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DateNameCompanyComment
 Steven PattenCity of Milton-FreewaterOn March 30, 2020, a limited license application for artificial groundwater recharge (AR) was received by OWRD from Sevein Water Association (SWA) for the diversion of up 8.7 cfs from Dry Creek to be treated and injected into the basalt aquifer system northwest of the City of Milton-Freewater. The proposed goal of the project is to stabilize and sustain groundwater levels within the mandatory levels required by Sevein’s water rights. The limited license application and map were published on OWRD’s website for review and comment. Complete documents were updated to the OWRD website and published in the May 12 public comment notice. The City of Milton-Freewater has the following comments on the proposed artificial groundwater recharge project: 1 – The proposed AR wells are all completed in the Grande Ronde Basalt unit of the Columbia River Basalt Group (CRBG), as stated in the application. The City has at least one well that is also confirmed to be completed in this unit, but likely additional City wells are completed in the Grande Ronde basalt unit. Currently, the City utilizes these aquifer units as the sole source of drinking water for the City of Milton-Freewater. Therefore, any project that proposes to inject water into these aquifer units should be required to meet OHA drinking water standards before injection of water. The proposed application does not describe details on treatment options for the source water. Additional treatment details should be explored before approval of injection of source water into the basalt aquifers. 2 – Project construction is proposed to be adaptively designed to implement the injection of Dry Creek source water into the basalt aquifer (AR Project Description Report, page 1). The City would like to see treatment details developed and treatment tested and verified before any injection of source water into the basalt aquifer occurs. 3 – The Dry Creek and Pine Creek drainages are a known source of Toxaphene contamination (Hobbs. W. and M. Friese. 2015. Pine Creek Toxaphene Source Assessment. Washington State Department of Ecology, Olympia, WA. Publication No. 15-03-020. 53 pgs. https://fortress.wa.gov/ecy/publications/summarypages/1503020.html). This chemical should be added to any sampling that occurs for the project and the sampling plan updated to include this information. 4 – The proposed concept of detaining and regulating Dry Creek flows may increase seepage loss from Dry Creek (into the Wanapum unit), as noted in the report, increase evaporation loss from Dry Creek due to increase surface area and increase evapotranspiration due to increased riparian area/vegetation, all leading to increased water loss from the Dry Creek system. Are these new potential water demands included in the requested diversion rate of 3.35/8.7 cfs? 5 – In the AR Project Description Report, Tables 3 and 4, SWA is asking for OWRD to formally grant them ample time to achieve the stated performance goal without regulatory action. The permit requirements have been in place since the permits were initially issued. OWRD should have the same requirements for all water users in the basin when it comes to regulatory action. Water levels have been declining for decades with most wells in the subbasin showing significant annual declines. 6 – In the AR Project Description Report (page 4), it is noted that the highest priority of the project is to ensure the correct hydrogeological response to the injection of AR water. The City would request the highest priority be maintaining the water quality conditions of the basalt aquifer system as it is currently the sole drinking water source for the City of Milton-Freewater and many private domestic wells. 7 – The applicant requests permission to conduct preliminary injection testing by pumping water from one well and injecting into another well. In conjunction with the previous comment, the City requests that this injection testing only be conducted after water quality testing has been completed to ensure the drinking water source is not degraded. This would include verifying that the delivery system between wells will not introduce potential contaminants or any other potential source of contaminants that could be introduced into the aquifer system? If the storage bulges will be utilized in the testing, then they should also be included in any water quality testing before injection. 8 – The City requests the addition of maintaining the municipal drinking water quality for the basalt aquifer to the Monitoring Goals, in the water quality sampling and analysis plan (page 4). 9 – The Hydrogeologic Feasibility Study report indicates that fewer water supply wells rely on the CRBG, however, the Cities of Milton-Freewater, College Place and Walla Walla all rely on the CRBG wells to supply all or a portion of their municipal drinking water supply. Some of these wells are completed into the Grande Ronde unit of the CRBG. These CRBG units have thin highly permeable interflow zones, as noted in the hydrogeologic report, and the connections across some structural deformities are unknown or have not been quantified. This means there is the potential for project wells to be in connection with water supply wells, including the City wells.
 Steven PattenCity of Milton-FreewaterOn March 30, 2020, a limited license application for artificial groundwater recharge (AR) was received by OWRD from Sevein Water Association for the diversion of up 8.7 cfs from Dry Creek to be treated and injected into the basalt aquifer system northwest of the City of Milton-Freewater. The proposed goal of the project is to stabilize and sustain groundwater levels within the mandatory levels required by Sevein’s water rights. The limited license application and map were published on OWRD’s website for review and comment. The City of Milton-Freewater has the following comments on the proposed artificial groundwater recharge project: 1 – The proposed AR wells are all completed in the Grande Ronde Basalt unit of the Columbia River Basalt Group (CRBG), as stated in the application. The City has at least one well that is also confirmed to be completed in this unit, but likely additional City wells are completed in the Grande Ronde basalt unit. Currently, the City utilizes these aquifer units as the sole source of drinking water for the City of Milton-Freewater. Therefore, any project that proposes to inject water into these aquifer units should be required to meet OHA drinking water standards before injection of water. The proposed application does not describe details on treatment options for the source water. Additional treatment details should be explored before approval of injection of source water into the basalt aquifers. 2 – Project construction is proposed to be adaptively designed to implement the injection of Dry Creek source water into the basalt aquifer (AR Project Description Report, page 1). The City would like to see treatment details developed and treatment tested and verified before any injection of source water into the basalt aquifer occurs. 3 – The Dry Creek and Pine Creek drainages are a known source of Toxaphene contamination (Hobbs. W. and M. Friese. 2015. Pine Creek Toxaphene Source Assessment. Washington State Department of Ecology, Olympia, WA. Publication No. 15-03-020. 53 pgs. https://fortress.wa.gov/ecy/publications/summarypages/1503020.html). This chemical should be added to any sampling that occurs for the project and the sampling plan updated to include this information. 4 – The proposed concept of detaining and regulating Dry Creek flows may increase seepage loss from Dry Creek (into the Wanapum unit), as noted in the report, increase evaporation loss from Dry Creek due to increase surface area and increase evapotranspiration due to increased riparian area/vegetation, all leading to increased water loss from the Dry Creek system. Are these new potential water demands included in the requested diversion rate of 3.35/8.7 cfs? 5 – In the AR Project Description Report, Tables 1, 2 and 3 are missing from the application document available on the OWRD website. These tables show the project uncertainties, the implementation roadmap and the water treatment stages. Without these tables, it is not possible for complete review of the application by the public. 6 – In the AR Project Description Report (page 4), it is noted that the highest priority of the project is to ensure the correct hydrogeological response to the injection of AR water. The City would request the highest priority be maintaining the water quality conditions of the basalt aquifer system as it is currently the sole drinking water source for the City of Milton-Freewater. 7 – The applicant requests permission to conduct preliminary injection testing by pumping water from one well and injecting into another well. In conjunction with the previous comment, the City requests that this injection testing only be conducted after water quality testing has been completed to ensure the drinking water source is not degraded. This would include verifying that the delivery system between wells will not introduce potential contaminants or any other potential source of contaminants that could be introduced into the aquifer system? If the storage bulges will be utilized in the testing, then they should also be included in any water quality testing before injection. 8 – The City requests the addition of maintaining the municipal drinking water quality for the basalt aquifer to the Monitoring Goals, in the water quality sampling and analysis plan (page 4). 9 – The Hydrogeologic Feasibility Study report indicates that fewer water supply wells rely on the CRBG, however, the Cities of Milton-Freewater, College Place and Walla Walla all rely on the CRBG wells to supply all or a portion of their municipal drinking water supply. Some of these wells are completed into the Grande Ronde unit of the CRBG. These CRBG units have thin highly permeable interflow zones, as noted in the hydrogeologic report, and the connections across some structural deformities are unknown or have not been quantified. This means there is the potential for project wells to be in connection with City wells.