HomeMy WebLinkAbout054Michelle Farfan
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Sent:
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M ichel le Farfan < M Farfan@co jefferson.wa.us>
Monday, April L7, 2017 10:04 AM
Susan Porto
Your comments
Porto comments on NWSP.pdf; Porto(JeffCoHealth)-Decl--L0CommentResponseMemov
Susan.pdf; Porto Comments 8-20-2009.doc
Hi Susan:
This is what I found in David's file... Hope it helps
Michelle Farfan
Associate Planner, Pleasant Harbor MPR Lead
Jefferson County Department of Community Development
621 Sheridan
Port Townsend WA 98368
V: 360-379-4463
F:360-379-4451,
mfa rfa n @co. iefferson.wa. us
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Public Records Act, a state law found at RCW 42.56. Under the Public Records law the County must release this e-mail
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production to the requester according to state law, including RCW 42.56 and other state laws.
1
We appreciate the opportunity to make comments and recommendations to the report of examination
We are responding with the understanding that the two memorandums dated February 25,2070
contained within the Report of Examination have replaced the memorandum labeled Revised Pleasant
Harbor Groundwater Monitoring Plan from Scott Bender dated December 22,2009 and the Water
Supply Program of December 29th, 2009.
Comments pertain to the "Pleasant Harbor Golf and Marina Resort Neighborhood Water Supply
Program" (NWSP), and the incorporated 'Pleasant Harbor Golf and Marina Resort Ground Water
Monitoring Plan' (GMP) memos, both dated February 25 zOtO.
Jefferson County Environmental Health offers the following comments in direct response to the two
memos as presented:
Pleasant Harbor Golf and Marina Res_ort Neishborhood Water Supplv Proeram
1. Monitoring Plan:
The NWSP memorandum refers to the project site as not being located in a High Risk SIPZ Zone.
Just to clarify, we have updated our seawater intrusion zone GIS mapping with the water quality
information submitted by John Pearch in his Hydrogeologic Memo Part 1, 2 and attachments,
dated January 14th 2010.
For items (a), (b), (d), and (i), indicate where these monitoring activities will be conducted. Will
any of these activities occur at offsite wells? For example, will you be installing flow meters on
offsite wells per item (b), or do you mean the onsite monitoring wells?
a
a
a
a
For item (f), please support this assertion.
For item (g), more information is needed. What hydrogeological analysis are you referring to? ls
it a delineation of the unconfined ("sea level") aquifer? ln any case, who will be conducting the
analysis and how will the data be provided?
2. We surmise that for (d), you are referring to the GMP's network of eight wells presented in
Figure 1. For the (five) wells where water quality will be sampled it seems the samples should be
taken at a depth that will give an early indication of seawater intrusion. ls this plan for
monitoring wells adequate both in number of wells and frequency of sampling to allow for early
detection of a "potential widespread lateral sea water intrusion" as J. Pearch has referenced.
3. Recharge areas:
You indicate that the "identification of an impact" is in the county's SIPZ program. Please be
specific and define the identification of an impact rather than simply referencing the SIPZ
program,
a
4. As a result of John Pearch's report, high risk SIPZ zones have been created on Black Point
Peninsula that impact future development reguirements. You indicate that Pleasant Harbor will
"set aside recharge areas to mitigate an impact scenario". Please clarify what you mean by this
statement,
5. lnitial Mitigation Measures:
ln the event of an impact from seawater intrusion, you intend to implement "a plan to
mitigate". Such a plan should be described in greater detail. Lowering pumping rates or adding
points of withdrawal should be included as a subsection of the program and quantified.
a
a
a
a
6. Water Supply Replacement:
The Neighborhood Policy required by Jefferson County is not intended to circumvent state
water laws or any anti-degradation requirements. The replacement strategy is unlikely to
mitigate continued impacts to the unconfined aquifer, especially if the measures described in
paragraphs 2 and 3 have already been unsuccessful.
We concur with all of John Pearch's comments /recommendations in reference to this section
with specific emphasis as follows:
o 4 (a) "Pleasant Harbor should pay the cost of hooking up and maintaining a
water supply to the impaired individual and that the homeowner's
responsibility will be limited to the cost that the homeowner would have
spent on electricity running their old system."
o 4 (b) "Ecology recommends that all wells be included on the Black Point
Peninsula as long as they are completed in the Sea Ievel aquifer. However, if
there is excess of 10 neighboring residents who ask Pleasant Harbor to
sample their well, Pleasant Harbor should choose only 10 wells that are
appropriately located between the proposed withdrawal and the coast, and
not focus on one specific area. This will help to evaluate if a widespread
lateral sea water intrusion occurs."
Is there a plan for Ecologr to "delineate the area of influence?"
o 4 (b) "Ecology also recommends in the case if any particular neighboring well
that experiences a 10o/o increase in chloride but is still below 100 mg/L, that
same well should be sampled at least two additional months following. This
will provide a much clearer picture of potentialwidespread lateral sea water
intrusion."
o "Ecology strongly recommends that any decrease in frequency of monitoring
should only occur 10 years after the resort reaches full build out."
Pleasant Harbor Golf and Marina Resort Ground Water Monitoring Plan
As stated above we believe that the monitoring program should be extended to a period "beyond full
build out."
General Comments:
We recommend that the two memos be combined as one cohesive monitoring plan
(neighborhood and groundwater) for clarity and consistency. ln addition, offsite wells
designated for monitoring should be located and identified, and a recorded notice to title be
executed to allow agency and Resort access for the purpose of implementing the plan.
a There is an inactive Group B public water supply (K and P Oyster Company WS# 23601 f ) that is
known to have nitrate levels in excess of State maximum contaminant levels. The owner is Ken
Gaul, APN 502153032. lt seems this should be considered as a part of a monitoring plan.
a ls Pleasant Harbor setting aside sufficient water right to supply full build out within the high risk
SIPZ, should this be necessary, or are they relying exclusively on the potential transfer of water
rights from the existing senior rights?
lf senior water rights show degradation, is it possible that Statesman would have to prove their
water system is not the cause vs. the other way around as stated?
We have concerns that the assessment does not address how low rainfallyears would affect
assumptions. What are the drought contingency plans?
Respectfully,
Susan Porto
Environmental Health Specialist 3
Jefferson County Public Health
a
a
a
SUBSURFACE GROUP LLC
PMB 154, 1992 S Elger bay Road.
Camano lsland, Washington 98282
(360) 631-5600
To:
From
CC:
Date:
RE:
MEMORANDUM
Garth Mann, Tom McDonald
Scott Bender
Craig Peck
December l, 201
REVISED
SUSAN PORTO, JEFFERSON COLINTY PUBLIC HEALTH
We are in receipt of comments made by Ms. Susan Porto of the Jefferson County Department
of Health. This memorandum provides some additional information and clarifies some of
initial responses. We provide the following responses:
Pleasant Harbor Golf and MarinaNeighborhood Water Supply Proeram
1. Monitoring Plan
a) Of the twelve domestic off-site wells sampled
concentrations in excess of 200 mg/I, which
classifies them as 'High Risk' wells. Ecology
the County, who then incorporated that
database. Under the program, a 1,000-
around the well in question; any future
withdraw groundwater from within this
protective measures" to prevent a
copy of the County's map is You will see that a very small part of
the protective zone falls on the P Harbor property. Our proposed
monitoring well MW-8 is just or outside of the boundary. Our water
supply wells will be over 1,800 away from the edge of the protective
zone. It is my understanding
of that 1,000 protective zone,
if the proposed water supply well is outside
no new measures are necessarv. Ms. Porto
issues the comment for c
necessary.
b) All items in Monitoring Item I will be performed at on-site wells only
Off-site well addressed in the Monitoring Plan. There is no plan
to install flowmeters off-site domestic wells.
c) Water quality collected during pumping of the American
Campground well during the pumping test, and from MW-2. The analysis
reports are attached.
I believe no further action on our part is
Thank you for your response to my comments. I will have to rely
your expertise to adequately address the concerns related to the
of this project on the aquifer. I also understand that Ecology has
ready reviewed this project and approved the water rights. I've limited
accordin - Susanres
Your statements in this regard were ,
"The existing well has supplied water
at similar to proposed rates with no
adverse impacts (chlorides = zero." I
don't understand how a pump test
can be equated to "similar rates" that
this project.are
SUBSURFACE GROUP, LLC sG0601-02
Memorandum to Statesman Corporation
December 1,2010
Page2
d) The hydrogeologic analysis referred to is presented in our Draft Water Supply
and Groundwater Impact Analysis Report dated December 17, 2008. That
report contains a narrative of our understanding of the aquifer and aquifer
conditions, as well as supporting water level and pumping test data.
2. The wells described in Item (d) and shown on Figure I of the Monitoring Plan
map cover the resort, concentrating on the borders of the property. The intent is
to monitor groundwater drawdown, which given sufficient drawdown for an
extended period of time is the principle indicator of the potential for sea water
intrusion. It is our opinion that the number of wells is more than adequate. The
depth of the wells is also adequate to monitor for these purposes. In addition, the
American Campground well is an exceptionally deep well; monitoring of
groundwater quality from this well will provide an understanding if upwelling of
saltwater could be occurring. As the project will be introducing more water into
the aquifer, we do not believe that a "potential [for] widespread lateral sea water
intrusion" exists; however, we have built a monitoring program and contingencies
to address the concerns of the community and to protect
community and resort itself.
3. Recharge Areas: We consider an 'impact' as
'High Risk' levels presented in the County's SIPZ
identify impacts in paragraph 4(b) of the attached F
Water Supply Program. Our opinions regarding the
impact are summarized on Page 18 of our
report cited above.
4. As noted in pages 16 through l8 of our December 008 report, the hydraulics of
the resort will be such that there will be more water recharge to the aquifer
This is largely a function ofduring operation ofthe resort than presently
collecting water from the roof tops and roadways and infiltrating it before the
water can evaporate be consumed by vegetation. Infiltration galleries will be
constructed beneath the golf course fairways that will be used to infiltrate excess
stormwater. These galleries will be placed around the resort to enhance aquifer
recharge. Attached is a preliminary facility map in which we have set aside
recharge areas as infiltration galleries.
5. At this time there have been many mitigation measures already incorporated into
a water supply plan that shows a net benefit to the aquifer. Beyond all of those
measures, there are options to add additional wells that will pump at lower
individual rates, to focus groundwater recharge to areas of concern, or even to
treat surface water. In our opinion these are suitable mitigation measures for
I'm not familiar enough with the
details of your project to
adequately comment on this.
My overall concern is whether
you have planned adequately
drought years and the
limitations of recharge
SUBSURFACE GROUP, LLC sG0601-03
Memorandum to Statesman Corporation
December 1,2010
Page 3
planning purposes, and the appropriate measures will be taken to protect the
community's and resort's water supply should a situation arise.
6. Water Supply Replacement:
a) We are not aware of the mitigation plans presented to be in violation of any
state law or policy. Based on our understanding of the hydrogeology beneath
Black Point, the monitoring and mitigation plans offered by the resort are
proactive and conservative.
b) As we have discussed with Eco other
conditions of the water are
unnecessarily diffi cult to
c) The monitoring influence from
the water supply
data from the of the
drawdown
L
2.
ite wells will be identified as the proj
The Gaul well can be considered for mon
with existing poor water quality may not
monitoring plan. Pleasant Harbor will use and
collected from the resort's monitoring network
stage
has been
of a well
compromised by construction or operation.
3. The water rights provided in the permit from Ecology have
with sufficient quantity for the development. The delivery
neighborhood plan to adversely impacted well owners,
by obtaining and consolidating the water rights
owners.
4. The process for addressing impacts to other
the
part of an impact assessment.
5. Groundwater monitoring at the site has
very low water years such as 2006 and
groundwater levels even in
Surface water storage will be
sufficient to supply more than one year of irrigation supply; however, the long-
term precipitation data do not provide any indication that the surface water
storage will not be replenished even in a dry winter.
from the wells.
This is a very
will
I don't believe you
have answered my
concerns here. To
reiterate a portion
of my comment
3126110, "...and
a recorded notice to
be executed to
allow agency and
Resort access for the
purpose of
implementing the
il
Doesn't it seem like
stability is a
nction of the fact
the well had
little use during
years?
SUBSURFACE GROUP, LLC sG0601-03
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l) Well locations are approximate. Domestic well locations
typically to nearest quarter quarter unless better known.
2) See Appendix for well logs
A
o
Monitoring Well Location (MW = monitoring
well; VWP : vibrating wire piezometer
Water Supply Well Location
Subsurface Group,
LLC
Pleasant Harbor Marina and Golf Re
Groundwater Impact Evaluation
Statesman Corporation
Domestic Well and
Monitoring Well
Locations
Project Number
sG060 l -03
Figure I
I
PLEASANT HARBOR NEIGHBORHOOD WATER SUPPLY PROGRAM
APPLICATION NO. G2.30436
February 24,2010
The following four elements to protect existing water rights concern water right
application no. G2-30436:
1. Monitorinq Proqram
This monitoring program meets and exceeds all requirements for a High Risk
SIPZ zone as defined by Jefferson County. Though Pleasant Harbor is not
located in a high-risk zone, the resort has committed these resources to assure
its neighbors and the County that the aquifer is being wisely used and protected
A copy of the Pleasant Harbor Groundwater Monitoring Plan, as revised
February, 2010, is attached and incorporated herein ("monitoring plan").
The following summarizes the monitoring program.
(a) Water quality samples will be collected on a quarterly basis.
(b) Flow meters will be installed.
(c) Pleasant Harbor will have a very thorough network of monitoring
wells (8) which will be used to document draw down conditions in
the aquifer.
(d) The network will include monitoring aquifer salinity conditions on
one-half hour increments.
(e) The locations of Pleasant Harbor wells will be located over 1,000
feet from any neighboring well or the shoreline.
The existing well has supplied water at similar to proposed rates
with no adverse impacts (chlorides = 0).
(g) Hydrogeologic analysis is completed
(h) Pleasant Harbor wil! route all site water into the aquifer in such a
manner that the aquifer will actually be receiving more water than
under existing natural conditions.
This program will be continued for five years or until the resort has
achieved fu!l build-out, whichever is longer.
2. Recharqe Areas. Pleasant Harbor will set aside recharge areas to
mitigate an impact scenario or provide access (connect) to neighboring parcels to
(0
(i)
Neighborhood Water Supply Program - Page 1
the Pleasant Harbor water system in the event of a problem with increased
chlorides (we also have the option to drillthem a new well). The identification of
an impact is already presented in the County's SIPZ program.
3. lnitial Mitiqation Measures. lf the monitoring program and evidence of
increased chlorides in neighboring wells show a probable salt water intrusion
impact on the wells from Pleasant Harbor's withdrawal of groundwater, Pleasant
Harbor will implement a plan to mitigate or minimize such impact by considering
lower pumping rates and/or adding points of withdrawal, in addition to recharge
as provided in paragraph 2 above.
4. Water Supplv Replacement. ln Jefferson County's approval of the FEIS
completed for Pleasant Harbor, Jefferson County has included condition P, the
Neighborhood Water Policy, which requires Pleasant Harbor to provide access to
its water system by any neighboring parcels if salt water intrusion becomes an
issue for neighboring wells on Black Point. Statesman proposes to expand and
define the terms of this policy as a condition of the water rights, as follows.
lf the initial mitigation measures stated in paragraphs 2 and 3 above do not
correct or resolve the salt water impacts detected by the monitoring program,
Pleasant Harbor will offer at its cost sufficient mitigation and/or replacement
water for potable water for any existing home on a well that has an increase in
chloride levels as follows and under the following conditions:
(a) The neighboring resident's well is within the radius of influence of
the Pleasant Harbor wells. Until such time that Ecology has
sufficient evidence to delineate this area of influence, wells located
on the Black Point Peninsula in the same aquifer as Pleasant
Harbor's wells are covered by this neighborhood policy.
(b) The well owner provides conclusive evidence that, over a
statistically relevant period of time, chloride levels have increased
over chloride levels in the well prior to Pleasant Harbor's use of
groundwater, including but not limited to, evidence that the increase
in chloride levels is from the Pleasant Harbor groundwater use and
not from the construction of the well owner's wel!, and the data from
the monitoring program is consistent with the increase in chlorides.
As a default standard, Pleasant Harbor will provide an alternative
water supply if chlorides in a well exceed baseline (pre-Pleasant
Harbor groundwater use) by 15o/o that results in levels above 200
mg/l; or levels increase by 30o/o that results in levels above 100
mg/l over a 12-month period (250 mg/l is the SDWA standard).
(c) Pleasant Harbor has the right to request additional evidence from
the resident showing that the Pleasant Harbor groundwater
withdrawal is the cause of the increase in chlorides if the increase
Neighborhood Water Supply Program - Page 2
is isolated to one well, the increase is likely caused by another
problem, and the only reasonable water replacement is a new well.
(d) The monitoring program will be continued for five years or until the
resort has achieved ful! build-out, whichever is longer. After this
period, the level of monitoring may be decreased unless there is
significant data showing increased chlorides, and Ecology
determines the monitoring program must be continued.
(e) lf Pleasant Harbor provides replacement water from the Pleasant
Harbor system, it may apply for consolidation of the water rights
under RCW 90.44.105. The well owner will waive any claims
against Ecology or against Pleasant Harbor for any impairment of
the water right if Pleasant Harbor offers a reasonable alternative
source as provided above.
Neighborhood Water Supply Program - Page 3
!
BASIN_17
GRlPttrC SCAIX
,i,x5J.
PLEASANT HARBOR MARINA & GOLF RESORT
SECTIONS 15 &22, TOWNSHIP 25N., RANGE 2W., W.M.
Figure B.3
PLEASANT HARBOR
INFILTRATION FACILITY
LOCATIONS
BASIN-BASIN-12
BASIN_6
15BASIN
BASIN-1J
BASIN_10
BASIN_9
BASIN-
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