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HomeMy WebLinkAbout048Michelle Farfan From: Sent: To: Cc: Subject: Attachments: Consu ltares@aol.com Tuesday, September 10, 2013 9:19 PM teresa.wa I ker@doh,wa.gov; S Porto@co jefferson.wa.us; garth.mann@statesmang roup.com peckassoc@comcast.net; paul@statesmanusa.com; diane@pleasantharbormarina.com; don@ pleasantharborma rina.com; mcoleman@ pleasantharbormarina.com Pleasant Harbor 05 - 149-F application.pdf; 10 - ltr rev of submittal - approach.pdf; 15 - MPR Boundary.pdf; 20 - EX-01 EXIST WTR SYS.pdf; 22 - MPR WATER PRESSURE ZONES.pdf; 24 - MPR WATER Layout.pdf; 30 - Marina Well 1 Test-Analysis.pdf; 32 - Harbor Certificate-G2-2a359-C.pdf;34 - MPR Certificate-G2-30436.pdf; 36 - Project Report 370- F self assess.pdf; 40 - expansion demand-13.09.10,pdf; 42 - historical data - 09.08.pdf; 50 - reservoir volume-13.09.08.pdf To all prior receivers, Consultares has been requested to insert the package with an application form, and we were to only send to Teresa and Susan. Corina stated she does not require the product We were asked to submit the documents in hard copy, as email is not acceptable. So, you all get another email delivery.!! have a good rest of the week thanks dwight Gonsultares Engineering Dwight L Holobaugh, PE PO Box 608 Issaquah, WA 98027 cell 206-919-1319 consultares@aol.com 1 AWffi Project Approval Application Form Please fill in all project description information and check all boxes that apply below. If you are submitting a Water System Plan, please use the Water System Plan Submittal Form DOH 331-397. Bistro Expansion and Storage lmprovement (project name) Pleasant Harbor Marina & Golf Resort [I\PR] 47629 Dwight L Holobaugh, PE, Principal Jefferson County (county) (water system name) Pleasant Harbor Marina and Golf Resort PWS ID#(design engineer) Consultares Engineering (system owner) 3089 l 3 l0l Brinnon (engineering firm) 23712SE 1706 Street WA (steet) Maple Valley wA 98038 (city) (800) s47-3479 (state)(zip code)(city) 206.919.1319 (st) (zip code) (phone number) Diane Coleman, Manager (phone number) (8oo) s+z-sqzg (project contact ifdifferent than above) Don Coleman, Operations & Maintenance (daytime phone number) (360)796-4611 (evening phone number) (866 848-461 r) (billing contact name--required ifnot the same as above) Same as above (billing phone number)(billing fax number) (billingaddress) (city) (state/zip) SYSTEM CLASS: I c.oup A Community ! c.oup A NTNC Elcroup A TNC ! croup n # SERVICE CONNECTIONS (for Group A systems only - # services afier project completion): -rlM L"sthan 100 E too-soo ! sor-eee E t,ooo -g,ggg ! to,oooormore PROJECT DESCRIPTION:- AREA SERVED (for distribution projects only-name subdivision, site qddress, parcel numberg efc./:Master Planned Resort by JCC TYPE OF PROJECT (check all that app$i Reminder: If submitting a Water System Plan, use form #331-397. t. !owsnrroan Application # Loan # :. f] New Group B design report (Workbook) 4. E New Water System (A completed Water Facilities Inventory Report Form (WFI) must be included with this submittal) s. Ellro.lect report: (Is a water system plan required: EIv tr N If required, is it current and approved: E v M N1 (Is the project identified as part of the capital improvement plan: EIt tr lrlf 2. l-l Enforcement Type Docket # Filtration or other complex treatment Chemical addition only (ion exchange, hypochlorination, corrosion control, or fluoridation) Complete new water system trtrtr EI rrru3o, system modification Special reports or plans: ! Corrosion Control Report 7. ! Predesign study Corrosion Control Study Plan to Cover Uncovered Reservoir Uncovered reservoir plan of operation Tracer study plan Surface water or GWI treatment facility operation plan ! fittration pilot study DOH Form 331-149 (Updated 08/10)Page I of2 98320 6.E g. E Pxistingsystem approval n Non-.*p*ding; not detailed evaluation ! Nor-"*panding, detailed evaluation ! expanding, not detailed evaluation EI rxpanding, detailed evaluation e. ! Construction documents: lo.! Waivers: trT Inorganic chemical (initial) Organic chemical (initial) Use Area wide renewal Inorganic chemical (renewal) Organic chemical (renewal) Use (renewal) Coliform (w/departmental inspection) Coliform (w/third-party inspection) tt.! other Ttr Filtration or other complex treatment Chemical addition only Complete new water system New source only System modification f] system modification; design standards used; PE prepared V Well-site evaluation and approval Regulatory monitoring plan Unfiltered system annual report Water system compliance report (loan letter) Water right self-assessment (if applicable) 12. Other projects (describe) Please return completedform to the Ol/ice of Drinking Water regional ol/ice checked below. Elsouthwest Drinking Water Department of Health PO Box 47823 Olympia, WA 98504-7823 Phone: (360) 236-3030 Fax: (360) 664-8058 For Department use only ODW Project lnvoice # Initial fee Amount Fee received: Date construction report received: Date invoice mailed: _; Review lefters sent: Approval Date: Area served: DOH Form 331-149 (Updated 08/10) # approved connections Page2 of2 Provisions: trTtrtr CONSULTARES ENGR Dwight L. Holobaugh, PE Cell:206-919-1319 2013 September 08; Revised 2013 September 10 Ms Teresa Walker, Regional Engineer Washington State Department of Health Town Center # 3 243 lsrael Road SE Tumwater, WA 98501 Ms Susan Porto, Sanitarian Specialist Jefferson Co Public Health 615 Sheridan Street Port Townsend, WA 98368 Re: Pleasant Harbor Water System, lD # 47629 Source Approval and Capacity Approval Stage l, Phase I Preliminary Project Report Ms. Walker, and Ms. Porto: First, Consultares thanks you for the response as recently made by Corina regarding our questions. In our effort to proceed quickly, we are spurred to present our understanding of the key items as follows: l) The existing upland system of the harbor area is planned to be fully replaced in Stage l, Phase I of the Master Planned Resort construction. This action will be described in some detail as will be a part of the submitted Water System Plan this early fall of 2013 September. 2) In discussions with Consultares, Ms Walker focused on and requested us to provide a capacity analysis as the base information, and then we can have continuing discussions. Consultares has prepared the capacity analysis. 3) During the meeting with DOH and Jefferson County at the site at Pleasant Harbor, Consultares suggested the Deli is planning to expand, and we project our capacity may even allow for 24 additional daily rental units southerly of the Harbor House and northerly of the planned Maritime Building. At this time, we have decided to not include the two new buildings between the Harbor House and Maritime Bldg. 4) Along with the capacity request, DOH had previously suggested we test the existing Well # I and make application for purposes of source approval. We have conducted the test for Well # I Source Approval application, and believe you will find the Well # I source as adequate. 5) Having analyzed the expansion capacity, we intuitively recognize the necessity for additional storage. The capacity we had currently have, and the amount we could immediately use, we noted our obligation to assure both the capacity and the storage with others system facilities required our analysis. We have therefore fully analyzed the entire existing system for proficiency and confirmed the only component needing improvement was concerning storage volume. We have calculated the present plus expansion volume requirement, and have PO Box 608 Issaquah, WA 98027 consultares@aol.com To: DOH / JC Date: 2013 September 08 determined the appropriate betterment. You will find the storage calculations to be a second base function of the existing water system. We believe you will find the storage improvement adequate for the existing system along with the expansion need. 6) These analysis packages as developed also will be used when considering the ultimate facilities over the next two years or so, and will be useful for the soon to be submitted WSP. Technical Efforts l. Background a. The existing water system has two wells, one storage tank, a pressure booster pump, and piping for transmission and distribution. Service meters have not yet been installed, however source meters are available. b. In an effort to move forward on full improvement with both the water service and the sewer service for the harbor and its upland development, we are seeking to obtain of the capacity analysis approval of the existing water current capacity. The Pleasant Harbor and Consultares are seeking expansion of this water system to include services to more patrons in the deli, lounge, pool, laundry, restrooms, day rentals, and if sufficient capacity is existing, to use that capacity to improve conditions of services to the attractions and revenue for marina operations. d. The source testing of Well # I has been completed and is documented by Binder Consulting, LLC Well Aquifer Test attached hereto. 2. Analysis a. Using the record of the recent two years of historical consumption, we have the monthly average daily demand for the last 24 months, and we can identify the monthly maximum amounts of consumption, and with calculations we can identify a MMD. b. With the records of the daily reads during 2013 July 04 Holiday period, we have also derived a very probable MDD. i. Please note given the seasonal usage which is, and we believe the MDD will always be, one of the first Saturday of May Boat Season, or Memorial Day, or July 04, or Labor Day. ii. Installing meters for distribution will also assist knowledge of operations and are required on or before 2016 December 3 L c Holobaugh page 2 of 6 To: DOH / JC 3. Process 4. Results Date: 2013 September 08 a. Obtain and use the records of the MAD during each month through-outthe2 years, and find the highest monthly demands, and compare to the records from Apr 15, until Sep 15. Consider the findings of comparison to understand the seasonal issues. b. Derive the results of the ADD of a new twin development according to the DOH Table 5 - 2 from the Dec 2009 Design Manual. Use this for a comparison between the calculated result and the existing source meter result. c. Search through the data for indications for a guide to a MDD, and confirm monthly information as to seasonal [summer] high usages. d. A spreadsheet is attached to this document showing the last 24 months from: i. From June of 201I thru July 2013 a. The monthly source production meter that has been recorded on a monthly basis for the recent 2 yearc, then has been reduced to provide an Annual Average Daily Demand [ADD] at6,847 gallons. i. Please note the calculated Annual ADD per the DOH 2009 Design Manual, Chapter 5, Table 5 - 2 shows the calculations for a result in the amount of annual ADD at 9,483 gallons - - - a ratio of 1.38 the records. ii. As to this result, Consultares recommends using the 2 year records as opposed to the DOH Manual, therefore the ADD is 6,847 gallons. b. Consultares recognizes we do not have a Maximum Daily Demand [MDD] from the 2 years of records. However, having foreseen the need for MDD Consultares did take advantage of the 2013 July Holiday period as follows: i. We began reading the Well# I flow meter daily from beginning 2013 Jul 01 and ending at20l3 Jul 08. There were two time errors in the meter readings, but not of a large significance. ii. Consultares recommends using the DOH ratio at 1.75 for western Washington, therefore the MDD is I1,982 gallons. c. Consultares has plans to bracket Labor Day for MDD efforts. We will begin daily readings 2013 Aug 28 and ending daily readings as 2013 Sep 05, all at the same time each day. d. Consultares intends to compare our findings of both Holidays, and if significant issues arise, to forward our findings to your offices, along with any recommended changes we have considered. Holobaugh page 3 of 6 To: DOH / JC Date: 2013 September 08 e. We have confirmedl the capacity facilities for this analysis are the well # 1 pump and the storage, and in combination with each other. f. Note that the distribution and / or transmission has been functioning satisfactory, and is primarily pvc about 40 years aged. g. We find no past reason to have and operate a treatment system and I or hypo- chlorination. Further, the only transmission piping will be from Well # I to the pump house, which has never shown any evidence of transmission carrier problems. h. Well # I has been tested as needed for submittal to DOH to obtain source approval of Well # l. The approval request has been created and it will be a portion of this Capacity Report, and it is a part of this submittal for DOH approval. i. The Well # I DOE well log identifies its capacity is 18 gpm. In discussion with Scott Bender, PE, who is the professional engineer that performed and certified the source testing report for DOH, Mr. Bender also recommends a l5 gpm flow rate of production. Consultares recommends the existing well pump is l0 gpm, and will have significant rest times given a combination with storage improvement. Therefore, the l0 gpm well pump is of sufficient volume to maintain adequate flow, and we recommend it not be changed until in the future if needed. If however a change is indicated, the well can be changed to 15 gpm. i. ADD :6,847 gallons ii. The well at l0 gpm has a volume accumulation in excess of MDD of ll,gg2 l. 24 hrs = 14,400 gallons 2. l8 hrs: 10,800 gallon iii. As can be seen above, with a production of the 12,000 gallons there will be ample time to replenish full storage capacity j. The storage items and calculations yield the following: i. Existing: 3,183 gallons ii. Fire suppression: 4,000 gallons iii. Stand-by: 0 gallons iv. Equalization 2,579 gallons v. Operational 1,441 gallons l The -a*i.um number of service connections or ERU's that the water system can serve when considering the limitation of each water system component such as source, treatment, storage, transmission, or distribution, individually and in combination with each other. page 4 of 6Holobaugh To: DOH / JC Date: 2013 September 08 It is imperative to review the calculations spreadsheets attached to this report. We believe the calculations have been done well, and will provide the required storage that the system can handle easily. Reservoir Storage There remains one portion of storage not currently resolved, and that is Fire Suppression Volume. Meetings are in process to find a resolution in good faith with the local Fire Chief of the Brinnon Fire Department. A confirmation of the approach by both parties, and will be resolved shortly. We expect to make an acceptable proposal for the next two years, and we will advise DOH of our resolution with the FD. A letter of confirmation is attached with a copy of said letter. The calculations currently contain the results of Standby, Equalizing, Operational, and existing storage. At this time, we are anticipating a temporary storage "pillow" with capabilities for storing at 15, 000 or 20,000 gallons of system volume. The pillow volume will be at a slightly higher elevation [2'] then the existing steel tank, and will be controlled by an altitude valve for storage usage between the pillow and steel tank. The wellwill fill the pillow, the altitude valve will allow flow between the pillow and the steel tank give certain elevations, and the pressure booster pump will provide the appropriate pressure distribution for services. System Expansion The "capacity" analysis found that Well # 1 production is recommended to be l0 gpm, which will be automated for call on / call off depending on the steel tank storage elevation at any time. The expansion of the existing system is only possible by the well production which is set for operations such that resting times will be readily available through-out any maximum day demand. The ERU's as existing currently, were calculated as they are derived per DOH Guide for ADD of the unknown. However, in this case, Pleasant Harbor has historical data records such that we used the most recent 2 year period. From that comparison, we found that the actual ERU's [39] were in fact 38% less than the DOH Guide. That finding then set the existing for comparison with the system facilities of the DOH Guide but without the reduction in expansion ERU's. Given the discussion immediately above, there is an actual number of 39 ERU's existing. Further, the future expansion is available without reduction for comparison. The availability can support increase for service areas for the deli [restaurant] and lounge,. This provides for l0 additional ERU's. Together, the actual and planned expansion can readily provide service from the improvements being proposed for additional storage and source production. The Marina water facilities including Production and Storage will all be fully replaced in approximately 2 years. By that time when both a sewer Reclamation Treatment Plant and additional source improvements including approximately 310,000 gallons of storage will be in service for all of the PH MPR including the marina. Holobaugh page 5 of 6 To: DOH / JC Date: 2013 September 08 This important Project analysis is now recommended as: o *"1 o,i1T,:;H:ffi'*lilis:;",1iffi ffil#;,- qua,itv o Existing and Proposed Storage Volume and controllers o Existing transmission lines are at par with2" diameter pvc with flow of 78 gpm o Service lines are at par with l" diameter pvc functioning well at 20 gpm At this point however, we hereby ask for your approval of the Well # I Source Application, and your approval of the Capacity, Expansion analysis, and storage betterment for the Marina during a temporary time of approximately 2 years. Present o This document anticipates a full replacement of the Marina Harbor water facilities as shown within the coming submittal of the WSP of the Pleasant Harbor Master Planned Resort. A map of the MPR proposed replacement is attached hereto. o Consultares considered the Well # I production as the primary factor. The well has recently been tested for purposes of aquifer quantity, intruding man-caused un-safe contaminates, natural un-safe contaminates, and of course general water quality. o The system does have records for meter flows, however there is only one source meter of importance, and with no service meters at this time. Consultares references the WS DOH Design Manual, Chapter 5.2,we note that source meters are acceptable for quantifying system capacity, and that is how we have presented our findings. Mr. Mann has asked that we seek a response as quickly as reasonable, and I ask that you contact us with any questions such that we can investigate any problems immediately if necessary. As you know, Holobaugh page 6 of 6 Pleasant Harbor Marina and Golf Master Planned Resort Brinnon MPR BOCC Adopted Bound"ry January 14.2008 DNR Lease I Legend E] MPR Bourxlary * 0 250 500 1.000Fc.t lrrrlrrrl Flgurc 8 2013 September C o n s u I ta res E n gi n e e ri n g I I \ I {I I l-*.__.? i I II I,t II I It t i, t I I I a If h t € I il I WELL T1 EXSIING 2'WAIER ./ \ "",/)/ /lt/ / .' ./ \ PUMP HOUSE GRAPHIC SCALE EXEflI{G Z WATER WE-L ( EXSNNG 3/4'WATEB /, EXSIING 1'WATER I L -J _---_\-./ /-----: tl i i\l! ttrl -..-" (- " I PLEASANT HARBOR MARINA SECTIONS 15 &22, TOWNSHIP 25N., RANGE 2W., W.M. I 5 .l ol I b q E I ; (,ll2| EilzIEI Ell, Elle r> 50 !4? =;E i8. lri< EooE z o UJ o- SIEEI EX-01 / ,""h -"I-/ GRAPHIC scALE gfiE- FrPrflElrot It TAt( TE.Tl4 f S€R'EE /'( .LEGEt{D{2 PS f--*..ri-----ri----!g - - - -lt:s----li--*-!u -, - - -l l t a\\ l;o: ) "Jli \\ 2fia 200 150o PESSE ZOIG 292 FI PES$EZq\E E4FT /,PETTE ZOIG ?4FT PESS,E ZOIG $FT {I r- ---- -_\_ ,-.t ----_----\ -./ -./- \" PESSEED(rcIGVALVE AAC( ROW PEIET{IEniJ,iEIU{EEYAIq{ E_OWOP€t \ I I I JiEIloI AEVAIrcil 0-45 Pg -'-- -t'TISIION E-EVAIIOI{ /tF& PS PLEASANT HARBOR MARINA & GOLF COURSE SECTIONS 15 &22, TOWNSHIP 25N., RANGE 2W.. W.M. R 5i ,i !: i ;9 s5E: oo <€.9oO)v n nO(l}i0)(/,OL< @" ? z 7 0klI Elps 2t sz Sr ,.El -. > Ei ExdB6;Q An, rd ^!: &qo ao r'.& -L.F.Wo&Ur! I 2 .//./ \ ,'/'l/ // ,l // / /'\,,///HIrcE- PUP to.E rlo t I It p l' U SEfiTEE ( GRAPHIC SCALE PS {aRI/, { I L --,----\- --a--l---.-....----) .ri r\llI' tlrl tl _/ -./ // ,-t -/- PLEASANT HARBOR MARINA & GOLF COURSE SECTIONS 15 &22, TOWNSHIP 25N., RANGE 2W., W.M. IU' E*oi?.tig{ jd.9,r{I q'- 8 !:Ei P 3 3:;;i(Jo-<:!J3 @" x ! PU:A Lrr6>SS trLd tsuu) F t!, ord () .-.\..m..wffiu8 I 4 August 8,2013 Mr. Garth Mann The Statesman Corporation 7370 Siena Morena Blvd. S.W. Calgary,Alberta T3H 4H9 BENDER CONSULTING. tTC AV pl it rl 6 rott ul a,t I e r Stl u I io r s P[.tB l5{ 1992 Souli Elgcr Br!.RoodCffio liLnd. ltA 9t:t: ph lfl)6ll.5a(xr .cll {l( Aq{ Xe{ | vrttt l*ilv|fu *rm tds.htnlarllc.utm PLEASAI\T HARBOR MARINA WELL TESTS AND ANALYSIS, PLEASAI\TT HARBO& WASHINGTON Dear Garth: This letter summarizes the procedures, analysis, and findings from testing Well I at the marina. The testing was performed to identit/ the performance of the well, aquifer properties in the vicinity of the well, and to provide the basis for a susceptibility analysis for the well and aquifer. Marina Well I The marina supply well I is located on the north end of the site as shown in Figure l. The well was drilled to a depth of 88 feet in 1977 . Based on the well log, the sand and gravel aquifer was encountered between depths of about 76 and 88 feet. The aquifer is confined by overlying and underlying glacial till. The well log is provided in Figure 2. Marina Well 2 is located on the south end ofthe site. This well is about 195 feet deep and is completed in basalt. This is the closest known well to Well l. Since the well is located in a different aquifer, the well could not be used for a monitoring well during the test. Methods Pumping and recovery tests were performed at Marina Well I in general accordance with the procedures in Appendix E ofthe Washington State Departrnentof Health Water System Design Manual (2009). In preparation for the test the water storage tank at the Marina was filled and the piping from the pump was reconfigured to pump the water to waste; water could not be sent to the tank because the varying head conditions the pump would realize over time would change, and this would affect pumping rates and invalidate the assumptions of the test. Due to the limited storage capacity at the site, a step test was not performed. An initial test was performed for about 10 minutes to check the piping and drawdown in the well. The water level was then allowed to recover to static. BENDER CONSULTING, LLC ClUs6\S@tt Badcr\Docmmts\0535-01 PleMt HlrbodPle6et Hsrtor\lt{arina Tesing\Plml }larbor Mrina Well T6t ed Analysis.doq 1026-01 € Letter to Mr. Garth Mann August 8, 2013 Page2 The pumping test was performed atarate of 7 .2 gpmfor a period of 24-hours. Groundwater drawdown in the well was about l7 feet at this rate. Groundwater level recovery was then monitored for a period of about 1,000 minutes, though full water level recovery occurred within 200 minutes ofpump shut down. Groundwater levels were measured and recorded with a datalogger installed in the supply well. Manual measurements were also made periodically throughout the test. A datalogger was also installed in Pleasant Harbor to record tidal fluctuations. Static Water Level Based on site survey information, the elevation of the well head is 48.63 feet. A static depth to water measurement was collected I hour before a high tide of 8.08 feet in Pleasant harbor. The depth to water was 42.90 feet below top of casing. The static water level elevation was therefore 5.73 feet. Pumping Test Analysis Groundwater level data were first corrected for tidal fluctuations based on pre-test static water level information. A tidal efficiency of about 0.22 was measured. This correction was applied to the pumping and recovery data to eliminate the effects of the tides. The drawdown and recovery data were then plot according to methods by Theis and Jacob. Figure 3 shows graphical plots ofthe test data. The semi-log plot indicates that a positive hydraulic boundary was reached within about 20 minutes ofthe test start. The hydraulic boundary is presumably that of Pleasant Harbor; this does not mean that the aquifer is receiving water from the harbor, but merely that it is within the hydraulic influence ofthe harbor. The positive boundary was also measured during the recovery test. Analysis of the drawdown portion of the test indicates an aquifer transmissivity of 0.06 to 0.14 d/minute. Analysis of the recov ery data indicates an aquifer transmissivity of about 0.24 fflminute. The estimation of aquifer transmissivity from a single well (supply well) pumping test is always underestimated because friction losses in the well screen during pumping increase drawdown greater than actually occurs in the aquifer. It is for this reason that monitoring wells provide a better indication of aquifer transmissivity during aquifer tests. Figure 4 provides a plot of calculated water level elevation in the aquifer for a rate of 7.2 gpm under the calculated range in transmissivity. As shown, the calculations become invalid for an aquifer transmissivity of 0.06 f/minute or less; in this case the aquifer would be pumped dry, and the pumping conditions in the well clearly indicated that this did not occur. BENDER CONSULTING, LLC C:\Users\Scott Bender\Documens\o535-01 Pleset Hebor\Ple6ut Hador\trleina Testing\Plesmt Harbor Meina Well Test md Analysis.docx t 026-0 I Letter to Mr. Garth Mann August 8,2013 Page 3 Based on the pumping and recovery analyses, we conclude that aquifer transmissivity is on the order of 0. I 4 to 0.24 ff lminute. At a pumping rate of 7 .2 gpm, this produces an aquifer drawdown (outside the well) between2.5 and 4.5 feet. Thestoragecoefficientisestimatedtobelxl0-3orless(dimensionless). Asinglewellpumpingtestdoes not yield a storage coeffrcient. Because the water level in the well is above the contact with the overlying confining unit, the aquifer is confined. As such, the well and supply is not groundwater under the influence of surface water. WellEfficiency We understand that the well has been used effectively for many years. In a few years, however, the well has had a lower yield; these were times such as the July 4 holiday weekend when there was a high demand. Figure 4 indicates that there is likely less than 4.5 feet of drawdown in the aquifer, just outside the well, when pumping at a rate of 7 .2 gpm. A drawdown of l7 feet was measured inside the well. This is direct evidence of well ineffrciencies. We would anticipate a maximum drawdown inside the wellof 5 feet for the given aquifer conditions and well construction. Figure 5 shows the entire record of drawdown measured during the site visit. Drawdown after July 17, 2013 17:00 is due to normal operation of the well. This was a period of relatively low use ofthe marina. As shown, oyer27 feet of drawdown occurred in the well during this period; this is about 60 percent of the available drawdown in the well. Given the types of water uses at the marina (showers, facilities, dock use); it is possible that the remainder of the available drawdown can be consumed during peak periods. It is our opinion that the drying up of the well is not due to seasonal influences. First, the aquifer is confined and very pervious; even in low recharge years with a typical, say, 5 feet of regional groundwater level decline, there is still over 40 feet ofwater available to the well. Second, if the aquifer essentially dried up, then given the proximately and hydraulic connection to Pleasant Harbor, sea water intrusion would have occurred. The well has years of use with no decline in water quality. The occasional limitation in supply can only be from well inefficiencies. It is our opinion that the well limitations during peak use times are related to inefficiencies in the well screen. Well screens can become clogged with native materials in the aquifer and/or incrustation of the screen over time. The well log indicates that the well screen has 0.050 inch-wide slots; this is a large slot size for most sand and gravel formations in the Pacific Northwest. It is possible that sand particles have wedged in and partially clogged the slots. BENDER CONSULTING, LLC Ci\Users\Scott Bender\Documents\os35-01 Pleomt Hrbor\Pleomt Harbor\.1\,luina Testing\Ple6mt Hebor Marina Well Test md Analysis.docx 1026-0t Letter to Mr. Garth Mann August 8,2013 Page 4 Since the well is generally operating reliably, you may choose not to improve the inefficiencies at this time. You could also choose to pump at lower rates for longer durations to reduce pump and piping wear. You also have the option to redevelop the well to remove particles and/or incrustation from the well screen. This carries some risk since the formation material is largely unknown, and could increase the flow of sediments through the screen. Water Ouality Water samples were collected during the pumping test. The test results are attached. The water appears to be free of contaminants. The chloride levels are low and are within State and County drinking water standards. Susceptibilitv The aquifer is overlain by about 76 feet oftill. Till is a very dense soil consisting of sand, gravel, and silt. The silt percentage in tills is sufficiently high to make the unit an aquitard, which significantly limits the vertical migration ofwater. As such, tills are confuring unis and groundwater in the underlying outwash aquifer is confined. Due to the thickness and low permeability of the till, the susceptibility of the well and aquifer to contamination at ground surface is low. The attached water quality test results indicate that the supply is not contaminated. Because the source of supply is in a confined aquifer, the well is not under the influence of surface water (Gwr). The well is not susceptible to sea water intrusion at the past and projected water demands. The water quality data from the test samples indicated that the chloride levels are between 3.5 and 4.3 mg/I. This is far below the State maximum contaminant level of 250 mg/I. This is also far below the Jefferson County "at Risk" chloride level of 100 mg/I. The projected aquifer drawdown in the well is at or above sea level, and as such, does not promote sea water intrusion. This is confirmed by many years of well use without poor water quality. BENDER CONSULTING, LLC C:\Use6\Scott Bender\Documents\o535-01 Pledut Harbor\Ple6ut Harbor\Ir{uina Testing\Plesilt Harbor Meina Well Test md Analysis.docx I 026-0 I Letter to Mr. Garth Mann August 8,2013 Page 5 Thank you for the opportunity to be of service. Please call us at (360) 631-5600 should you have any questions or comments. Sincerely, Scott F. Bender L.H.G., C.G.W.P. Mr. Dwight Holobaugh Mr. Craig Peck Enclosures:Figure 1. Well Location Map Figure 2. Marina Supply Well 1 log Figure 3. Pumping and Recovery Test Data Figure 4. Calculated Actual Water Level Elevation Outside of Marina Well I Figure 5. Groundwater Level and TidalData Collected During Testing Program Water Quality Data CC a74 SCOTT F BENDER BENDER CONSULTING, LLC C:\UserelScon Boder\Docmens\os35-01 Plecot Hubor\Plec&t Harbor\l\,Idina Te$ing\Ple6et Hebor Meina Well Tet od Analysis.docx I 026-0 I MARINA IIPII\NDS II\YOUT rQ6&a uF a*Ga.@H(I$X.C-S . r&(lAlltCF.!l! AMENDED FINAL BINDING SITE PLAN FOR PLEASANT HARBOR MARINA APORTTONOp@vr.t0t,S8C. tJ,T.2Jl.i.,R:W.,W.M.,'EPFBRSO|C?UNTY,WASIINGION ./ /' uL^12-fi207 / slJBr2-ooor8 WCtc*, NOITS: oorro(rl r,[A i $qilIns aEr gnr 20 6 {ffrrtr 8omorrrtlul ru rf,at [rrfot,il(" r) rrlfr(mrs$xrIil lf urt,rcu.ril nxEcolnd.Gtaol uof,.rltFlx. i0rilAr rs@rlo tOrS lls PiwtD \/+r,7* algE n 0 B $ F lFctlto €[rrrnr. Ff.,E] oan c,aa! irD?-r,rx.l SSR($.9 F-i .r-E ,rrtfl, rrix'tltaeaf, stt.t CRAPHIC SCALE corrn Eiroll txrort!, trE r! linIncawtrEnitmr1tm{ nllf, r6gdl alti araS [r t ,ll ro Eardt t rElra tgrBrtrrltae$tDn (el.lt|u$Gs rmplrrt{lr?r^l. rt rrn$lc st.tr trErt S}IEEI J OF 5 BENDERC-coNsutTtNG. Itc Atrli.l Cr!!ilE trt sdl.tio$ Pleasant Harbor Marina and Golf Resort Marina Supply Well Evaluation Statesman Corporation Site Plan Project Number 1026-01 Figure I m, v#-- Drd lfa. Darrhcrt ol Eold, f;ifft#.^tti*ElBI'WA'l'Ell WELII llEPOBf,' 81raE O" r,rEEleil)f, 4!tlx r.lSrr..nillwr. OWNE& (2) rocAmoN oF !IEL: o o ,--t-oct ll { 36a! rrr,...woB&OFITTE(4) hmf(ril.tott$rafaE riG'GrrEhD'Elo LlcaDsaii'l.ndlptteturi LOG:(10) WBLLIullrlDrlE(ltrrdllPffOPOSEI'(1) ni!--rr btGYdrsr&TTEI.L :rEd{r*. aLalttsoalora !!E altal....ItrATEB o tr IIEE D6.rr. tr' rdar6 0 .i oo.oE o3gsI g o Eo g l! E Etg o€ Lo Eto (!-oo ot -tro E(! 3 Foz otE E Lo E IEo.t o F otllGwclltrl tr rc|rd tlO Drt.o ElEl tnd tr lo lc IL nft-L-ilrtdlcd: ttEdtd C.d!g tbb ltll tt ELl &-4n b,-91_s. -lllc-r! :tE b ,tatr ro.d ar.ctrrl.[. -. toa.--tLb-lL Dttt obL ldE, httod: tr r.ll DcCDarad i@.tfnalad lf.t Omdt,"? LB (5) DIU![{SIO!8SI trrrrEd 'dt'Diqr6---.---..--.rt. DaD6 C clcdht a lt a. It IL rL lL It 4 . SoIbGa nL yrq, xan rr. rl.t.bE ' t.O*-;ffij'f, H;ti,fff-- 7,tfr1777 Dta E tur odl dlr art I'rlf, l"? trffr drtt--. D+il drEt- IGHds.[!r!hr@ DEfAILllscoNsrarrGuoN(6) b.G,.Da&bragoo. .{oarb6PG rdottDbdd E!rB.ilollrtsdat. DlE" h.a D&lroqE.nBo Pcrtroratior: FCL.&Gisv.l CrcdGavrl slNotrYB BlfoScrcasr de .b LardEturtrtPTIMP:(o Dcearl.oatIiD. StzE DatbnuElc FsdEtm JradqadoE tu Dle-&UG-.ard tlr-- lr0all'' tat'fiiraiartw,,aJ zlt : I.EIIES:4,/-(8) (0) I'E alral aortfl|{It[ttt/lftttt Tfi'.vsht -b DE,[.T'S Ef,AMEllD . : *$ rrr ifullhd mdrr'ry lusb.t&6cB rtl tLb t!!ct |!U! bc5t oC ny.haltdltc ild DtU.l WU.L lltirbna li r.?. lre. ,tt]-$(Bor_. a-?! r. (urr ^DDl.lIqllAL6!t!D!! r llrcEltlffi) ct AltG'E tdL; €, Dtff Pr tJtv EoF.z;m t l)>21 G 4trl ,hl. l4-Rlt : 77 L BENDER coNSutTtNG. llc Artttc'l c.ot.h'.t.. Srl.tiofi Marina Well I Log Pleasant Harbor Marina and Golf Re Marina Supply Well Evaluation Statesman Corporation Project Number I 026-0 I Figure 2 --!-T-*i ': : _' I r^ A-7.....?-f tt37 0.0 4.0 -I I T T t I + I I I I 1-l-t J O()t\ '3 E IJ .0 I 2 .0 16.0 20.0 0 200 400 600 800 1000 1200 1400 1600 1800 Time Since Pumping (Minutes) 0.0 0.0 uT-Tiril'l \\ \ \ 4.0 4.0 6) 6)IL 'o 'Eo 8 .0 8 .0 ofl -a 12.02.0 16.0 16.0 20.0 20.0 0 I t0 t00 1000 Time Since Pumping Minutes) l 0000 I l0 100 t/t' 1 000 I 000( I \ \tl t+,tl l\t ,r I BENDER CONSUI.TING, lLC AtFl i.l C J\,rnl r.t.. So I tt io.. Pleasant Harbor Marina and Golf Resort Marina Supply Well Evaluation Statesman Corporation Marina Well I Pumping and Recovery Test Data Project Number I 026-0 I Figure 3 l| ilLl- - tltltl | | |t| | |t| | |t tltlt | |il| | |t t | |ilt | |il t | || | | |l| | |l t | || | | |l tllttllt C 6.0 4.0 -- Static Piezometric o Z z.o B6 . 0-0 c 5 -2.0 -4.0 -6.0 -100 -80 -60 -40 -20 Horizontal Distance (feet) 0 20 40 + T : 0.24 ft2lmin at7.2 gpm per well + T : 0.14 ft2lmin at 7.2 gpmper well + T: 0.06 ft2lmin at7.2 gpm per well L rf / i I BENDEReCONSULTING. tLC A$l irl C t.,tal rrt.. S.l, t i.r, Pleasant Harbor Marina and Golf Resort Marina Supply Well Evaluation Statesman Corporation Calculated Actual Aquifer Water Level Elevation outside of Marina Well I Project Number t026-01 Figure 4 *III J #-------F t-__i --l-+i ft I_ H I +++l rtr ---# l l- I l ,t ):0 20 5 l5 c10oe =(B 615 o L Cd2zo l0 5 oe o o-]()! F c) (B 0)& 0 25 -5 30 -10 711611311:00 7/1611317:00 711611323:00 7117113 5:00 7l'l7l'1311:00 711711317:00 711711323:00 7/18/13 5:00 €- Corrected Marina Well Drawdown -E Relative Tide Level BENDERecoNsutTtNG. ltc AtFl ir t GtrurlF.r.. So I t r iot. Pleasant Harbor Marina and Golf Resort Marina Supply Well Evaluation Statesman Corporation Groundwater and Tidal Data Collected During Testing Program Project Number 1026-0t Figure 5 l: : ,t. t. t:I I : T" ) TWISS ANALYTICAL LABORATORIES, INC. 26276 Twelvc Trecs lanq Suite C Poulsbo, WA 98370 Tclcphonc (360) 779-sl4l FAX (360) 779-5150 IOC. SHORT IOC - SHORTby Various EPA Approved Methods Source / Point ofEntry - Report ofAnalysis (Stst Rr,porting Lq,ol} itrdica6 thc minimum Eporting lcvcl rcquircd by &c Wa$iryton Dcputmcat of Hodth (Do[D. DOH Drintiry Wrlcr rosponro lcrrcJ. Sgcms with c,qounds dcrcctcd u coocotntiors in cxccss of this lcwl st rcqu&cd to ta&c ad&liooat sarylos. Conhc,t your rcgiooal DOH oftoc.br firltor iftm*ion. (tttadnu Contrriout Lad), If lho coil.ndDaot ooum oxoccds thc MCL, ;m.di.r"lt contact your rcgional DOH offco. (NotAtrdyzcd), ia6. rc$tl6 ooho! itrdic.Es 6is com0ornd wrs oot inoludoditrtts crurEut ebrsb. (Not DacaoQ, in ho rlailts colwro iodicatB ttis co@pqlnd wrs atralzod ad not dctoscd at a lq!,!l grrd6 than or cqual to 0ro SRL indicrtos 6e aompound was not ddcctcd in tbc sampla at or abow the cooccotration indicatod th.0.010 Eg& MCL for Arscoic is for GroW A NTI{C ay$aos. All o&cr sptcmr Sorld chc& wi& lhcir oootrty lical6 Distriot to &tcrminc wh* lmJ is rplicablc. SRL: Triggrr I.orol: MCL: NA ND: < (0.0Ot): Date Collccted: 7/1712013 SystemlDNo: 47629}I Lab - Sample #: 01089203 Sample Locuion: Well I 0800 Samplc Purpose: RC Sample Compositionl S Send Roport To: Plcasant Harbor Marina 308913 Hwy l0l Brinnon, WA 98320 Group: Systcm Name: County: DOH Sourcc No: Date Reccived: Date Analyzcd: Date Reportcd: Sample Type: Collccted By: Phonc Number: Bill To: A Pleasant Harbor Marina Jcfferson s0r 7tfin0t3 7il8n013 7tDn0t3 PretrcatmenURaw Scott Bonder 360-796,4611 Pleasant Harbor Marina 308913 Hwy 101 Brinnos WA 98320 DOH#Analyte Results Units SRL Trigger MCL*MCL Erceeded Mcthod (Analyrt Init ) -1il 21 Chlmidc 777 nsll .20 250 250 EPA 300.0 (KW) 133892 TWrSS ANALYTTCAL LABORATORIES, rNC. 26276 Twelvc Trccs lamc, Suirc C Poulsbo, WA 98370 Telcphone (360) 779-Sl4l FAX (360) 779-5150 IOC - SHORT IOC - SHORT by Various EPA Approved Methods Source / Point of Entry - Report of Analysis (Se Rtpatiry l,1,!l), idic.tss the mhirnuur rcpoting lad reqtrild by Oc W8hin8lom Dcp.rtDctrt of Hcalth (DOH). DOH DdnldDg W.br rc$ooso lanl, Syscor with oompoundr tlaccbd at cooomarios in cxccrs of this lorrcl E! roquirad !o tekc additioal sanplcr. Cooa yon rcglnat DOH otrco ftr finthor infrrnatio- Qufuimua CoOoinm Lcnd), If drc cominut mord Gf,occds 6c MCI imdigtofy odte.t yolr rcgioorl DOH offco. (Not Atr8lyz.d), in tho rault! colmn indicdcs 6is conporud was not includcd in 6o otnont nnalysic. (Uothgctsd),h60rcsoltcoolumn indicatcsthisco|ryoudqasenalyzdardnotdctcdcdstsl.1€lgrcatatbmo(GquEltoftGSRL idicatoc tho oooporrd wss lot d.tcclcd in tto ranplo af or $ow tho concootsatim indicorcd. nE 0.010 mg/L MCL ftr Arsctris i8 hr Ctoup A NINC sysEtr8. All othc systas sl(Alld ohcc& wilh thcir county ttroalth Dbtsict b detdninc rdst l6rcl fu Eplioablo. MO,: N'': ND: <(0.0k): a SRL: Trigg:t lad: Dats Collected: 7/l7D0l3 SystemlDNo: 47629H Lab - Sample#: 01089202 Sample Location: Well I 1200 Sample Purpose: RC Sample Composition: S Scnd Rcport To: Pleasant Harbor Marina 308913 Hwy l0l Brinnon, WA 98320 Group: SysternNamc: County: DOH SourceNo: Date Received: Date Analyzed: Date Reporbd: Sample Type: Collected By: PhoneNumbcr: Bill To: A Pleasant Harbor Marina Jefferson SOI 7^7t20t3 7/18/2013 7fi9t2013 Prc-trearment/Raw Scott Bcnder 360-7gfi46tt Pleasant Harbor Marina 308913 Hwy l0l Brinnon, WA 98320 DOH#Analyte Results Units SRL Trigger MCL*MCL Exceeded Method (Analyst Init)Y( 21 Chloride 3.53 ms.lL 20 250 250 F.pA 3ff) 0 rKW) 133892 MCL: N/6u ND < (0.0k): TWrSS AN.A.LYTICAL LABORATORIES, INC. 26276TwclveTres Lrnc, Suite C Poulsbo, WA 98370 Telcphonc (360)779-5141 FAX (360) 779-5150 IOC. SHORT IOC - SHORT by Various EPA Approved Methods Source / Point of Entry - Report of Analysis (Suc Rcpctiog Lwl), itrdicdGs thc minimm 6pr66tfug hry6l rcquircd by tfic Wasbiogm OofqMt of Hoath (DO[I). DOH Dri*ing Waicr rcspoogc laGl. Sys6r wi6 coalpouo& dctaotod d concootrstimr in orccss of thir lcnrel arc roquircd to tah addirtional smplcs. Conurt f,ourrginal DOH oficc 6r firrta idormatio. (lfodnum Comuinot Lowl), Iflto oontminaot @rd cxoocds thc MCl" imcdianly c@t .t yor rcgiooal DOH oftcc. fio fnd5rc{, lo thc rocults cohm indicaes tlis coopmd was not inchrdcd iE tb orrrot an lysit. (Nd Ddctad), in ltc rcsulB cohrurn indioslcs lhir coq€nlsd wa ortzod ord Dot ddoctcd s[ a levd grcilGr tlal 6 cqud b rhr SRL indicabs &c c@poud was not dacctod in the surylc at or abovc thc conccarntior indicrtcd. Thc 0.0 I 0 mg/I. MCL for Argric is fc GroW A NINC systcsrs. All olbcr systccrs shorld cbock wift thoir oouoty HcsIh Disfist b dctlrminc what lct cl ic qpliccblo. SRL: Triggalarrl: Date Collccted: 7/l6D0l3 System ID No: 47629H Lab- Samplc#: 01089204 Samplelocation: Well I 1730 Samplc Purpose: RC Samplc Composition: S Scnd Rcport To: Pl€asant Harbor Marina 30E913 Hwy l0l Brinnon, WA 98320 Group: System Namc: County: DOH SourccNo: Date Received: Datc Analyzed: Date Rcported: Sample Type: Collected By: Phone Number: Bill To: A Pleasant Harbor Marina Jefferson s0r 7fi7t2013 7^8/2013 n9n0t3 Pre-treatmemVRaw Scott Bcndcr 360-79il61r Ploasant Harbor Marina 308913 Hwy 101 Brinnon, WA 98320 DOH#Analyte Results Units SRL Trigger MCL*MCL Exceedcd Method (Anatyrt IniL)fi 2l Chloridc 4.?O moll 20 )5$250 EPA300.0 (KW) 133892 TWISS ANALYTICAL LABORATORIES, INC. 26276Twelve Trees Lane, Suite C Poulsbo, WA 98370 Telephone (360\779-5141 FAX (360) 779-5t5C IOC - IOC IOC - IOC by Various EPA Approved Methods Source / Point of Entry - Report of Analysis Date Collected: 7ll7l20l3 SystemIDNo: 47629H Lab - Sample #: 01089001 Sample Location: Well I Sample Purpose: RC Sample Composition: S Send Report To: Pleasant Harbor Marina 308913 Hwy l0l Brinnon, WA 98320 Group: System Name: County: DOH Source No: Date Received: Date Analyzed: Date Reported: Sample Type: Collected By: Phone Number: Bill To: A Pleasant Harbor Marina Jefferson s0l 7lt7l20t3 7lt9l20t3 7t31t2013 Pre-treatment/Raw Scott Bender 360-796-4611 Pleasant Harbor Marina 308913 Hwy l0l Brinnon, WA 98320 DOH#Analyte Results Units SRL Trigger MCL*MCL Exceeded Method (Analyst Init.) EPA/State Regulated 4 Arsenic <(0 0014)ms/I 0 0014 0 0l 0 0l EPA 200 9 (KW) 5 Barium <(0. I )ms/L 0.1 2 2 EPA 200.7 (KW) (\Cadmium </0 001 |mo/l .0 001 0 005 0 005 F,PA ?OO 7 (KW) '1 Chromirrm <(0 007)ms/l 0 007 0l 0l EPA 200 7 (KW) ll Mercuru <(0.0002)ms/[0.0002 0.002 0.002 sM 3l l2 B (KW) t2 Selenium <(0 002)ms/l .0 002 00s 00s EPA 200.9 (KW) I l0 Rerullirrm <(0 000i\ms/l .0 000i 0 004 0 004 F.PA 200 7 (KW) lll Nickel <(0.005)melL 0.005 EPA 200.7 (KW) tt2 Antimonv <(0.003)msJL 0 003 0.006 0 006 EPA 200.9 (KW) I Ii Thallirrm <(0 001)ms/l.0 001 0 002 0 002 EPA 200 9 (KW) I l6 Cvanide Free msJL 0.1 0.2 0.2 SM 45OO-CN F (ST) ls Fluoride <(0.5)mq/l .05 )4 EPA 100 0 (KW) 114 Nitrite-N <(0 l)ms/l.0l 05 I EPA 100 0 (KW) 20 Nitrate-N 0.36 mslL 0.5 5 l0 EPA 300.0 (KW) l6l Total NitrateNitrite 0.36 ms/L 05 5 t0 EPA 300.0 (KW) 8 Iron <(0 l)msll.0t 03 EPA 200 7 (KW) l0 Mansanese <(0.01)melL 0.01 0.0s EPA 200.7 (KW) li Silver <(0.1 )ms/L 0l 0l EPA 200.7 (KW) 2t Chlorrde 429 mpJl 20 250 EPA 300 0 (KW) 22 Sulfate <(50)melL 50 2s0 EPA 300.0 (KW) 24 7.ina <(0 2)ms/l .o2 5 FPA 2OO 7 TKW\ t4 Sodium s.04 ms^5 EPA 200.7 (KW) t5 Hardness Total /as CaCO3)770 sfl. as CaCC l0 sM 2i40 B (KW) t6 Conductivitv l6l uS/cm 70 700 SM 25IO B (ST') 17 Turbiditv 015 NTII 0l SM 2130 B (ST) l8 Color <(l 5)CI]l5 l5 sM 2120 B (ST) EPA/State Unregulated 9 | .eatl <(0 001)mall.0 001 F.PA 200 I (KW) z)Cooner <(0.02)melL 0.02 EPA 200.7 (KW) r 33890 TWISS ANALYTICAL LABORATORIES, INC. 26276Twelve Trees Lane, Suite C Poulsbo, WA 98370 Telephone (360\779-5141 FAX (360)'779-515C IOC - IOC IOC - IOC by Various EPA Approved Methods Source / Point of Entry - Report of Analysis Date Collected: 7ll7l20l3 SystemIDNo: 47629H Lab - Sample #: 01089001 Sample Location: Well I Sample Purpose: RC Sample Composition: S Send Report To: Pleasant Harbor Marina 308913 Hwy l0l Brinnon, WA 98320 Group: System Name: County: DOH Source No: Date Received: Date Analyzed: Date Reported: Sample Type: Collected By: Phone Number: Bill To: A Pleasant Harbor Marina Jefferson s0l 7n7t2013 7n9t2013 713U2013 Pre-treatment/Raw Scott Bender 360-196-4611 Pleasant Harbor Marina 308913 Hwy l0l Brinnon, WA 98320 DOH#Analyte Results Units SRL Trigger MCL*MCL Exceeded Method (Analyst Init.) SRL: Trigger Level: MCL: NA: ND: < (0.00x): (State Reporting [rvel), indicates the minimm rcporting lwel required by the Wruhington Departnent of Health (DOH). DOH Drinking Watu response level. Systems with compomds detsted at concentrations in exess of this level ue required to take additional mples. Contact you regional DOH office for firtho infomtion. (Muimm Contaminmt Level), If the contaminilt ilnout exceeds the MCL, imediately contact you regional DOH offic. (Not Analyred), in the rcsults colm indicates 6is oompomd wm not included in the clmt malysis. (Not Detected), in the results colm indicates this compomd wm malyred md not detected at a level greater thm or equal to the SRL indicates the compomd w6 not detected in the sanple at or above the concentration indicated. The 0.010 mg,/L MCL for Anenic is for Group A NTNC systems. All other systm should check with their comty Health District to detemine what level is applicable. l 33 890 trDGCANATYTICAL Burlington WA Bellingham WA Portland OR cdryde ffi@ Mdobiolow tfrqobidoilChemw 1620 S Wahut St - 98233 805 Odrard Dr Sto 4 - 98225 9i50 SW Pionsor Ct Ste W- 97070 800.755.9295 .360.757.1400 360.67'1.0688 503.682.7802 N ACcO ReferenceNumber: 13-12907 Project: Pleasant Harlcor Marina oo I LABORATORIES Client Name: Twiss Analytical Laboratories 26276 Twelve Trees Lane Ste C Poulsbo, WA 98370 VoLATTLE ORGANTC COMPOUNDS (VOC) REPORT Page 1 oI2 System Name: System lD Number: DOH Source Number: Multiple Sources: Sample Type: Sample Purpose: Sample Location: County: Sampled By: Sampler Phone: PLEASANT HARBOR MARINA 47629H 01 B - Before treatment C - Compliance Well#1 Jefferson Scott Bender 360-796-4611 Field lD: Lab Number: Date Collected: Date Extracted: Date Analyzed: Report Date: Analyst: Released By: 133891-0'1 046-29291 7117113 12:00 524_130723 07t23t13 7t30113 HY DOH#COMPOUNDS RESULTS UNITS SRL Trigger MCL COMMENT 160 57 60 47 48 49 50 51 63 66 67 68 71 73 74 45 75 76 52 84 95 46 56 102 103 EPAIState Regulated TOTAL XYLENES T - 1,2 - DICHLOROETHYLENE CIS - 1.2 - DICHLOROETHYLENE 1.1,1 - TRICHLOROETHANE CARBON TETRACHLORIDE BENZENE 1,2 - DICHLOROETHANE TRICHLOROETHYLENE 1,2 - DICHLOROPROPANE TOLUENE 1,1,2 - TRICHLOROETHANE TETRACHLOROETHYLENE CHLOROBENZENE ETHYLBENZENE M/P -XYLENE VINYL CHLORIDE O - XYLENE STYRENE P - DICHLOROBENZENE O - DICHLOROBENZENE 1,2,4, . TRICHLOROBENZENE 1,1 - DICHLOROETHYLENE METHYLENE CHLORIDE *ETHYLENE DIBROMIDE (EDB) 1,2.DI BROMO-3-CHLOROPROPANE EPA/State Unregulated ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND ND NO ilD ND ilD ND NO ND ND ND ug/L ug/L ug/L ugil ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.01 0.02 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.02 0.04 Screening Only / PQL 0.5 ug/L Screening Only / PQL 0.5 ug/L NOTES: lf a compound is dctected > or = to thr State Roporting Lcvel, SRL, spscitird increascd monitoring frequcncics may occur per DOH. blank MCL value indi@tes e level is not curently cstablishod. ND (Not Oetocled): indicatc8 that th6 parameterwas not delected above the State Roponing Limil (SRL). An ' in front ofhe paramatar nane indicatas it is not NELAP acqcditcd but it is accreditcd through WSOOH or USEPA Region 1 0. These test results meet all the requirements of NELAC, unless olherwise stated in writing, and relate only to these samples. lf you have any questions concerning this report contact Lawrence Henderson at the above phone number. FORM: VOC trDGjFANATYTIEAL Reference Number: 13-12907 Lab Number: 046-29291 ReportDate: 7/30/13 10:38 Page 2 ot 2 LABONATORIES VoLATTLE ORGANTC COMPOUNDS (VOC) REPORT DOH#COMPOUNDS RESULTS UNITS SRL Trigger MCL COMMENT 58 59 86 62 104 64 65 69 53 70 72 87 79 78 80 81 88 89 54 82 90 91 92 83 93 94 55 97 96 98 85 31 27 28 29 30 0 1,1 - DICHLOROETHANE 2,2 - DICHLOROPROPANE BROMOCHLOROMETHANE 1,1 . DICHLOROPROPENE DICHLORODIFLUOROMETHANE DIBROMOMETHANE CIS - 1,3 - DICHLOROPROPENE TRANS- 1,3 - DICHLOROPROPENE CHLOROMETHANE 1,3 - DICHLOROPROPANE 1, 1,1,2 - TETRACHLOROETHANE ISOPROPYLBENZENE 1,2,3 - TRICHLOROPROPANE BROMOBENZENE 1,1,2,2 - TETRACHLOROETHANE O - CHLOROTOLUENE N - PROPYLBENZENE 1,3,5 - TRIMETHYLBENZENE BROMOMETHANE -P - CHLOROTOLUENE TERT - BUTYLBENZENE 1,2,4 - TRIMETHYLBENZENE SEC - BUryLBENZENE M - DICHLOROBENZENE P - ISOPROPYLTOLUENE N - BUTYLBENZENE CHLOROETHANE HEXACHLOROBUTADIENE NAPHTHALENE 1,2,3 - TRICHLOROBENZENE TRICHLOROFLUOROMETHANE EPA Regulated - Under Trihalometh TOTAL TRIHALOMETHANE CHLOROFORM BROMODICHLOROMETHANE CHLORODIBROMOMETHANE BROMOFORM State Unregulated - Other METHYL TERT-BUTYL ETHER ND ilD ND ND ND ND ND ND ND ND ND ND ND ND ND ND NO NO ND ND ND ND ND ND ND ND ND ND ND ND ND rnes Prog ND ND ND ND ND ND ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L ug/L em ug/L ug/L ug/L ug/L ug/L ug/L 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 1.0 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 0.5 60 NOTES: lla is detgcted > or = to the Stale by EPA: may occur p.. DOH. Fede.al Aclion Lcwls are 0.015 mg/L lor Lcad and l.3 mgA for Copp€r. Sodium has a rocommended limt ol 20 mg/L. AMCLContominant Level) muimum blank eslablished ND (Nol Oeteded): indicates that the parameterwas nol detec{ed above the Stat6 RcponinE Limit (SRL). An r in lront ofhe parametcr hame indicates it is not NELAP .cdcdited bd it i6 acdcdilcd through WSOOH or USEPA Rcgion 1 O. These test results meet all the requirements of NELAC, unless otherwise stated in writing, and relate only to these samples. lf you have any questions concerning this report contact Lawrence Henderson at the above phone number. FORM: VOC value indicales -?-- I : I tl .}(.a (. $ATEOFWASTINGN)N EPARTMEr{TOFEOOUIOY CERTINCATE OF VATER RIGHT EI &d.E we l#Sffi#9,$ffiSffitr;3'lfr*Sth$g$ina'r E crq,r,o wm? g#Imgf#,ggffi,S$Tffi.ffi*-o Dec.ober I XAII TMEnll E. IBtrTI ..: AODiEI' 6]l[ED PrO Bor tl6 tC llvl l:rP cooEt !rlanoa I|aohl,lrcoD 9832() G 3.0 acra-fect pgr year c@rralt5r tloocrtlc arpply cmtLlrrously locAflm OF Ollctgon prronAtrAr ar9ioora?E LocATrona o? orvcRatoaHiltHERewalfrell t 1: 1lifil f.rt esrt *rr ![ff! feat south froa th. N6thtrEst coraer of SGctr,os Ii. rl8l'l. I 2: 1!i05 lG.t ..ct .{t 1100 fe€t sotrtb froa tbe nofthrf,st corocr of Sccttoa 1:i. Lt3 Gover@eot Lt 3, Seetl.oa 15, f. 25 til.' R. 2 w.W.U. eod ffid{llt lr{,aB south of Stste B18ht6, No. 101, ls Scc. 15 T. 25 N., B. 2 I,1.$.1t., TOGEf,IEB tt:tlE the tideleoda of Secoad Clace 1r froat of Gover@cot I.ot 3. 15 ruTruEI ECY OaO.t.2 (ir.a-rl ISEE [V3ntE SrOEt GERTTFTCATE I OOR- . 3.O been in hws -J '._-.-.:! 7 FrrcuSus It .ccc6a porC aa roqulrcd 6 yalr psrolt ahall be od,rtalnait at ell tbea. "All sater u.LL. coo.carccod rdthla at .rata sball orst tta !il&lE ataieilg fc cortruc- ctoB 8Di D.tot.r.!Eo ar prclnrn usa.s GtlPt r 18.f00 IGf (Warn|'88g@ t.tst lhll' h.Eilct .oo AEt of f9rl) ssd Ch.Et r lr3-1q, WAG Obtm Stuilsrt! fc Co.tttreCtoD d utatoaocc oG lgater t{clls).tr Th. tBh, to t h. us ot rha rrut, clondd rtrrr0.y antfutlrd ts r*lctrd a rrtc M G &e ol w hq*t descdbd, cxct?, ot Weldd h RCW 90.03.380, 90.0t.t90, ad 90.,U.020- rlir ccrdtrc.la o, u.t r illB lr .Decltr ruy .trU.ct b ]t hdahdtr htr !o@G of rrta a Dtodn a lD iot eo.r+rl0. t Gh;1n.under nt hord and the scal of thls olficc at of ... ........... 4pr.ll..................... ..., I 9 1.A.......... r:i-.r:XEERIiC D^T^ hy WILBUA C. EAII.AIIEB, DIBEST{'B Dspsrtmcnt ofEcologyW,GK-E.U. NSELSTINE, Bs3loael llaila€r OIyryir ox..... /.2!.;.,.. -.....,.... : \ l Ii ll adttryna, i tih - -.P. *... b' .i i FOB COUNfy USE OilL' 7 o*'f,.ffi1\1iilii:86!1tu*-{w .'li', "i rt,t. j'tt irt0t0Gr STATE OF WASHINGTON DEPARTMENT OI'ECOLOGY REPORT OF EXAMINANON WRTS FileNo.C'2-3M36 (llruGd itr rscodae witfi thc misim of C'hetar ll7- hw of tsshilgM for lgl]-md mftdmmt! hqrto, dnd thc rfucs md rcgulations of tlE [Epaimaltof Eolo6/.) (lsucd in eodacc yith thcwfuimofchEta263- lsof Wahingtm for l9{5, and amirdmmb th@lo, dnd thc il|Gs snd Egulatiffi of fic [Eplrtmmt of Eslogy.) Surfa6'W8tsr Oround WEEr October I 2007 APPLICATION NI,,IMBER G2-30436 PERMITNI'MBER NAME Pleasant Harbor Marina and Golf Resort ADDRESS(STREET) CITY 308913 US Highway 101 Brinnon STATE ZIP@DE wA 98320 PIIBLIC WATERS TO BE APPROPRIATEI) 3 Wells l2l ac-ftlw (Additive) Multiole Domestic and Commercial SuDDlv Year-round- as needed 105 ac-ftfvr inon-addiiive) Irrimiion (61 acres) ' Aoril 1 to S'eDt. 30h 28 ac-ftIyr (non-additive) trri[ation (tZO acre fire Smart Program) Affi t to Sebt 30h LOCATIONOT APPROXIMATE LOCATION OF DIVERSION_WTII{DRAWAL Well 1 800 fest north and 1700 fest west of the SE comer of Section 15 Well 2 to be constructed in the SW yt SE yt - site to be determined Well 3 to be constructed in the NW y.N % - sit€ to be determined sw%sE% NE%N% Jefferson SECTION t5 22 TOWNSHIPN. 25N 2sN RAl.rGE, (E OR w') W.M. 2 W.W.M. 2 W.W.M l6 W,RLA LEGAL DESCRTPTTON OF PROPERIY ON WmCf, WATER TS TO BE USEn PLBASANT IIARBOR MARINA & GOLF RESORT IOCATEd iN JEFFERSON COUNTY, WASHINGTON AII WithiN portions of SECTIONS 15 and 22, both in TOWNSHIP 25 NORTII, RATIGE 2 WEST, W.M. AND GOVERNMENT LOT 7 OF SAID SECTION 15, AND GOVERNMENT LOTS 2 AND 3 OF SAID SECTION 22; Including: PRJORTTY DATE LOTS l, 2 and 3 O.F WATERTOUCH SHORT PLAT, AS RECORDED IN VOLUME 2 OF SHORT PLATS, PAGES 205 AI{D 206, RECORDS OF JEFItsRSON COUNTY, WASHINGTON, BEING A PORTION OF SECTION 15, TOWNSHIP 25 NORTII, RANGE 2 WEST, W.tvL, JEFFERSON COUNTY, WASHINGTON, and LOTS I and 2 ofPLEASANT IIARBOR MARINA SHORT PLAT, AS PER PLAT RECORDED IN VOLUME 2 OF SHORT PLATS, PAGES 221 TO 223 AND AMENDED IN VOLI,JME 3 OF SHORT PLATS, PAGES 8 TO I O, RECORDS OF JEFFERSON COUNTY, WASHINGTON A complete legal description ofthe project's boundaries is located in thb file G2-30436_Pleasant Harbof P4e2 Three wells serving the Pleasant Hartor development DEVELOPMENT SCHEDI'LE BYTruDATE: July l, 201 I 1,20251,2018 PROVISIONS Water Use Metering and Reporting l. An approved measuring device shall be installed and maintained for each of the diversions authorized by this water right, in accordance with the rule "Requirements for Measuring and Reporting Water Use", wAC 173-173. 2. Wder use data shall be recorded weekly and maintained by the project owner for a minimum of five years. The maximum monttrly rate of withdrawal and the monthly total volume shall be submitted to the Departrnent of Ecolory by February 28 ofeach calendar year. 3. Reported water use data may be zubmitted via the lotemel To set up an Iatemet reporting account access https://fortress.wagov/ecylunr./wrx/Ivlet€ring/. If you do not have Intemet access, contact the Southwest Region Office for forms to submit yor.u data 4. Chapter 173-173 WAC describes the requirements for data accuracy, device installation and operation, and information reporting. It also allows a water user to petition Ecology for modifications to some of ttre requirements. Installation, operation, and maintenance requirements are enclosed as a document entifled "Water Measuremeirt Device Installation and Operation Requirements." S. Departnent of Ecolory personnel, upon presentation of proper credentials, shall have access at reasonable times, to the records of water use thd are kept to meet the above conditions md may inspect at reasonable times, any measuring device used to meet the above conditions. Static Water Lwel Measurements By February 28 of each year, the following information shall be zubmitted to the Departuent of Ecolory, Southwest Regional Office, Lacey, Washin$on. Static water levels shall be measured quarterly from the following monitoring wells according to Pleasant llarbor's Groundwater Monitoring Plan, which include: VW?-l, YWP-3, MW-5, VWP-6, MW-2, MW4, MW- 7, and MW-8. Data shall include the following elements: o UniqueWelllDNumberr Measurementdate andtimeo Measurement method (air line, elecfric tape, pressue transducer, etc,) o Measurement accuracy (to nearest foot, tenth of foot etc.) r Description of the measuring point (top of casing, souuding tube, etc.) o Measuring point elevation above or below land swface to the nearest 0.1 footr Land surface elevation at the well head to the nearest foot.r Static water level below measuring point to the nearest 0.1 foot. If nearby punping wells interfere wirh monitoring well water levels, pumping wells may need to be shut of for as long as 4 hours to allow monitoring wells to recover to static conditions. Chloride Sampling Chloride and conductivity samples shall be collected quarterly from the wells authorized under this permit Data shall be submitted to the Department of Ecology, Southwest Regional OfEce, Lacey, Washingtoq by February 28 ofeach year The ohemical analysis shall be performed by a statc-accredited laboratory. The chloride/conductivity sampling and the static water level measurement mentioned above shall be oonducted on the same day. This data collestion will assist the applicant and Ecology in determining if actions arc necessary to prevent an hsreaqing trend in chloride concentrations (an indicator ofseawater intrusion). Preventative actions may include - reducing the instantaneous pumping rate, reduoing the armual volume pumped, scheduling pumping to coincide G2-3(Xit6_Pleasant Harbor PagE 3 DESCRIPTION OF PROPOSED WORI(S with low tides, raising the pump intake, and./or limiting the number of serrrice connections. Additional methodologies have been outlined by Pleasant Harbor in their Crrormdwater Monitoring Plan Groundweter Monitoring Plen l. Issuance of this permit is continge,nt with ongoing compliance with the Groundvvater Menitoring Plen: 2. The monitoring program will continue for five years or until full build-out whichever is greater, at ufoich time the frequency of monitoring may be adjustcd based on resrrlts. 3. The pemit holdcr is requircd to prcparc and submit an annual report sgmspf izing monitoring-rasults. The report must be reviewed and stamped by a licensed hydrogeologist and is due by February 28u of eaoh year. Neighborhood Program hsuanco of this penurit is contingent with ongoing complianco with tho Nelghbofiood Weter Suppty Program roquirod by Jofforson County Plmning. Ecolog/s approval ofthis pormit doos not limit any torms tho Comty may roquirc in the Noighborhood Watr Supply Program rcglrding access to tto Pleasant Harbor wator syste,nr by neigtboring parcols ifsah wator intrusion becomes an issue for neighboring wells on Black Point peninsula" Dwelopment Schedule . The development schedule shall be as follows: Construction shall begin by July l,20ll Cons&uction shall be completed by July 1,2018. Proof of Appropriation shall be filed by July 1,2025. The issuance ofthis permit in no way authorizes or grants any other perrrit required ofthe applicant, including arxhorizations that may be required from the Deparment of Ecology Water Quality Program and the Deparhent of Health regarding stormwat€r mrnagemeut and reclaimed water. The water user is advised that quantities recommended for the instantaneous aud annual rates of withdrawal may bc roduced at the time of issuance of a final water right commensurate with the oapacity of the installed systertr and the amount of water used" While this ground water right authorizes water for the full development of this project domestic needs will be phased in as the resort builds our Accordingly this groundwater permit may be used for both domestic supply AND irrigation of 61 acres, with the 133 acre feet of inigation demand designated as a non-additivey'alternate quantity as adhorizcd by surface water permit S2-30437, To the extent the surface water right has provided a reliable source of zupply for the irrigation requirements, the finel certificate for the groundwater right may be issued to authorize only domestic, potablq watir, and quantities reported on the Proof of Appropriation form limited to domestic supply. FINDINGS OF FACTS AIYD ORDER Upon rcviewing the investigator's r€port, I find all facts, relevant and material to the subject application, have been thoro'tshly invcstigated. Furthermore, I find water is available for appropriation and the appropriation as recommended is a beneficial use and will not be detrimental to existing rights or the public welfare. Therrefore, I ORDER that a pemrit be issued rmder Ground Water Application Numb er G2-3}436zubject to existing rights and indicated provisions, to allow appropriation of public grormd water for the emount and uses specified in this report. You have a right to appeal this ORDER. To appeal this you must: o File your appeal with the Pollution Control Heaings Board within 30 days of the "date of receipf' of '\is document Filing means actual receipt by the Board duing regular office hourso Serve your appeal on the Deparhent of Ecology within 30 days of the l'date of receipt'; of this document. Service may be accomplisfugd by any of the procedures identified in WAC 371-08-305(10). "Date of receipt" is defined at RCW 43.218.001 (2). G2-3(X36_Pleasant Harbor Page 4 Be sure to do the following: o Include a copy of this document that you arc eppenling with yow Notice of Appeal.r Serve and file your appeal in paper form; electouic copies are not accepted. 1. X'ile your appeal with the Pollution Contrul Hearingp Board Mail appeal to: Deliver yor.n ap,peal in person to: The Pollrtion Control Heaings Board PO Box 40903 Olympia, WA 9850+0903 2. Scrve your rypeal to the Department of Ecologr Mail appeal to: The Pollution Contol Hearings Board 4224 - 6th Ave SE Rowe Six, Bldg 2 Lacey, WA 98503 Deliver your appeal in person to: The Deparhent of Ecology Appeals Coordinator 300 Desmond Dr SE Lacey, WA 98503 OR The Department of Ecology Appeals Coordinator PO Box 47608 Olympia, WA 9850+7608 OR 3. Send e copy ofyour appeal to: Thomas loranger Department of Ecology Southwest Regional Offi ce POBox47775 OlympiaWA 98504-7775 For additiorwl ir{ormation vtstt the Erwironmental Hearings Ofice Website: http:/hvww.eho.wagw. Tofind lou,s ond agency ruler visit tlze Washington Sta/;e Legislatwe Website: http:/hvwwl.leg.wagov/CodeReviser . Siped at Olympia, Washington,this /b,rh a"y or {un*2010. Thomas [oranger, Section lvlanager $y'ater Resourccs Phogram Southwest Regional Office G2-3(Xil6_Pl6s8art Harbor Page 5 gn*u . IIYYESTIGATOR'SREPORT Water Right Permit No. G2-30436 BACKGROUND DESCRIPTION AND PURPOSE On October I l, 2007, Pleasant tlarbor Marina and Golf Resort filed two Applications for Water Right Permits; the first to withdraw ground water at the mardmum rates of 300 gpm for mtrnicipal zupply and inigation of 108 acres; and a second application to use water from a rainwater collection system, also for municipal supply and irrigation of the same project The applioations were assiped application nr.unbers G2-3U36 and 52-30437 respectively. The project site is located on the Black Point Peninsula situated betr:veen the Dosewallips and Duckabush Rivers, on the east side of Hood Canal, in the Skokomish River Watershed Inventory fu€a (WRIA lQ in Sections 15 atd22 of T25N, R2W. Based ou the provisions of RCW 43.21A.690 and RCW 90.03.265, Pacific Groundwater Group (PGG) pre,pared this report under contract to Ecology. PGG reviewed all available documents pertaining to these applications, including site conditions, historical water use, existing rights, and seniority of pe,nding applic*ions that could potentially be affectcd by the ryplication" PGG also performed zupplemental analysis to evaluate recharge, aquifer properties, and drawdown associated with the proposed pumping (PGG, 2009). Final detenninations of water availability were made by the Department of Ecology. Under the provisions of RCW 90.03.290 nd90.44, a water right sha[ be issued upon findiugs thgt wafsl ig available for appropriation for abeneficial use, tbat the appropriation will not impair existing rights or be detrimental to the public welfare. ln accordance with these provisions, I recommend issuance of Permit G2- 30436. LEGAL REQUIREMENTS FOR ISSUANCE OF AWATER RIGHT PERMIT .Public Notice A public notice ofthe proposed appropriation was published in the Jefferson County Leader on December 17fi and24h,2008. In response to the notice a protest letter was received from Mr. Gerald Stecl on behalf of the Brinnon Grorp, @rinnon). These comments are addressed in the Report of Exnmination under the section entitled Consideration of Prorcstant's Conce,rns. State Envlronmental Policy Act (SEPA) While thc Pleasant Harbor projecfs withdmwal of watcr is less than 2250 gallons per minrfre, rryhich does not in itself trigger a SEPA review, a water right application is still subject to a SEPA threshold determiuation in situations where it is part ofa lrger proposal that is subject to SEPA for other reasons (e.g., the need to obtain other permits that ae not cxempt from SEPA). The Statcsman Crroup of Companies, L'[D, and Black Point Properticq LLC, gubmitted an application with Jcfferson County for a lvlagter Plarucd R€sort (MPR) in the Black Point area This project required an amendment to the County's Comprehensive Plan, and thus this application is part of larger SEPA process. The County, acting as lead agency, detemined that this proposal was likely to have sipificant adverse environmental impacts, and required that an Eovironmeirtal ImFact Statement @IS) be prepared. The Final Environmental Impact Statement for the proposcd Brinnon Master Planned Resort was issued by the Jefferson Co.rmty SEPA-responsible official oh November 27 , 2007 , and a final decision was made on January 14;2008. Water Resources Statute and Case Lar Chapters 90.03 and 90.44 RCW arthorize the appropriation of public water for beneficial use and describe the proc€ss for obtaining water rights. I-aws governing the water riglt permiting process are coutained in RCW 90.03.250 through 90.03.340 and RCW 90.,14.050. In accordanc€ with RCW 90.03.290, favorable determinations must be made on the following four criteria in order for an application for a water right to be apprbved: . Water must be available. . There mustbe no impairmeut of existing rights. Pleasant Harbor Page 6 . The water use must be beneficial. . The watcr use mustnot be detimental to the public hteresl INVESTIGATION Evaluation of this application include{ but was not limited to, rqsearch and/or review of the following: . Departnrent of Ecolory records of surface aod ground water rights and clri-", and well construction reports within the vicinity of the subject production wells. . Documents and reports applicable to the are4 as refereirced in the conclusions of this report . A field visit conducted by Peter SchwarEman of Pacific Groundwater Group and Jobn Pearch of Ecology on May 7h,z}Og. . Subsequent analysis ofdrawdoum and pumping water lcvel associated with the requested withdrawal. PGG developed a pr€liminary groundwater flow model of the Black Foint Peninsula and used the model to evaluate responses to pumping. . Chapters 90.03,90.44 and 90.54 Revised Code of Washington LOCATION OF PROJECT SITE The Pleasant Harbor development is situated adjacent to Hood Canal, two miles south of Brinnon on the Black Point Pednsula The peninsula has an area of about 710 acres, and is surrounded on tbree sides (north. south and east) by the wmers of the Hood Canal. The north side of the Peninsula is also bounded by Pleasant Harbor, an inlet connected to the Hood Canal via a narrow channel. The westeru edge of Black Point Psninsula is defined by US Highway l0l, beyond which occur the foothills of the eastem Olympic mormtain rmge. The property contains stands ofpredominantly coniferous forests, interspersed with open meadow areas that were logged approximately 40 years ago by previous ownerc. The property is characterized by terraced artas separated by steep *kettle" formations caused by reoeding glaciers. The projeot site has been logged and was formerly the site of a 500-unit Thousand Trails (American Carryground) seasoual campground for trailers and campers. INTENT OF WATER RIGHT APPLICATION The intent of these filings is to s€curc water rights for the proposed Pleasant llarbor Resort and Golf Club (Resod). The final plan for the Resort encompasses approximately 250 acres and includes the golf couse resort area of approximately 220 acres and the marina resort arpa of approximately 26 aqes. The development will be a Master Planned Resort that will include at the golf cor.use resort area up to 890 residential units (802 toumhouse style condo units and at the marina resort 88 residential unis), 46,000 square-feet of commercial space - including retail and conference spac€s, an l8-hole golfcourse, I 1,5fi) square feet ofcommercial space and the existing 3 I l-slip marina PROJECTED WATER USE The water supply for this project will combine the use of existing gror.rndwater rights, new groundwater rights, aquifer infiltration" rainfall water harvesting, and treatment and reuse of wastewater. Groundwater wells will be the potable water supply sor.nce for the resorl Groundwater will also be used idtially for inigation; however, as surface-water collection facilities arc constructed on the property, surfrce water will replace grormdwater as a primary source for irrigation- The applicant is also pursuing plans for the development of reclaimed water for the irrigation program. As this water becomes available, groundwater and surface water use will be reduced by the available reclaimed water and as provided by the terms in ttre reclaimed water permit. Ultimately, at full resort buildout, reclaimed water could potentially supply the majority of the irrigation demand, thus reducing the ovsrall use of groundwater aud srrrface water POTABLE WATER DEilIANDS The proposcd development is being designed to consume less than 40% of the water that a typical development uses by implementing water saving devices. Pleasant Harbor proposes the irse of low flow toilets, motion activated faucets, low flow showerheads, and high-efficiency washing machines. The applicant has calculated the potable residential water demand to be only 70 gallsns per day (gpd) for each residential vnit, Waer resornce mqnagement rcport, 2020 Engineering Report, Morch 22, 2007, section 2.1.2 P8qleT TRRTGATTON (NON-POTABLE) WATER DEUAND The irrigation program includes irrigation of the golf course, and a "Firr Smarf'program intended to promote natural vegctation and reduce firE hazards in other areas. Irrigation at the golf course will be applied to 61 acres with state-of-the-art equipment desiped to minimiz€ water use aod promote efficiency. PGG estimated water demaod at the golf course based on the Washington Inigation Guide assuming turf grass grown in the vicinity of Quilcene with an inigation efficiency of 85 percenq as summarized below: Table 2. krigation Der-nnnds In addition, the applicant has requested 28 aflyr to be applied to I20 aores under the Fire Smart program during the April-to-October growing season. The FirE Smaxt Program has been designed to promote native vegetation growth and reduce fire hazards. Native vegetation is primarily domrant in the sumrnermonths and a 20 percent evapotranspiration faotor has been assip to wet them. Statesmcn applied this rate to 120 aces of properfy that will not be developed by the proposal, and calculated a Fire Smart program demand ofabout 28 acre-feet per year. Total irrigation demand is therefore estimated to be 133 aflyr. ' DOH recommends using 175 gpd /ERU for ADD and 350 Sxd/ERU for the maximum daily demand (MDD) to calculate potable demand, as stipulated in Sections 5.2.1.1 aud 5.2.1.5 of the DOH Water System Design lvlanual (Design manual) Page I Potable Water Demand Based on 890 units Occupanoy %85o/o 50o/o 30% # of Month 4 months 3 months 5 months # Units Occupiod/Day :t57 445 267 Potable Vy'ater/Day 132,t13 77.240 47.000 Potable Water/Year t6-tt7-79t 7-106-093 7,106,093 Armual use l2l acre-feet per year (includes additional 28 acre-feet associated with commercial uses) Month Crop lnigation Requirement (in/mo) Crop lrrigation Requirement (acre-ft) Total I nigation Requirement (acre-ft) April 0.il 3.25 3.E3 May 2.37 12.05 14.17 Junc 3.31 16.83 I9.80 July 5.12 26.03 30.62 August 3.99 20.28 23.86 Scptembcr 2.10 r0.68 t2.56 Total t7.53 89.1 I 1(M.84 Q020 Repon). Also see Chapter 3 of the EISfor the Resort. Howev€r, this is recopized to be a low residential demand" The State Department of Health (DO[D, who will approve the number of connections for the water syst€m, rocornm€,lrds that for planning purposes, a higher number be used with the that actual demand.may be more in line with the applicant's estimates. The annual quantity of water that will be authorized for the domestic use of the Resort is based on the ADD dnd the seasoual occupancy of the Resort. Because there are no records at ttris time for the lower 70 gpd/ERU estimste, the application is considered for " *u"st at this time for a quantity of water for ftll development based on the 175 gpd/ERUr. The occrqrancy ofthe Resort is determined to raoge from 85% in the high season to 30olo in the low season, with an average of 53o/o occqpancy. 2020 Report EIS, chapter 3; S/ater Supply and Groundwater Analysis, Subsurface Group LLC, December 77,2N8 (Subsurfacc Report). At 175 gpd - proratcd to accouot for seasonal usage, the annual dmand for residential potable water supply is 93 acre feet per year. The application applied fol the water right basd on this.calculation, witl the expectation that in the futrne thp actual water use will be 40% of this amount. In addition to domestic water needs associated with the living units, the applicant has estimated 25,000 gpd or 28 aff for commercial use over an expected total area of approximately 57,500 square feet This is a reasonable quantity requested whe,n considering the commercial uses include a restauant, lounge, commercial kitchen, a cooference ceirter for tp to 400 guests, marina operations, offices, and shops. Given these estimates, the potable water demand at the desip occulnncy is about l2l ac-ft per year. Table I details the resorts estimated water demand based sn projected occupancy rates. ' Tablo l. Potable Water Demand Assuming that the Fire Smart program is applied between July and September, PGG estimates that average monthly irrigation deinand would approach the total requested Qi for the two wat€r rights (300 gm) {uring the ma:rimum inigation month (July). Because irrigation demand comprises a significant portion of the total requested Qi duing the dryer summer months, satis&ing this demand will rely on storage of water during other portions of the year. Irrigation water wil be stored in Kettle B located near the &iving range. The ksttle will be lined to form a storage pond, and should be capable ofholding 60 million gallons ofwater. Subsurface Memorandurq page 15. (Note that the total irrigation demand of 133 af is equivaleat to 43.3 million gallons.) \Mater will be pumped tom the pond with a pressurized pipins system to meet inigation and fire flow needs. Groundwater under this water right will be used to establish the golf course; however as altemate sources of water become available they will provide an increasing portion of the irrigation demand- Surface water will come from rrroftop collection systems and storm runoff. The use of this surface water would be authorized rmdEr surface water right application 52-30437'. The groundwater right will remain available as a back-up source; however groundwater is not e:rpected to be needed. Additionally, the Resort is planning to apply for a reclaimed water permi! and if approved the non-poable water derived from wastewaGr teated to Class A reclaimed water standards will be the primary source for irrigation of the 61 acre golf course and also the developer's "Fire Smart''program. Both the groundwater right and the zurface.water right wi[ be retained as back-up supplies if the reclaimed water source'is not available or is inadequate for a period of timc. The reclaimed water will be authorized for use under a D€partment of Ecology Water Quality Program Reclaimed Water P€rmil Total lnlgaUon Requltement Since the Washington State Cooperative Extension does not calculate inigation demands for a Brinnon station, irrigation duty for this project are based on climatic conditions at the nearby Quilceire, l l miles north of the Black Point Peninsula- The crop irrigation requirements for the irrigation of pasture and turf amount to 17.54 inches per acre over an April to September irrigation season. The applicants will be installing a new, efficient irrigation system assumed to be at l€ast 85% efficient . Using a Crop Inigation Requirement (CIR) for pasturr/turf, of 17.54 in/yr for the inigation season, the CIR for 6l acres is (17.54 rn/12 in/ft) {' 6l acres = 89 ac-ft/yr. ApplicationEfficiency @a) forpop-up sprinklers is approximgtely 85% efficient assuming a 107ri evaporatibn factor, the estimated Total Irrigation Requirement (TR) = 105 ac-ff/yr. TOTAL WATER REQUIREMENT Annual Quantl0es The total water requirements for this project amount to 254 acre-feet per year. It should be noted that rryhile the ground water right would anthorize water for the fu.ll developm.ent of this project it is the ryplicant's intent that domestic needs willbe phased in as the resod builds out. Accordingly the groundwater pemit should be used for both domestic supply AND irrigation (and Fire Smart) with the 133 acre feet of irrigation demand designated as an alternste source and a zon-addittve quantity to the right authorized by surface water perurit S2-3M37. lnstantaneous quantltles The application requests 300 gallons per minute. This is a maximum quantity of water that would be withdrawn from up to the 3 wills on the site. ffgr.oundwater supplied the entire Resort, both potable and inigation" the quantity withdraum from the ground was calculated by the applicant to amount to 150 gallons per minute on an avsrag€ annual basis. At such time that surface water is available for irrigationthe av€rage annual withdrawal will be 75 gallons per minute, with a range over thg year of a low of 50 gallons per minute to a peak of 109 gallons per minute. Based on the need for this water for the initial developm.ent and recognizing the needs of ma"ximum demands for water system planning under DOH regulations, the 300 gallons per minute is reasonable. EXISTING WATER RIGHTS ASSOCIATED wlTH PROJECT SITE There are currently 5 other water rights appurtenant to the same property. Two, ground water certificates G2- 20465 ail.G2-24359, are associated directly with facilities that Statesmen will now operate. On paper these two rights arnount to 28 acre-feet per year. S/ater right certificates G2-27964, G2-21134 atdG2-23623 te associated with the Pleasant Tides Water Co-op which serves water for domestic supply on the Black Point 2 Rooftop rainwater collcction systems ae excmpt ftom the wacr right permitting process; however thc applicant has electod to get a waer right permit for tiis portion of their wator use page 9 Peninsula While the Statasmen project is located partially within the scrvice area of the Co-op, and Pleasant Tides could zupply an additional 12.5 acre-feet, the parties have uot reached an agree,ment ud Statesne,n has elected to pursue its own righs. Tablo 3. Existing Watcr Rights $rrmmnry Status of Exiating Rightr Ground watcr c€rtificate G2-2}465issued to American Campgrounds is apprrtenant to one of the production wells tbat will bc uscd for the resorl The certificate authorizes the withdrawal of 55 gpm, and 25 acre-feet per year, based on the projected water demand of an 800 tailer RV park and other inciiental water usc. The facility was never met€red it is uoknown how much watcr was actually used- Since it has been a number of years since the campground was fiilly operational, the applicant has requested that this certificale not be considered as an available sourcc ofsupply for tltis project Ground water certificate Cr2-24359 was iszued for the domestic de,mands of the existing Pleasant llarbor marina area, including a small comnercial establishment and also.water used at the marina Givelr the tlpe of projec! and without evidence to the contary we assume that the firll 3 acre-fect is a reasonable water dutlr HYDROGEOLOGIC ANALYSIS/GROUND-WATER FLOW SYSTEM Regional Setting, Land Use, and Topography Black Point Peninsula ii located in the northem portion ofthe Hood Canal, southeastern Jefferson County, about J milss south of Brinnon and 40 milss aerth of Shelton (Figure l). The Peninsula is pefi of Water Resource Irwentory Area 16 (Skokomish-Dosewallips). The Peninsula is primarily residential with a small marina on the north side, however much of the Peninsula was originally intended to be developed as a campground area The sur'fac€ area of the Peninsula is approximately 1.1 square miles (696 acres; area of the Peninsula east of Highway l0l) of which Statesman holds approximately 0.34 square.miles Q20 acres) (['igure 1). The topography ranges from steep, coastal bluffs to genfly rolling uplands. Most of the shoreline consists of steep bluffs with nanow beaches. The ceirtral portion ofthe Peninsula contains large surface depressions known as kettles. Kettles are landform features from the Vashon ice age that resulted in blocks of ice calving from the front of the receding glacier and Seesming buried partially too wholly by glacial outwasb- The Peninsula is bounded by saltwater on three sides, from Pleasant Harbor to the nortll the Hood Canal to the east and the Duckabush River delta to the south- The gound surfaoe elevation ranges from about 60 feet in the deepes't kettle, to elevation 320 feet on a hill in the southeast portion ofthe site. The average site elevation ofthe Pleasant llarbor Resort is about 180 to 200 feer CLITATE The site oscus in the rain shadow of the Olympic Mormtains, although the raih shadow effect is smaller near the site than furlher to the north and northwest. The climate is northwbst marine; where winter months are typically moderate and wet, while surnmer months are typically mild and dry. Over 55 inohes of precipitation faliin Quilcene, about 1l miles north of the site. Most of the precipitation events in the site area are generated from southerly storms that move north up the canal. Precipitation data are also available from Madrona Ridge, which is.on the West side of Hwy.l0l across from Pleasant Harbor. The data are collected by Mr. Bruce Klanke, who was trained by and uses an automated weather station approved by NOAA. His data are tnnsmitted to Mesowest and are available at their website under location 4'546l . Comparison of dara from the two locations shows slightly more precipitation at Madrona Ridge (59 vs. 55 in/yr over the period 1992 through 2008), with very similar seasonal variation @GG, 2009). Over a period from 1948 throryh 2005, average annual precipitation at Quilcene gage'2 SW" (456840 was 55.4 in/yr, with monthly av€rage temperatures ranglng from a 60.7 T high to a39.7 Trlow fttto://www.vrrcc.dri.edu/cgi-bin/cliMAlN.pl?waouic). For estimating precipitation recharge to the Black Point Peninsula, PGG used Quilcene precipitation and temperature data for the period of 1948 to 2005. Page 10 File #Percon Do c Pdortty Us e QI (spm) Qa (aflvr)TRS ao/o G2- 20d€,5C American CampErounds Cer t 8129t1972 DM 55 25 25.0N 02.0W 15 SWSE G2- 211vC Black PointWater Co lnc Cer t 6t14t1973 DM 40 60 25.0N 02.0W 15 SW/N W G2- 2#23C Black Point Wabr Co lnc Cer t 't/2ot'ts75 DM 45 60 25.0N 02.0W 15 SWN w G2- 2/t359C REILLY ROBERT E Cer t 1U131197 6 DM 60 3 25.0N 02.0W 't5 G2-27Xt4 Pleasant Harbor Beach Tract Pmt '121241199 0 DM 215 25 25.0N 02.0W 15 Geologlc Setting The project site lies on the boundary of the Physiographic province of the Ollmpic Mountains and the Puget Sound lowland. The geology of the Peninsula has been mapped by Dragovich et al. Q002) and Carson (1976), with some additional mapping by Subsurface Group (2008) on the Statesman prop€rty. Surficial geologic mapping in the site vicinity shows exposures of recent beach deposits, Vashon age glacial sediments, pre-Vashon non-glacial sediments, and older bedrock. Multiple glaciatious have occurred in the project vicinity during Pleistocene times (10,000 to 200,000 years ago). These glaciations, and intervening non-glacial periods, have deposited sediments in the project area that reflect a complex history of deposition and erosion Wells and outcrops on the Black Point Peninsula show that the bedrock is overlain by both glacial sediments from the most recent glaciation (Vashon Stade of the Fraser Glaciatioq which occupied the area about 19,000 to 13,000 years ago) and older non-glacial sediments. In some places, the Vashon glaciation is interpreted to have eroded away substantial thicknesses ofpre-Vashon sediments; urhereas in other areas the pre-Vashon non-glacial sediments are observed closer to the land surface. The Vashon glacial deposits are interpreted to be thickest in the western and central portions ofthe peninsulq whereas in more eastem portions ofthe peninsula the older non-glacial sediments escaped deep erosion, and are observed cropping out on the south-central and south-east beach bluffs. Vashon glacial sediments include a sequetrce (from bottom to top) of advance outwash, glacial till, and spotty occunences ofrecessional and ice-contact outwash. As the glacial ice known as the Puget Lobe advanced into the project area, meltwater steams began depositing advance outwash deposits; Coarser sediments (e.g. sands and gravels) were deposited in fluvial (stream) environrnents, whereas finer sediments (e.g. silts and silty sands) were deposited in glacioJacustrine (ake) environments created when portions ofthe Puget lobe blocked drainage of the meltwater sreams. As the Puget Lobe advanced into site vicinity, advance outwash deposits were overrun by the glacier and a dense mixture ofsilts, sands, gravel, cobbles and boulders known as Vashon glacial till was deposited under the advancing glacial ice. As the glacier retreated, the project site experienced active ice margin deposition and later ice stagnation. Glacial Lake Leland began draining and releasing large volumes ofwater that flowed through the arca, eroding advance ounrash and till in some areas and depositing recessional outlvash in others. Large stagnant blocks ofice eventually melted and produced deep localized depressions known as kettles. Sqrficial geolory on the Black Point Peninsula is dominated by exposures ofglaoial till, ice-contact deposits and recessional outwash. Older Pre-Vashon non-glacial deposits are interpreted as part of the Whidbey Formation. They are composed of very dense sfratified fine to coarse sand interbedded with gravelly sand with occasional 2 to 6-inch thick clayey silty beds. The sands and gravels are fluvially deposited with a source area in the Olympic Mounain foothills to the west. The bedrock rmit of the Peningula is knounr as the Crescent Formation (basaltl, locafed on the strrface along its northem and east-central portions. The bedrock is ocposed on the northeast comer and the eastern-central portions of the Black Point Peninsula and in the foothills northwest and southwest of the peninsul4 bedrock is also known to be close to land surface in locations immediately west of the peninsula Howwer, it is not ccrtain how deep the Crescent Formation extends below the srrrface, in the southern portion of the Peninsula. Wells have only penetrated the Crescent Formation on west of Highway 101 and indicate a sepante aquifer that is disconnected from the Sea Level aquifer. The bedrock surface in the project vicinity has be€n shaped by former glacial episodes and by the Duckabush and Dosewallips rivers. On the Black Point Peninsula, an e'rosional valley formed during prior glaciations is interpreted to hend north-south tbrough the westem and ceirtral portions ofthe peninsulq and has beetr fiId in by both glacial and non-glacial sedimenrs. GROUNDWATER OCCURRENCE Groundwater in the vicinity of the Black Point Peninsula occurs in the Vashon advance outwash deposits, the pre-Vashon non-glacial drposits and to a lesser extent in bedrock. Because the Vashon and pre-Vashon deposits have no intervening low-permeability aquitar4 these two unis form a single aquif€r where both are preseut below the regional water table. For the purpose efthis lgperg saturated conditions within either or both ofthese units is referred to as the "sea level aquifet''. The sea-level aquifer is can be moderately productive, and is capable ofproviding several hundred gallons per minute to properly constructed wells. In contrast, bedrock produces low quantities of groundwater from fractrnes, and therefore constifutes a minor aquifer in the study area The following points describe salient featwes of the groundwater flow system beneath and immediately adjacent to the Black Point Peninsula: 1. Investigation of hydrogeologic conditions in the bedrock.aquifer immediately west of the Black Point Peninsula concluded that the bedrock and sea level aquifers are relatively separate and do not exhibit sigrificant hydraulic continuity with one another (Aspecq 200Q. This conclusion was based on aquifer testing conducted at the Tudor Well (water right application G2-29065), which found that drawdoum in the bedrock aquifer did not propagate to the glacial aquifer and that chloride concentrations increased sigrificantly in the bedrock aquifer but remained stable in the glacial aquifer system. Page 11 2. The sea level aquifer generally occnrs under unconfined conditions. The till which overlies the aquifer is somewlrat discontinuous. No springs or seqrs weFe identified or sampled from the sea level aquifer by the Subsurfacc Crroup (2008). The top ofthe sea level aquifer isjista few feet above sea level on most parts of the Peninsula, whereas the aquifer base is well below sea level. Most wells tap this aquifer, but none pene-trate the entire thickness. 3. The sea level aquifq is expected to be moderately tansmissive based on sedimeirtary textures and aquifer lhickness. A 24-horn, 65 gallons-per-minute (gpm) pumping test was conducted at the American Campground on the project site, aud showed a delayed yield r€sponse q/pic8l ofunconfiaed aquifer conditions (Subsurface Group, 2008). Early-time data from the aquifer test provided an estimated tansmissivity of approximarcly 2,500 ff/day and a corfined storago coefficie,nt of 0.0007 (PGG; 2009). Over timefizmes of months to years, rmconfined storage coefficieirt values (e.g. 0.1 to 0.2) are expected in the sea levcl aquifer. 4. PGG estimated precipitation recharge to the Black Point Peninsula based on precipitation and temperature data from Quilcene gage'2 SW' (456846) over the period from 1948 through 2005 and the observatiou that most precipitation infiltrates into surficial soils without sipificant runoff(Subsurface Group, 2008). Using a proprietary version of the USGS "Deep Percolation Model", PGG estimated that out of an average precipitation of 55.4 in/yr, associated rccharge is on the order of37.7 in/yr with losses to evapotranspiration of about 17.7 in/yr (PGG,2009). Potential evapotanspiration was estimated to b€ 26.9 idyr. In addition to recharge from precipitation, the peninsula receives recharge from the foothills to the west, likely as a combination ofsubsurfabe groundwater flow ('subfloui) and surface runoff. 5. Groundwater discharge from the Black Point Peninsula primarily occr:rs to maxine water, but may also occur to small surface-water features and to gromd{/ater wells. The peninsuta is surrounded on three sides by the' marine waters of Hood Canal. Groundwater in the sea level aquifer discharges to marine water to ttre north (along Pleasant Ik$oD and towards the south- An eastem discharge pathway may also occur, but is at least partia[y blocked by bedrock 6. Groundwater elevations were mapped at select monitoring wells on the peninsula by the Subsurface Group' (2008). The mapping shows groundwater elevations on the order of 9 to 10.5 fe,et NGVD88 in central portions of the peirinsula (at wells MW-3 and VW?-6). Higher groundwater elevations (15.2 feet NGVDSS) are observed along the western peninsula near SRlOl, likely due to the effects of groundwater.recharge from the uplands to the wesl An anomalously high groundwater elevation is observed along the eastem portion of' the southern coastline (27.5 feet NGVD88 in Well MW-2), urhich PGG interprets as possibly affeoted by subsurface bedrock topography. Based on the geometry of the peirinsula and its hydro-geologic tamewor*, it is reasonable to e:rpect groundwater flow towards the southern and northem coast-lines, a possible flourp*h towards ttre eastem coastline (depeoding on the zubsurfacc oocumence of bedrock.towards the east), and higher groundwater elevations in the wpstern and central portions ofthe peninsula. '7. PGG pcrformed a preliminarywater balance for the peninsula. Precipitation rechargc is estimated to be approximately 2,230 aflyr over the entirc 710.'acre pe,ninsula and 785 atlyt over the 250-acre project site based on a recharge rate of 37.7 in/yr. In developing the analytic element groundwater flow model, PGG produced one interpretation ufiere recharge inflow (sribflow) from the $,sstem foothills was estimated to be on the order of 100 aflyr, although other interpretations could.also be developed" Out of a total groundwater inflow of 2,330 afly., cuilent groundwater withdrawals are estimated to be on the order of 47 aflyr (about 2 percent oftotal recharge). This rough estimate is based on an assumed 300 gpd water use at 140 residences (the Pleasant Tides Water Coop system serves a total of 103 hookups, the Black Point Commercial Power . water system serves 6 hookups, and about 30 well-log locations are contained iu Ecology;s online well log database). Given that existing residences predominaofly employ septic systems, at least half that groundwater withdrawal is re-introduced to the groundwater flow system as septic efluent. On a net basis, about 99 perc€xil of the recharge to the peninsula is curreirtly unconsumed by pumpins. Most of that recbarge is e4pccted to discharge to marine water, although a small portion may discharge to various minor surface-water feanrrcs. 8. Given that the Black Point Peuinsula is surounded on three sides by marine water, both the sea level aquifer and the bedrock aquifer are potentially vulnerable to saltwater intrusion. The potential for saltwater intrusion depends, in part" on the relative balanoc between freshwater flushing through the aquifer and the magnitu6" ofgroundwater withdrawals. The bedrock aquifer system appears to be highly susceptible to intusion under small to moderate ratcs of withdrawd. High chlorides plague the Tudor Well and Pleasant llarbor Well #2, nrhich are both completed in bedrock. In contrast, the Pleasant Tides Well and Pleasant Harbor Well #3, both completed in glacial sediments, have no appaxent issues with chloride. Seawater Intusion is fiuther discu&sed in this ROE in a zubseque,nt section entitled Seawater Intrusion. Page 12 GROUNDWATER AVAILABILITY Pleasant Herbor WelI Construction The existing (former American Campground) production well is located in the cental portion of the Black Point Peninsula in the SW % SE % Section 15, Township 25 North, Range 2 West W.M. The well was completed in Jnly,1972 to a total depth of 271 fee! approximately 2,100 feet inland from the sor$heastern shoreline of the Peninsula The land surface elevation at the well head is 145 feet above meau sea lsvel (MSL). The well is screened in the sea level aquifer (Pre-Vashon non-glacial deposits) from 215 to 270 feet below ground surface (bgs) (-70 ft to -125 ft MSL). In May, 200E the static water level in the well was 136.1 feet bgs (S.74 ft MSL) (Subsurface Group, 2008). In addition to the existing former campground weU, two additional production wells will be constucted on the Pleasaot tlarbor prcperty. One of these two new wells is intended as a possible replacement sf 1fos QamJiground. well whibh is an older well with possible infrastructtue limitations. The other poteirtial new well is to be locaM on the southeastern portion of theproperty, approximately 340 feet from the southern shoreline of the Hood Canal in Section 22. To date, availability has only been established at the Sectioo 15 location, and based on the analysis of PGG (2009) and Pearch 2010). Monitoring Vy'ell "MW-2" was installed at the Section 22 location, encoutered grouudwater at a depth of 15 I feet below land surface; however, aquifer testing at this location would require installation of a larger test or production well. As previously noted, Well MW-2 has an anomalously high groundwater elevation that may be indicative of a relatively high zubsurface bedrock elwation, and which could limit available groundwater flow to aproduction well instatld atthis location Becruse groundwater eveilability et the Section 22 gite has not yet been esteblished, epproval of this Permit is br$d solely on the at'tributeg of the Sectiqn 15 sitc. Before the applicant would be allowed to withdraw groundwater from the Sestion 22 locatiorq they would need to: l) install and test a new well, 2) show that the aquifer test data suggest sufficient availability at the site, and 3) show thd pr.mping from the site will not causc n€w impairment to zurrormding senior wder-rigfut holders or be dehimerilal to the public interest due to saltwater intusion conoents (see Section on '!rovisions'). Regardless of whether of the Section 22 site provides sufficient water supply, Ecolory and PGG find that zufficient zupply for all tbree wells could be derived from the Section 15 site. Groundwater availability at the Section 15 site is established based ou: r Interpretation of the 24-hour, 65 gpm aquifer test performed on the American Campground Well; r Iaterpretation ofshort duration well testing at higher rates (250 and 307 Spm) by the driller; o Estimated long-term aquifer drawdoram based on aquifer property estimates; an4 o Consideration ofavailable drawdoum in properly constnrcted production wells. A conservative €stimate of maximum total drawdovm at the American Campground Well pumping at 300 gpm is 54 feet, however drawdown in multiple production wells would be considerably less if the pumping were distributed befween two or more wells. The American Qsmpground Well is screened between 275 and,270 feet bls and has a static grouadwater level of 135 feet bls. This provides an available drawdown qf about 80 feet, qf rrvhio[ 6 minimum of 15 feet should be rcserved for a well pump and seasonal water-lwel fluctuations, thus providing a usable drawdown on the order or 65 feet. Thus, available drawdown appea$ to be sufficient to supply either the American Campground Well pumping at a maximum pumping rate of 300 gpm or two wells in this general vicinity dividing this total pumping. Water balances for the area indicate that estimated groundwater recharge on the Black Point Peninsril a Q.,330 aayr) is sipificantly higfuer than the annual allocation associated with the water right Qsa aflyr). Therefore, water availability is considered highly likely both at the scale of the production well and the aquifer system. POTENTIAL IMPACTS TO EXISTING GROUND AND SURFAGE WATER RIGHTS The proposed water right would withdraw as much as254 aflyr of groundwater from wells completed within the sea level aquifer. This tanslates to an avqage annual withdrawal of 158 gpm. The water right would be limited to a maximum instantaneous withdraural of 3 00 gpm from three wells. A portion of this water right quantity is expocted to be supplied from surface water sources - ufrich are addressed in a separate ROE, or from reclaimed water. However, for the purpose of evaluating impacts, a conservative approach assumes that the full quantity of water could be pumped from the sealwel aquifer. Page 13 PGG developed a groundwatcr flow model to imp,rove estimates of aquifer transmissivity bencath the peninzula to estinste draudown associated with thc pr,oposcd pumping, and to estimate seawater intrusion potcntial assooiated with pumping eGG, 2009). Several model scenarios were developed to address ucertainties regarding aquifer ocourrence (i.e. occltrrence of subsurface bedrcck boundaries), grdtmdwater zubflow from upgradient (areas west of Highuay I 0 I ), and alternative interpu,etations of aquifer transmissivity by the Subsurhc€ Group (2008). Modeling resulB found that drawdowns assooiated with the pumping scenarios are relativcly smalt amoss the peninsula (predicted drawdowns.were ou the order of scveral tmths of a foot iu near coastal locations), and are not expected to impair the ability of existing wells to obtain customary wdll yields; SEAWATER INTRUSION lncreasing chloride concentratious in nearby domestic wells as a result of scawater intusion is a concem to many individual well orryners and residents on the coast of the Black Point Peninsula In response to these concerns, Ecolory conducted a study to determine bsseline chloride levels in existing coastal domestic wells in order to establish a future groundwatsr monitoring stratery for the Pleasant Harbor development. The goals of thiS study werc to: (1) wahiate the gmaal extent of seawater intrusion; and (2) assess the need for future monitoring of groundwarcr levels and chloride concentrations. Perch lly*ogeologic Memo Port I: Chloride Sotpling in Coastal Domestic Wells onthe BlackPoint Peninsula, JeffersonCounty, Washingto4 pertain@to Water Right Application G2-j0 I 46 Jaru.ary 20 I 0. The results of this sttrdy allow Ecology to give Pleasant Harbor appropriate provisions pertaining to water quality aird water level monitoring. Specific mitigation measures will be ideirtified and applied to Pleasant Harbor in case their production wells increase chlorides levels in any neighboring wells. This teport describes the findings ofan investigation ofgeology, groundwater quantity, ground-water quality, and seawater intrusion potential on thc Black Point Peninsula, Jefferson County, Washington. Ecology fnds that seewater intrusion is not a widespread problem on the Peninsula - chlrcride concentations are within acccpable limits in most domestic wells. However, there are two ar€as near the shoreline where local intrusion appears to be indicated in the seaJevel aquifer. Iocal upconing ofthe saltwater wedge was evident in two domestic wells that exceeded the MCL of 250 mg/L (Washington State Deparhent of Health drinking water standards). The 367 feet deep well on Corrrorant Drive (ACY954), 3,100 feet west of the ACG well, was sampled in Augusg 2009 and'had a chloride concentation of 3,500 mg/L. The 58 foot well on Black Point Road (ABAI l2), 2,400 fcet northcast of the ACG well, was sampled in September, 1998 and had a chloride concentration of 12,053 rlg[L. It is assumed that both of these wells were originally drilled at a depth within or close proximity.of the saltwater wedge and high chlorides have forced these wells to be unusable. However, additional domestic wells sampled in August, 2009 indicate there is not presently a wide-spread lateral intrusion occnning in the sea-level aquifer (well water in 8 other domestic wells e:rhibit chlorides to be less then 26 wglL), More detailed reporting of Ecology's sampling results can be found in Pearch (2010). Regardless, domestic wells on the coast of Black Point Peninnila are still potentially at risk of a wide-spread latcral seawater intrusion as a result ofPleasant Harbor's proposed groundwater withdrawals. Thus Pleasant Harbor must continue to monitor chlorides in production wells and monitoring wells @er Pleasaut Harbor's Groundwater monitoring Plan) and selected private domestic wells (per Jefferson County Ordinance 01-0128-08 Neighborhood Water Supply Prograril). (See attached documents.) Chloride\Seawater lntrusion fonitorlng Recommendaflons Both Ecology and Jefferson County have agreed that monitoring for chloride, electical conductivity and static water levels is essential for ensuring that Pleasant Harbor will maintain an adeguate water supply for the proposed Pleasant Hartor wells and for thc existing domestic wells oo the coast of the Black Point Peuinsula As a condition of permit issuance Bcology is requiring monitoring of both onsite production wells and a series of dedicatd monitoring wells. Ilrith Ecologr's irput Pleasant llarbor has establishd a monitoring plan that will monitor for saltuder intrusion in all Pleasant hrbor wells and nearby dome*ic wells. Continued compliance with the Groundwater Monitoring PIan is a requirement of the permit issuance. The monitoring plaraddresses thc location of both dedicacd and private monitoring wellg the frcquency of data colleqtion and sampling parmeters. Pleasant llarbor is rcquired to srmmarize this data in an aonual rqort u,ith will be submittcd to Ecolory for review. The plau is intended to bc adaptable and can be modified if vuarranted based on monitoring rcsults. In addition to the Monitoring Plan, Jefferson County's approval of.the FEIS completed for Pleasant llarbor requires the projest to be zubject to a Neighbortood \ilater Supply Progrem which establishes a smtegy to protect domestic wells, as well as provide a contingency plan should other water users experience high chloride levels. The Neighborhood Water Supply Program is required by Jefferson County in Ordinance 0l-0128-08, and also by this water right permit The Neighborhood Water Supply Program requires Pleasant Harbor to provide access to its water system by neighboring water users if saltwater intrusion becomes an issue for wells on Black Point peninsula. (see Neighbortood Water Supply Program for details) PEge 14 CONSISTENCY WITH WATERSHED PLAN NING In 1998, the Washington State Legislaturc passed the Watershed Management Act, codified in the Revised Code of Washington RCW 90.82. This law focuses on addressing water quantity, water quality, fish habitat, and instreasr flow at the local level. In the Skokomish-Dosewallips watershed (WRIA lQ, the Planning Unit consists of Mason and Jefferson colmties, the Skokomish Tribe, t}te Port of Hoodspor! Mason County Public Utility Disfrict #1, local community groups, citizen representatives, and other environmental, developmen! and recreation interests. The WRLA 16 Planning Unit has been working together on watershed planning since 1999. The WRIA 16 planning Unit (also knoum as the Skokomish-Dosewallips Water Resource Inventory Area) prepared awatershed plan for the area which was adopted by the Boards of County Commissioners in both Jefferson and Mason Counties. The plan includes numerous recommendations to protect and enhance the water quality, water resoruces and habitat througfuout the watershed. While the group has opted not to recommend any specific flows for the watershed and has directed Ecology to work direcfly with the Skokomish Tribe to formally establish insneam flows, there are recommendation in the plan related to this project, specifically: l. Develop a golf course management plau that addresses both water conservation and use of pestioides and fertilizers (see plan recommendation 3.2.4). 2. Conduct compiehensive water quality monitoring at the site. 3. In putrership with a reoopized land tus! permanently protect the shoreline buffer area with a conservation easemert to ensure that no stuctures are dweloped there and fhat native-vegetation is maximized and retained. 4. Evaluate and address the indirect and cumulative impacts sf rhis developnent on the Dtrckabush and Dosewallips River watersheds, including indirect and cumulative impacb to habitat for listed species and to health.of Hood Canal. The project proponents are aware ofthe goals ofthe watershed plan, and have ocpresSed intent to develop this project accordingly. Other components of the Statesman project that are addressed by the watershed plan include: Exploring water reclamation from wastcwat€r heafuent plants. Water from wastewater treatrrent plants can be teated to such a high level that it can be reused safely for nondrinking purpos€s zuch as inigation, streamflow augmentation, or aquifer recharge. Statesmen intend to use as much non-potable water as possible to meet its needs. Enact low-impact development requirements to minimize i6p6lvieus surface and maximize onsite management of storm water, Low Impact Development (LID) is an innovative approaoh to storm \ilater management that shives to manag€ storm water on-site rath€r than convey and manage it thrd"gh large, costly infrastucture investnents. The proposed project is desiped to ma,ximize storm water rccharge, as well as control runofffrom the site. a CONSIDERATTON OF PROTESTANT'S GONGERNS: A protest letter received from Mr. Gerald Steel on behalf of the Brinnon Gronp, @rinnon) raise.d several issues regarding this project, specifically that l. The applicetions filed by the applicant were incomplete because the locations of the wells are not specified. PGG notes tlat these applications were accepted as complete by the Deparhent of Ecology. As required by statute they included information regarding the rate of withdrawal and proposed locations of the production wells and diversionpoints defi:red by quarter/quarter section. The applications w€re supplemented by other planning documents specifically the "Water Management Plan" which is included in the references. Two wells were originally proposed. The first well (American Campgrormd Well) is already installed and testcd" The second well location has not been teste4 andPGG/Ecology note that it may not provide favorable hydrogeologic conditions for a production well. ln that case, the second (and third) wells can be located adjacent to the American Campground Well site, and ttre site is expected to provide sufficient yield (see water availability section). 2. The project has. not been sufriciently well defined and that it is dfficult to assess ftrture water demaud. The Protestsnts note discrepancies in thq dgtril ofthe project between the various planning documents. Pago 15 PGG agrces that this is a large complicated project and that numerous planning doct'ments have been prepared over the lengthy plnnning process. While there is some variation in certain figrnes, the brcakdown ofthe project's various component (potable, non-potable) and the source ofthat water (groundwater, rain captur,e, reclaimed water) is foundto be generally consistent. Giventhe lead tim: needed to secure a water right it is not uncorlmon for the details of projecs to change slightly so long as the oricinal intent remains consistenl 3. Thet some of tte existing water righ6 characterized as aVailable for the Recort are not valid in the full cerfficated amount end should not be considercd for additionel dwelopmenL The Prctestants ako note tret actuel weter use on the peninrula hes not been adequatcly asEcEled. PGG concru with the protestant's comment that not all of the water characterized as available is necessarily in good standing and we have factored that into the overall water budget for this projecl as discussed in the section of this ROE entifled Other Water Riehts Appurtenant to the Proj€ct Since water use records are not available from thb American Campground well, and water use today is modest, the applicants have requested that this water right not be considered as an available source ofsupply 4. That there ere uncertainties in the hydrogeological assessment conducted for the project and issue of adequate water availability ic unresolvcd Prior to the issuance of a water right permit Ecology must be able to make a finding that u/at€r is available without impairment to neighboring wate,! users or the surouuding environment. As detailed in this ROE under the section entitled Water Availability, available hydrogeologic infolrmation suggest that sufficient groundwater is available for appropriation at the American Campground site.. 5. That no analysis of the potentid impacb to eristing water righh has been done, and that gea water intrusion could occur as a result ofthis proiect This ROE addresses both the risk to surrounding water users as well as the potential for seawater intrusion. Interference drawdowns on neighboring wells due to pumping are expected to be relatively small and should not impair water availability. Supplemental information detailed in Ecology's seawater intnrsion assessment indicate that while coastal aroas ile always at some risk for seawater intrusion that this project, as proposed, will not withdraw enough water to adversely impact ttre water balance. The applicants are zubject to stringent monitoring requirements as described in Pleasant llarbor's Groundwat€r Monitoring Pla& ['INDINGS Under the provisions of RCW 90.03.290 and 90.44, a water right shall be issued upon findings thet water is availablc for appropriation for a beneficial use and that the appropriation theroof, as proposed in the application, will not impair existing rights or be detrimental to the public welfare. Under state law the following four criteria must be met for a permit to be approved: o Watermustbeavailabler There must be 16 imFairment of existing rightsr Thewateruse mustbebeneficialo The water use must not be detrimental to the public inter€st Water Availability Water is available for appropriation The aquifer in which the Pleasant Harbor wells are completed is reasonably mn$nissive and capabie of supporting the additional withdrawals requested. Use of the proposed new production wells will be contingent on the applicant demonstrating th* they are properly constucted and adequirtely tested. The quantity appropriated reflects the amorrit needed to meet the needs of the applicant's intended use. Water is thereforejudgcd to be available for appropriatioo under existing Ecology regulations. Impairment of Erirting Righb The approval of this application will not impair existing rights. Giv€n the prov€n transmissivity and yield of the aqffq: the proposed groundwater withdrawals will not impair existing rights. Beneficial Use\Purpose of Use Thesc applications were originally filed for a purpose of use designatcd at Municipal Supply, which encompasses avariety of water uses including domestio, commercial, industrial and inigation. Sincc the original filin& thc King County Superior Court mled that several sections of the munioipal water bill were unconstihrtional. One of tbo scstioDs that uns struck was RCW 90.03.015(aXa) u/hich defind zuppliers and municipal supply purposes. The Attomey General's Office has interpr€ted tb€ ramificatioas of this ruling to mean that eirtities Page 16 such as Statesmen, and uses ofwater such as proposed for Pleasant Harbor, do not qualifr as municipal rights. Accordingly this permit will be issued for Multiple Domestic Supply, and tnigation. According to RCW 90.14.031, both irrigation and multiple domestic supp.ly are considered a beneficial use of u/Bter. Public Interest The use of the requested allocation of water for public domestic use and irrigation puqrcses is consistent with the public interesf As additional protection due to the risk ofseawater intrusion in coastal areas conditions requiring monitoring will be placed on this water right permit, as well as included in the permits issued by Jefferson County. RECOMMENDATIONS Under the provisions of RCW gO.O3.2gO and 90.2t4 a water right shall be issued upon findings that water is available for appropriation for a beneficial use and that the appropriation, as proposed in the applicatioq will not impair existing rights or be detrimenal to the public welfare. I recommend approval of this application and issuance of apermit authorizingwithdrawal of 300 gpm, nd,254 acre-feet per year from 3 wells, (l2l acre-feet for domestic zupply and 133 for inigation). The period of use for domestic supply shnll be year-round as needed while the irrigation portion may be exercis€d from April 15 to September 30th. Reviewedby: Crane WderR€sourc€s Progrm [f you rced this publication in qn alternate fortnat, please call Water Resowces Progron at (360) 407-6600. Peisons with luwing loss can call 711 for Washingon Relay Service. Persons with a speech disability con call 877433-6i41 REFtsRENCES Pearc[ J. January l4,zlll,Hydrogeologic Memo Part I: Chloride Sampling in Domestic Wells on the Black Point Peninsula, Jefferson County, Washington Pearcfu J. January 14,20L0, Hydrogeologic Memo Part II, Pleasant Harbor Monitoring requiremeirts aod aquifer testing review. Pacific Groundwater Group @GG), June 4, 2009, Technical memorandum, Pleasant Harbor Modeling Analysis, To Phil Crane, Frology; From: Peter Schwartzuran, PGG Subsurface Group, LLC; December 17 , zWE, Water Supply and Groundwater Inpact Analysis, Pleasant Harbor Marina and Golf Resort Brinnon, Wdshington, Prepared for Statesman Group, SDEIS Groundwater vl-4. Page 17 t /frrffi; Project Report Form Water ts Self Assessment lf you need this publication in an alternate format, call (800) 525-0127. For TTY/TDD call (800) 833-6388 DOH Form 331-370 (Updated 08/10) Dniin q Etuiwilntel Halh W@ afDd*htw@ Existing System Capacity - based on water right limits Proj ects Productior/withdrawal with New Project On-line Projected System Capacity Status (excess or deficiency ofwater riehts) Permit Certificate or Claim # Name of rightholder or claimant Priority Date Source NameA.Iumber Primary or supplemental Maximum Instantaneous Flow rate (Qi) Maximum Annual Volume (Qi) Maximum Instantaneous Flow Rate (Qi) Maximum Annual Volume (Qa) Maximum Instantaneous Flow Rate (Qi) Maximum Annual Volume (Qa) Permits/ Certificates t.G2-30436 Pleasant Harbor Marina and Golf Resort 2007 Octoberll N/A Primary 300 gpm 121 Acre Ft No increase No increase No deficiency No deficiency 2. G2-24359 Pleasant Harbor Marina and Golf Resort 1976 December l3 N/A Primary 60 gpm 3 Acre Ft No increase No increase No deficiency No deficiency Claims I. NONE Total 360 gpm 124 AcleFt Existing Limits on Intertie Water Use Projected Productior/W ithdrawal with New Proiect On-line Current Intertie Supply Status (Excess/Deficiency) Intertie Name/Identifier Name of Purveyor Providing Water Marimum Instantaneous Flow rate (Qi) Maximum Annual Volume (Qa) Maximum Instantaneous Flow rate (Qi) Maximum Annual Volume (Qa) Maximum Instantaneous Flow Rate (qi) Maximum Annual Volume (Oa) I. NONE TOTAL To return form, please see reverse side. Please retum completed form to the Office of Drinking Water regional office checked below, E Northwest Drinking Water Department of Health 2042572nd Ave S, Suite 310 Kent, WA 98032-2358 Phone: (253) 395-6750 Fax: (253) 395-6760 E Southwest Drinking Water Department of Health PO Box 47823 Olympia, WA 98504-7823 Phone: (360) 236-3030 Fax: (360) 664-8058 E Eastern Drinking Water Department of Health 16201E lndiana Ave, Suite 1500 Spokane Valley, WA 99216 Phone: (509) 329-2100 Fax: (509) 329-2104 E X P AN S I ON S Planned perDOH chaft 5 - 2 gallons per notes Unit Capacity Analysis Units patron per day seats total 125 Bistro 14 hrs 50 with toilets | 7 + with lounge 2 seats;@5Uo/o I 9 350 peak usage divided by 1.75 for MADD for expected ,[JSE'' patrons per gallons per consumed day day per day 3,150 3,150 ERU's E x I S T I N G USE 1,800 10 USE 6,847 39 Well# I 1440 pump flow @ 7.2 gpm: Well # | 1440 pump flow @ l0 grm = Well # I 1440 pump flow @ 15 gpm : Well # I 1440 pump flow @ 18 gpm: 5.2.1 Maximum Day Demand 10,368 14,400 21,600 25,920 gal I gal I gal / gal / MADD ERU's duy day day day Based on the information available, DOH recommends a MDD to MMAD peaking factor of: .7.7 for water systems in Western Washington. 4 @t.s 4@t.s I 2 310 I I l8 4t I Harbor Harbor House - kitchen use Swimming pool - Bathhouse Central bath - and toilets Store per toilet room Laundry hrs - washing machines deli seats : @50% patron per hr per seat all moorage @67% 4 4 1 I 300 60 300 80 1 I aJ I 75 8.5 28s DOHchart5-2 400 9 6 6 30 8 150 190 1,710 1.710 ERU's 70.2 50 l0 l0 l0 35 400 52s0 400 36 174 2,700 1,481 2,700 1,481 8,647 49 date time WATER USAGE gal Ave / day comments 9,669 I 1,008 9,366 9,522 7,443 7,906 6,208 3,127 4,747 6,768 6,438 7,897 7,659 7,346 7,471 6,455 6,692 5,540 4,677 3,729 6,968 5,669 6,437 construction: rebuild pool, fill pool and hot tub6,431 6,005 jul 2013 171,,L78 jun 201 I jul 201 I aug 201 I sep 2011 oct 201 I nov 201 I dec 201 I jan2012 feb 2012 mar 2012 apr 2012 may 2012 repair leak in pool area drain and fill pool monthly gallons 299,751 341,257 280,977 295,782 223,278 245,098 L92,460 88,326 L47,L51, 203,037 !99,578 235,998 237,423 227,729 23L,602 193,657 207,463 156,191 744,995 775,592 196,856 175,742 193,'J,Lg 199,347 180,148 t99,21!MADD anomaly anomaly used used 2012 2012 20t2 20r2 oct2012 nov2012 dec2012 jan2013 feb 2013 mar 2013 apr 2013 2013 jun 2013 348,619 MMD