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Home My WebLink About003January 14, 2010 (REVISED) Hydrogeologic Memo Part II: Aquifer test review and monitoring requirements pertaining to Water Right Application G2-30436 This memo supersedes the Hydrogeologic Memo dated December.4.2009 To: Phil Crane (Ecology) From: John Pearch, L.H.G ( (r DffiM"*--*-h.Ilit As required by RCW 90.44, all water right applications approved for groundwater withdrawals require a positive determination that: l) water is available in the proposed wells, 2) the proposed wells do not impair existing rights or nearby wells, 3) the proposed wells do not impact surface water and 4) the proposed wells are not a detriment to the public welfare. Results of the aquifer testing and chloride sampling analysis in Part I (Pearch, Hydrogeologic Memo Part I, 2010) allows Ecology to move forward and recommend approval of Water Right Application G2- 30436. Ecology requires Pleasant Harbor to conduct groundwater monitoring on proposed production and monitoring wells to ensure saltwater intrusion does not occur in Pleasant Harbor's wells as well as coastal domestic wells. This Hydrogeologic Memo (Part II) identifies the validity of Pleasant Harbor's aquifer test and also gives specific requirements for groundwater monitoring and testing in Pleasant Harbor wells. Additional monitoring recommendations are given for monitoring coastal domestic wells in Pearch, Hydrogeologic Memo Part I, "Chloride sampling in coastal domestic wells on the Black Point peninsula, Jefferson County, Washington" (2010). This memo gives specific recommendations intended for the draft Report of Examination for Water Right Application G2-30436. IvtATJHEW of Ecology t Pearch, Hydrogeologic Memo Part II: Aquifer test review and monitoring requirements Pleasant Harbor Well Construction The ACG Well is located in the central portion of the Black Point Peninsula with Hood Canal surrounding it on three sides (See Figure 2).The ACG well was completed in July, 1972 to a total depth of 271feet, approximately 2,100 feet inland from the southeastern shoreline of the Peninsula. The land surface elevation at the well head is 145 feet above mean sea level (MSL). According to Subsurface Group LLC (SSG, 2008), the well is screened in the Pre-Vashon glacial deposit (Qu) from 2I5 to 270 feet below ground surface (bgs) (-70 ft to -125 ft MSL). In May, 2008 the static water level in the well was 136.1 feet bgs (8.74 ft MSL) (Subsurface Group, 2008). Two additional production wells have yet to be drilled. One of these wells citing was planned on the southeastern portion of the Pleasant Harbor propert), approximately 340 feet from the southern shoreline of the Hood Canal. Based on the analysis of PGG (2009) and Pearch Part I (2010), it is recommended that the two new proposed production wells be located in SW 7+ SE % Section 15, Township 25 North, Range 2 West W.M. Groundwater Monitoring Pleasant Harbor has six existing monitoring wells identified as MW-2, MW-4, MW-5, MW-6, VWP-l and VWP-3. Both VWP-1 and WVP-3 are geotechnical soil borings with vibrating wire piezometers (VWP) installed in them to measure groundwater. All wells were constructed to monitor groundwater and are completed to a minimum depth of 10 feet below the water table (within the Sea Level Aquifer). VWP-1, MW-2, VWP-3 wells were used to monitor groundwater continuously with dataloggers from June, 2006 to May, 2009. MW-4 and MW-5 were only used to monitor groundwater levels during the aquifer tests conducted from May 19-20, 2008. Construction details of all monitoring wells are listed in Table L Pleasant Harbor proposes to construct two additional monitoring wells into the Sea Level Aquifer near the ACG Well (see Figure 1). Coastal domestic wells are recommended to monitor based on Pearch, Hydrogeologic Memo Part I (2010). Well No.Latitude vwP-1 MW-2 47' 39'2L.73" .122' 55' 23.18" 47 " 38',49.51" L22" 54', 43.74" 47'39'06.86" 47'.39',07.39" 47' 39', 07.45" 47 " 39', t2,94" 47' 39'24.09" 47'39',06.20" Well Depth (ft btoc) (in) 160.5 6" (w/ vwp) t70 2" Well Head Well Diam Elevation (ft msl) Screen Depth SWL msl Date of SWL no scree n (vwp 153.47 at 175 ft) t64.46 760-t70 15.20 27.64 VWP-3 MW.4 MW.5 MW.6 MW-7 MW-8 ACG well . no screen (vwp L22. ss, 02.97" 176.5 6" (w/ vwp) ,rr.ru ,.* a ,.ao r,) 722" 54',46.37" 181 6" 145.95 176-181 122" 54'53.88" 229 6" 208.89 225-230 122'55'08.57" 2L8 2" 203.95 208-218 122" 54'55.38" >>proposed locations TPD no well drilled yet 122" 55' 12.66" >>proposed locations TPD no well drilled yet 47 " 39'06.78" L22" 54',46.56" 277 8"lM.82 10.5 8.73 8.00 8.99 255-270 8.73 5l2t/200873:L3 5/2t/200873:tL s/2L12008I3:1s sl2!2008l3os sl2t/2008L3:ts s/2U2@8L3:2o 2008 13:00 Table 1: Pleasant Harbor Monitoring wells and existing production well location and construction information. Ll1.4120L0 Page 2 Pearch, Hydrogeologic Memo Part II: Aquifer test review and monitoring requirements According to SSG (additional monitoring data provided in October,2009), groundwater levels were measured from June, 2007 to May, 2009. Based on data collected from MW-4, MW-5, and MW-6 monitoring wells, water levels in the interior of the Peninsula were approximately 8 to 9 feet MSL, within the Sea Level Aquifer. These monitoring wells were measured only during the aquifer test on the ACG well. The ACG well is screened in the Sea Level aquifer. SSG (2008) also identifies a small groundwater mound in a 10-foot contour line beneath kettles B and C. SSG interprets the data to show that the aquifer receives limited recharge through infiltration of precipitation through the kettles. These water level contours were based on water levels taken from wells MW-6 and MW-3. However, MW-1 and MW-2 monitoring wells show water levels that were higher and not as representative of water levels near the ACG well. The MW-2 had the highest measured water level throughout the Black Point peninsula (from 27 to 29 ft MSL). SSG asserts that the high groundwater heads measured in MW-2 well may be related to the presence of shallower bedrock on the east side of the peninsula. This monitoring well site has also been proposed to drill a production well site. However, no aquifer test was conducted for this area to identify the question of water availability and impairment on neighboring wells. Therefore, this production well site should be moved to the area near the ACG well that is more representative of the Sea Level aquifer and aquifer test. Long term monitoring is required in all Pleasant Harbor monitoring and production wells. Pleasant Harbor have already established a monitoring plan that will monitor for saltwater intrusion in specific Pleasant Harbor wells and nearby domestic wells. Ecology have provided additional requirements for measuring groundwater levels and sampling water quality parameters in Pleasant Harbor's monitoring and production wells (see below for more details). 1,/1,412010 Page 3 LEGEND * Pleasant Harbor Production \ ,bllfieu location (ACG l &ll) A, Pleasant Harbor Moniloring t ,blls Recommended Coastal Monitoring wells (with Well Tag No.) 15 Section Number (within Township 25 North, Range 2 \ rbst) I Statesman - Pleasanl Harbor properly Pearch, Hydrogeologic Memo Part II: Aquifer test review and monitoring requirements Miles0 0.125 0.25 0.5 0,75 Figure l: Pleasant Harbor production well and monitoring well locations. MW-7 and MW-8 are only estimated locations. Recommended coastal domestic wells are located with a GPS. See Pearch, Hydrogeologic Memo I, 2010 for more details. Base map from U.S. Geologic Survey- Brinnon, Washington Quadrangle, l:24,000 Contour Interval 40 feet (NGVD 29) (Map photo revised 1985) ) L/t4/20L0 Page 4 Pearch, Hydrogeologic Memo Part II: Aquifer test review and monitoring requirements Pleasant Harbor Aquifer Test Pleasant Harbor conducted an aquifer test from May l9-20, 2008 on the American Campground (ACG) well (Subsurface Group (SSG), 2008). The ACG well was pumped at a constant rate of 65 gpm for a period of 24 hours. Groundwater levels were monitored in all of the onsite monitoring wells by hand and datalogger methods. According to Subsurface Group, 2008, measured drawdown in the pumping well was about 8 feet. Drawdown at a radial distance of 50 feet from the pumping well was only about 0.46 feet. Water levels were recorded in a second monitoring well (MW-5) at 600 feet from the pumping well. However, no drawdown was observed in the MW-5 well. Analysis conducted by SSG and additional analysis by Pacific Groundwater Group (PGG) have different calculated results for transmissivity but show similar conclusions that the aquifer is unconfined (SSG, 2008 and PGG, 2009). According to SSG, it was intended to run the constant rate pump test for 72 hours. However, due to problems with the pump occurring at approximately 24 hours, the test had to be stopped. Ecology agrees with PGG that the pump test should have been conducted longer but was sufficient enough since there were signs of delayed yield,l an indication of an unconfined aquifer (see Figure 2). Pleasant Harbor have agreed to conduct a longer constant rate test on all new production well (up to 72 hours) to identify the pump capacity for each well. However, the aquifer test along with PGG's groundwater flow model is adequate for the impairment analysis. In addition, a preapproved Aquifer Testing Plan must be submitted to Ecology to verify sampling procedures during the aquifer test (see permit provisions listed below). Regardless of PGG' model analysis for pumping continuously at the proposed 300 gpm, Pleasant Harbor (SSG, 2009) has offered that their wells will only pump up to 300 gpm (peak demand) at short periods of time during construction. The groundwater demand for the entire resort during construction, both potable and irrigation, is calculated at 150 gallons per minute on an average annual basis, with a range over the year of a low of 50 gallons per minute to a peak of 200 gallons per minute average monthly. For the purposes of the impairment analysis, Pleasant Harbor will reduce this demand on the system by 105 gpm. Therefore, a permit provision is also included for Pleasant Harbor to pump wells up to 300 gpm only during the construction phase and reduce well production to 195 gpm after construction of the resort. This Groundwater Right also relies on Surface Water Right 52-30437 (i.e. with proposed surface water impoundments in kettles); if a sea water intrusion occurs as a result of groundwater withdrawals. lBor.d on Kruseman & de Ridder (1991), delayed yield is shown when the time-drawdown data curves on log-log graph show a typical S-shape, from which three distinct segments: a steep early-time segment, a flat intermediate-time segment, and a relatively steep late-time segment. The Theis method can be applied to early-time segment of the time-drawdown curve, provided that the data from the monitoring wells near the pumping well are used because the drawdown in the distant monitoring wells during this period will often be too small to be measured. 7/74/2010 Page 5 Pearch, Hydrogeologic Memo Part II: Aquifer test review and monitoring requirements 0.1 I I I I I -E L- ! I I 0.4 0,5 0 10 r00 Tirne Since Purnping (l\dinutes) 1000 r0000 0,0 ,20 0.3 u 0"tu- o f, I Figure 2: lnterpretation of Drawdown Data in MW-4,50 feet from the ACG pumping well (from PGG,2009). PGG's Groundwater Flow Model During a meeting held on May 21,2009, Ecology and Pleasant Harbor agreed to have PGG develop a groundwater flow model to improve the estimation of aquifer transmissivity for the Black Point peninsula and to estimate distant drawdown from the proposed Pleasant Harbor groundwater withdrawal on an annual basis. The drawdown analysis also provided predictions of groundwater under pumping conditions and the potential for saltwater intrusion between the coastline and the proposed pumping center. Ecology identified monitoring requirements specific to sea water intrusion, regardless of the predictions made by PGG's model. Groundwater flow models can be useful for developing an understanding of the hydrogeology of an area. However, the predictions made are only as accurate as the assumptions and simplifications that go into the model. In the case of PGG's Gflow analytical element model there are a number of assumptions that makes this model limited but is suited for the predicting hydrogeologic conditions on the Black Point peninsula. The limitations to PGG's analytical model include: ) t/L412070 Page 6 Pearch, Hydrogeologic Memo Part [I: Aquifer test review and monitoring requirements The model could not be calibrated using SSG's calculated transmissivity (14,000 ft2lday). Therefore, PGG had to estimate transmissivity in order to match the targeted heads in MW4 and MW-l monitoring wells. The model also does not accurately identify the bottom of the aquifer in order to fully evaluate the potential for seawater intrusion. Therefore, without knowing the aquifer bottom the model could not accurately predict whether the freshwater head will be sufficient to exclude the saltwater wedge. The ACG well is the deepest well in the area and penetrated to an elevation of approximately -l 15 feet MSL without encountering bedrock or deep low permeability unit. However, PGG identifies that the saltwater wedge cannot proceed inland beyond locations where freshwater heads are high enough to displace the saltwater interface below the aquifer bottom. The model did not include water levels from MW-2 (i.e.,27 ft msl) that are much higher than water levels representative near the ACG well. The higher water level observed at the MW-2 well location is most likely due to shallow bedrock in this area, which PGG simulated in Scenario B of the model. a a a J Ecology and Pleasant Harbor agreed with PGG during the meeting held in May, 2009, that the model would be run with different scenarios that would included the maximum instantaneous pumping rate (300 gpm) as well as the annual average pumping rate (157 gpm). The maximum withdrawal was simulated in the model as an expedient means to evaluate seasonal pumping impacts. PGG also ran a hybrid steady state/transient simulation which represented year-round pumping at the annual average rate of 157 gpm plus an additional 143 gpm (total 300 gpm) pumped over three months during the summer, when saltwater intrusion is most prone to occur. Scenarios A and B were calibrated by varying the aquifer conductivity (K) until the target calibration head of 10 feet MSL was matched. Scenario C was calibrated by gradually increasing both aquifer K and groundwater inflow from the prescribed flux boundary until both calibration heads were matched. The values of aquifer T shown above were calculated by multiplying aquifer K by saturated thickness in the middle of the Peninsula. Scenario D employed a fixed T value of 14,000 ft2/d for general consistency with SSG's late-time aquifer test T estimates, and was calibrated solely by varying the groundwater inflow from the prescribed flux boundary until the head target near this boundary was matched. Scenarios A through C showed good agreement with the calibration targets summarized in PGG report. However, PGG could not calibrate the model to Scenario D, as predicted heads in the middle of the peninsula were too low (3.6 as opposed to 6.0 feet above mean sea level). PGG suggests that the transmissivity value of 14,000 ft2tday is likely too high to sustain sufficient mounding in the interior of the peninsula. L/L4/zoLO PageT Pearch, Hydrogeologic Memo Part II: Aquifer test review and monitoring requirements Modeling Conclusions PGG's model results suggest that the saltwater intrusion has the lowest likelihood of occumence if pumping is held constant year-round (i.e. onsite storage is used to eliminate significant seasonal variations) and pumping is distributed over SW % SE % Section 15, Township 25 North, Range 2 West W.M. With year-round pumping distributed onsite within this quarter section, model predictions suggest that lateral intrusion to the pumping center could be avoided as long as the aquifer bottom occurs above -200 to -225 feet msl. Alternatively, if pumping is concentrated at the ACG Well site and is allowed to vary seasonally up to 300 gpm for several months at a time, conditions are marginal for avoiding saltwater intrusion. Pleasant Harbor has agreed to conduct groundwater monitoring from the eight monitoring well locations and from production wells. All of these wells will be corelated with the ongoing Neighborhood Monitoring network on the coast (see Pearch, Hydrogelogic Memo Part I, 2010). Regardless of the limitations to the model, Ecology agrees that the model is only a predictive tool for simulating drawdown in the aquifer and for evaluating the potential for seawater intrusion. However, the following is what makes this model valid: l) The model incorporated the entire Black Point Peninsula approximately 710 acres (1.1 m''; *hi"h is well within the accuracy of analytical element model (Gflow software- Haitjema,2007). 2) There are no streams subject to an instream flow rule on the Black Point Peninsula. Most all groundwater discharges to marine waters of the Hood Canal. 3) As many as 30 well logs (from Ecology well log database) were used to estimate the water balance for the Peninsula. Pleasant Tides Water Coop and Black Point Commercial Power water systems were also included in the water balance. 4) PGG performed a preliminary water balance, estimating precipitation recharge at approximately 2,230 acre feet per year (afy) over the entire 710 acre-peninsula and 785 afy over the 250-acre project site on a recharge rate of 37 .7 in/yr. Out of the total groundwater inflow of 2,230 afy, current groundwater withdrawals were estimated to be on the order of 47 afy (about 2 percent ofthe total recharge). This water balanced used the same algorithm as developed in the USGS Deep Percolation Model (DPM). 5) Site specific bedrock geology was applied to the model (i.e., no flow bedrock boundaries towards the east side of the peninsula to represent shallow bedrock). 6) The model represented an unconfined aquifer with uniform hydraulic conductivity and a base elevation of -100 feet mean sea level (msl). 7) The model was calibrated to the heads observed in the middle of the peninsula - specifically heads of about 10 feet NAVD88 near wells MW-3 and MW-4 (SSG, 2008). The target head value for this area was adjusted to 6 feet relative to msl (mean sea level is approximately 4.1 feet NGVD). In addition, two versions of the model were also calibrated to a higher head observed along the western edge ofthe peninsula, (15 feet NAVD88 in Well MW-1). This higher head is presumably due to "mountain front 1./L4lZOLO Page B Pearch, Hydrogeologic Memo Part II: Aquifer test review and monitoring requirements recharge", and was modeled by simulating groundwater inflow along the prescribed flux boundary. Alternatively, the higher head could be due to geologic conditions underlying the bottom of the monitoring well. 8) As mentioned above, the saltwater wedge cannot proceed inland beyond locations where freshwater heads are high enough to displace the saltwater interface below the aquifer bottom. The saltwater interface elevation is typically estimated with the Ghyben- Herzberg approximation based on the density of saltwater. While a l:40 ratio between the freshwater head (above sea level) and the saltwater interface (below sea level) is typically assumed, a ratio of 1:50 was more appropriately applied to the model. This ratio was changed to reflect slightly less saline water in the Hood Canal. 9) The model employed a feature included in Gflow to simulate the saltwater interface. Gflow assumes that the bottom of the freshwater lens (above the saltwater wedge) represents the bottom of the aquifer. The presence of a saltwater wedge therefore limits the thickness available for freshwater flow. This correction provides more accurate prediction ofheads along the coast. l0) The four model scenarios were developed to bracket existing hydrogeologic understanding and uncertainties about the groundwater flow system. These four versions of the model were generated to provide a range of "hydrogeologic scenarios" consistent with available understanding of the groundwater flow system. Conclusions Based on the above information, Ecology concludes that: l) Water is available for the existing and proposed production wells 2) The proposed wells will not impact surface water. 3) The proposed wells will not be a detriment to the public welfare. 4) There should be no impairment to nearby wells as long as the withdrawals do not exceed 300 gpm (Qi) during the construction phase. After construction, reduction in Qi to 195 gpm of groundwater withdrawals must be implemented. This water right approval is based on agreement from Pleasant Harbor who plans monitor groundwater from existing and new monitoring wells. 1./1.4/20L0 Page 9 Pearch, Hydrogeologic Memo Part II: Aquifer test review and monitoring requirements References Kruseman, G.P. and N.A. de Ridder, N.A., 1991, Analysis and Evaluation of Pumping Test Data, Second Edition, Publication 4T,International Institute for Land Reclamation and Improvement Pearch, J. November,2010, Hydrogeologic Memo Part I: Chloride Sampling in Domestic Wells on the Black Point Peninsula, Jefferson County, Washington Pacific Groundwater Group (PGG), June 4, 2009, Technical memorandum, Pleasant Harbor Modeling Analysis, To Phil Crane, Ecology;From: Peter Schwartzman, PGG Subsurface Group, LLC, December 17, 2008, Water Supply and Groundwater Impact Analysis, Pleasant Harbor Marina and Golf Resort, Brinnon, Washington, Prepared for Statesman Group, SDEIS Groundwater vl -4. Subsurface Group, LLC, October 20,2009, RE: Response to Pacific Groundwater Group June 4, 2009 Technical Memorandum, Memorandum to Tom McDonald, from Scott Bender Washington State Department of Health, August, 2001, Water System Design Manual, Appendix E, Recommended Pumping Test Procedures. ) LlL4/2070 Page 10 Pearch, Hydrogeologic Memo Part II: Aquifer test review and monitoring requirements Based on Pearch's analvsis in the Hvdrogeologic Report Part I and the above analvsis. Ecolosv finds the mitieation proposal to be sufficient to offset impacts and accepts Pleasant Harbors proposal with the following recommendations and requirements: The use of the requested allocation of water for municipal and irrigation purposes is consistent with the public interest. However, because of the risks of seawater intrusion, conditions will be placed on this water right. It is in the public interest to prevent seawater intrusion, not to treat it after it occurs. Thus, simple chloride monitoring of existing wells along the coastline and within Pleasant Harbor property is adequate. While seawater intrusion of existing coastal wells is of greatest concern, the aquifer below these wells must also be protected. The cause and true extent of any declines on the Black Point peninsula is uncertain because of the lack of long-term, continuous water-level data. However, considering that coastal wells show no sign of extensive lateral seawater intrusion, the proposed withdrawal will be in the public interest. Any new allocation in these circumstances must be issued cautiously and with conditions to assure that no harm to existing water rights or to the public interest occurs as a result. Case law also exists suggesting that new water rights should be conditioned where there is a "possibility" that well development might result in sea water intrusion of a domestic supply aquifer.l Since this development may increase the potential for sea water intrusion, monitoring and testing measures are necessary to prevent sea water intrusion and are imposed upon this water right. The monitoring system description and initial data collected will be submitted by Pleasant Harbor to Ecology for its review and approval within 3 months of the effective date of the Report of Exam. I See Hillcrest Water Assoc. v. DOE, PCHB No. 80-128; Bryant v. DOE, PCHB No. 87-245; Citizens for Sensible Development v. DOE, PCI-IB No.90-134, ) Page 11 LlL4/2070 Pearch, Hydrogeologic Memo Part II: Aquifer test review and monitoring requirements Monitoring Requirements to be inserted into Permit Provisions: By January 15 of each year, the following information must be submitted in writing to Ecology. During construction, all production and monitoring wells must be sampled for chloride if there is a257o increase in conductivity. Monitoring wells must be monitored according to the Groundwater Monitoring Plan. After construction, all production wells must be sampled quarterly of each year and include the following: 1) Chloride and electrical conductivity (chloride analysis must be performed by a state- accredited laboratory) 2) Depth to static water level (with pump off long enough to allow for full recovery) The chloride/conductivity sampling and the static water level measurement must be conducted concurrently. This data collection will assist the applicant and Ecology in determining if actions are necessary to prevent an increasing trend in chloride concentrations (an indicator of seawater intrusion). Preventative actions may include - reducing the instantaneous pumping rate, reducing the annual volume pumped, scheduling pumping to coincide with low tides, raising the pump intake, and/or limiting the number of service connections. The monitoring program will continue for ten years after full build-out. Pleasant Harbor must implement their Groundwater Monitoring Plan. Pleasant Harbor Groundwater Monitoring Plan has additional specifications in addition to those specified in these provisions. Additional recommendation to be inserted as a Permit Provision: Before the testing of any production well, an Aquifer Testing Plan must be submitted and approved by Ecology. Upon completion of construction, this water right must reduce the instantaneous quantity (Qi) from 300 gpm to 195 gpm. As soon as surface water impoundments are built for Water Right Permit 52-30437, these must be exercised concurrently with groundwater withdrawals in Water Right permitG2-30436. Recommendations to be included in Pleasant Harbor's Groundwater Monitoring Plan: Comments for construction of new production wells and additional aquifer testing:. Any new production wells must be constructed into the Sea Level aquifer and located near the ACG Well, within SW % SE % Section 15, Township 25 North, Range 2 West W.M. It is not recommended to construct a well in the proposed location at the MW-2 monitoring well site. uL4/20L0 Page 72 Pearch, Hydrogeologic Memo Part II: Aquifer test review and monitoring requirements r Production wells must be constructed in accordance with Chapter 173-160 WAC. r See above permits provisions for submitting an Aquifer Testing Plan, which must include the following: o A minimum 72hour aquifer test will be conducted at each new production wells. o It is recommended that Pleasant Harbor use guidelines specified in the Washington State Department of Health Water System Design Manual, Appendix E, Recommended Pumping Test Procedures. o All production wells are recommended to be pumped simultaneously at a constant pumping rate, at the designed pump capacity of each well (not to exceed 300 gpm). o All wells will be sampled for chloride concentrations and electrical conductivity during the pump tests. o All new production wells and the existing ACG well must obtain an initial static water level before performing the aquifer test. o A measuring point on all new production wells must accurately locate within 10 feet horizontally and 0.1 foot vertically. o A licensed hydrogeologist in the State of Washington must be present when conducting any pump tests on the production wells. Comments for new and existing monitoring wells:o The two new monitoring wells (MW-7 and MW8) must be constructed into the Sea Level aquifer and located as specified in Figure I or Table 1. All new monitoring wells must accurately locate a measuring point within 10 feet horizontally and 0.1 foot vertically. o Monitoring wells must be constructed in accordance with Chapter 173-160 WAC. o Monitoring wells MW-4 and MW-5 must only be used for the purpose they were constructed, as resource protection wells. These monitoring wells were constructed without a proper surface seal. However, both these resource protection wells were required to have a surface seal from the top of the screen to land surface. Water levels observed from these wells (and future monitoring) are less valuable but are still valid for the use of the aquifer test and future monitoring. The following are additional requirements to include in Pleasant Harbor's Groundwater Monitoring Plan (Comments on Scott Bender (SSG) Memorandum to Tom McDonald, December 22,2009)zo Dataloggers that record groundwater pressure will be installed at VWP-1, VWP-3, M-W- 5 and MW-6. Dataloggers that measure both groundwater pressure and fluid conductivity (which can be correlated to salinity) will be installed at MW-2, MW-4, MW-7 and MW- 8. These units will record groundwater measurements on a 0.5 hour basis. The dataloggers will be downloaded every two months during construction season and quarterly in the winter months when there will be minimal well use. Comment: Static water levels must also be measured manually during these download periods in each monitoring wells to establish a reference datum (elevation above mean sea level). LlL4/2010 Page 13 Pearch, Hydrogeologic Memo Part II: Aquifer test review and monitoring requirements o About one month before construction and during the entire monitoring period specified above, dataloggers will be connected to all of the wells at the site. Comment: The connection of dataloggers to the wells must include at least one month before construction of all production wells and construction of the surface water impoundment in the kettles. r During construction, chloride will be collected from the two water supply wells, MW-4, MW-7 and MW-8 if an anomalous conductivity trend is observed. Comment: Ecology views an anomalous conductivity trend as follows: If there is an increase in conductivity by 25Vo from the previous measurement, Pleasant Harbor must sample for chlorides once as soon as possible in that same well. . All samples will be sent to an accredited laboratory for analysis of chloride. Comment: Sampling chloride should follow guidelines specified in: Washington State Department of Health, Water System Design Manual, Appendix E, Recommended Pumping Test Procedures. o After construction and occupancy of the Pleasant Harbor resort, the dataloggers will be downloaded quarterly. Water quality samples will be collected from the supply wells quarterly. Comment: This is included into permit provisions (see above). o This program will be continued for five years or until the resort has achieved full build- out; at which time the monitoring plan will be adjusted based on the results of the program. The data will be transmitted to Ecology for their review. Comment: See above permit provisions. Ecology requires that monitoring frequency only be adjusted 10 years after full build-out, when it is known that construction or full build-out shows no increase in chlorides. Additional comments to the Pleasant harbor's Groundwater Monitoring Plan:. All water level data must be submitted to Ecology in electronic form (e.g. spreadsheet) and must be in feet above mean sea level (Datum NAVD 88).. All lab results must be submitted to Ecology by January 15 the following year. o Pleasant Harbor should follow these guidelines for measuring static water levels in wells: Ecology, Standard Operating Procedures for Manual Well-Depth and Depth-to-Water Measurements http://www.ecy.wa.gov/programs/eaplqaldocs/ECY EAP SOP 052ManualWellDepth& DepthtoWaterMeas urgs_v_ 1 _0. pdf Pleasant Harbor should follow these guidelines for groundwater sampling for chloride and electrical conductivity: http://water.usss.gov/owq/FieldManual/ Pleasant Harbor should develop a Quality Assurance Monitoring Plan that is similar to the QAPP developed by Pearch (August, 2009). The SOP's specified above must also be included in the QAPP. Additional recommendations for sampling from domestic wells can be found in Pearch, Hydrogeologic Memo Part I, 2010. a a a 1./74120L0 Page 14 Pearch, December,2009, Hydrogeologic Memo Part I: Chloride Sampling in Domestic Wells on Black Point Peninsula O Manual MeasurementSWL (ftmsl) -Pressure Transducer Water Level (ft msl) -PortTownsend Tides (observed ft MS L) 4 8 Water Level Elevation and Tidal Stage - Wel! BBB054 oo 11 oo C{ ooo C{ N oc{ 6 l t^o! o o o =F J2 6 E>0o J o 63" -4 -4 -5 -8-6 oo(: ooq 6ooqoq Figure 9: Water level and Tidal Stage at well BBB054. Water lrvels were measured irom a presswe trarsducer which determined a continuous water levelfluctuationofapproximately5feetin24hoursdueto[dalinfluenceoftheHoodCanal.'Iliswaterlevelindicat€swellpumpinginfluencewherethe water levels are vertical. Pressure transducer was bung approxirnately 16 f€€t below top of the vJell (apFoximately -5 ft MSL). Page | 1 8 6 WellWater Levels and Tidal Stage - Wel! BBB051 ooo N @ 6 4 2 0 -2 -4 -5 -8 -10 2.9 2.8 2.7 = 2.6 E E.g z.soJ e 63 z.q 2.3 2.2 2.L 2 E oaG G!F oooN @ 6 oood r @ oooN 6 @ ooo N o @ ooo N o @ 6ooN 6 oooN € -Pressure Transducer waterlerels (ft MSL) l Manual Measurement SWL (ft MSL) -Port Townsend Tides (obsered) nn nn AA,t I I I I [1t I I )I l \I V I I U t/u \,$ll U/! {\lt I U t It \ /tl U I tItIil\l] lt !\ V Pearch, December,2009, Hydrogeologic lVlemo Part I: Chloride Sampling in Domestic Wells on Black Point Peninsula Figure 10: Water level and Tidal Stage at well BBB05 l. Water Levels were measured from a pressure transducer which determined a continuous water level fluctuation of approximately 0.2 feet in 24 hours due to tidal influence of the Hood Canal. This water level indicates well pumping influence where the water levels vertical. Pressure transducer was hung approximately 75 feet below top of the well (approximately -21 ft MSL). Page | 2 Map No APPENDIX A Table 1: Previous chloride sam of Black Point Peninsula domestic wells. tab Previous Lab Prcvious lah chloride (mi@ilemens/c Owner Date BBBO5l no previous chloride (see 1 Method LJsed Road AGR712 Rd-5housewell 1 6 1 8 Black Road Robin5on Road Robinton dohestic well sM4soecl E (KW) chloride 5ampling BqBo52 ro,previouschloradesampling verbalreportedbyPhyllisweisenburger sM450GCl B 888055 chloride BBBO54 5.2 LaboEtories, lnc.B Robinson Road 888056 10 noACY9s4 11 Gaul - Domestic well BBBO57 no previous chloride sampling Road 72 Porter Point Road 13 Tides well ABR318 8/8/2@L 5 Point Road Rhododendron Ln -5M450GC| B 41108 7971, 4 Cook - Cormorant Way Thompson - 1085 Black Point Rd 4SWy4 1.3 85 sampled in 1971 reoortl Page | 3 Robinson Road 150 Public Health Laboratories sM45oGCl-D sM450GCl B no previous chloride sampling ABA112 9/291798 12053 Cascade Analytical Seryice Twiss Analytical Laboratories, lnc. 2m Rhododendron Ln Lo/79h998 AFT763 71!7912mr ry4lry AC\9@ t3l3!799B 2 19.5 Water Management Laboratories lnc. Twiss.Analytical Laboratories, lnc. Water Management Laboctories lnc. Twiss Analyticl Laboratories, lnc. . Twiss Analyti@l Laboratories, lnc. 8/slre68 8,lsl7%8 repon) 15 NW 1/4 NE V4 APPENDIX A Table 2: Static Water Level (SWL) measurement results of Black Point Peninsula domestic wells taken on August 13, August 14, or August 2009. Table includes information obtained from Ecology well log or from nal communication with the owners well Depth (ft S<r€en,/Perf well Log Static water August level (ft Sampling Well Head Stickup August Elevation Hght (ft Sampling (ft msl) above Lidar Map No (ree Well Depth Owner well Well well Oate Well log SWL Date Oate Bolin&/Porter(tEnsducrinstalledl OlympicDrilling BBSO51 U13 Black Point Road yes L!2t19€2 97 -46.9 open hole 97ft 171317992 14.1 th3l2@9 ElackiPolnt Community Well Stoican Drilling Co- 8/7912@9 8/7312fi9 51.9 1.8 lack Point Rd - 5 house well Arcadia Drilling lnc. 2120 Black Point Road domesticwell no well log available 242 Robinson Road Phyllis Wi€senburger- irritation well Mel Williams Drilling ln BB8052 242 Robinson Road Robinson Mel Williams Drilling ln AGC522 238 Robinson Road OlympicDrillingCo. BBB055 250 Robinson Road * (transdu.erinstalled) Maberry Well Drilling BBB054 2zE Robinson Road Hal B€attie AGR712 AFT605 888053 -51.05 -58.62 open hole 88 ft July, 1970 74-80ft 2lsl2m1 7ut3/1e8s !26120pt 8/2O/L9t38 6.07 51.9 0.95 3.78 8/L1/2W 11.38 25.95 8/131200D zlrzlz(rr yes yes no no yes yes luly, 1970 2lst2g'/7 APPROX 12l1989 u26/zcDt ttlT/793,0 8120/1988 -0.57 4.& 72.43 11.14 11.14 t2.77 29-34 29 -77.73 open hole 29 ft bulk head on shoreline is 10.5 feet -22.A6 -22.86 -27.a3 8lt1/2W 8/rsl2cf9 sl13/2fis 8/r4/2fi9 8lM/2co9 ths/2me 8/79/2W 8lt4l2w NO SWL access -0.9 -0.9 -0.9 -0.9 1.3 1.25 7.25 10:10 12125 11:35 13:5 13:07 12.77 12.77 12.77 12.17 187./E 56.46 56.46 2.4t 2.71 pumping? 8174/2@9 8lr9lzcFD Elack Point Road 8179l2W Hood canal Drilling ABR318 yes 7u261,jJ74 274 -85.91 205-210 17122/1974 9.29 thol2w * lndicates depth was given to Ecology from property owner. No well log was available for this well Xen Gaul 266 Cormorant property used by a trailer Gaul - DomesticWell - no sample Hood Canal Drilling BBB057 yes 51717978 28 -16.14 23-28ft 4129/t978 2.81 8/19/2W L2:77 11.86 1.05 taken Iilliawell orilling ABA112 yes 42017998 58 -1.54 48-58 2l2olt9!8 47.75 8lr3l2w 10:18 2142 14:10 tAo.72 t&.72 136.82 737.21 1.8 1.8 14:N 15:00 52.8 52.5 135.1128.G) 0.8 Page | 4 Static Water l-€rl(ft swt(Ft 1.6 5.91 3.Al 1.5 5.94 1ft .pprox NO SWL ilcess lftapprox NOSWLaccess 47,8 2.3 NO sWL access2 3 Maberry Well Drilling 888056 Olympic Drilling ACY954 April,1994 -4€,.52 231-236 ft 4122h994 5.18 16:40 12:55 l\47 APPENDIX A Table 3: Chloride water results of Black Point Peninsula domestic wells taken on Map No (see Figure 2) Chloride Conductivity Chloride Conductivity (mg/Ll Field reading 16yq Lab results Field Hach (microsiemens Manchester (micromhos/ Omer Date Time Well testkit lab results 8h3l20@ 1L:29 BBB051 207 2.L8 1113 Black Point Road Point CommunityWell L2:57 14:21 !5:L2 0908el8-02 oso80a8-oE 090801&0s ust 13 and st 14, 2009 Manchester L:b Number 0908048-01 4 Black Point Rd - 5 house well Evans Black Point Road domestic well Robinson Road Wysenberger - irrigation well 242 Robinson Road Robinson Robinson Road Robinson Robinson Road Myhre * (transducer installed! 248 Robinson Road Hal Beattie Ken Gaul 266 Cormorant rented property used by a trailer Ken Gaul - Domestic Well Robinson Road Ben Porter 1117 Black Point Road Pleasant Tides Well Black Point Road 8/L3l2cfp 8lt3lzcfE t/13lzcfp 8113lzcfB 8h3/2w 8h3lz(rE 8/L4lzfrp 15:25 16:4O tl:47 L0:55 L3:59 0908048-04 090804&06 090804&08 AGR712 AFT6O5 BBBO53 2.31 3.23 exceeded field test kit >400 BBB052 m8/t 3054 AGC522 1Gls mg,/L 23o s.25 BBBO55 <i0mg/L BBBO54 3G35 26.1 3110 6 7 e 0908048-07 0908e$-0998174l20cp888056 <10 mglL 116 2.55 exceeded field test kit >400 414/2W 3:41 ACY9S4 mc/L @3 BBB057 NoAugst, 2009sample ABA112 NoAugst, 2009sample slLolz(xE 15:m ABR318 3500 10300 090804&010 Water Management Laboratories lnc. Sampled by Washington Water Service Co. Pleasant Tides Property Owners Association well is a municipal well.- Page | 5 10 737 .2.11 119 375 892 261 2 3 10 10 11 12 7\2 A: Table 4: Latitude and Latitude Coordinates of Domestic Water Wells sampled in August, 2009. Map No.ID 47.656743585BBBO51 Well 2 AGR712 47.650869631 AFT6O5 47.650017203 -122.903527t08 BBBO53 47.65!863476 -!22.926232894 BBBO52 47.6s12639t4 -722.92603726t 6 AGC522 47.657938751 -722.92654881.4 8 BBBO54 47.55712938L -722.92461.4185 BBBO55 47.6511.41970 -122.924572035 9 BBB055 47.6s1392335 -122.922029163 ACY954 47.652298295 -L22.925489543 11 BBBO57 -L22.925556U947.651669333 t2 ABA112 47.655960267 -t22. Latitude/Longitude Coordinates collected using a GPS Trimble GeoXT (datum NAD83) tt Page | 6 i t: 4' APPENDIX B: Individual Sample Results Eastern coastline of the Black Point Pentnsula 1) The Boling/Porter well (BBB051) was sampled for chlorides and continuous water level reading was recorded to adjust for tides in this area, Chloride analysis from the Manchester Lab was at2.45 mg/L which is below the background chloride concentration. The static water level was manually measured on August 13,2009 (2.45 tt MSL) and August L9,2009 (2.30). The elevation of this well is at 5 1 .9 ft MSL. This well is recommended for inclusion in the Pleasant Harbor monitoring network sampling for chloride and specific conductance. See the Tidal Effects section on how this well is tidally influenced. 2) The Black Point Community Well (AGR712) was sampled for chlorides on August 13, 2009. However, a static water level measurement could not be obtained because there was no access port on the well cap. Chloride analysis from the Manchester Lab was at2.13 mglL which is below the background chloride concentration, Previous chloride sampling of this well (<5.0 mE/I-, DSHS Public Health Laboratories, October, 1985) indicates that chlorides have been stable in this area. The elevation of this well is at26.95 ft MSL. It is recommended that a new well cap with an access port be installed on this well in order to measure static water levels, This well is recommended for inclusion in the Pleasant Harbor monitoring network. 3) The Evans well (AFT605) was sampled for chlorides on August 73,2009. Chloride analysis from the Manchester Lab was at2.3L mg/L which is below the background chloride concentration. The static water level was measured once prior to sampling for chloride on the same sampling date (3.87 ft MSL). Previous chloride sampling of this well (<20.0 mg/L, Twiss Analytical, October, 1985) indicates that chlorides have been stable in this area. The elevation of this well is at 1 1.38 ft MSL. l2) The Porter domestic well (ABAl l2) was only measured for static water levels. Chloride was not sampled for this well since it was not connected to a water spigot for sampling. The static water level was measured twice on August 13,2009 (2.41tt MSL) and August 19,2009 (2.71ftMSL). The elevation of this well is at56.46 ft MSL, based on LIDAR elevation data (Puget Sound LIDAR Consortium,2002). Previous sampling of this well indicates an extremely high chloride concentration of 12,053 mg/L (Cascade Analytical Services, September, 1998). This well is currently not being used by the property owner. Southwestern coastline of Black Point Peninsula 4) The Wiesenburger domestic well (BBB053) was sampled for chlorides August 13,2009. However, a static water level measurement could not be obtained because there was no access port on the well cap. Chloride analysis from the Manchester Lab was at3.23 mg[L which is below the background chloride concentration. The elevation of this well is at 12.4 ft MSL. 5) The Wiesenburger irrigation well (BBB052) was sampled for chlorides on August 13,2009 However, a static water level measurement could not be obtained because there was no access port on the well cap. The elevation of this well is al 12.4 ft MSL. Chloride analysis ) Page | 7 from the Manchester Lab was at892 mgll which exceeded the background chloride concentration. This well is causing upconing in the salt water wedge, resulting in salt water intrusion. However, it is not certain if a lateral saltwater intrusion is occurring since this well depth is not certain (owner reports to be only 25 feet). No testing results of chloride or specific conductance could be retrieved from the well driller to identify if the well was originally drilled near the natural zone of diffusion. Even though his well is only being used for inigation, it is recommended pumping this well be reduced to prevent lateral saltwater intrusion in nearby domestic wells. Jefferson County should report this high chloride concentration in this well and update the SIPZ accordingly. 6) The Robin Robinson domestic well (AGC522) was sampled for chlorides on August 13, 2009. Chloride analysis from the Manchester Lab was 5.25 mglL which is below the background chloride concentration. However, this well could not be located during the sampling day. The well was located on August 19,209 and a static water level was measured (3.02tt MSL). Previous chloride sampling of this well (<5.0 mg/L on October, 1985) indicates that chlorides have been stable in this well. The elevation of this well is at 11.14 ft MSL. 7) The Chuck Robinson domestic well (BBB055) was sampled for chlorides on August 14, 2009. However, a static water level measurement could not be obtained because there was no access port on the well cap. The elevation of this well is at 12.17 ft MSL. Chloride analysis from the Manchester Lab was at 26.8 mg/L which slightly exceeds the background chloride concentration. 8) The Myrhe's domestic well (BBB054) was sampled for chlorides on August 74,2009 and a continuous water level reading was recorded to adjust for tides in this area. Chloride analysis from the Manchester Lab was at 26.7 mg/L which slightly exceeds the background chloride concentration. Previous chloride sampling of this well (5.2 mg/L on July, 2004) indicates an increase in chlorides and this well is at risk of sea water intrusion. The static water level was manually measured on August 74,2009 (5.29 tt MSL) and on August 79,2009 (3.42). The elevation of this well is at 12.17 ft MSL. This well is recommended for inclusion in Pleasant Harbor's monitoring network sampling for chloride and specific conductance. See the Tidal Effects section on how this well is tidally influenced. 9) The Beattie domestic well (888056) was sampled for chlorides on August 14,2009. Chloride analysis from the Manchester Lab was at 2.55 mg/L which is below the background chloride concentration. The static water level was measured once prior to sampling for chloride on the same sampling date (5.03 ft MSL). The elevation of this well is at 187 ft MSL. This well is recommended for inclusion in Pleasant Harbor monitoring network sampling for chloride and specific conductance. 10) The Gaul deep domestic well (ACY954) was sampled for chlorides on August 14, 2009. The static water level was measured on August 14,2009 (2.10 tt MSL) and on August 19,2009 (1.71 ft MSL). The elevation of this well is at140.7 ft MSL. Chloride analysis from the Manchester Lab was 3,500 mg/L which far exceeds the background chloride concentration Page | 8 and drinking water standards. The property owner that the pump was lifted approximately 40 feet higher about a month prior to the August sampling. However, lifting the pump setting above the bottom of the well should have improved water quality. Regardless, the well is also coincidently experiencing saltwater intrusion (most likely local upcoming of the saltwater wedge). However, it is not certain if a lateral saltwater intrusion is occurring since no other wells are drilled at this depth (367 feet into glacial material). No testing results of chloride or specific conductance could be retrieved from the well driller to determine if the well was originally drilled near the natural zone of diffusion. Based on conversation with the property owner, this well did not have a salty taste until July, 2009 and plants died as a result of irigating with the water. Since the chloride concentration was very high and the well is already intruded, it is not recommended that Pleasant Harbor include this well in their monitoring network. However, the chloride concentration analyzed suggests that sea water intrusion is a high risk at this close proximity (approximately 400 feet) to the coast. The static water levels were also approaching mean sea level which suggests vulnerability to sea water intrusion. It is recommended that the property owner contact Jefferson County Public Health to determine if monitoring for chlorides should continue if this well has domestic use, If the property owner wants to continue to use this well, it is also recommended that chloride levels and water levels be monitored until DOH drinking water standards (less than 250 mglL) are reached. 1 l) The Gaul shallow domestic well (BBB057) was only measured for static water levels on August 19,209 (2.31 tt MSL). The elevation of this well is at I I .9 ft MSL. The location of this well is next to the hillside, similar to the location of AGC522, and had a similar static water level to BBB057. Chloride was not sampled in this well, since a representative number of other domestic wells nearby had already been sampled. Northwest portion of Black Point Peninsula 13) Pleasant Tides well (ABR3l8) was also sampled for chloride by the Washington Water Services Company on August 10, 2009. This well is one of three that withdraw groundwater under Water Right Certificates G2-23623 and G2-21134 with a combined instantaneous quantity of 85 gpm and annual quantity of 120 acre-feet per year. Chloride analysis from the Water Management Laboratories was at2.0 mg[L, below the background chloride concentration. The static water level for this well was also measured by Washington Water Services Company on August 10, 2009. However, this water level was reported to be at 135 ft, l0 feet below the top of the casing (-7.81 ft MSL). This water level measured by Washington Water Services most likely suggests interference from other nearby Pleasant Tides wells. The elevation of this well is at 128 ft MSL. Washington Water Services also reported water levels fluctuating between -4 to -7 feet MSL (132 to 135 ft btoc) throughout the year. Previous chloride sampling of this well has been reported to be 5.0 mgll or less, indicating chlorides have been stable in this area as a result of the production of all three Pleasant Tides wells, (Twiss Analytical Laboratories, August, 2001; Twiss Analytical Laboratories, May, 1998; TestAmerica Laboratories, 1995; and Washington State Public Health Laboratories, June, 1987) tI Page | 9 -) Due to time constraints, additional domestic wells located on the Black Point Peninsula were not sampled or field verified. However, one well that was previously sampled and reported to Jefferson County indicated chloride concentrations suggesting risk from sea water intrusion. In 1999, well ACY964 (the Loring well) had a chloride concentration of 19.5 mg/L. This level is approaching the assumed background chloride concentration. If accessible, with permission from the property owner, it is recommended that Pleasant Harbor include this well in their monitoring network to determine background chloride concentrations. Other wells that were not sampled during this study elsewhere on the Peninsula may also be at risk from saltwater intrusion. It is recommended that Pleasant Harbor contact these property owners to see if they are interested in testing their wells for chloride and specific conductance. Page | 10 a t APPENDIX C Jefferson County should report and update the following wells into the Seawater Intrusion Protion Zone (SIPZ) database and map accordingly as specified in Jefferson County Ordinance No. 09-0923-02: Well ABA1 l2 should also be reported and updated into the SIPZ since the previous lab results (1998) indicates a potential sea water intrusion. Porter ABA112 Oomestic Well T 25 N, R2W, Sec 14, SW. NW 12,o53 gt29/7w cascade Analyti@i servie Gau I Tax Parel Ecolosy Well Tas lD Well Tvre TownshiD Ranse Section U4ll4Address tab NAD (fromGPS- Results Al and Phvllis Wiesenbuner r25 SW al74lO93:47 Page | 11 Datum s02153031 502153041 ACY954 BBB052 Domestic Well lrrigation Well