.
Lake Level
Monitor lake (located in the central -eastern portion of Black Point Peninsula)
level elevation over the period of a year concurrent with other monitoring data
collected.
The Brinnon Group is also concerned that previous environmental impact analyses of
traffic are incomplete and misleading. Collisions with animals and motorcycle accidents,
both of which can be fatal, do not seem to be included. Only traffic accidents at
intersections are included. Many accidents, some of them fatal, have taken place in
recent years on 101 in places other than intersections. We would like to see complete
numbers of accidents reflected in the SEIS. We would also like to see an analysis of the
period of time that the Hood Canal Bridge was closed and the impact on the rate of
accidents and other traffic data, such as traffic congestion.
Brinnon Group
Comments for Scoping Process
November 30, 2009
Emailed to DCD November 30, 2009
In addition, there needs to be an analysis of the impact of an estimated 3400 truck loads
of soil being removed and the additional logging trucks that will be used to strip the
current trees from the site.
The Brinnon Group is concerned that Statesman will negotiate shoreline buffers that are
not compatible with those being adopted by the Jefferson County Commissioners. Many
citizens have given input on preserving our shoreline and moving to 150 foot buffers.
This is particularly important along the Hood Canal. Will the development agreement
negate our best scientific knowledge about how to protect our habitat and water quality in
Hood Canal? What are the buffers that are proposed for the new development. If they do
not meet the county's shoreline management program, what are the reasons? What will
be done for mitigation? Is mitigation appropriate?
The Brinnon Group urges the county to enforce the adopted shoreline buffer rules and not
to give any variances to this large and potentially damaging development.
The Brinnon Group is concerned about the discharge of nitrates from the proposed golf
course. How will Statesman ensure that the drinking water and Hood Canal water
standards are met?
Sincerely,
( ;, I t,dj.
i Nh�&
CVou�ture
President, Brinnon Group
4
Waterworks Consultants
4017 Willowbrook Lane
Bellingham, WA 98229
360-296-8084
Memo
To: Gerald Steel
From: Llyn Doremus
Date: July 17, 2009
Re: Technical review of: Water Supply and Groundwater Impact Analysis
Pleasant Harbor Marina and Golf Resort — November 20, 2008 (SDEIS)
Recommendations for Additional Hydrogeologic Testing at Black Point
Background
The Pleasant Harbor Marina and Golf Resort is planned for construction on the
Black Point Peninsula in Hood Canal. The peninsula is surrounded by saltwater
for more than 75% of it's shoreline. At least 15 wells are located along the Black
Point eastern and northern shorelines that are at risk of seawater intrusion.
Hood Canal is known to have a serious problem with depleted dissolved oxygen
content, which has resulted in what has been termed a "dead zone". The dead
zone creates conditions where a wide range of sea life that requires dissolved
oxygen in the waters of their environment cannot survive. The depleted oxygen
condition is known to result from enhanced activity of bacteria and algae that is
promoted by discharge of nutrients (nitrogen and phosphorus) dissolved in
surface and groundwater to Hood Canal. The two conditions: seawater
surrounding the Black Point Peninsula and the potential for seawater intrusion to
degrade water quality in shoreline wells, and extreme sensitivity of Hood Canal
biologic health to the release of nutrients generate a very delicately balanced
hydrogeologic environment in which the Resort is proposed for construction.
The Resort water supply for residential, commercial and irrigation purposes has
been proposed through a combination of rainwater capture, reuse, reclamation,
infiltration, and groundwater withdrawal processes. While the general scheme of
the supply system has been outlined in previous documents, the specifics of how
each of the components will operate has not yet been accurately defined. The
potential for negative impacts of the various supply system components on the
delicately balanced hydrogeologic environment is high. A sophisticated
understanding of the Black Point hydrogeologic system is mandated to assess
potential for degradation from the proposed water supply scheme to dissolved
oxygen levels in Hood Canal, to seawater intrusion into the Black Point aquifer,
and for the design, maintenance and operation of that system to function without
degrading the Black Point aquifer and Hood Canal.
These comments address the hydrogeologic characterization presented in the
report: Water Supply and Groundwater Impact Analysis, Pleasant Harbor Marina
and Golf Resort by Subsurface Group, LLC. November 20, 2008 (Report) with
respect to the information necessary for characterization, design and operation of
a water supply system that does not degrade the Black Point aquifer. The
accuracy and completeness of the Report assumptions, information and
conclusions are assessed, and recommendations for additional testing to fill in
the information gaps in the Report are listed.
Hydrogeologic System
Groundwater moves through the sediments and rock, which, along with the other
water moving through the system, defines the hydrolgeologic system of a specific
site. Sediment tends to form in layers, which can be visualized as a "layer cake"
type configuration. Sediments and rock layers with a large percentage of void
spaces typically transmit water more quickly, which is termed a high permeability
hydrogeologic unit. Sediment layers that are more dense, with tiny void spaces
are termed "low permeability" or "impermeable". Low permeability sediment
layers impede downward migration (infiltration) of groundwater, and tend to
accumulate water on their upper surface. This is normally how unconfined
aquifers form. The permeability of an aquifer is usually determined by
conducting a pump test. With the exception of the single pump test of the
American Campground well, and the marginal data generated from that test,
there is no data presented on the aquifer properties of the various hydrogeologic
units on the Black Point Peninsula.
RECOMMENDATION FOR ADDITIONAL TESTING
The Report describes results from a pump test conducted in the American
Campground well for 48 hours to assess the permeability and other aquifer
properties in the well vicinity. The data generated by the test was found to
be insufficient to assess the aquifer properties, because the drawdown in
Water Supply and Groundwater Impact Analysis, Pleasant Harbor Marina and Golf Resort
Technical Review and Recommendations 2
the monitoring wells was almost undetectable. Pump testing should be
conducted in all of the wells that are proposed for water supply purposes.
The pumping rate used should be equivalent to the rate at which water is
proposed for withdrawal for the water supply needs of the resort (at a
minimum 75 gallons per minute to provide the 121 acre feet annual use
projection), because of the likelihood that individual wells may be relied
upon for the full volume for the resort water demand when problems with
water level drawdown and seawater intrusion occur. The tests should be
run for sufficient duration (minimum 72 hours) to derive measurable
drawdown curve in at least one of the monitoring wells, so that reliable
aquifer properties can be calculated.
The direction of groundwater movement is defined by the groundwater gradient.
Groundwater moves from locations of high water elevation level to low elevation
discharging eventually to lower -elevation surface water bodies. The groundwater
elevation pattern often mimics the ground surface topographic elevation pattern.
Downgradient (lower groundwater elevation) locations manifest the affects of
groundwater movement and withdrawal in higher elevation locations. It is
important to understand the directions of groundwater movement in order to
assess the magnitude and distribution of ground water level decreases
associated with groundwater withdrawal (pumping from wells). In particular,
reduction in the groundwater levels in shoreline areas increases the risk of
seawater intrusion into water supply wells.
The Report presents an interpretation of groundwater flow direction towards the
center of the peninsula and then to the east (discharging into Hood Canal). The
groundwater surface elevation contours are illustrated in Figure 4 of the Report,
and suggest that a groundwater high point (at MW -2) dominates groundwater
flow direction on the entire peninsula. That single data point (MW -2 water level
elevation) is disproportionally valued in interpreting the groundwater flow
directions.
RECOMMENDATION FOR ADDITIONAL TESTING
Groundwater levels should be measured in every accessible Black Point
Peninsula well on the same date, so that a groundwater elevation contour
level map can be constructed that is reliable for use in interpreting the
direction(s) of groundwater movement. A better understanding of the
direction of groundwater movement will support a better interpretation of the
groundwater withdrawal impacts to private wells on the Black Point
Peninsula and seawater intrusion risk.
Water Supply and Groundwater Impact Analysis, Pleasant Harbor Marina and Golf Resort
Technical Review and Recommendations 3
Diagrams of the Black Point Peninsula hydrogeologic system are presented in
the Report Figures 11, 12 and 13. Much of the site is covered with dense, low
permeability till. About one third of the site has additional sediments deposited
on top of the till that are higher in permeability and allow water to migrate more
quickly through them. Water that migrates downward through these higher
permeability sediments might slow down and accumulate in a "perched" aquifer
upon encountering the underlying low -permeability till. There is no evidence of
perched conditions at this site presented in the Report.
Basalt bedrock is shown in Figures 13 in wells located on the northern part of the
site. The contribution of groundwater flow transmitted through bedrock to the
Black Point aquifer is not well characterized in the Report, nor is the bedrock
permeability, or the hydraulic connection between bedrock and the overlying
unconsolidated sediments. With the exception of the single pump test of the
American Campground well, and the marginal data generated from that test,
there is no data presented on the aquifer properties of the bedrock or
unconsolidated sediment hydrogeologic units on the Black Point Peninsula, or on
the hydraulic continuity between unconsolidated sediment units and the bedrock
underlying them. Further pump testing (as previously described) is necessary to
better define aquifer properties of the hydrogeologic units and the hydraulic
continuity with bedrock on the site.
Water Budget
A water budget uses estimates or measurements of each component of the
hydrologic cycle to assess the entire movement of water through a specific
hydrologic system annually. For the purposes of characterizing the impact of the
proposed water management scheme on the the Black Point Peninsula aquifer
and hydrogeology, the water budget should encompass the entire Peninsula. To
prevent or at least minimize detrimental impacts it is essential that the
components of the water budget are defined as accurately as possible.
A typical equation for a water balance is as follows.
Ppt = E + Q + dS9 + dSs
Where:
Ppt = annual precipitation
E = annual evaporation plus transpiration (evapotranspiration)
Q = stream flow or surface water runoff
dSs = the change in quantity that is stored as surface water for the year
(negative for a decrease in the water quantity in surface storage)
Water Supply and Groundwater Impact Analysis, Pleasant Harbor Marina and Golf Resort
Technical Review and Recommendations 4
dSg = the change in the water quantity that is stored as groundwater for
the year (negative for a decrease in the groundwater storage, indicating a
drop in groundwater levels)
Surface Water Flow
Although surface water is not flowing onto the proposed Pleasant Harbor Resort
site, the quantity of water discharged from Black Point Peninsula as stream flow
impacts the water budget for the Peninsula. Accurate stream flow
measurements help reduce uncertainty in other portions of the hydrologic budget
that are more difficult to estimate. Stream flow emitting from the lake in the
eastern -central portion of Black Point Peninsula, as well as any other stream flow
on the Peninsula needs accurate assessment in order to calculate its contribution
to the water budget, and its influence on the other components of the budget.
RECOMMENDATION FOR ADDITIONAL TESTING (Q)
Stream flow emitting from the lake on the eastern -central margin of the
Peninsula, and flowing to the east shoreline should be monitored to assess
the rate of surface water runoff from the Peninsula.
Surface Water Storage
Surface water is typically stored in lakes and wetlands. To better understand the
changes in surface water storage that are ongoing under current conditions
(dSs), and that may be expected from the proposed use of kettles as water
storage facilities, the water stored in Lake (on the eastern margin of the
Peninsula) should be monitored for changes in lake elevation. It is likely that the
lake is in hydraulic continuity with groundwater, and receives groundwater
discharge. A better delineation of lake level variations, and their relationship to
precipitation quantities and timing, and groundwater levels will improve the
understanding of how groundwater moves through the Peninsula hydrogeologic
system.
RECOMMENDATION FOR ADDITIONAL TESTING (dSs)
Monitor lake level elevation over the period of a year (concurrent with other
monitoring data collected).
Precipitation
Precipitation provides water that supports the various water uses and hydrologic
components. Annual precipitation at this site is poorly understood because of the
variability in precipitation along the north south extent of Hood Canal, and the
lack of monitored data collected in the Black Point Peninsula or Brinnon vicinity.
Water Supply and Groundwater Impact Analysis, Pleasant Harbor Marina and Golf Resort
Technical Review and Recommendations 5
RECOMMENDATION FOR ADDITIONAL TESTING (Ppt)
Precipitation should be monitored on the Black Point Peninsula for an entire
year. In addition, the data available from the NOAA approved weather
station at location AS461 on the west side of Hwy. 101 across from
Pleasant Harbor should be analyzed. See Attachment 1 hereto.
Groundwater Storage
Groundwater that is stored in an aquifer is the amount of water that is added to
the aquifer over the course of the year (termed recharge) minus the amount
withdrawn or discharged from the aquifer. Recharge to an aquifer derives from
precipitation that infiltrates into the ground. Discharge from an aquifer typically
goes to stream flow (Q), or it may be pumped for water supply or irrigation
purposes, or, in this case, includes flow into Hood Canal to diminish salt water
intrusion into the fresh water supply. The difference between the amount
recharged and the amount discharged is the change in storage (dSg).
Quantification of recharge is an important factor in assessing the storage
changes in groundwater, as is quantification of the discharge.
Recharge of an aquifer results from vertical infiltration of precipitation that falls on
the ground surface overlying the aquifer. Aquifers are more rapidly recharged
when the sediment overlying the aquifer is of "high permeability" and when there
is high annual precipitation. Consider if the precipitation that infiltrates to
recharge the aquifer is half (50%), the standard assumption when data is not
available to calculate actual recharge rates. For this site the annual precipitation
rate is not well known, which makes the annual recharge rate even more difficult
to assess. Table 3 lists 55 inches for annual precipitation in Quilcene (the
closest site monitored). Half of this is 27 inches, or 2.3 feet. For this 220 acre
site, this provides an annual recharge of 504 acre feet (significantly less than the
783 acre feet claimed in the Report on page 17). The presence of low
permeability till will slow down groundwater infiltration, and likely reduce the rate
of groundwater recharge to the aquifer even further than estimated using these
assumptions.
There will be substantial additional evapotranspiration caused by the watering of
the golf course and other vegetation in the hot months of the year. This has not
been adequately considered.
RECOMMENDATION FOR ADDITIONAL TESTING (dSg)
Groundwater levels in the three monitoring wells (MW -1, MW -2 and MW -3)
should be monitored for at least one year, to determine the variation in
groundwater elevation. Precipitation should be monitored on the site for at
Water Supply and Groundwater Impact Analysis, Pleasant Harbor Marina and Golf Resort
Technical Review and Recommendations 6
least one year to determine the actual precipitation received annually
(concurrently with other monitoring data collected). Analyses of recharge
quantities and rates should be done using monitored data, and presented in
the calculation of the water budget for the site. A separate set of
calculations should be done assuming serious drought conditions — perhaps
an estimated 500 -year drought.
Quantification of groundwater discharge is calculated using measurements of
changes in groundwater elevation, stream flow measurements, pumped
quantities from the aquifer, and precipitation measurements. It is important to
delineate the groundwater flow direction and to delineate locations of
groundwater discharge, to more accurately assess the annual amount of
groundwater discharging from the aquifer. The change in groundwater storage
calculated amount (dSg) relies upon an accurate estimation of annual
groundwater discharge and its relative value with respect to the annual recharge
amount. Additionally, discharge of groundwater from beneath the proposed
resort to Hood Canal, that contains contaminated landscaping chemicals
(especially nitrate and phosphorus) poses a significant risk to the environmental
health of Hood Canal.
Evapotranspiration
The information presented in the Report on estimations of evapotranspiration
(24.1 or 24.2 inches per year), need to be presented with data, formulas, tables,
and assumptions used in those calculations, as part of the comprehensive water
budget estimation.
Summary of Recommendations for Additional Testing
To better understand the hydrogeologic response to the proposed water supply
management scheme in this relatively sensitive groundwater environment, each
of the components of the hydrologic cycle should be more accurately quantified.
In addition, the aquifer properties must be better defined to design a supply
system that does not overstress the aquifer. The following tests are
recommended in order to gather that information.
Aquifer properties
Aquifer testing — pump tests should be conducted for a minimum of 72 hours in
any wells that might be proposed for water supply purposes (American
Campground Well, Pleasant Tides Coop Well (Sam Boling Water System/Black
Point Water Company) and MW -2). Pump tests should be conducted for long
Water Supply and Groundwater Impact Analysis, Pleasant Harbor Marina and Golf Resort
Technical Review and Recommendations 7
enough to generate a measurable drawdown in at least two monitoring wells in
the vicinity. Pumping rate at the Pleasant Tides Coop Well should include the
300 gpm for existing water rights plus the proposed new withdrawal.
Pump testing at MW -2 should include installation of a monitoring well, at a
location that is as close as existing wells are to the eastern shoreline, in
line with the MW -2 well. Chloride testing of water pumped from the
aquifer should be done when the MW -2 is pump tested.
Pump testing at the Pleasant Times Coop Well should include monitoring
for water level drawdown and for chloride at the other Black Point Water
Company wells, the Babare well, the Tudor well and the other Pleasant
Harbor Beach Tract Owners wells.
Seawater intrusion
Chloride content in groundwater should be determined in samples collected from
wells pumped adjacent to the marine shoreline over the duration of the pump
tests. At a minimum one sample should be collected prior to initiation of
pumping, another after at least 12 hours of pumping and a third shortly before
pumping is stopped. More samples provide more confidence in the data
collected, and the interpretations derived from that data. Chloride concentrations
between 100 and 200 mg/I indicate wells at moderate risk for seawater intrusion,
with 200 mg/I being the trigger for high risk, according to Island County's
Seawater Intrusion Policy (a copy is included with these comments as
Attachment 2).
Groundwater movement
Groundwater levels should be measured in every accessible well on the same
date, so that a groundwater elevation contour level map can be constructed that
is reliable for interpreting the direction(s) of groundwater movement. A better
understanding of the direction of groundwater movement will support a better
interpretation of the groundwater withdrawal impacts to private wells on the Black
Point Peninsula and seawater intrusion risk.
Water Budget
The presentation of the water budget in the Report makes it impossible to assess
the individual components of the water budget, their relationship to each other,
and what data was used to derive them. A comprehensive explanation of the
water balance calculations must be provided. This should include:
• water budget equation used
• Values for each component the equation
Water Supply and Groundwater Impact Analysis, Pleasant Harbor Marina and Golf Resort
Technical Review and Recommendations 8
• data, calculations and assumptions used to derive each value
In particular the following components need better delineation.
Precipitation
Precipitation should be monitored on the Black Point Peninsula site for the
duration of a year (concurrent with other monitoring data collection).
Recharge
Groundwater levels should be monitored with continuous electronic logs in the
three monitoring wells, and reported for the duration of a year to assess the
range of groundwater level variation, and the recharge resulting from
precipitation events. Precipitation monitoring should coincide with groundwater
level monitoring periods. Precipitation should be used to evaluate the changes in
groundwater levels associated with precipitation events (i.e. recharge)
Evapotranspiration
Evapotranspiration calculations, and the data and assumptions used in those
calculations needs to be presented in report form.
Streamflow
Stream flow emitting from the lake on the eastern margin of the Peninsula, and
flowing to the east shoreline should be monitored to assess the rate of surface
water runoff from the Peninsula.
Lake Level
Monitor lake (located in the central -eastern portion of Black Point Peninsula)
level elevation over the period of a year concurrent with other monitoring data
collected.
Water Supply and Groundwater Impact Analysis, Pleasant Harbor Marina and Golf Resort
Technical Review and Recommendations 9
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capable of supplying water to wells (aquifers). These aquifers are interbedded with lower
permeability layers of silt and clay (aquitards) that pass water more slowly.
Aquifers and aquitards in Island County vary spatially in
on review of water use proposals on an individual basis. The scope and detail of the project review
has relied on a triggering mechanism known as the Island
County Saltwater Intrusion Policy.
2.0 Current Saltwater Intrusion Policy
36 In 1989 the Island County Health Department, in
37 conjunction with the Washington State Department of
38 Health, adopted the Island County Saltwater Intrusion
39 Policy. The primary function of the policy is to trigger
40 additional review (of potential for seawater intrusion) of
41 new or expanding public water systems in areas where
42 seawater intrusion appears to be occurring. The goal of
43 this policy is to protect public water supplies from
44 seawater intrusion.
45
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The policy utilizes chloride concentrations in wells as its
indicator of seawater intrusion and defines `risk zones',
drawing ''/z mile circles around wells with elevated
chloride concentrations. An area where all wells within
'h mile have chloride concentrations less than 100
milligrams per liter (mg/1) is considered `low risk'. An
Isla Couuh%
In
Seawater InPolio'
Cirele Map
.x
3
C 1 f 3 4 S
area where one or more wells have chlorides between 100 Figure 5.
and 200 mg/l is considered `medium risk', and an area with one or more wells with chloride
concentrations greater than 200 mg/l is considered `high risk'. Drawing %2 mile circles around wells
with elevated chloride concentrations yields the map shown in Figure 5 known as the Circle Map.
Inspection of Figure 5 shows a pattern where the majority of the %2 mile circles fall along the
shoreline, which makes sense in light of the conceptual model shown in Figure 2 with the freshwater
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1 lens having a maximum thickness near the center of the island, thinning approaching the shorelines.
2 However there are exceptions to this pattern, where isolated circles, and even clusters of circles fall
3 away from the shorelines toward the island interiors. This discrepancy suggests a problem, either in
4 the conceptual model of groundwater flow and seawater intrusion in an island environment, or with
5 the use of chloride concentrations as the indicator of seawater intrusion.
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2.1 Limitations of the Current Saltwater Intrusion Policy
Over ten years of experience in the application of the Saltwater Intrusion Policy has shed light on
some limitations of the policy. The first limitation is the fact that there are other sources of chloride
in the environment other than seawater intrusion. Non -intrusion chloride sources include: connate
(very -old) groundwater, septic system effluent, very hard groundwater, windblown sea spray, and
recharge from irrigation, agricultural practices, and well disinfection. Chloride from any of these
sources can result in elevated levels of chloride concentrations in an aquifer, triggering the Saltwater
Intrusion Policy when in fact the aquifer is not intruded. This erroneous interpretation of data is
known as a false positive, where a test identifies a problem that does not in fact exist.
Figure 6 displays a chloride circle map for a portion of
Central Whidbey Island. Although some of the circles
bordering the shoreline on the map probably represent
elevated chlorides due to seawater intrusion, it is believed
that the majority of the inland circles are caused by
something other than seawater intrusion; in this part of
Whidbey Island, very hard groundwater appears to be to the
source.
Various chemical analysis tools have been utilized in an
attempt to differentiate between chlorides caused by seawater
intrusion and other sources, however no tool has been found
that can differentiate all of these sources. In some cases,
Circle Map
such as windblown sea spray, an aquifer may be Impacted by
seawater that is entering the aquifer from above. Chemically this may be indistinguishable from
seawater entering laterally, but this movement of seawater into the aquifer has nothing to do with
over -drafting the aquifer and classical seawater intrusion. The ambiguity of chloride source can
result in incorrectly classifying a proposal as having risk for seawater intrusion, potentially costing
significant time and financial costs for both the applicants and the permitting agencies. Denial of
applications based on apparent risk for intrusion that is non-existent is also possible.
False positives are one potential problem for the Saltwater Intrusion Policy; a second involves the
opposite effect, a false negative. False negatives occur when a test indicates that a problem does not
exist, when in fact it does. In the overview of groundwater and seawater intrusion presented earlier
in this paper, the mechanisms that influence the location and movement of the saltwater interface
were discussed. The processes of groundwater recharge, flow, mixing, and discharge all combine to
hold the interface position in a roughly stationary position. A change to any of these processes will
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1 result in a change in the position of the interface. However, the change in interface position
2 following a change to the flow regime is not instantaneous, but instead the interface can take a
3 significant amount of time to come into a new equilibrium position.
4
5 One of the principal tools used in evaluating proposed groundwater withdrawals is an aquifer test,
6 where a well is pumped for a period of time and the aquifer's response (drawdown) to this pumping
7 is monitored. Analysis of how an aquifer responds to pumping yields numeric values that quantify
8 the hydraulic characteristics of the aquifer, primarily hydraulic transmissivity and storativity. These
9 aquifer parameters can then be utilized to estimate how the aquifer will respond to pumping over
10 longer periods of time.
11
12 In areas where seawater intrusion is a concern, water samples are typically collected during the test
13 and sent to a laboratory for analysis of substances related to seawater intrusion. Since most of the
14 `other sources' of chlorides tend to be persistent, significant rises in chloride concentration during an
15 aquifer test can generally be attributed to seawater intrusion. If no variation in chloride
16 concentration occurs during a test, it is tempting to assume that seawater intrusion is not, and will
17 not become a problem. However, a lack of change in chemistry during an aquifer test does not prove
18 that intrusion (caused by the proposed withdrawal) will not occur at some later time. It is quite
19 possible that the interface was at some distance from the well at the beginning of the test, and moved
20 toward the well during the test, but did not reach the well screen, and as a result no change in
21 chemistry was detected. Once the well is put into full time use, the interface may continue to move
22 inland resulting in seawater intrusion.
23
24 Using chemistry as a tool to evaluate risk for seawater intrusion may show intrusion is occurring
25 (excluding the problems with false positives discussed previously), but it cannot evaluate if intrusion
26 is likely to occur in the future. In essence, chemistry is a not a predictive tool - it cannot predict that
27 intrusion will occur in the future. Instead, chemistry is a reactive tool, capable only of reacting to
28 intrusion once it begins to occur, and in some cases too late to prevent significant degradation of
29 groundwater quality.
30
31 The use of a reactive rather than a predictive test for intrusion risk results in a lack of confidence in
32 the water resource. Areas of the circle map that are currently ranked as low risk (no circles) have no
33 information beyond the fact that intrusion has not occurred to date. This map gives no indication of
34 whether or not there is either an ample supply of water or if intrusion is about to begin. This leaves
35 the public and water resource managers in a state of constant uncertainty. Ultimately we need a tool
36 that can assess the adequacy of our aquifers, and differentiate between those aquifers that have
37 ample fresh water quantity and those that are only marginal.
38
39 13.0 Water Level Elevations and Seawater Intrusion
40
41 Earlier in this paper, the factors that influence the position and movement of the saltwater interface
42 within an aquifer were discussed. Primary among those factors is the pressure in the freshwater zone
43 relative to sea level, known as the Ghyben-Herzberg Relation. In order to prevent seawater from
44 entering a freshwater aquifer, adequate freshwater pressure must be maintained. An aquifer's
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1 susceptibility for seawater intrusion can be evaluated by measuring the distribution of water level
2 elevations. Thus the relationship between an aquifer's water level elevation and its susceptibility to
3 seawater intrusion can be utilized as a planning and resource management tool. If employed in the
4 same manner as the current Seawater Intrusion Policy, as a method of flagging a proposal for more
5 detailed review, it may overcome virtually all of the policy's current limitations.
7 An aquifer that has water level elevations (pressure) significantly above sea level is not at risk for
8 seawater intrusion, while an aquifer that has near sea level water levels is at risk. A more
9 sophisticated analysis would be required to answer the question of whether or not the low-pressure
10 aquifer would actually intrude due to a proposed withdrawal, but the risk for intrusion is definitely
11 present. If aquifer water level elevations can be accurately determined, incorrectly identifying an
12 area as being at risk for intrusion (false positives) should not occur.
13
14 The ability to accurately predict whether or not a proposed withdrawal will induce seawater intrusion
15 into an aquifer varies with the complexity of the aquifer system, and how well the aquifer system is
16 understood. However, predicting the long-term impact of a proposed withdrawal on the water level
17 elevations in an aquifer is relatively simple, and thus it would be unlikely that a proposal would be
18 ranked as having no risk of intrusion (false negative) where risk actually exists. Thus using aquifer
19 water level elevations coupled with aquifer testing and some type of drawdown calculations provides
20 a predictive tool for evaluating risk for future intrusion.
21
22 Finally, in areas where aquifers have substantial pressure above sea level, the public and water
23 resource managers can be assured that unless this pressure is reduced, the aquifers are not at risk for
24 intrusion. Similarly if an aquifer does not have significant pressure, but intrusion has not yet
25 occurred, planning and management tools can be employed to help alleviate problems before they
26 occur.
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29 4.0 Phase II Assessment
30
31 The primary goal of the Watershed Planning Phase II Assessment is to quantify the water resources
32 within a water resource inventory area ("IA). For many WRIAs the primary resource is a river
33 system, and quantification of the resource is relatively straightforward, involving collection of flow
34 data from that system. In WRIA 6 (Island County) our primary water resource is contained in
35 multiple discontinuous aquifers, with variable connection to recharge areas and the saline waters of
36 the Puget Sound. The complexity of our groundwater system makes it virtually impossible to
37 accurately quantify of the resource as a whole. As a result, the WRIA 6 planning unit opted to make
38 the primary focus of its Phase II Assessment the evaluation of risk for seawater intrusion, utilizing
39 water level elevations as the assessment tool.
40
41 In order to determine the water level elevation in an aquifer, two measurements are required. First a
42 depth to water measurement is taken, finding the distance between the measuring point (typically the
43 top of the well casing) and the water level. In order to convert this depth to water measurement into
44 an elevation, the elevation of the measuring point must be determined. The depth to water is then
45 subtracted from the measuring point elevation to find the water level elevation.
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1 Determination of the elevation of the measuring point has traditionally been accomplished through
2 the use of a differential level loop survey from the nearest vertical benchmark(s) to the well.
3 Although traditional surveying can provide accurate elevation data, in many cases the time and costs
4 associated with this method make it impractical. Recent advances in survey -grade GPS (Global
5 Positioning System) technology have resulted in devices that are capable of determining the
6 elevation of a location in a fraction of the time required for traditional surveying methods.
7
8
9 14.1 Phase II Data Collection
10
I 1 In order to evaluate the effectiveness of water level elevation as a tool for assessing seawater
12 intrusion risk, water level elevation data from both intruded and non -intruded areas of the county
13 was needed. To fulfill this need, data was collected from nearly 400 wells across the county, or
14 roughly two wells per square mile. For each well utilized in the study, depth to water measurements
15 were collected, and where possible a computerized data logger was installed in the wells to evaluate
16 water level variations over time. In addition a water sample was collected from each well, and sent
17 to a state -certified laboratory for major ion analysis.
18
19 Through a grant provided by the Washington State Department of Ecology, Island County was able
20 to purchase a global positioning system (GPS) consisting of three survey -grade receivers and
21 associated hardware. Two of these receivers were set up as permanent base stations to provide post -
22 processing data, and the third was utilized as a roving unit to collect measuring point elevation data
23 from each well utilized in the study.
24
25 Volunteers willing to let the county collect data from private and public water system wells were
26 solicited via newspaper articles and direct mailings. In selecting wells for use in the study, we
27 attempted to achieve an even distribution spatially at approximately two wells per square mile.
28 Since we hoped to measure static (non -pumping) water levels, preference was given to wells with
29 fewer homes connected. Preference was also given to wells completed (screened) below sea level.
30 In any given area, if more than one aquifer was present, we attempted to collect data from the two
31 most frequently utilized below sea level aquifers.
32
33 Over 730 wells were volunteered, of which field crews visited more than 470. Not all wells that
34 were visited by our field crews could be utilized in our study. Wells that did not have access for
35 measuring depth to water, or wells that did not have the ability to provide an untreated water sample
36 were dropped from our study, resulting in a total of 379 wells from which all necessary data was
37 successfully collected. Water level and chemistry data was collected from the study wells during the
38 summers of 2001 and 2002; surveying of measuring point elevations was conducted from the spring
39 of 2003 through the spring of 2004.
40
41 Aquifers can be influenced by tidal fluctuations in adjoining marine waters, resulting in variations in
42 both water level and chemistry. Generally, wells that are affected by seawater intrusion and that are
43 tidally influenced tend to exhibit higher chloride concentrations and water levels during higher tides.
44 In an attempt to collect consistent data, wells that fell within''/2 mile of the marine shoreline were
45 monitored (water sampling and depth to water measurements) during a +6 foot or higher tide stage.
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14.2 Phase II Data Analysis
The primary goals of the Phase II Assessment were to evaluate the use of water level elevation data
as a tool for determining seawater intrusion risk, and to provide water level elevation data on a
countywide basis to provide a new view of intrusion susceptibility. Evaluation of water level
elevation data as a seawater intrusion tool can be approached in several ways. One method involves
comparing intrusion (or lack thereof) from the perspective of water chemistry to the water level
elevation data. As discussed earlier, there are several problems associated with the use of chemistry
for evaluation of seawater intrusion. These problems complicate the use of chemistry as a tool for
validation of the water level elevation methodology for seawater intrusion analysis.
Several different methods were utilized in our analysis of the chemistry data. The most simple of
these methods was simply comparing chloride concentrations to water level elevations as shown in
Figure 7. One problem with this analysis is the significant number of `false positives' where there
400
300
0
0 200 400 600 800 1000 1200 1400 1600
Chloride (mg/1)
Figure 7.
are elevated chlorides that are not due to seawater intrusion. One area of known false positives for
chloride data is Central Whidbey Island. These wells are impacted by very hard groundwater, which
results in elevated chloride concentrations that do not appear to be caused by conventional seawater
intrusion. Figure 7 differentiates the wells in Central Whidbey from all other wells as shown in the
legend. With the exception of the data from Central Whidbey, the plot displays the expected results,
with elevated chloride concentrations occurring with lower water level elevations.
Another type of analysis that has application to seawater intrusion is a piper diagram, where
chemical sample results are plotted based on the relative proportion major ions (Figure 8). For each
water sample, a point is plotted in the lower left triangle based on the proportions of positively
charged ions (cations), and a second point is plotted in the lower right triangle based on the
proportions of negatively charged ions (anions). These two points are then extrapolated up into the
upper diamond to place a third point.
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In general, fresh groundwater samples will land
near the area labeled as `fresh' in the upper �8 •�
diamond, while pure seawater will plot near the
`sea' label. Water that results from conservative 91
mixing (mixing without ionic exchange reactions) ' "'
between freshwater and seawater wouldP lot �\
along the line labeled `mixing'. When mixing -<094�--
occurs in the presence of aquifer materials, ion
exchange reactions often occur between the
groundwater and the aquifer material, which alter 8 �\ $ e •
the chemical composition of the water. This 8 b
change in chemical composition results in a
deviation from the conservative mixing line on the s $ • s�
piper diagram, moving theP oint upward into the b ��
upper portion of the diamond during intrusion, DD
and downward toward the lower portion of the G'°"m 20 2D °���
P Figure s.
diamond during freshening. Using this method, it
is possible to deduce not only if a water sample is impacted by intrusion, but also if the intrusion was
getting worse (intrusion exchange) or better (freshening exchange) at the time the sample was taken.
Figure 9 is a piper diagram plotting the chemistry data from all of the wells utilized in the Phase 2
assessment. The color of the each data point in the upper diamond reflects the elevation of the
bottom of the well as shown in the legend. The radius of each upper diamond data point reflects the
total dissolved solids (TDS)
G. ceding Criteria for that sample, with larger
Screened Elevation is:
Fresh 0 Above sea Level (5 +30') circles having greater
0 Slight Intrusion .' Near Sea Level (+/- 30') quantities of dissolved
0 Intrusion t 0 Below Sea Level (< -30')
F-1SlightConservativeAlixing $ << g+ minerals. A program was
Conservative Mixing b developed that
�] Slight Freshening 10000ppm
_ � = automatically evaluates the
Freshening
(—:.,jpm sample results, assigning
each sample a code
Yin ` Total Dissolved Solids
(parts per million) indicating where it lands on
_- the diagram as shown in
Figure 9. The samples
A, collected as part of the
Phase II Assessment were
$ .. ...... f a . �,...... `...... �, ` processed using the above
"* methodology to evaluate
the ion balance of each, and
��/ �r -- �\ then these results were
` �`_ ° `. •X grouped and the average
so so 40 20 4c so �` water level elevation (in
Mlalde .._---- feet above MSL) for each
Cations Figure AnionFigure 9. grouping was evaluated.
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The results of this evaluation are presented in Table 1. This analysis was performed on data that
excluded wells that are completed above sea level and those wells in Central Whidbey where
anomalous chemistry is known to occur.
Another diagnostic tool used to analyze
chemical sampling results as they relate to
�at3r�'Lve�
}�
seawater intrusion is to evaluate the ratio of
Normal Groundwater 16.0
-29.3
chloride to electrical conductivity. This
Slight Freshening Exchange 18.1
5.1
analysis is especially suited for evaluating
Freshening Exchange 34.0
6.5
areas where extremely hard groundwater
Slight Conservative Mixing 5.5
2.0
results in elevated chloride concentrations.
Conservative Mixing 4.6
3.9
The concept behind this tool is that electrical
Slight Intrusion Exchange 6.2
5.7
conductivity is directly related to the overall
Intrusion Exchange 5.7
3.1
quantities of dissolved solids. For any given
Table 1.
concentration of chloride, one would expect a
much higher conductivity value if the chlorides
were the result of very hard water due to the
presence of other dissolved constituents.
139.3
44.4
300.7
7.5
5.4
6.6
8.6
Figure 10 is a chloride vs. conductivity plot displaying the samples taken during the Phase II
Assessment; sample points are color -coded based on the water level elevations as shown in the
legend.
10000
1000
a 100
10
100
cnioncie vs.
1000 Conductivity (jWcm) 10000
Figure 10.
Water Level Elevation
0 <= " feet MSL
C , to 15 feet MSL
o 15 feet hISL
>K CentraINIV19+1bey
100000
Table 2 summarizes the results of this analysis, grouping results by the diagnostic technique
presented in Figure 10, and comparing those results with average water level elevations for each
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group of results. This analysis was performed on data that excluded wells that are completed above
sea level and those wells in Central Whidbey where anomalous chemistry is known to occur.
Another method for evaluating water level elevation.
as a tool for seawater intrusion risk assessment is to
Pat�t;rel °io:
17 de yrs�� -1M8
compare water level elevation data to the conceptual�;�
'_�
model for groundwater flow in a marine island
Normal (green) 16.2 -29.2 300.7
environment as discussed earlier. The conceptual
Mixed (yellow) 7.9 2.0 19.7
model predicts that water level elevations should be
Seawater Intrusion (red) 8.4 3.1 24.
highest near the center of the island, with water levels
Table 2.
dropping toward the shoreline. The conceptual
model also predicts that if seawater intrusion was to occur
in an area, it would occur first along the
shoreline, moving inland as the situation worsens.
0 1 2 4 6 8 10
Horizontal
Scale in Feet x 1000
Chloride Co
Figure 11.
. . . 200
levation
Figure 11 displays a section of Central Whidbey, with a map of Phase 11 well locations, and a
vertical `stick' diagram of well stratigraphy including elevations of the water table at each well
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represented by the blue triangles. The diagram shows that the water level elevation data is in good
agreement with the conceptual model. Also shown at the base of each well in the stick diagram is
the chloride concentration from that well. The elevated chloride concentrations in wells near the
center of the island, including wells that are completed (screened) significantly above sea level (such
as wells AMU and A4U), represent the anomalous chemistry found in Central Whidbey wells
discussed previously. Previous analysis of Central Whidbey that utilized chemistry as the primary
analysis tool correctly identified those wells that were completed above sea level as being non -
intrusion sources. However, those wells that were completed below sea level remained somewhat in
question. Using water level elevation data provides clear differentiation between those wells that are
impacted by intrusion and those that are not (false positives).
One final analysis was performed on the data collected during the Phase 11 Assessment. This
analysis involved review of all available data including the various chemical analysis described
above, water level elevation, and when available, historical chemistry data for analysis of variations
in chemistry over time. Also included in this review was data from other nearby wells that appear to
be completed in the same aquifer. For each well in the study, a determination was made based on all
available data as to the likelihood that the well was suffering from the impacts of seawater intrusion.
Wells were grouped into one of three categories as follows:
Summary Analysis # of Wells
No Indications of Intrusion 242
Inconclusive Indications of Intrusion 101
Positive Indicators for Intrusion 36
This analysis is used for two purposes: in study results discussions with each volunteer / participant
in the Phase 11 Assessment, and in the statistical evaluation of water level elevation data presented in
Section 5.1.
Figure 12 presents a countywide view of the Phase II Assessment wells, grouped by water level
elevations. With a few exceptions on North Whidbey (which will be discussed later in this paper),
the elevation data closely conforms to the conceptual model. Virtually all the red, orange and yellow
data points (lower water level elevations) are located along the shorelines, while the green and cyan
data (higher water level elevations) are located inland. Lower elevation data are almost always
clustered in groups, indicating that these areas have reduced water level elevations.
Water level elevation data can be used to identify `false positives' in chemistry data, and in addition
it can be used to identify `false negatives'. Several shoreline areas on South Whidbey and Western
Camano have relatively low water level elevations (red and orange data points), but as of now have
not experienced any chemical indications of intrusion. These areas can be interpreted as being at
risk for intrusion, although intrusion has not yet begun to occur. Larger project proposals in these
low water level elevation areas should be evaluated from the perspective of seawater intrusion.
Chloride data alone would. not have provided this advance warning of pending intrusion problems,
but instead could only react after intrusion actually begins to occur.
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Water Level Elevation
0 very High (> 20)
0.Hull (8 tD.20).
0 Medium Higb (6 to 8)
p Meditim (4 to 6):
Low (1.20 4).
i vett low (<.1)
meet Above Mem Tide
i
0 l 2 3 4 5
Scale in Miles
*to eonveat fi out Alean Tide Level hi the Pttgd
Somatl to Mean Sen Level (NAND SS),add
fom• feet to Clle Aiaau Tk—kI owei.IUPsttrsluent.
Figure 12.
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An additional benefit of using water level elevation as a tool for evaluating seawater intrusion risk is
the ability to define areas where intrusion is unlikely to be an issue in the foreseeable future. Areas
in Figure 12 with cyan data points have water level elevations more than twenty feet above mean
tide. These areas are unlikely to suffer from intrusion, even when substantial withdrawals and
drawdown occur.
In many cases, water level elevations can be pulled significantly below sea level at a pumping well
and yet not induce seawater intrusion, as long as the water level elevations in the aquifer rise high
enough between the pumping well and. the submarine aquifer outcrop to prevent saltwater from
entering into the aquifer.
This situation creates what is known as a
`false interface' and is illustrated in Figure
13. The drawdown cone at the pumping
well extends below sea level, which causes
the Ghyben-Herzberg predicted interface
position to move upward to the well screen.
Water level elevations are significantly
above sea level in the aquifer between the
well and the shoreline (A), resulting in the
predicted interface position falling
significantly below the bottom of the aquifer
(B), and preventing the movement of
saltwater to beneath the well, which
prevents seawater intrusion at the well.
The important factor in preventing seawater intrusion is not the water level at the pumping well, but
instead it is the water level in the area between the well and the shoreline. If water levels in an
aquifer are lowered, reducing the pressure above sea level (A), the predicted interface position at (B)
will rise until a critical level is reached where the base of the interface rises up to the base of the
aquifer. Once the critical rise has been reached, intrusion of the pumping well will occur rather
rapidly. Once water level elevations are lowered below the critical level and the seawater interface
moves into the base of the aquifer beneath a pumping well, the strategies for mitigation change.
From that point forward, attempts to control rather than prevent intrusion are required. Measures
such as relocating wells.. reducing pumping rates, and raising well intakes (screens) are typically
employed.
There is one additional conclusion can be drawn from examination of the water level elevation study
results: risk for intrusion is highest near the shoreline, and decreases as you move inland. In some
cases, wells currently showing signs of intrusion may exhibit intrusion problems even if they were
the only wells completed in that particular aquifer. In these cases, the problem is not so much one of
over -drafting the aquifer, but rather one of poor selection of well location. These wells were initially
installed into the zone of diffusion, and thus experienced elevated chlorides from the day they were
installed.
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Figure 14 presents an example of this situation, with Water Level Elevations nl u
an aquifer with high freshwater flow discharging a and Well Placement
substantial amount of water to the Puget Sound. Shoreline
Some of this freshwater discharge could be utilized as well
a water source, if the resultant movement of the
interface could be tolerated. Two wells are shown indl] r aT a
Figure 14: a shoreline well with its well screen s""' Sao
positioned at the base of the aquifer and an inland
well with an elevated screen. As in the previous
example, pumping of the inland well, even at a.
substantial rate, will not result in intrusion of the
inland well. In contrast, the shoreline well will suffer Figure 14.
from intrusion, even when pumped at a relatively low rate. Depending on the specific aquifer
conditions and the distance of the second (inland) well, pumping of that well may induce drawdown
.on the shoreline well. Such drawdown would result in a worsening of intrusion problems for the
shoreline well. Although the aquifer has significant capacity for additional withdrawals, the poor
placement and subsequent intrusion of the shoreline well would be interpreted as a degradation of
water quality, resulting in limiting future withdrawals from this aquifer in the immediate area. In
fact, given the above-described scenario, the Washington Department of Ecology (DOE) would not
approve a water right application for the inland well, based on the degradation of water quality it
would cause on the shoreline well.
Seawater intrusion can be viewed as an inverted version of the partially penetrating well construction
situation described above. An aquifer that could otherwise produce a significant quantity of water
could be rendered useless due to "intrusion", caused by poor well placement and construction (too
close to the shore, and/or too deep). If maximizing the use of groundwater resources is a desired
goal, then a solution to this problem, similar to the fully penetrating solution described above, will
need to be devised and implemented.
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1
2 Groundwater in Island County is too limited to waste due to poor well design and placement. Long -
3 term strategies for resource management in a marine island environment need to include the concept
4 of placing the points of withdrawal away from the shoreline, toward the center of the island where
5 the risk for intrusion is less. Existing shoreline wells could be converted to observation wells, for
6 monitoring the position of the interface to insure that it is not moving inland further than desired.
7
8
9 5.0 Seawater Intrusion Policy - Revision Options
10
11 The proposed Seawater Intrusion Policy is made up of three principal components as follows:
12
13 1. Suggested Triggering Mechanism: A criterion for evaluating where the policy should or
14 should not apply. Chloride concentrations and water level elevations are examples of
15 potential triggering mechanisms.
16
17 2. Applicability: A criterion for evaluating what type of projects should be reviewed under the
18 policy. Adding connections or creating new public water systems, drilling of new wells, and
19 subdivision of land are examples of actions that could be reviewed for potential to cause /
20 exacerbate intrusion problems.
21
22 3. Implications: A set of actions that result from triggering review of a project for which the
23 policy applies. Testing, monitoring, hydrogeologic analysis, and phased development are
24 some possible implications when an applicable proposal is flagged via the triggering
25 mechanism.
26
27 For each of these components, there exists a wide range of possible methods and implementation
28 options. It is not possible in the context of this paper to discuss and review all of these potential
29 options, so instead these discussions have taken place within meetings of the WRAC's groundwater
30 subcommittee, and this paper reflects the resulting recommendations.
31
32 To be effective, any policy needs to be easily understood and implemented. The simpler the
33 regulation, the more likely it is to accomplish its goals. The current Seawater Intrusion Policy has a
34 relatively complex implementation matrix with a total of 12 categories, with 14 options that can be
35 required, potentially required, or recommended within each category. Recently, the Washington
36 State Department of Health (DOH) has re -assessed its role in implementing the Seawater Intrusion
37 Policy. DOH found that it has little legal authority to regulate public water systems based on
38 resource protection issues, and as a result DOH no longer utilizes the 100 and 200 mg/1 chloride
39 triggering system, but instead relies on the 250 mg/1 secondary MCL as a threshold for triggering
40 management options. This has resulted in a situation where smaller Group B water systems
41 (overseen by Island County Health) undergo more strenuous seawater intrusion testing / review than
42 the larger Group A systems (overseen by DOH). In addition, discussions with DOH have revealed
43 that even the 250 threshold currently utilized may not be enforced in the future. A new/revised
44 Seawater Intrusion Policy needs to provide a rational and consistent approach for proposal review.
45
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1 Ultimately, the selection of trigger levels, applicability, and implications needs to balance the burden
2 on applicants and regulators (costs involved with evaluating proposals for potential intrusion
3 impacts) against some measure of the cost of having an aquifer intruded to any given level. Lower
4 trigger values, wider applicability and more significant implications may increase costs for
5 applicants and regulators, but will provide greater protection for groundwater resources.
6 Conversely, higher trigger thresholds, more restricted applicability, and milder implications result in
7 lower cost but provide less protection and may result in more severe intrusion problems prior to
8 triggering regulatory protection measures.
9
10
11 5.1 Suggested Triggering Mechanisms
12
13 One goal of the Phase Il Assessment was to evaluate the possibility of using water level elevation as
14 a tool for assessing seawater intrusion risk. Data collected during the Phase II Assessment indicate
15 that there are areas in Island County where water level elevations are low, but as of yet the wells in
16 these areas have not suffered from chemical impacts of intrusion such as rising chloride
17 concentrations. It is possible that additional small withdrawals can be obtained in these areas
18 without causing intrusion, and so these areas could be treated differently from areas where water
19 levels are low and chemical impacts have occurred.
20
21 The proposed triggering mechanism combines water level elevation data with chemistry data. Low
22 risk areas would be defined as those areas with high water level elevations, regardless of chemistry.
23 Under this triggering criterion, the false positive problems described earlier (where elevated
24 chlorides result from process other than seawater intrusion) would be defined as low risk as long as
25 the water level elevations in the area were above the triggering threshold. Medium risk areas would
26 be those areas where water elevations fall below some triggering threshold, while high risk would be
27 defined as areas with lower water level elevations and elevated chloride concentrations. A new
28 category, very high risk, will be defined where water levels are low and chloride concentrations
29 reach a more severe level.
30
31 The chloride concentration trigger levels (100 and 200 mg/1) utilized by the current policy to define
32 medium and high-risk areas were likely selected (on the high side) with the issues related to false
33 positives and non -intrusion sources in mind. Using water level elevation as the initial screening
34 criteria may reduce or eliminate these problems, enabling the use of a more conservative (lower)
35 threshold chloride concentration (trigger). Alternatively, selecting a relatively high trigger level
36 such as 250 mg/l would provide consistency with current DOH guidelines and the EPA secondary
37 MCL for chloride. One could argue that any selected trigger level will - in the long run - be met or
38 exceeded in many coastal areas / aquifers since certain types of development will continue to occur
39 without regard for intrusion while concentrations fall below the selected trigger level. (see Section
40 6.0)
41
42 One option for defining a trigger value for chloride would be to couple the trigger to health risks
43 presented by intrusion. The U.S. EPA is responsible for setting maximum contaminant levels
44 (MCL) for drinking water, with primary MCL values representing health risk standards, while
45 secondary MCL's are esthetic (taste, odor, color etc.) standards. The EPA has set a secondary MCL
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I for chloride at 250 mg/1 based on taste thresholds. Although the EPA considers sodium a primary
2 (health risk) contaminant, they have not set an MCL for sodium, but rather have issued a
3 recommended level of 20 mg/1 for those consumers who may be restricted for daily sodium intake.
4 Using water quality data from sampling marine waters around Island County, the ratio of chloride to
5 sodium in these waters is approximately 1.8 mg/1 of chloride for every mg/1 of sodium. Using this
6 ratio to extrapolate the chloride concentration that would accompany 20 mg/1 of sodium yields a
7 concentration of 36 mg/1 chloride. Despite the logical link to health effects, a chloride trigger level
8 as low as 36 mg/l would only be feasible if it makes sense from the perspective of groundwater
9 chloride concentrations in groundwater that is not impacted by seawater intrusion.
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A second analysis was performed to assess Island County groundwater chloride concentrations. This
analysis utilized all chloride and conductivity sampling data on file, first filtered to include only
those water samples that appear to be normal groundwater (not intruded) based on chloride vs.
conductivity ratios (see Figure 10), wells that are completed below sea level, and excluding Central
Whidbey wells. The mean chloride concentration in these water samples was 38.8 mg/1 with a
standard deviation of 30.6. Adding two times the standard deviation to the mean value yields the
statistical value below which 97.5% of all samples will fall, which calculates to be 100.0 mg/1.
An idealized graphical representation of this
concept is presented as a frequency of occurrence
plot in Figure 16. The horizontal axis displays
chloride concentrations while the vertical axis
U
displays the frequency of occurrence, with higher
v
points on the curve representing concentrations
that occur more frequently. The peak of the curve
ou
represents the mean or average chloride
concentration (38.8 mg/1), and moving two
standard deviations to the right defines the value
(100 mg/1) below which 97.5% of all samples will w
fall (hatched area).
2 Standard
Deviations
Mean
(Average)
X97.5% of
all samples
The mean chloride concentration in Island County
(38.8 mg/1 for non -intruded wells) is very near the 38.8 100
trigger level derived using the sodium health Chloride (mg/1)
based chloride criteria (36 mg/1). As a result this Figure 16
trigger cannot be utilized since its use would identify nearly half of all non -intruded wells as
exceeding this value. However, the chloride concentration analysis does provide a possible trigger,
the chloride concentration for which the vast majority of wells that are not suffering from intrusion
would fall below. Selecting a value of 100 mg/l would provide a fairly conservative triggering
mechanism, yet have relatively few false positives. This value also has the advantage of having been
utilized by the current policy and thus has some level of public acceptance.
A water level elevation triggering value also needs to be selected in order to incorporate this tool
into the seawater intrusion policy. Data pertaining to water level elevations and intrusion levels are
available from the Phase II assessment. In this case, elevations lower than the trigger level will be
interpreted as having risk for intrusion, so the evaluation will target maximum water level elevations
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1 in wells that are known to be intruded. Using the methodology outlined above, the mean water level
2 elevation in wells classified as having positive indicators for intrusion (see page 12, lines 10 - 25) is
3 5.6 feet above mean sea level (MSL, NAVD 88) with a standard deviation of 1.4 feet. Adding two
4 times the standard deviation to the mean yields a value of 8.4 feet MSL, below which 97.5% of the
5 water level elevations for intruded wells would fall.
6
7 It should be noted that the mean sea level datum does not equal mean tide level in the Puget Sound.
8 The National Geodetic Survey (NGS) maintains tidal benchmarks around the Puget Sound, and these
9 benchmarks have information relating to various vertical datum including NAVD 88 and the mean
10 tide levels. The mean tide level in the Puget Sound varies spatially, but typically in the area of
11 Island County the mean tide level is at just over four feet on NAVD 88. Thus the 5.6 feet level
12 identified in the previous paragraph equates to just over 2 feet above the mean tide level.
13
14 Using the criteria defined above, the new Seawater Intrusion Policy would be defined as follows:
15
Risk Cateizory Water Level Elevation' Chloride Concentration Z
Low Greater than 8.4 Any'
Medium Less than or Equal to 8.4 Less than 100
High Less than or Equal to 8.4 Between 100 and 250
Very High Less than or Equal to 8.4 Greater than 250
16 Table 3.
17
18 'Water Level Elevation in feet above Mean Sea Level (MSL) NAVD 88. +4 feet MSL = 0
19 feet relative to Mean Tide Level in the Puget Sound. For example, 8.4 feet MSL = 4.4 feet
20 above Mean Tide Level.
21 2Chloride Concentration in Milligrams per Liter (mg/1)
22 ' Where water level elevations are greater than 8.4 feet, chloride concentrations are irrelevant
23
24 The current Seawater Intrusion Policy defines risk areas by placing ''/z mile radius circles around
25 wells with elevated chloride concentrations; utilizing circles has worked reasonably well and is
26 easily implemented. The new policy would maintain this strategy, utilizing '/z mile circles
27 around wells with low water level elevations, and wells with elevated chloride concentrations.
28 The combined overlay of the chloride and water level elevation maps will be used to define risk
29 areas.
30
31 A preliminary map generated using the above criteria is presented in Figure 17. Of particular
32 interest on this map are the green and yellow areas. Green areas are areas with elevated chloride
33 concentrations but high water level elevations, previously described as `false positives', such as
34 Central Whidbey Island south of Coupeville. Yellow areas represent areas with low water level
35 elevations, but without elevated chlorides; these areas are considered to be `false negatives' or
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Legend
Very High Risk
High Risk
'Medium Risk 140
` - Low Risk (Previously Medium or High
Low Risk
Map generated ntilizir; data frim Tammy 2005
2 Revised Seawater Intrusion Policy `Circle Map'
3 Utilizing Water Level Elevation and Chloride Data
4 Figure 17.
5
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areas where intrusion risk is present but intrusion has yet to be
identified based upon existing data.
It should be noted that ICHD currently has significantly more
chloride data available than water level elevation data. In
particular, certain areas of the county have no water level data but
do have chloride data. If the chloride concentrations in these areas
are elevated (but there is no water level data), then these areas are
mapped as green or low risk. Without water level information it is
uncertain if these areas are truly represented as low, medium or
high risk. Water level data elevation must be collected in these
areas to determine what risk category should actually apply.
Examples of where this problem is likely occurring are portions of
the panhandle on Camano Island, and in the kettles region west of
Penn Cove on Whidbey Island.
A lack of water level elevation data occurs most frequently in areas
where larger public water systems are present, such as within the Figure 18
service area for the City of Oak Harbor, and in the area of NAS
Whidbey Island. A map showing water level elevation data coverage is presented in Figure 18.
The need for additional water level elevation data to fill these information gaps is discussed in
Section 5.3.
5.2 Applicability
Based on the factors influencing seawater intrusion presented in Section 1. 1, it is clear that once
an aquifer reaches a critically low water level elevation, any groundwater withdrawal has the
ability to induce intrusion. Areas that have water level elevations above this minimum (low risk
in Table 3) are not at risk for intrusion, and so proposals within these areas would not be
subjected to review for seawater intrusion.
33 Medium risk areas as defined in Table 3 have low water level elevations, but have yet to
34 experience any groundwater quality (chlorides are below 100 mg/1) impacts. Proposals that
35 withdraw relatively smaller volumes of water have a lower potential for impact, and therefore do
36 not pose as high a risk to a marginally adequate aquifer as larger proposed withdrawals. As
37 such, smaller proposals that would potentially add 6 or less equivalent residential units (ERU)
38 would be allowed to occur in a medium risk area, but those proposals that would include more
39 than six connections would be subject to review. Exempted proposals include subdivisions of up
40 to six lots, addition of up to six connection approvals to an existing water system, or creation of a
41 new water system with up to six connections. Note that the above description defines the
42 expansion of a water system, which entails the addition of new connection approvals (either
43 within or outside of the systems defined service area), not the putting to use of previously
44 approved but currently unused connections. It is anticipated that in most cases, connecting to
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I systems that are growing into previously approved connections will occur on a house -by -house
2 basis, and will generally occur at a relatively low rate.
3
4 High-risk areas as defined in Table 3 have low water level elevations and have chloride impacts
5 between 100 and 250 milligrams per liter. In this situation, even smaller (6 ERU's or less)
6 proposals can potentially push the aquifer into significant deterioration due to seawater intrusion.
8 In high-risk areas, any proposal that would add more than 1 ERU, which includes subdivision of
9 land, creation of any new public water system, and expansion or infilling of public water systems
10 would be subject to review. In addition, individual wells on parcels of less than 1.5 acres in size
11 would also be reviewed in high-risk areas.
12
13 Very high-risk areas are defined as having low water level elevations, and chloride
14 concentrations in excess of 250 milligrams per liter in the source of water that is used for the
15 proposal. In this situation, the well has reached a significant level of contamination, and the
16 potability of the water begins to come into question. Water systems with chloride concentrations
17 greater than 250 milligrams per liter would be placed on moratorium (no new connections
18 allowed) until the situation can be remedied or mitigated. Individual wells on parcels less than
19 five acres in size will also be subject to review.
20
21 Chloride concentrations in wells that are impacted by seawater intrusion typically peak during
22 the late summer and drop off during the winter months. In most cases, this is not due to changes
23 in recharge to the aquifers, because the travel time (the time it takes a raindrop to move down
24 through the overlying stratigraphy to recharge an aquifer) is on the order of years. The annual
25 rise and fall of chloride concentrations is actually caused by the increase in pumping associated
26 with lawn watering and other seasonal water use. For this reason, a drop in chloride
27 concentration associated with seasonal variation will not, on its own, be considered a mitigation
28 of seawater intrusion.
29
30 The applicability of the policy as defined above primarily targets the subdivision of land, and
31 creation or expansion of water systems (including individual wells under certain circumstances).
32 All of these actions involve the use of additional groundwater resources associated with growth,
33 or the addition of new buildings and/or residents within the county. It is acknowledged,
34 however, that existing water users within an area suffering from seawater can contribute to
35 intrusion problems, and that placing the burden of finding and implementing remedies solely on
36 those systems that are expanding may not be equitable. For example, two existing adjacent
37 public water systems may have wells completed in the same aquifer. If this aquifer begins to
38 suffer from seawater intrusion, and one of the systems desires to add new connections, that
39 system could be required to find and implement mitigation measures to avoid further intrusion.
40 If the other system has no plans to expand, currently no mitigation would be required even if the
41 system operated in a manner that exacerbated the problem.
42
43 Ideally, measures to mitigate seawater intrusion would be enacted by all users of the impacted
44 resource, regardless of whether or not growth is occurring in an area. In reality, state and local
45 governments have limited legal authority to regulate groundwater withdrawals unless they are
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either applying for a permit (such as a development permit) or they are in violation of state water
law (conservation, beneficial use, etc.). As such, voluntary participation in mitigation efforts
should be encouraged, and strategies for long-term regulatory mechanisms should be
investigated. This investigation must take into account the legal mechanisms and limitations
associated with a more holistic groundwater management effort that identifies existing
management tools and the relationship between State Water Law and Groundwater Degradation.
5.3 Implications
It is proposed that public water systems (3 or more connections) that have sources (wells) that
fall within medium, high, or very high risk areas would be required to collect water samples from
these sources in April and August of each year, and submit those samples to a state certified
laboratory for chloride and conductivity analysis. Water level elevation data would be collected
from all potentially regulated projects other than individual wells. (See Figure 19.)
Proposed projects that fall within risk areas as defined in Section 5. 1, and meet the applicability
criteria defined in Section 5.2, will be evaluated to determine if the proposed withdrawal will
negatively impact the aquifer by inducing or worsening seawater intrusion. In most cases this
evaluation will require the collection and analysis of data pertaining to the well and the aquifer in
which the well is completed (screened).
Sampling
Seawater- Intrusion Review
Flevatic,ns
Figure 19
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1 It is worth noting that implementation of the current Seawater Intrusion Policy has changed
2 substantially since the policy was initially developed. When the policy was initially adopted,
3 Island County Health did not have a professional hydrogeologist on staff to assist in evaluating
4 projects. As a result, all applicable projects that were found to be at risk (medium or high risk as
5 defined by the current policy) were required to supply a full hydrogeologic assessment of their
6 project. Now that the department has hydrogeologic expertise, projects that fall under review
7 can be screened for the applicability of the policy to the specific project. Smaller quantities of
8 initial data can be collected at a greatly reduced cost and an initial determination can be made as
9 to the need for additional data based on the preliminary results. This can result in a significant
10 savings for some applicants, while allowing other applicants to make informed decisions on
11 whether or not to pursue the additional data collection (with the associated costs) given the
12 results of the preliminary testing, or perhaps to evaluate other more promising courses of action.
13 This methodology of phased review and staged data collection (and incremental costs associated
14 with this data) is expected to continue regardless of any potential modifications to the triggering
15 requirements.
16
17 If a proposed project were determined to be at risk based on the preliminary data, aquifer testing
18 and analysis would be required to determine the hydraulic characteristics of the aquifer. The
19 results of this testing will be used to evaluate the long-term impacts the proposed withdrawal will
20 have on the aquifer and nearby wells. The aquifer testing and impact prediction analysis would
21 result in a hydrogeologic report; a hydrogeologist licensed in the State of Washington should
22 prepare this report and oversee the aquifer testing and analysis. The specific details of data
23 collection and analysis requirements will be determined on a case-by-case basis. Costs
24 associated with data collection and analysis will be borne by the applicant.
25
26
27 6.0 Options
28
29 O tip on # 1 No Action
30
31 The no -action option relies on the continued use of the current (chloride based) seawater
32 intrusion policy. This option has both benefits and drawbacks; the primary benefit is ease of
33 implementation. The drawbacks associated with this option relate to the shortcomings of the
34 current seawater intrusion policy discussed earlier in this paper. These are the false positives
35 (elevated chlorides identifying areas as being at risk for intrusion where no risk exists) and false
36 negatives (the failure to identify risk until after intrusion occurs). This option has low additional
37 cost and moderate to low effectiveness.
38
39 Option #2 Seawater Intrusion Policy Modification
40
41 This option involves modification of the Seawater Intrusion Policy to include the use of water
42 level elevation as described in Section 5 of this paper. As with the no -action option,
43 modification of the Seawater Intrusion Policy has both advantages and disadvantages. The
44 primary drawback for this strategy is the increased cost to the applicant. Although depth to
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1 water measurements are relatively easy and inexpensive to obtain, the surveying of measuring
2 point elevations will result in additional expense. Advantages to modifying the Seawater
3 Intrusion Policy far outweigh the disadvantages, and include the elimination of false positives
4 (flagging of proposals for risk where in fact none exists) and of false negatives (flagging of
5 proposals that present risk that were previously missed). Modifying the Seawater Intrusion
6 Policy will provide security for those systems that are not at risk for intrusion, and give direction
7 to those seeking a more adequate water supply.
8
9 The current Seawater Intrusion Policy was approved and adopted by agreement between the
10 Health Services Director for the Island County Health Department and the Manager of State
11 Department of Health, Northwest Region, Drinking Water Operations. Modifications to policy
12 could be accomplished through several approaches, each having distinct advantages and
13 disadvantages. These options include the development of a new joint policy, the development of
14 an Island County policy, adoption of a Resolution by the Board of Island County
15 Commissioners, or the inclusion of the review criteria into Island County Code. This option is
16 anticipated to have moderate cost and high effectiveness.
17
18 Option #3 Monitoring Network Modification
19
20 Island County Health currently operates a long-term groundwater -monitoring network. This
21 network is meant to provide data for analysis of long-term trends in groundwater quality and
22 quantity. The network is composed of individual and group domestic water supply wells. At the
23 time that the network was developed, chloride concentration was selected as the tool for
24 evaluating seawater intrusion trends. Water level elevation will provide an earlier warning of
25 pending intrusion problems for aquifers that occur below sea level, and also provide warning of
26 dewatering (lowering of water levels) in above sea level / perched aquifers.
27
28 Because the current network utilizes water supply wells as its monitoring points, small-scale
29 trends (on the order of fractions of a foot per year) are virtually impossible to detect. This is
30 because the wells are almost always in a state of recovery from some pumping prior to
31 monitoring. For example, if a well had been pumped an hour prior to monitoring, it may have
32 recovered to with a 10 of a foot of static, but if it had been pumped 15 minutes prior to
33 monitoring it may be one half foot below static. Dedicated monitoring wells located some
34 distance from larger water supply wells would always be static since they would not be pumped
35 other than for sampling. As a result, they would provide much higher quality data pertaining to
36 seasonal and long-term water level changes.
37
38 Water quality data (chloride concentrations) collected from wells that are subject to intrusion is
39 highly dependant on the timing and duration of pumping prior to sampling. Thus a water supply
40 well could be sampled twice during a 24-hour period, and different chloride values may be
41 obtained depending on how much the well had been in use prior to the arrival of the sampling
42 staff. Dedicated monitoring wells would not suffer from this problem, since the wells would not
43 be in use prior to sampling and the values obtained would be much more consistent and
44 comparable. Using a network of dedicated monitoring wells, the quality of data obtained from
45 the network would be significantly improved, with detection of trends in water level or chemistry
Editor: Doug Kelly - C:\My Documents\Word\WatershedPlanring\Seawater Intrusion (Final).doc
25.
SEAWATER INTRUSION TOPIC PAPER (Final)
Approved by WRAC: 2/3/05, Approved by BOCC 3/16/05
Island County / WRIA 6 Watershed Planning Process
1 at a much earlier point / lower level. Early detection of trends in water level and / or chemistry is
2 a critical element of a successful groundwater resource management program. This option is
3 considered high cost and high effectiveness.
4
6 Option #4 Uniform Application of Seawater Intrusion Review
7
8 Regardless of how the current Seawater Intrusion Policy is modified to include water level
9 elevation data, the resultant policy/resolution/code should be applied uniformly to all water
10 system developments, including those currently outside the purview of the Island County Health
11 Department (i.e. Group A Systems). Island County, along with DOH and DOE, needs to
12 formally address how the seawater intrusion protection strategy will be applied to developing
13 Group A water systems. ICHD currently reviews individual wells, smaller water systems (2 to
14 14 connections/Group B), and land subdivision proposals. ICHD review of these projects from
15 the perspective of seawater intrusion is expected to continue in the future. DOH provides
16 oversight of larger (Group A) public water systems, while the DOE provides oversight of the
17 water resources of the state including the review of water right permit applications. DOH has
18 recently re -assessed its partner role in implementing the Seawater Intrusion Policy. DOH has
19 determined that it has legal authority to regulate public water systems based on public health
20 issues only (i.e. not on any resource protection issue basis).
21
22 Most Group A water systems in Island County are required to obtain a water right permit from
23 DOE. When the aquifer proposed for use is at risk for seawater intrusion, DOE generally applies
24 provisions relative to seawater intrusion, including monitoring requirements. In the event of
25 rising chloride concentrations, the provisions allow DOE to require mitigation / corrective action.
26 If mitigation measures are not successful in controlling the increasing chloride concentrations,
27 DOE has the ability to freeze the system at the current stage of development. Some older water
28 right permits may not contain specific provisions related to seawater intrusion. In these cases
29 DOE still has the ability to provide resource oversight based on the water quality / anti -
30 degradation policy (WAC 173-200-030).
31
32 The proposed mechanism for review of Group A water systems involves utilizing DOE's
33 technical staff and regulatory authority to provide oversight of Group A water systems when
34 review is triggered by the seawater intrusion policy. Three agencies would be involved in this
35 process; Island County Health would maintain the policy maps (circle maps) that identify risk
36 areas; DOH would utilize these maps to evaluate what water system actions would result in a
37 need for seawater intrusion review; and, when triggered, DOE would provide the technical
38 resource review. The details of this arrangement would be outlined within an interagency
39 agreement or Memorandum of Understanding between the three agencies and should be explored
40 further during the implementation of the watershed plan.. Prior to the initiation of such an
41 agreement it is imperative to fully understand the legal basis of applying limitations on
42 withdrawals as they pertain to existing water rights. This option is anticipated to have low cost
43 and high effectiveness.
44
45
Editor: Doug Kelly Q\My Documents\Word\WatershedPlanning\Seawater Intrusion (Final).doc
26.
SEAWATER INTRUSION TOPIC PAPER (Final)
Approved by WRAC: 2/3/05, Approved by BOCC 3/16/05
Island County / WRIA 6 Watershed Planning Process
1 Option #5 Future Policy Recommendations
2
3 As Island County aquifers are recharged annually by rainfall, it is important to manage
4 withdrawals so that they do not exceed sustainable yields. To support this goal, Island County
5 should develop valid and verifiable thresholds, using chloride levels and water levels above sea
6 level, as indicators that water withdrawals are exceeding recharge, which reflects a depletion of
7 fresh or potable water supplies from county aquifers.
8
9 To reverse such possible depletion, Island County should pursue the development of incentives
10 and regulations which, in applying to all freshwater withdrawals within an area where the
11 freshwater within an aquifer is being depleted, would implement water use reductions to both
12 prevent further depletion and return the aquifer to a maintainable water balance. Due to legal
13 and administrative hurdles, this option is not feasible at the current time. However the WRAC
14 recognizes the need for such policies and recommends that strategies to overcome these hurdles
15 be pursued.
16
17
18 7.0 Conclusions
19
20 Island County has historically taken a leading role in understanding and protecting its
21 groundwater resources, particularly in the area of seawater intrusion. The adoption of the
22 Seawater Intrusion Policy in 1989 represented a significant step toward this goal of protecting
23 our aquifers. This topic paper attempts to provide an overview of current science and
24 regulations, and makes recommendations for future resource protection efforts. Specifically this
25 paper provides recommendations for updating the Seawater Intrusion Policy to incorporate
26 additional analysis tools, and to simplify and streamline the use of the policy. These changes
27 result in a tool that overcomes many of the problems associated with the current policy. Both the
28 current policy and the proposed policy revisions define a screening tool used to evaluate risk for
29 seawater intrusion and trigger additional review where needed. Neither the current policy nor
30 the proposed policy revisions are meant to draw conclusions regarding the likelihood of seawater
31 intrusion posed by any particular proposal.
32
33 As in the case of the 1989 seawater intrusion policy, science, technology, regulatory and political
34 issues continuously change through time. The recommendations of this paper should not be
35 taken as static and final, but only one step in a long-term strategy of adaptive management,
36 critical to the protection of our water resources into the future.
Editor: Doug Kelly C:\My Documents\Word\WatershedPlanning\Seawater Intrusion (Final).doc
27.
David W. Johnson
From: Barbara Moore -Lewis [brinnongroup@gmail.com]
Sent: Tuesday, November 03, 2009 9:47 AM
To: David W. Johnson
Subject: Fwd: comments in response to notice of scoping
Attachments: Comments for Scoping Meeting (2).doc; waterworksConsultantsWaterReview.pdf;
seawaterintrusion. pdf
Attached are my comments in response to the notice of scoping for preparation of a supplemental impact
statement (SEIS) to address zoning code admending, development agreement, and project -level environmental
review of the master plan for the Brinnon master planned resort (BMPR).
I'm attaching a letter, comments on water issues by Waterworks Consultants, and Island County's Seawater
Intrusion Policy. I would like all of these documents to be presented in full in the public record and all of them
to be considered in the scoping process.
As for an alternative to the BMPR, we have a number of residents who have e -businesses or telecommute.
Broadband for the entire community would be a minuscule investment compared to the cost of a resort. This
would allow the development of small businesses that are the backbone of this country and of this county,
instead of a large foreign -investment development, environmentally challenged development. This would be an
economic development that could be accomplished fairly quickly, bring revenue to the county that is steady,
and have minimal impact on the environment and the community.
Thank you for the opportunity to comment.
Barbera
a
Barbara Moore -Lewis b
Comments for Scoping Meeting
October 28, 2009
Emailed to DCD November 3, 2009
Thank you for the opportunity to speak.
o SubSurface Group LLC has prepared a document titled "Water Supply and
Groundwater Impact Analysis."
o The document is dated November 20, 2008 and was date-stamped into the
Jefferson County Department of Community Development on April 1, 2009.
o This document was sent for comment to state and local agencies, tribes, and
interest groups on June 30, 2008, after internal review by DCD.
o Comments were due to David Johnson July 17, 2009.
o Waterworks Consultants submitted comments on behalf of the Brinnon Group at
that time. Waterworks Consultants pointed out significant gaps in the information
needed to assess the Black Point hydrogeologic system. These comments are
attached.
o My remarks are based on the recommendations of Waterworks Consultants.
Summary of Recommendations for Additional Testing
To better understand the hydrogeologic response to the proposed water supply
management scheme in this relatively sensitive groundwater environment, each
of the components of the hydrologic cycle should be more accurately quantified.
In addition, the aquifer properties must be better defined to design a supply
system that does not overstress the aquifer. The following tests are
recommended in order to gather that information.
Aquifer properties
Aquifer testing — pump tests should be conducted for a minimum of 72 hours in
any wells that might be proposed for water supply purposes (American
Campground Well, Pleasant Tides Coop Well (Sam Boling Water System/Black
Point Water Company) and MW -2). Pump tests should be conducted for long
enough to generate a measurable drawdown in at least two monitoring wells in
the vicinity. Pumping rate at the Pleasant Tides Coop Well should include the
300 gpm for existing water rights plus the proposed new withdrawal.
❑ Pump testing at MW -2 should include installation of a monitoring well, at a
location that is as close as existing wells are to the eastern shoreline, in
line with the MW -2 well. Chloride testing of water pumped from the
aquifer should be done when the MW -2 is pump tested.
❑ Pump testing at the Pleasant Times Coop Well should include monitoring
for water level drawdown and for chloride at the other Black Point Water
Company wells, the Babare well, the Tudor well and the other Pleasant
Harbor Beach Tract Owners wells.
Barbara Moore -Lewis
Comments for Scoping Meeting
October 28, 2009
Emailed to DCD November 3, 2009
Seawater intrusion
Chloride content in groundwater should be determined in samples collected from
wells pumped adjacent to the marine shoreline over the duration of the pump
tests. At a minimum one sample should be collected prior to initiation of
pumping, another after at least 12 hours of pumping and a third shortly before
pumping is stopped. More samples provide more confidence in the data
collected, and the interpretations derived from that data. Chloride concentrations
between 100 and 200 mg/1 indicate wells atmoderate risk for seawater intrusion,
with 200 mg/l being the trigger for high risk, according to Island County's
Seawater Intrusion Policy (a copy is included with these comments as an
Attachment ).
Groundwater movement
Groundwater levels should be measured in every accessible well on the same
date, so that a groundwater elevation contour level map can be constructed that
is reliable for interpreting the direction(s) of groundwater movement. A better
understanding of the direction of groundwater movement will support a better
interpretation of the groundwater withdrawal impacts to private wells on the Black
Point Peninsula and seawater intrusion risk.
Water Budget
The presentation of the water budget in the Report makes it impossible to assess
the individual components of the water budget, their relationship to each other,
and what data was used to derive them. A comprehensive explanation of the
water balance calculations must be provided. This should include:
❑ water budget equation used
❑ Values for each component the equation
Water Supply and Groundwater Impact Analysis, Pleasant Harbor Marina and Golf
Resort
Technical Review and Recommendations 9
❑ data, calculations and assumptions used to derive each value
In particular the following components need better delineation.
Precipitation
Precipitation should be monitored on the Black Point Peninsula site for the
duration of a year (concurrent with other monitoring data collection).
Barbara Moore -Lewis
Comments for Scoping Meeting
October 28, 2009
Emailed to DCD November 3, 2009
Recharge
Groundwater levels should be monitored with continuous electronic logs in the
three monitoring wells, and reported for the duration of a year to assess the
range of groundwater level variation, and the recharge resulting from
precipitation events. Precipitation monitoring should coincide with groundwater
level monitoring periods. Precipitation should be used to evaluate the changes in
groundwater levels associated with precipitation events (i.e. recharge)
Evapotranspiration
Evapotranspiration calculations, and the data and assumptions used in those
calculations needs to be presented in report form.
Streamflow
Stream flow emitting from the lake on the eastern margin of the Peninsula, and
flowing to the east shoreline should be monitored to assess the rate of surface
water runoff from the Peninsula.
Lake Level
Monitor lake (located in the central -eastern portion of Black Point Peninsula)
level elevation over the period of a year concurrent with other monitoring data collected.
Thank you for the opportunity to comment on these important environmental issues.
Barbara Moore -Lewis
PO Box 303
3
Waterworks Consultants
4017 Willowbrook Lane
Bellingham, WA 98229
360-296-8084
Memo
To: Gerald Steel
From: Llyn Doremus
Date: July 17, 2009
Re: Technical review of: Water Supply and Groundwater Impact Analysis
Pleasant Harbor Marina and Golf Resort — November 20, 2008 (SDEIS)
Recommendations for Additional Hydrogeologic Testing at Black Point
Background
The Pleasant Harbor Marina and Golf Resort is planned for construction on the
Black Point Peninsula in Hood Canal. The peninsula is surrounded by saltwater
for more than 75% of it's shoreline. At least 15 wells are located along the Black
Point eastern and northern shorelines that are at risk of seawater intrusion.
Hood Canal is known to have a serious problem with depleted dissolved oxygen
content, which has resulted in what has been termed a "dead zone". The dead
zone creates conditions where a wide range of sea life that requires dissolved
oxygen in the waters of their environment cannot survive. The depleted oxygen
condition is known to result from enhanced activity of bacteria and algae that is
promoted by discharge of nutrients (nitrogen and phosphorus) dissolved in
surface and groundwater to Hood Canal. The two conditions: seawater
surrounding the Black Point Peninsula and the potential for seawater intrusion to
degrade water quality in shoreline wells, and extreme sensitivity of Hood Canal
biologic health to the release of nutrients generate a very delicately balanced
hydrogeologic environment in which the Resort is proposed for construction.
The Resort water supply for residential, commercial and irrigation purposes has
been proposed through a combination of rainwater capture, reuse, reclamation,
infiltration, and groundwater withdrawal processes. While the general scheme of
the supply system has been outlined in previous documents, the specifics of how
each of the components will operate has not yet been accurately defined. The
potential for negative impacts of the various supply system components on the
delicately balanced hydrogeologic environment is high. A sophisticated
understanding of the Black Point hydrogeologic system is mandated to assess
potential for degradation from the proposed water supply scheme to dissolved
oxygen levels in Hood Canal, to seawater intrusion into the Black Point aquifer,
and for the design, maintenance and operation of that system to function without
degrading the Black Point aquifer and Hood Canal.
These comments address the hydrogeologic characterization presented in the
report: Water Supply and Groundwater Impact Analysis, Pleasant Harbor Marina
and Golf Resort by Subsurface Group, LLC. November 20, 2008 (Report) with
respect to the information necessary for characterization, design and operation of
a water supply system that does not degrade the Black Point aquifer. The
accuracy and completeness of the Report assumptions, information and
conclusions are assessed, and recommendations for additional testing to fill in
the information gaps in the Report are listed.
Hydrogeologic System
Groundwater moves through the sediments and rock, which, along with the other
water moving through the system, defines the hydrolgeologic system of a specific
site. Sediment tends to form in layers, which can be visualized as a "layer cake"
type configuration. Sediments and rock layers with a large percentage of void
spaces typically transmit water more quickly, which is termed a high permeability
hydrogeologic unit. Sediment layers that are more dense, with tiny void spaces
are termed "low permeability" or "impermeable". Low permeability sediment
layers impede downward migration (infiltration) of groundwater, and tend to
accumulate water on their upper surface. This is normally how unconfined
aquifers form. The permeability of an aquifer is usually determined by
conducting a pump test. With the exception of the single pump test of the
American Campground well, and the marginal data generated from that test,
there is no data presented on the aquifer properties of the various hydrogeologic
units on the Black Point Peninsula.
RECOMMENDATION FOR ADDITIONAL TESTING
The Report describes results from a pump test conducted in the American
Campground well for 48 hours to assess the permeability and other aquifer
properties in the well vicinity. The data generated by the test was found to
be insufficient to assess the aquifer properties, because the drawdown in
Water Supply and Groundwater Impact Analysis, Pleasant Harbor Marina and Golf Resort
Technical Review and Recommendations 2
the monitoring wells was almost undetectable. Pump testing should be
conducted in all of the wells that are proposed for water supply purposes.
The pumping rate used should be equivalent to the rate at which water is
proposed for withdrawal for the water supply needs of the resort (at a
minimum 75 gallons per minute to provide the 121 acre feet annual use
projection), because of the likelihood that individual wells may be relied
upon for the full volume for the resort water demand when problems with
water level drawdown and seawater intrusion occur. The tests should be
run for sufficient duration (minimum 72 hours) to derive measurable
drawdown curve in at least one of the monitoring wells, so that reliable
aquifer properties can be calculated.
The direction of groundwater movement is defined by the groundwater gradient
Groundwater moves from locations of high water elevation level to low elevation
discharging eventually to lower -elevation surface water bodies. The groundwater
elevation pattern often mimics the ground surface topographic elevation pattern.
Downgradient (lower groundwater elevation) locations manifest the affects of
groundwater movement and withdrawal in higher elevation locations. It is
important to understand the directions of groundwater movement in order to
assess the magnitude and distribution of ground water level decreases
associated with groundwater withdrawal (pumping from wells). In particular,
reduction in the groundwater levels in shoreline areas increases the risk of
seawater intrusion into water supply wells.
The Report presents an interpretation of groundwater flow direction towards the
center of the peninsula and then to the east (discharging into Hood Canal). The
groundwater surface elevation contours are illustrated in Figure 4 of the Report,
and suggest that a groundwater high point (at MW -2) dominates groundwater
flow direction on the entire peninsula. That single data point (MW -2 water level
elevation) is disproportionally valued in interpreting the groundwater flow
directions.
RECOMMENDATION FOR ADDITIONAL TESTING
Groundwater levels should be measured in every accessible Black Point
Peninsula well on the same date, so that a groundwater elevation contour
level map can be constructed that is reliable for use in interpreting the
direction(s) of groundwater movement. A better understanding of the
direction of groundwater movement will support a better interpretation of the
groundwater withdrawal impacts to private wells on the Black Point
Peninsula and seawater intrusion risk.
Water Supply and Groundwater Impact Analysis, Pleasant Harbor Marina and Golf Resort
Technical Review and Recommendations 3
Diagrams of the Black Point Peninsula hydrogeologic system are presented in
the Report Figures 11, 12 and 13. Much of the site is covered with dense, low
permeability till. About one third of the site has additional sediments deposited
on top of the till that are higher in permeability and allow water to migrate more
quickly through them. Water that migrates downward through these higher
permeability sediments might slow down and accumulate in a "perched" aquifer
upon encountering the underlying low -permeability till. There is no evidence of
perched conditions at this site presented in the Report.
Basalt bedrock is shown in Figures 13 in wells located on the northern part of the
site. The contribution of groundwater flow transmitted through bedrock to the
Black Point aquifer is not well characterized in the Report, nor is the bedrock
permeability, or the hydraulic connection between bedrock and the overlying
unconsolidated sediments. With the exception of the single pump test of the
American Campground well, and the marginal data generated from that test,
there is no data presented on the aquifer properties of the bedrock or
unconsolidated sediment hydrogeologic units on the Black Point Peninsula, or on
the hydraulic continuity between unconsolidated sediment units and the bedrock
underlying them. Further pump testing (as previously described) is necessary to
better define aquifer properties of the hydrogeologic units and the hydraulic
continuity with bedrock on the site.
Water Budget
A water budget uses estimates or measurements of each component of the
hydrologic cycle to assess the entire movement of water through a specific
hydrologic system annually. For the purposes of characterizing the impact of the
proposed water management scheme on the the Black Point Peninsula aquifer
and hydrogeology, the water budget should encompass the entire Peninsula. To
prevent or at least minimize detrimental impacts it is essential that the
components of the water budget are defined as accurately as possible.
A typical equation for a water balance is as follows.
Ppt=E+Q+dS9+dSs
Where:
Ppt = annual precipitation
E = annual evaporation plus transpiration (evapotranspiration)
Q = stream flow or surface water runoff
dSs = the change in quantity that is stored as surface water for the year
(negative for a decrease in the water quantity in surface storage)
Water Supply and Groundwater Impact Analysis, Pleasant Harbor Marina and Golf Resort
Technical Review and Recommendations 4
dS9 = the change in the water quantity that is stored as groundwater for
the year (negative for a decrease in the groundwater storage, indicating a
drop in groundwater levels)
Surface Water Flow
Although surface water is not flowing onto the proposed Pleasant Harbor Resort
site, the quantity of water discharged from Black Point Peninsula as stream flow
impacts the water budget for the Peninsula. Accurate stream flow
measurements help reduce uncertainty in other portions of the hydrologic budget
that are more difficult to estimate. Stream flow emitting from the lake in the
eastem-central portion of Black Point Peninsula, as well as any other stream flow
on the Peninsula needs accurate assessment in order to calculate its contribution
to the water budget, and its influence on the other components of the budget.
RECOMMENDATION FOR ADDITIONAL TESTING (Q)
Stream flow emitting from the lake on the eastern -central margin of the
Peninsula, and flowing to the east shoreline should be monitored to assess
the rate of surface water runoff from the Peninsula.
Surface Water Storage
Surface water is typically stored in lakes and wetlands. To better understand the
changes in surface water storage that are ongoing under current conditions
(dSs), and that may be expected from the proposed use of kettles as water
storage facilities, the water stored in Lake (on the eastern margin of the
Peninsula) should be monitored for changes in lake elevation. It is likely that the
lake is in hydraulic continuity with groundwater, and receives groundwater
discharge. A better delineation of lake level variations, and their relationship to
precipitation quantities and timing, and groundwater levels will improve the
understanding of how groundwater moves through the Peninsula hydrogeologic
system.
RECOMMENDATION FOR ADDITIONAL TESTING (dSs)
Monitor lake level elevation over the period of a year (concurrent with other
monitoring data collected).
Precipitation
Precipitation provides water that supports the various water uses and hydrologic
components. Annual precipitation at this site is poorly understood because of the
variability in precipitation along the north south extent of Hood Canal, and the
lack of monitored data collected in the Black Point Peninsula or Brinnon vicinity.
Water Supply and Groundwater Impact Analysis, Pleasant Harbor Marina and Golf Resort
Technical Review and Recommendations 5
RECOMMENDATION FOR ADDITIONAL TESTING (Ppt)
Precipitation should be monitored on the Black Point Peninsula for an entire
year. In addition, the data available from the NOAA approved weather
station at location AS461 on the west side of Hwy. 101 across from
Pleasant Harbor should be analyzed. See Attachment 1 hereto.
Groundwater Storage
Groundwater that is stored in an aquifer is the amount of water that is added to
the aquifer over the course of the year (termed recharge) minus the amount
withdrawn or discharged from the aquifer. Recharge to an aquifer derives from
precipitation that infiltrates into the ground. Discharge from an aquifer typically
goes to stream flow (Q), or it may be pumped for water supply or irrigation
purposes, or, in this case, includes flow into Hood Canal to diminish salt water
intrusion into the fresh water supply. The difference between the amount
recharged and the amount discharged is the change in storage (dSg).
Quantification of recharge is an important factor in assessing the storage
changes in groundwater, as is quantification of the discharge.
Recharge of an aquifer results from vertical infiltration of precipitation that falls on
the ground surface overlying the aquifer. Aquifers are more rapidly recharged
when the sediment overlying the aquifer is of "high permeability" and when there
is high annual precipitation. Consider if the precipitation that infiltrates to
recharge the aquifer is half (50%), the standard assumption when data is not
available to calculate actual recharge rates. For this site the annual precipitation
rate is not well known, which makes the annual recharge rate even more difficult
to assess. Table 3 lists 55 inches for annual precipitation in Quilcene (the
closest site monitored). Half of this is 27 inches, or 2.3 feet. For this 220 acre
site, this provides an annual recharge of 504 acre feet (significantly less than the
783 acre feet claimed in the Report on page 17). The presence of low
permeability till will slow down groundwater infiltration, and likely reduce the rate
of groundwater recharge to the aquifer even further than estimated using these
assumptions.
There will be substantial additional evapotranspiration caused by the watering of
the golf course and other vegetation in the hot months of the year. This has not
been adequately considered.
RECOMMENDATION FOR ADDITIONAL TESTING (dSg)
Groundwater levels in the three monitoring wells (MW -1, MW -2 and MW -3)
should be monitored for at least one year, to determine the variation in
groundwater elevation. Precipitation should be monitored on the site for at
Water Supply and Groundwater Impact Analysis, Pleasant Harbor Marina and Golf Resort
Technical Review and Recommendations 6
least one year to determine the actual precipitation received annually
(concurrently with other monitoring data collected). Analyses of recharge
quantities and rates should be done using monitored data, and presented in
the calculation of the water budget for the site. A separate set of
calculations should be done assuming serious drought conditions — perhaps
an estimated 500 -year drought.
Quantification of groundwater discharge is calculated using measurements of
changes in groundwater elevation, stream flow measurements, pumped
quantities from the aquifer, and precipitation measurements. It is important to
delineate the groundwater flow direction and to delineate locations of
groundwater discharge, to more accurately assess the annual amount of
groundwater discharging from the aquifer. The change in groundwater storage
calculated amount (dSg) relies upon an accurate estimation of annual
groundwater discharge and its relative value with respect to the annual recharge
amount. Additionally, discharge of groundwater from beneath the proposed
resort to Hood Canal, that contains contaminated landscaping chemicals
(especially nitrate and phosphorus) poses a significant risk to the environmental
health of Hood Canal.
Evapotranspiration
The information presented in the Report on estimations of evapotranspiration
(24.1 or 24.2 inches per year), need to be presented with data, formulas, tables,
and assumptions used in those calculations, as part of the comprehensive water
budget estimation.
Summary of Recommendations for Additional Testing
To better understand the hydrogeologic response to the proposed water supply
management scheme in this relatively sensitive groundwater environment, each
of the components of the hydrologic cycle should be more accurately quantified.
In addition, the aquifer properties must be better defined to design a supply
system that does not overstress the aquifer. The following tests are
recommended in order to gather that information.
Aquifer properties
Aquifer testing — pump tests should be conducted for a minimum of 72 hours in
any wells that might be proposed for water supply purposes (American
Campground Well, Pleasant Tides Coop Well (Sam Boling Water System/Black
Point Water Company) and MW -2). Pump tests should be conducted for long
Water Supply and Groundwater Impact Analysis, Pleasant Harbor Marina and Golf Resort
Technical Review and Recommendations 7
enough to generate a measurable drawdown in at least two monitoring wells in
the vicinity. Pumping rate at the Pleasant Tides Coop Well should include the
300 gpm for existing water rights plus the proposed new withdrawal.
Pump testing at MW -2 should include installation of a monitoring well, at a
location that is as close as existing wells are to the eastern shoreline, in
line with the MW -2 well. Chloride testing of water pumped from the
aquifer should be done when the MW -2 is pump tested.
Pump testing at the Pleasant Times Coop Well should include monitoring
for water level drawdown and for chloride at the other Black Point Water
Company wells, the Babare well, the Tudor well and the other Pleasant
Harbor Beach Tract Owners wells.
Seawater intrusion
Chloride content in groundwater should be determined in samples collected from
wells pumped adjacent to the marine shoreline over the duration of the pump
tests. At a minimum one sample should be collected prior to initiation of
pumping, another after at least 12 hours of pumping and a third shortly before
pumping is stopped. More samples provide more confidence in the data
collected, and the interpretations derived from that data. Chloride concentrations
between 100 and 200 mg/I indicate wells at moderate risk for seawater intrusion,
with 200 mg/I being the trigger for high risk, according to Island County's
Seawater Intrusion Policy (a copy is included with these comments as
Attachment 2).
Groundwater movement
Groundwater levels should be measured in every accessible well on the same
date, so that a groundwater elevation contour level map can be constructed that
is reliable for interpreting the direction(s) of groundwater movement. A better
understanding of the direction of groundwater movement will support a better
interpretation of the groundwater withdrawal impacts to private wells on the Black
Point Peninsula and seawater intrusion risk.
Water Budget
The presentation of the water budget in the Report makes it impossible to assess
the individual components of the water budget, their relationship to each other,
and what data was used to derive them. A comprehensive explanation of the
water balance calculations must be provided. This should include:
• water budget equation used
• Values for each component the equation
Water Supply and Groundwater Impact Analysis, Pleasant Harbor Marina and Golf Resort
Technical Review and Recommendations 8
• data, calculations and assumptions used to derive each value
In particular the following components need better delineation.
Precipitation
Precipitation should be monitored on the Black Point Peninsula site for the
duration of a year (concurrent with other monitoring data collection).
Recharge
Groundwater levels should be monitored with continuous electronic logs in the
three monitoring wells, and reported for the duration of a year to assess the
range of groundwater level variation, and the recharge resulting from
precipitation events. Precipitation monitoring should coincide with groundwater
level monitoring periods. Precipitation should be used to evaluate the changes in
groundwater levels associated with precipitation events (i.e. recharge)
Evapotranspiration
Evapotranspiration calculations, and the data and assumptions used in those
calculations needs to be presented in report form.
Streamflow
Stream flow emitting from the lake on the eastern margin of the Peninsula, and
flowing to the east shoreline should be monitored to assess the rate of surface
water runoff from the Peninsula.
Lake Level
Monitor lake (located in the central -eastern portion of Black Point Peninsula)
level elevation over the period of a year concurrent with other monitoring data
collected.
Water Supply and Groundwater Impact Analysis, Pleasant Harbor Marina and Golf Resort
Technical Review and Recommendations 9
SEAWATER INTRUSION TOPIC PAPER (Final)
Approved by WRAC: 2/3/05, Approved by BOCC 3/16/05
Island County / WRIA 6 Watershed Planning Process
1 I Seawater Intrusion
2
3 1.0 Introduction
4
5 Saltwater intrusion is the movement of saline water into a freshwater aquifer. Where the source of
6 this saline water is marine water, this process is known as seawater intrusion. The marine / saline
7 waters of the Puget Sound surround Island County and as a result, all of the aquifers in the county
8 that extend below sea level are at risk for seawater intrusion. The high mineral content (primarily
9 salts) of marine waters causes these waters to be unsuitable for many uses, including human
10 consumption. Thus if intrusion problems become extreme, they can render an aquifer and any wells
11 that are completed in that aquifer unusable for most purposes.
12
13 As a result of the above concerns, Island County has historically taken a leading role in
14 understanding and protecting its groundwater resources. The adoption of the Island County /
15 Washington State Department of Health - Salt Water Intrusion Policy in 1989 represented a
16 significant step toward this goal of protecting our aquifers. Fifteen years later, limitations of this
17 policy have become evident, and significant new scientific information has become available. This
18 topic paper provides an overview of current science and regulations, explores management options,
19 and makes recommendations for future resource protection efforts.
20
21
22 1.1 Groundwater and Seawater Intrusion
23
24 When an aquifer is in hydraulic connection with saline / marine waters such as the Puget Sound,
25 portions of the aquifer may contain saltwater while other portions contain fresh water. Freshwater is
26 slightly less dense (lighter) than saltwater, and as a result tends to float on top of the saltwater when
27 both fluids are present in an aquifer. There is a relationship based on the density difference between
28 saltwater and freshwater that can be used to estimate the depth to saltwater based on the thickness of
29 the freshwater zone above sea level. The relationship is known as the Ghyben-Herzberg relation
30 (Figure 1). The boundary between the freshwater and the saltwater zones is not sharp but instead is
31 a gradual change over a finite distance, and is known as the zone of diffusion or the zone of mixing.
32
33 In Island County, all of our groundwater originates as
34 recharge from precipitation. This recharge creates a
35 pressure distribution within our aquifers that tends to
36 be highest in the center of the islands, lowering as you
37 approach the shorelines. The pressure distribution
38 leads to a flow in the aquifers that is vertically
39 downward near the center of the islands, then flowing
40 radially outward toward the shore (Figure 2).
41
42 Two mixing processes (diffusion and dispersion)
43 continuously move saltwater into the freshwater zone.
44 Flow in the freshwater zone sweeps this mixed -
Figure 1.
Editor: Doug Kelly C:\My Documents\Word\WatershedPlanning\Seawater Intrusion (Final).doc
1.
1
2
3
4
5
6
7
SEAWATER INTRUSION TOPIC PAPER (Final)
Approved by WRAC: 2/3/05, Approved by $OCC 3/16/05
Island County / WRIA 6 Watershed Planning Process
Figure 2.
brackish water toward the shoreline where it discharges at submarine seeps. The processes of
recharge, flow, mixing, and discharge all work in unison to hold the interface position in a roughly
stationary position. A change to one or more of these processes can result in a change in the position
of the interface, an inland movement of the interface boundary known as lateral intrusion.
8 When a well is pumped, water levels in the vicinity of
9 the well are lowered, creating a drawdown cone
10 (Figure 3). If a saltwater zone exists in the aquifer
11 beneath the well, the saltwater will rise up toward the
12 well screen. This rising up of saltwater is known as
13 upconing and is the second type of seawater intrusion.
14
15 The previous figures describe various characteristics
16 of groundwater in coastal marine environments, from
17 the perspective of a single aquifer. In reality the
18 groundwater system in Island County is made up of
19 multiple layers of unconsolidated sand and gravel,
Figure 3.
Editor: Doug Kelly C:\My Documents\Word\WatershedPlanning\Seawater Intrusion (Final).doc
2.
David W. Johnson
From: r_swarts [ravens rest@embargmail. com]
Sent: Thursday, November 19, 2009 4:51 PM
To: David W. Johnson
Subject: Black Point Resort Supplemental EIS
To: David Wayne Johnson, Project Lead Planner
dwjohnson co.iefferson.wa.us
Jefferson County Department of Community Development
Thank you for the opportunity to comment on the scoping process now taking place.
Statesman has used different numbers in different planning documents for the amount of
water that will be needed for the proposed resort. However, none of the planning
documents defines the aquifer from which the water will be taken. It appears that no one
has defined this aquifer. There are already wells with existing water rights of 5000 gallons
per day. Before any water can be claimed by Statesman, there must be a scientific
definition of the capacity of the entire aquifer, minus existing water rights. Then we can
begin to define what water Statesman might be able to use.
To define the aquifer, various tests need to be done for the next year. Wells on Black
Point need to be tested at different times of the year for their capacity and, also, for salt
water intrusion. Detailed recommendations by Waterworks Consultants have been
submitted to you during this scoping process and are on the Brinnon Group website.
support those testing recommendations.
Sincerely,
Robert and Karen Swarts
M5bn&L-
COPH-. Al
CL_ • 1.)C%.;> %111-2-1011
To: Philip Morley NOV12 7009
From: Todd Wexman
to November 2009 JEFFERSON COUNTY
RE: Destination Resorts et al COMMISSIONERS
I've attached a document I put together with the help of co-worker Andrea Mitchell, who
forwarded much relevant documentary evidence to me.
The Crook County vote to outlaw MPRs was, first and foremost, about conserving water
resources ---and, secondarily, about maintaining a balanced community. Four thousand
houses in the destination resort category had already been approved. When built and
occupied, the newly entrenched constituency would constitute fully 25% of the County's
total population.
I'm reviewing documents going back to 1995, when residents of Brinnon first met to
discuss the future of their community. I spoke last Friday with persons who attended
those meetings. They remember "the maintenance of the area's rural character" as a
dominant theme. Among other things, the 1995 Brinnon Community Plan mentions "inns
and support services for recreational tourism."
Six years later, written documents talk of a Black Point MPR as "significantly different
and smaller in scale than the Port Ludlow MPR in that it is less structured towards
development of permanent residential accommodations and more so towards providing
recreational opportunities and support services for the traveling public that will benefit
local residents."
You must by now realize that county commissioners sat on their hands until Statesman
came onto the scene. This, you must admit, is not the way things should be.
I support the efforts of the Statesman Group to construct a recreational development
at Pleasant Harbor in Brinnon, Washington. I was a member of a dedicated team
comprised of about 30 Brinnon residents over a period of 12 years who worked on
the Brinnon Sub Area Plan. We considered many options we knew would comply
with the Growth Management Act and Jefferson County codes in all aspects of our
plan, including the Brinnon Master Planned Resort. We were particularly concerned
about designating the use of the Pleasant Harbor and Black Point area in a way that
would be good for the environment. Over the years we held public meetings where
many people had the opportunity to voice their opinions for or against our plan. The
Jefferson County Board of Commissioners approved the plan and Brinnon residents
were optimistic about the future of their community. The county has since
experienced setbacks by unsubstantiated appeals from a small group of opponents,
which has cost the taxpayers money that could have benefited so many in our county.
They have only to read and understand the proposed development that has been so
carefully planned by the Statesman Group and know that the majority of the Brinnon
community is in favor of allowing such a project to go forward. Jefferson County
cannot afford to delay approval of this well planned project that will improve, protect
and enhance our environment.
Dalila Dowd
P. O. Box 142
Brinnon, WA 98320
I am a Brinnon resident and Pleasant Harbor is the area where I prefer
to do most of my recreational activities. I am concerned that the runoff
from the un -maintained old NACO West Campground during heavy
rainstorms brings silt and sediment down into Pleasant Harbor; the
color of the harbor changes. Brown colored water can be seen entering
the southeast corner of the harbor, especially in the beginning of the
heavy rains usually in early November. The water originates on the
property of the proposed golf resort and crosses under Black Point
Road and continues down into the harbor. Most of it goes through the
Black Point Road culverts at .139 mile, .332 mile and .541 mile.
I am confident, having read all of the material and having attended all
of the meetings, that the proposed development by the Statesman Group
will address the runoff issues and Pleasant Harbor will be a cleaner
recreational body of water. For this reason, I am in favor of the
development and would like to see it done expediently.
John Dowd
P. O. Box 142
Brinnon, WA 98320
October 30 2009
Brinnon Resort Proposal
Comments
This project has been inappropriately scaled and sited from its
inception. The Black Point Peninsula is heavily populated and not an
appropriate site for a resort of the proposed scope.
The amount of impervious surface proposed is completely ridiculous
for the area, and the scope of the mitigating structures to offset the
impacts of the project are in themselves outlandishly oversized. The
level of noise and damage to the highways and disruption to the
community for the proposed excavation phase would be seriously
disruptive to the community.
The glare and sheer size of the project far exceeds anything
appropriate for Brinnon. The idea of using air transport to service this
project is abhorrent. We live in Brinnon for the peace and tranquility.
Air traffic on a regular basis along the Canal would cause noise
pollution of the worst sort and would defile our property values.
The aquifers for our dry rocky peninsulas are known to be finite and
finicky. Salt water intrusion has already occurred. Why would the
County invite the litigation that is could result from water rights and
runoff property damage?
Would any local residents or travelers be welcome to stop in for a
round of golf or to participate in the amenities of the proposed report?
The fact that financing for this behemoth has been glaringly scarce IS
related to environmental review. A project that is not financially viable
could create a vast hideous dangerous destructive eyesore on Black
Point. Excavation left, or systems part-way in, or unrented condos.
Life -time residents with water and drainage systems compromised: is
this an environmentally viable concept?
If the developers can press through a successful environmental review,
then the County will reap fees and the resort can be shopped
internationally as a viable project. This would be unconscionable.
Ample acreage is available in other parts of the County that might be
more appropriately suited for a resort development. Black Point in
Brinnon is not the place.
Celia Pedersen
P.O. Box 547
Brinnon WA
David W. Johnson
From: Person, Randy (PARKS) [Randy.Person @PARKS.WA. GOV]
Sent: Friday, October 30, 2009 3:17 PM
To: David W. Johnson
Subject: Pleasant Harbor/Brinnon Resort Scoping Comments
Thank you for the recent notice of the scoping phase of the Supplemental Environmental Impact Statement (SETS) for the
Brinnon Master Planned Resort. We find that some of the concerns in our response to the initial EIS have been
adequately covered, while others remain. The SEIS needs to cover the following:
The original EIS claimed that the development would "take some pressure off' the shellfish beach at Dosewallips State
Park. Our comment letter refuted that claim, but it is still there in the Final EIS (FEIS). We still find no evidence that the
proposed development will open new beaches to shellfish harvest. In fact, they will be closing much of their shoreline to
access. Since those who purchase in the planned resort presumably will do so partly because of natural resource
opportunities in the area, we must plan on a high percentage of resort visitors seeking public shellfishing. The most
convenient location for resort visitors will be at Dosewallips State Park. The SEIS needs to provide an estimate of the
added impacts to the shellfish resource and the park itself that will result from the increased use.
Very little is stated about the two public shoreline facilities in the project area itself: Pleasant Harbor State Park and the
Washington Department of Fish and Wildlife (WDFW) boat launch, both on Pleasant Harbor. The State Park is noted as a
moorage dock facility, but it also includes upland vehicular access and a newly installed public restroom facility. Currently,
park visitors may turn off of Highway 101 from either direction, meet friends arriving at the park by boat, and leave in
either direction on Highway 101. It's hard to tell from the scale of the EIS maps, but it appears that the park upland
ownership is not shown, access to it is cut off, and options for travel on Highway 101 are curtailed. The current level of
public access to this public property must be maintained.
The WDFW boat launch also currently has acceptable public access, which must be maintained. In addition, the current
facility is designed to accommodate use that does not include the intensive resort development proposed. If even as little
as 5% of the resort visitors bring a boat to launch to take advantage of the easy access to Hood Canal, it would
overwhelm the present facility. A thorough discussion of the impacts of trailered boats belonging to resort visitors is
needed. Substantial improvements to the existing launch facility may be required of the development to accommodate the
increased use at the launch.
Thank you for the opportunity to comment on the scoping of the SETS. Please respond or inquire to
local.government(aDparks.wa.gov. Different staff members will likely need to respond to different questions. This e-mail
address is monitored regularly, and using it will help assure that you receive a timely response.
Randy Person, Parks Planner
Washington State Parks and Recreation Commission
Phone: 360-902-8655
Fax: 360-586-0207
e-mail randypersonCo)parks.wa.aov
Snail mail PO Box 42650, Olympia, WA 98504
Street 1111 Israel Road SW, Olympia, WA 98504