United States
Environmental Protection
Agency
Off ice Of
The Administrator
(A101F)
EPA171-R-92-027
September 1992
r/EPA
Seawater Intrusion Control
In Coastal Washington
Department Of Ecology
And Practice
Printed on Recycled Paper
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EPA 910/9-92-023
vvEPA
United States
Environmental Protection
Agency
Region 10
1200 Sixth Avenue
Seattle WA 98101
Alaska
Idaho
Oregon
Washington
Water Division
Office of Groundwater
August 1992
Seawater Intrusion Control
in Coastal Washington:
Department of Ecology Policy and
Practice
U.S. Environment! Protection Agency
Region 5, Lite ;.i2j)
77 West Jach: , .. :^/arH i^,, r,
Chicago, IL 6GJW-3590 ' h Fl°°f
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Seawater Intrusion Control in Coastal Washington:
Department of Ecology Policy and Practice
By
Emily B. Tibbott
Prepared for the U.S. Environmental Protection Agency
Region 10, Office of Ground Water
August 1992
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Acknowledgements
The author would like to acknowledge and thank the U.S. EPA National Network for
Environmental Management Studies (NNEMS) Program, which provided funding for this
research. Martha Sabol, Hydrogeologist in the Office of Ground Water, sponsored the project
and provided direction and review in the creation of the report. In addition, the author
appreciates the willing and good-natured assistance of staff in various agencies during the
infonnation gathering process. Thanks are also due to the individuals who provided technical
review and comments on drafts of the report:
Bob Fritzen, Water Resources Program, Department of Ecology
Kirk Sinclair, Water Resources Program, Department of Ecology
Brian Walsh, Water Resources Program, Department of Ecology
Jonathan Williams, Underground Injection Control Program,
Environmental Protection Agency
Michael Abbott, Wilbee Research, Island County
Bert Bowen, Water Quality Program, Department of Ecology
Steve Deem, Northwest Drinking Water Program, Department of Health
Scott Downey, Office of Ground Water, Environmental Protection Agency
Chuck Lehotsky, Water Resources Program, Department of Ecology
Kate Marincic, Health Department, Island County
Bill Mullen, Office of Ground Water, Environmental Protection Agency
Cha Smith, Washington Toxics Coalition
Rod Thompson, Water Resources Program, Department of Ecology
Finally, thanks to Daniel Hall, Lou Keller, and Eric Wilmanns for consistent moral support
Disclaimer
This report was developed through the U.S. EPA NNEMS Program. The Program provides
funding for graduate students to investigate topics of particular interest to the U.S. EPA. This
project was administered from the U.S. EPA Region 10 in Seattle, Washington, and
monitored by Martha Sabol, Hydrogeologist in the Office of Ground Water. The report has
been reviewed by the Region 10 Office of Ground Water, and approved for copying and
dissemination. The contents and views expressed in this document are those of the author
and do not necessarily reflect the policies or positions of the U.S. EPA or other organizations
named in this report, nor does the mention of trade names for products constitute their
endorsement
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Abstract
Seawater intrusion into ground water has been identified by governmental and other entities
as a growing environmental concern in coastal Washington. Many coastal communities
depend primarily or exclusively on ground water as their source of fresh water. Massive
population growth and development in many of these areas are depleting what was once
imagined to be an abundant underground resource, frequently resulting in seawater
contamination of this resource.
The Washington Department of Ecology (Ecology) was created in 1970 to manage the air and
water resources of the State. As a result of increasing concern regarding seawater intrusion,
efforts to control and reverse this problem have, over the last several years, become a
Department focus. The Water Resources Program within Ecology is ultimately responsible
for the control of seawater intrusion. Through its role in water rights administration, the
Department decides whether to grant or deny water rights in seawater intrusion prone areas,
thus controlling intrusion in these areas by regulating water allocation.
Following an explanation of the mechanics, causes, and effects of seawater intrusion, this
report documents legal authority granted Ecology to control seawater intrusion as well as
current Department policies and practices regarding water rights administration. The report
concludes with an analysis of current policies and practices, considering both strengths and
deficiencies, and suggests potential improvements in problem areas.
11
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Table of Contents
Executive Summary 1
Chapter One. Introduction 3
Chapter Two. An Explanation of Seawater Intrusion 4
Ground Water Characteristics 4
Seawater Intrusion 5
Causes of Seawater Intrusion 7
Chapter Three. Seawater Intruded Areas in Washington 10
Chapter Four. State Policies and Regulations 11
Chapter Five. Agencies Involved in Seawater Intrusion Concerns 15
Department of Ecology 15
Other Agencies 17
Chapter Six. History of Ecology's Management Efforts 19
Seawater Intrusion Policy 20
Chapter Seven. The Water Right Process 23
Criteria for Evaluating Applications 23
Application Process 23
Water Permit Exemption 27
Chapter Eight Regional Office Policy and Practice 28
The Northwest Regional Office 28
The Southwest Regional Office 34
Chapter Nine. Analysis and Recommendations 37
Resource Constraints 37
Organizational Constraints 39
Policy Constraints 41
Political Context 44
General Recommendations 44
Chapter Ten. The Importance of Seawater Intrusion Prevention 45
Planning 45
Corrective Actions 46
Costs of Remedial Efforts 47
Chapter Eleven. Conclusions 49
111
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Appendix A: Ground Water Equations 50
Appendix B: Washington Department of Ecology Seawater Intrusion Policy 51
Bibliography
64
List of Figures
Figure One: The hydrologic cycle
Figure Two: Schematic sections showing hydrologic conditions
before and after intrusion in confined and unconfined aquifers g
Figure Three: Seawater intrusion prone areas in Washington 10
Figure Four: Water Resources organizational chart
of positions involved in seawater intrusion control 16
Figure Five: General steps in the water right application process 24
Figure Six: Washington Department of Ecology northwest and southwest regions .. 28
w
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Executive Summary
Seawater intrusion into ground water has been identified by governmental and other entities
as a growing environmental concern in coastal Washington. Many coastal communities
depend primarily or exclusively on ground water as their source of fresh water. Massive
population growth and development in many of these areas are depleting what was once
imagined to be an abundant underground resource, frequently resulting in seawater
contamination of this resource.
Occurrences of seawater intrusion in the state were first reported in 1922 in King County,
near the head of Elliott Bay. Much later, in the 1970's, localized severe cases of seawater
intrusion were observed in several coastal counties, with widespread intrusion experienced in
Island and San Juan Counties (U.S. Geological Survey, 1978, 1985). The Washington
Department of Ecology (Ecology) was created in 1970 to manage the air and water resources
of the state. As a result of increasing concern regarding seawater intrusion, efforts to control
and reverse this problem have, over the last several years, become a Department focus.
The Water Resources Program within Ecology is ultimately responsible for the control of
seawater intrusion, though its efforts must be coupled with those of local planning
departments, utilities, and other groups to be successful. Through its role in water rights
administration, the Department decides whether to grant or deny water rights in seawater
intrusion prone areas, thus controlling intrusion in these areas by regulating water allocation.
Following an explanation of the mechanics, causes, and effects of seawater intrusion, this
report documents legal authority granted Ecology to control seawater intrusion as well as
current Department policies and practices regarding water rights administration.
Documentation was achieved through review of relevant legal code and Department policy,
personal and telephone interviews, and examination of regional water right files. The report
concludes with an analysis of current policy and practices, considering both strengths and
deficiencies, and suggests potential improvements in problem areas.
This examination was motivated by the U.S. Environmental Protection Agency's (EPA) desire
to more fully support the state's practices in the control of seawater intrusion. Through a
thorough understanding of Ecology's practices in seawater intrusion control, the EPA hopes to
identify specific ways in which relevant federal programs (e.g. Sole Source Aquifer and
Wellhead Protection Programs) may support state efforts, and in turn, how the latter may
support federal programs. The report is also intended as an educational tool for agency staff,
legislators, citizen groups and others, as well as a mechanism for initiating necessary
procedural and policy changes.
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Chapter One. Introduction
Coastal regions of Washington are the most densely populated areas in the state.
Approximately 70% of Washington residents live in the state's fourteen coastal counties
(Department of Commerce, 1991). Some of these counties have experienced as much as a
30% population increase over the last ten years (Washington Department of Ecology, 1991).
As growth in these counties continues, particularly along the coast, the demand for fresh
water in some areas far exceeds, surface supplies. Municipalities, industries, and families are
increasingly looking towards ground water as a seemingly abundant source of fresh water.
For many communities, especially in island settings, ground water is the only source of fresh
water. However, unchecked exploitation of ground water in coastal aquifers has its costs;
seawater contamination of these aquifers has become a growing concern and, in many areas, a
reality.
Occurrences of seawater intrusion in the state were first reported in 1922 in King County,
near the head of Elliott Bay. Much later, in the 1970's, localized though severe cases of
seawater intrusion1 were discovered in several coastal counties, with widespread intrusion
experienced in Island and San Juan Counties (U.S. Geological Survey, 1978). The
Department of Ecology (Ecology) was established in 1970 to manage the water and air
resources of the state. Within Ecology, the Water Resources Program (Water Resources) was
created in part to protect and manage the state's ground water resources. This Program
focuses on water quantity rather than water quality concerns. Its purview includes control and
prevention of seawater intrusion into coastal aquifers through responsible allocation of ground
water. Water Resources' efforts in this regard have yielded mixed results. After an
explanation of the hydrologic principles and human practices which control seawater
intrusion, I will examine the legal authority granted Ecology for its control, as well as Water
Resources' implementation procedures in light of this legal responsibility.
1For the purposes of this report, seawater intrusion is defined as saline water originating from any
ocean, sound, or strait
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Chapter Two. An Explanation of Seawater Intrusion
Ground Water Characteristics
Aquifers are geologic formations which store and convey water rapidly enough to supply it in
useful quantities. They are a critical component in the hydrologic cycle because of their
ability to transmit and store water. Ground water flow operates on a different scale and time
frame than surface water; the accumulation and movement of ground water may take
thousands of years, and ground water aquifers sometimes span several states. Most ground
water originates as surface water, entering aquifers by means of infiltration from soil or
surface waters such as streams, lakes, and reservoirs. Ground water is stored and transmitted
through ground water aquifers, and may eventually return to the surface through pumping,
natural discharge to surface water bodies, or the transpirative and evaporative processes of
plants. Natural sources of ground water recharge include infiltration from streams, lakes,
reservoirs, and precipitation. Human-induced sources of recharge include excessive irrigation,
seepage from canals, and water applied with the intent to replenish the ground water system.
Figure One illustrates the hydrologic cycle.
Aquifers in western Washington are commonly composed of sand or gravel. Unconfined
aquifers have direct contact with the atmosphere through porous material, while confined (or
artesian) aquifers are separated from the atmosphere by a low permeability material. This
low permeability material forms an aquitard. The potentiometric surface represents the
height to which water will theoretically rise in a well completed in a confined aquifer. If this
surface is above the well head, then the well is a flowing artesian well.
Darcy's Law, which describes the flow of water through a saturated medium, tells us that rate
of flow through a unit aquifer area is directly proportional to the hydraulic gradient. (See
Appendix A for equation). That is, there will be a higher rate of flow when there is greater
change in hydraulic head2 over a given distance. To apply the equation requires knowledge
of the area! extent of the aquifer, the hydraulic gradient, and the hydraulic conductivity (the
capacity of the aquifer to transmit water). Hydraulic conductivity depends not only on the
porosity of the material (the amount of void space in the material), but also on the degree to
which the pores are connected; geologic material with larger and well-connected pores is said
to be permeable. Sand and gravel formations are materials with high hydraulic conductivity.
2Hydraulic head is the height of a column of water above a datum plane. In ground water systems, it is
composed of pressure head and elevation head.
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C"*" Clouds forming
X
X / / t
Evoporation /
Figure One. The hydrologic cycle
Source: Heath, Ralph C.; Basic Ground-Water Hydrology. Water Supply Paper 2220, U.S. Geological Survey, 1983, p. 5
Seawater Intrusion
Saline water is the most common contaminant to fresh water aquifers (Todd, 1980). In very
deep aquifers, it is often relict or old seawater which remains from some past era when sea
level was higher. In shallow aquifers, its presence is generally the result of surface water
pollutants which seep into the aquifer. In coastal aquifers, it occurs from infiltrating
seawater. This latter case is the focus of this report.
Seawater intrusion arises when there is a change in ground water gradients. In a circumstance
where there is a hydraulic connection between the aquifer and the sea, and when the aquifer
is undisturbed, the lighter fresh water floats upon the denser salt water. The underlying salt
water forms a wedge which thickens in the seaward direction. There is a salt water/fresh
water interface formed at the top of this wedge which slopes downward in an inland
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direction. When the process of ground water extraction through pumping upsets the
hydrodynamic balance, fresh water is displaced by salt water, and seawater intrusion can
occur.
In the early 1900's, two European researchers discovered that the intruding salt water occurs
not at sea level, but at a depth of about forty times the height of the fresh water above sea
level. The Ghyben-Herzberg relation determines the point of hydrostatic equilibrium at which
salt and fresh water form an interface based on their different densities (See Appendix A for
equation). This relationship does not consider flow variations, but rather assumes a
hydrostatic condition where flow is almost horizontal. Unfortunately, static ground water
conditions seldom occur in nature, especially adjacent to coastal areas where there is
significant water mixing due to heightened vertical turbulence. In situations like this, the
Ghyben-Herzberg relation underestimates the depth to the interface. In addition, the relation
assumes that the fresh water level or potentiometric surface (depending on the type of aquifer)
is above sea level and slopes seaward. Hubbert (1940) developed an equation in order to
explain a hydrodynamic situation in which the top of the aquifer is above or below sea level
(See Appendix A for equation).
It is important to further define the fresh water/salt water interface referred to above. This
interface is in reality not a sharp line, but a brackish zone in which fresh water is dispersed.
The thickness of this zone is determined by the amount of pumping, tidal fluctuation, and
area recharge. As these factors increase, the interface zone becomes thicker. This zone
generally ranges in thickness from one meter to 100 meters. Thicker zones often happen in
more permeable coastal aquifers which are heavily pumped (Todd, 1980). The salinity of the
transition zone, as one moves from top to bottom, increases from that of fresh water to that of
salt water (See Appendix A for relative salinity equation). Salinity may be measured as total
dissolved solids, chloride, or electrical conductivity (Todd, 1980). The mid-level of a
transition zone, or the line at which the salt water/fresh water interface would occur in a
hydrostatic condition, has a relative salinity of 50%.
The relationship between seawater and fresh water in island situations is often more delicate.
An island aquifer (typically composed of relatively permeable materials such as glacial
outwash or fractured bedrock in western Washington (Williams, 1992)) can be surrounded on
all sides by seawater (Todd, 1980). Given that the primary source of fresh water recharge of
these aquifers is rainfall, the fresh water/ground water layer is relatively shallow, extending
radially outward, creating a freshwater lens floating atop the underlying seawater. The depth
of the latter is dependent upon the amount of rainwater recharge, the hydraulic conductivity
of the aquifer, and island size. The transition zone is created by variations in tides, rainfall,
and atmospheric fluctuations. Because of the sensitive nature of the fresh water layer in
island conditions, island wells should be generally well-spaced and have low pumping rates to
avoid over-stressing the aquifer, and should be fairly shallow in order to avoid tapping salt
water (Todd, 1980). Some peninsulas in western Washington are practically islands. For
instance, only a narrow isthmus attaches the Kitsap Peninsula to the mainland. Such
peninsulas behave hydrologically almost as islands (Williams, 1992).
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When seawater enters aquifers, a chemical reaction takes place such that the result is more
than simply the mixing of salt and fresh water. Three processes are likely to occur (Todd,
1980): 1) a change in the chemical make-up of the salt water through its base exchange with
aquifer minerals, 2) a reduction in sulfates and their substitution by weak acid radicals, and 3)
the dissolution and precipitation of the salts in the water. These processes result in both
changes in total dissolved solids (from 1 and 2) and salt concentration (from 3). Revelle
(1941) proposed that measurement of chloride concentration was the best way to detect salt
water intrusion. Chloride is the primary anion in seawater, and alternately occurs very
minimally in ground water. Seawater includes approximately 35,000 mg/1 dissolved solids,
19,000 mg/1 of which is chloride. The Environmental Protection Agency (1977) requires that
public drinking water supplies not contain more than 250 mg/1 (milligrams per liter) chloride:
water with higher concentrations will exhibit a distinctly salty taste.
Causes of Seawater Intrusion
Ground Water Extraction
There are many causes of seawater intrusion; primary among them is ground water extraction,
most typically caused by well pumping.3 When excessive extraction occurs, the salt
water/fresh water interface is disturbed and, as a result, the salt water wedge advances in an
inland direction (Todd, 1980). When a well penetrates the fresh water layer of an aquifer
which is underlain with salt water, a process called upconing results from excessive pumping
whereby there is an upwelling of the salt water/fresh water interface locally below the well.
This process is illustrated in Figure Two.
As pumping levels escalate, the situation worsens until the well must be abandoned due to
contaminated, unusable water. After pumping ceases, the salt water recedes, and the salt
water/fresh water interface assumes its pre-extraction position. Because of this occurrence,
wells should be designed for shallow pumping in order to skim the fresh water from the top
of the aquifer without penetrating the salt water layer. From a management standpoint, well
location, spacing, depth, and pumping rates must be optimized to produce the greatest
quantities of fresh ground water without exceeding recharge rates.
In the analysis of upconing, Schmorak and Mercado (1969) developed a mathematical
relationship which links the salt water/fresh water interface directly to pumping rate using the
Ghyben-Herzberg relation as its base (See Appendix A for equation). For the sake of
simplicity, a sharp interface is assumed as was done for the Ghyben-Herzberg relation. There
is a critical rise (See Appendix A) above which the interface will accelerate towards the well;
this model works well only when rise is limited. However, a model has been developed to
define the level at which water may be pumped without salt water entering the well, that is,
3For purposes of this report, the term ground water extraction will be used to signify well pumping.
7
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Well tapping an unconfined (water-table)
aquifer under conditions of equilibrium-
no intrusion has occurred.
Well
Sea
Potentiometric_
" surface
Well tapping a confined (artesian) aquifer
under conditions of equilibrium—no
intrusion has occurred.
The same well under conditions of intensive
pumping—intrusion has reached the well.
The same well under conditions of intensive
pumping—intrusion has reached the well.
figure Two. Schematic sections showing hydrologic conditions before and after intrusion in
confined and unconfined aquifers
Source: Adapted with permission from Dion, NJ*. and S.S. Sumoika; Seawater Intrusion Tntn f^pp«^«1 Aquifers m
Washington. 1978. Water Supply Bulletin 56, Washington Department of Ecology, 1984, p. 8.
the maximum pumping level (See Appendix A). It is important to note that, while these
models present workable approximations, there is in reality no level above which salt water
will not rise in a situation of continuous pumping when a well is drilled below sea level4.
In considering the potential of seawater intrusion relative to well location, several distinctions
have been made (Custodio, 1987). Wells that are drilled well inland, in conditions where the
aquifer bottom is above sea level, experience little or no seawater intrusion although
4More than 90% of the wells in Island County are drilled to or below sea level (Abbott, 1992).
8
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continued pumping acts to deplete well yields as well as the saturated thickness of the
aquifer. In wells that are located inland, yet drilled into aquifers with bottom surfaces below
sea level, seawater intrusion can occur when extraction exceeds recharge (a process called
mining), though typically after a long period of time. Rates of intrusion are accelerated with
deeper aquifers. High volume inland wells may cause or accelerate seawater intrusion in
coastal areas without experiencing any intrusion themselves. In wells located near the coast,
but in areas where the seawater wedge has not yet penetrated, seawater intrusion will occur
when even a small fraction of ground water is extracted. Finally, in wells drilled in locations
penetrated by the seawater wedge, there is imminent danger of seawater intrusion through
upconing, even in shallower wells. Depending on a combination of factors including
extraction rate and aquifer characteristics, the salt water wedge can take years or decades to
work its way inland to aquifers; certainly, the more permeable the aquifer material, and the
smaller the aquifer volume, the faster the salt water wedge will intrude.
Indirect Causes of Seawater Intrusion
There are other, more indirect activities which cause seawater intrusion, many of which are
associated with population growth and urbanization (Custodio, 1987). When regions are
urbanized, or as industrial sites increase, lands which were formally grassy or wooded are
paved over. This process severely impedes infiltration of precipitation into the subsurface,
instead creating surface runoff relatively useless for recharge. Even in areas which are not
paved, vegetation is often disturbed or destroyed and soil is compacted, factors which
decrease infiltration as well. A second activity which diminishes ground water recharge is the
reduction in acreage of irrigated lands, or more efficient irrigation practices where surface
water is used. The replacement of diffusion wells or other subterranean disposal facilities by
more technically sophisticated sanitary networks also leads to a reduction in recharge. Forest
management practices which result in deforestation or other reduction of vegetative cover
decrease infiltration and increase runoff, thus negatively impacting recharge. Finally, a
phenomenon over which humans have little direct control, and which encourages seawater
intrusion, is drought. Certainly with a decrease in precipitation comes a decrease in recharge.
All of these activities negatively impact quantity and rate of recharge; an aquifer which is
being exploited, yet has little recharge, will be more immediately susceptible to seawater
intrusion. These activities also serve to upset the salt water/fresh water equilibrium; the shift
to a new equilibrium may take many years. At this point, the effects and their severity are
not completely understood and further study and observation must be conducted to predict
ensuing problems (Custodio, 1987).
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Chapter Three. Seawater Intruded Areas in Washington
British Columbia
Independent studies by the
United States Geological
Survey (USGS), the
Washington State Department
of Health, and Ecology have
identified coastal areas in
which seawater contamination
has occurred. Although all
coastal and island areas are
susceptible to seawater
intrusion, the most
widespread occurrences have
been documented in San Juan
and Island Counties (USGS,
1978, 1985; Department of
Ecology, 1988). In many
instances, chloride
concentrations measured at
wells in Island County have
been greater than 100 mg/1 (a
somewhat arbitrary level used
to indicate a seawater
intrusion problem (USGS,
1978)), and in several
instances, have exceeded the
drinking water standard of
250 mg/1. The same is true
in San Juan County. Both
counties depend heavily (and
in some areas, solely) on
ground water for their fresh
water supplies, and are
experiencing rapid coastal
development Currently, the USGS is conducting a study of ground water quality on Guemes
Island in Skagit County, a small island north of Anacortes which is beginning to experience
rapid population growth (Kahle, 1992). A preliminary assessment suggests that there are a
number of coastal wells with chloride levels exceeding 200 mg/1. In addition, Ecology is
completing a seawater intrusion study on Marrowstone Island (Jefferson County), where
suspicions of high chloride levels island-wide have been confirmed (Garrigues, Sinclair, in
press). Figure Three illustrates areas in Washington which are sensitive to seawater intrusion.
Figure Three. Seawater intrusion prone areas in
Washington (shaded portions)
10
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Chapter Four. State Policies and Regulations
The Department of Ecology, with its mission to protect and manage the ground and surface
waters of the state for the public good, is the state agency authorized to prevent seawater
intrusion. Outlined below are specific elements of the policies and accompanying regulations
which grant it this authority. It is important to understand Ecology's legal responsibilities
before considering its day-to-day practices in light of these responsibilities.
RCW 90.44: Regulation of Public Ground Waters (1945). In order to appropriate ground
water in Washington in amounts greater than 5000 gpd (gallons per day) or to irrigate more
than one-half acre, a water right must be acquired through Ecology's Water Resources
Program. This policy was established in 1945 as an expansion of the 1917 water code
addressing surface water appropriations (RCW 90.03). The granting of water rights in
Washington is governed by the prior appropriation doctrine; those water right applications
which are first in time are granted a superior right. Section .050: This section provides for
an exemption from the application process for withdrawals of less than 5000 gpd or irrigation
of less than one-half acre; in general, this applies to single or group domestic uses. These
users are, however, entitled to the same rights as holders of water rights, and do have the
option of undergoing the water right application process in the same manner as those desiring
larger appropriations. Regardless of exemption status, Ecology may require, at its discretion,
information about the nature, means and amount of the withdrawal. Section .060: This
section stipulates the four criteria which must be satisfied for a water right to be granted: 1)
the water desired for appropriation is available; 2) the water is intended for a beneficial use;
3) the desired water use will not impair existing water rights; 4) the public interest will not be
negatively impacted. Section .070: Limitations on withdrawals may be imposed if the
aquifer is incapable of yielding the desired amount of water under reasonable or feasible
pumping conditions, or if the withdrawal would adversely affect an existing water right. In
cases where the presence of either condition is suspected, Ecology may require additional
evidence or proof of no harm from the applicant before a project may proceed; the burden of
proof in this situation is placed on the applicant Section 250: Ecology may, at its
discretion, make investigations concerning location and extent of ground waters in the state,
and, to this end, may require reports from ground water appropriators as to the amount and
nature of use. Section .400: Ecology is authorized to identify and designate ground water
management areas in order to most effectively protect and manage the ground water resource.
These areas include aquifers that may be over-utilized or -appropriated, are primary or sole
sources of drinking water for a community, or may be threatened by surface contamination
due to land management practices; priority is given to aquifers which are imminently
threatened. Ecology is to adopt these plans by January 1, 1986. Section .450: Ecology may
require that withdrawals be metered as a condition of a new water right
WAC 173-150: Protection of Withdrawal Facilities Associated With Ground Water Rights
(1985). This regulation is sanctioned by the Regulation of Public Ground Waters Act
Section -110: This section refers to seawater intrusion specifically, saying that Ecology may
11
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control this condition through artificial recharge or water importation projects, or any other
means it deems "reasonable, feasible, and appropriate."
RCW 90.48: Water Pollution Control Act (1944). This act designates Ecology as the state
water pollution control agency under the Clean Water Act, and mandates that the Department
maintain all waters of the state in their highest quality as well as protect these standards for
the future. Though surface contamination (e.g. oil and sewage) is the focal concern of this
Act, seawater also classifies as pollution according to Act definitions; thus, this Act serves to
reinforce Ecology's role in aquifer protection.
RCW 9054: Water Resources Act of 1971. The purpose of this Act is to establish basic
water resource policy in the state-to insure that water is preserved for the highest benefit of
the public as well as to direct Ecology in the management of state waters. Section .050 (2):
If, in the process of making decisions regarding water resources, sound evidence or data is
lacking to make these decisions, Ecology may prevent further withdrawal of certain waters
until such data is available. Section .140: This section states that aquifers which are the only
source of drinking water for a community are given highest priority in terms of protection.
Section .180 (4): Ecology programs concerning strategies for efficient water use should focus
initially on areas where water is (believed to be) over-appropriated.
WAC 173-200: Water Quality Standards for Ground Waters of the State of Washington
(1990). This regulation serves to implement the Water Pollution Control Act and the Water
Resources Act of 1971. The goal of these regulations is to maintain high quality ground
water in an effort to protect present and future beneficial uses. Section -030: An anti-
degradation policy is set forth which includes the following directives: (2)(a) ground water
degradation which would interfere with current and future beneficial uses shall be prohibited;
(2)(c) high quality ground waters should be maintained at their current level of purity, even if
that level is higher than the stipulated quality criteria for those ground waters, unless an
overriding public interest dictates otherwise. A maximum contaminant level for chloride is
set at 250 mg/1 (Table 1). Section -050: This section sets guidelines for establishing
enforcement limits for contaminants (i.e. maximum acceptable levels assigned to contaminants
for the purposes of protection), stating that, in the setting of these levels, an attempt should be
made to set them as close to background levels as practical ((3)(a)(ii)), and that human and
environmental health, as well as beneficial uses, should be considered ((3)(a)(iii) and (v)).
Section -070: Guidelines for setting early warning levels for contaminants (i.e. levels at
which contaminants may be detected and controlled before they become injurious and that
represent a percentage of the ground water quality enforcement limit) are set forth.
Subsection (6)(a) states that in cases where an early warning value is reached or exceeded,
the holder of the water right must notify Ecology of this condition within ten calendar days of
its occurrence. Section -090: Special protection areas may be designated by Ecology or other
government agencies (or indian tribe) for ground water that requires special consideration.
Section -100(4): Permits may only be issued if they do not cause violations of ground water
quality standards set forth in this chapter.
12
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RCW 90.14: Water Rights, Registration, Waiver, and Relinquishment Act (1967). This Act
was intended to enable Ecology to gain greater control over the administration of state waters
It s passage was motivated largely by a stated uncertainty as to the volume of private water
claims in the state. Section .041 (2)(a). The Act required individuals claiming surface water
rights pre-dating 1917, or ground water rights pre-dating 1945, to file statements of these
claims with Ecology by June 1974.
RCW 18.104: Water Well Construction Act (1971). This Act serves to regulate well
construction and to regulate and license well contractors. Section .040 (2): Ecology is
authorized to conduct well inspections at times it deems reasonable. Section .040 (4)(f)-
Ecology has the power to limit well construction for the purpose of sound water resources
management.
WAC 173-160: Minimum Standards for Construction and Maintenance of Wells (1973) This
Regulation, authorized by the Water Well Construction Act, dictates the minimum standards
for construction of water supply and resource protection wells. Section -020 (1): In areas
sensitive to seawater intrusion, construction requirements beyond the minimum standards are
necessary. Section -050 (1): Within thirty days following well construction, a well driller
must submit well drilling records to Ecology. Section -055: A contractor must submit a start
card signalling an intention to start, alter, or abandon a well at least 72 hours prior to the start
of construction. Section -075: Wells must be adequately sealed in order to prevent inter-
aquifer contamination. Section -205: In areas of suspected contamination, wells must be
cased with impermeable materials. All wells must not be located within a minimum distance
from potential or known sources of contamination. Section -415. Abandoned wells must be
properly decommissioned to prevent surface water and inter-aquifer contamination.
WAC 173-162: Regulation and Licensing of Well Contractors and Operators (1973) This
Regulation, authorized by the Water Well Construction Act, provides guidelines for the
licensing and regulation of well contractors and operators.
WAC 173-100: Ground Water Management Areas (1985). This law, authorized by the
Regulation of Public Ground Waters Act, sets forth criteria for the designation and
management of ground water management areas for the purpose of aquifer protection.
Seawater intrusion is mentioned explicitly as a cause for developing a ground water
management plan.
WAC 508-64: Measuring Devices for Water Diversion and Withdrawal Facilities (1969)
This law was enacted due to the realization of increased competition for water resources It
regulates the installation and operation of water meters, as well as specifies the type to be
used, in order to prevent both waste and over-appropriation of this limited resource.
13
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Growth management language was codified into new and existing legislation in 1990. The
following excerpts are relevant in the control of seawater intrusion:
RCW 36.70A: Growth Management-Planning by Selected Counties and Cities. Section .070:
This section discusses the required elements of comprehensive management plans for cities or
counties. Among these is a land use element, stipulating that land use plans be made with
sensitivity to the protection of ground water used for public water systems.
RCW 58.17: Platting, Subdivision and Dedication of Land. Section .110: This section
reinforces the connection between land use and water availability, saying that subdivision and
dedication approvals are contingent upon sufficient water supplies.
RCW 1927: State Building Code Act. Section .097 (1): This amendment to the state
building code requires that apph'cants for building permits for structures needing potable water
supplies must show that adequate supplies of such water are available. Proof of adequate
supply may be shown by a water right permit, a letter from a certified water purveyor
confirming the ability to deliver water, or some other acceptable form. A county or city may
require, as a condition of a building permit, that the applicant hook up to an existing public
water system where there is available water.
These rules and regulations facilitate, both directly and indirectly, Ecology's prevention of
seawater intrusion.
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Chapter Five. Agencies Involved in Seawater Intrusion Concerns
Department of Ecology
The Department of Ecology's Water Resources Program has principal responsibility in the
control of seawater intrusion. Although seawater intrusion results in a water quality problem,
it is caused by a depletion in the ground water resource, thus its control has been assigned to
Water Resources. In 1989, a position was established within the Water Resources Program's
Policy and Management Section to form and lead a Seawater Intrusion Team. The Team was
created to develop and implement a strategy for seawater intrusion in Washington. This
decision came from pressure, applied both externally and internally, that Ecology address this
critical, unresolved water resource issue. Two other positions within the Section work on
seawater intrusion more indirectly. These involve the coordination of Ground Water Area
Management Plan development, as mandated in RCW 90.44.400 (see Chapter Four). Within
the Coordination and Hydrology Section, a hydrogeologist was assigned to the Seawater
Intrusion Team to serve as the technical lead.
On a regional level, Ecology's Northwest and Southwest Offices are responsible for
evaluating and making decisions on water right applications in affected coastal counties. The
Northwest Regional Office (NWRO), located in Bellevue, employs seven report writers (one
representing each county in the region) and four hydrogeologists, one of whom is dedicated to
coordinating well construction and operation. A report writer reviews water right
applications, makes findings, and, based on these findings, advises what action to take on the
permit (i.e. approval, conditional approval, or denial). Where information is lacking to make
an informed decision, Water Resources may ask the applicant to provide it When the factors
in making a decision are more complex (e.g., if seawater intrusion is a potential or reality in
the area), the report writer may seek the assistance of a hydrogeologist in the review of more
technical aspects of the situation. Assistance is sought when the application is located in a
seawater intrusion prone area, or when the report writer expects that the applicant will appeal
his decision (Fritzen, 1992). The hydrogeologist's input adds technical support to the report
writer's decision. His or her opinion may also be solicited in the review of a consultant's
report or if an aquifer test is necessary (Sinclair, 1992). As well as assisting in technical
review of applications, hydrogeologists perform aquifer studies and provide other technical
support. The Southwest Regional Office (SWRO) employs five report writers, four divided
evenly between the northern and southern parts of the region, and one specializing in
applications from municipalities. In addition, there are three hydrogeologists, one of whom
works as well drilling coordinator. Figure Four depicts an organizational chart of those
individuals responsible for various aspects of seawater intrusion management.
Ecology's Water Quality Program is minimally involved in seawater intrusion management
efforts. Seawater is just one of a host of contaminants it reviews, others considered more
imminently serious to instream habitat and human life. The Water Quality Program's primary
role is the issuance of waste discharge permits which stipulate allowable levels of industry-
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Policy and
Management Section
Seawater Intrusion
Policy Specialist
2 Ground Water
Management Area
Coordinators
Department of Ecology
Water Resources Program
Coordination and
Hydrology Section
Hydrogeotogist
Northwest Regional
Office
7 Report Writers
3 Hydrogeologlsts
Wen Drilling
Coordinator
Southwest Regional
Office
S Report Writers
2 Hydrogeologlsts
Well Drilling
Coordinator
Figure Four. Water Resources organizational chart of positions involved in seawater intrusion control
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and municipality-produced contaminants. More recently, the Program has begun monitoring
ground water quality, on a selective basis, in areas of waste discharge. This data is
potentially valuable to Water Resources, though no formal coordination efforts currently exist.
There is general agreement within Ecology that greater information sharing and coordination
is needed between the two programs as their functions are related, especially on the issue of
seawater intrusion. A data management task force was formed in December 1990, one of its
goals being data sharing between the two programs.
Other Agencies
Other agencies having concern and involvement in seawater intrusion management are the
Washington Department of Health's (DOH) Northwest Drinking Water Program and the U.S.
Environmental Protection Agency. Through its enforcement of drinking water standards (for
which the maximum contaminant level for chloride is 250 mg/1), the DOH monitors
approximately 13,000 wells statewide (Deem, 1992). This monitoring data has been shared
with Ecology, which has no ongoing monitoring program, and has, to date, mostly monitored
wells in crisis situations. The DOH, and its counterparts on the county level, perform well
site inspections and review public water system plans, thus regulating the same applicants that
Water Resources regulates. Additionally, the DOH and Island County Health Department co-
authored a Salt Water Intrusion Policy (1989). This was in many ways a prototype for a later
Ecology document. The DOH-Island County document sets similar risk categories to those in
Ecology's document, requires more frequent chloride monitoring in higher risk areas, and
mandates denial of new water systems or additional service connections to existing systems if
chloride levels exceed 200 mg/1 (DOH, 1989). Though it is not as stringent as Ecology's
policy (discussed in Chapter Six), it was tremendously instrumental in the formation of that
policy.
The EPA shares a role in seawater intrusion management through its Wellhead Protection and
Sole Source Aquifer Programs. In areas designated as sole source aquifers,5 the EPA reviews
federal financially assisted projects to determine contamination potential and threat to public
health. The EPA therefore has the authority to deny federal financial assistance for a project
that could cause or aggravate seawater intrusion. The Agency can also require project
modifications as a condition of receiving federal financial assistance. Through the Wellhead
Protection Program, authorized through a 1986 amendment to the Safe Drinking Water Act,
the EPA oversees states' efforts to protect ground water based public drinking water supplies
from contamination. The Washington state program is currently being developed by the
DOH. Wellhead Protection Programs are primarily implemented on the local level. There is
5Sole source aquifer designation is granted in cases where an aquifer provides at least 50% of a
community's drinking water supply, and where there is no economically viable alternative. As a matter of
policy, the EPA only makes Sole Source Aquifer designations in response to petitions by individuals and
organizations. Of pertinence to this study, Whidbey and Camano Island Aquifers have received sole source
designation.
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no strict regulation of seawater intrusion through this Program; however, in workshops for
counties developing wellhead protection plans, the DOH urges that seawater intrusion
concerns be addressed in management plans (Jennings, 1992).
The U.S. Geological Survey and the Pollution Control Hearings Board (PCHB) have also
performed roles in seawater intrusion concerns. The USGS has performed more extended
hydrogeologic studies, occasionally at the behest of Ecology, some of which have focused on
seawater intrusion (USGS, 1978, 1985). These have provided important regional data on
which to make management decisions and build policy. Finally, the Pollution Control
Hearings Board (PCHB) has issued opinions on seawater intrusion when water right
application decisions have been appealed and brought for hearing before the Board (PCHB
1981, 1983).
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Chapter Six. History of Ecology's Management Efforts
Since the passage of RCW 90.44 (Regulation of Public Ground Water) in 1945, the state has
required water rights for ground water withdrawals in excess of 5000 gallons per day or for
irrigation of more than one-half acre. Until the last several years, ground water was
perceived by top Ecology management as a fairly unlimited resource, and water rights were
granted routinely. There was little or no concern that a right would be denied. The
Department of Ecology was established in 1970 as the state agency responsible for water
rights administration. Water Resources, and more directly, its regional offices, carry out this
responsibility within the Department
In the late 1960's, elevated chloride levels were found in wells on the southern end of
Camano Island (Island County) (Department of Water Resources, 1968). Further studies by
the USGS in the 1970's, including a major study on seawater intrusion in all coastal areas of
Washington (USGS, 1978), revealed elevated chloride levels as both a localized yet severe
problem in some areas, and a more widespread problem in others (Island and San Juan
Counties being exemplary in the latter category). During the mid- to late 1970's, the NWRO
began issuing ground water permits with the proviso that "wells within one mile of the
shoreline must have the pump intake at/or above mean sea level" (Department of Ecology,
1985). This stipulation was later revoked as it was found that many coastal wells in Island
County, for example, exhibited very low, if any, chloride. It was also nearly impossible for
the NWRO to regulate the pump intake levels of individual wells. From 1979 to 1983, the
NWRO issued water permits with a proviso requiring that, if chloride levels exceeded 250
mg/1, pumping cease or the pump intake be raised above sea level. Thus, chloride was
considered a problem only when it reached recommended maximum contaminant levels for
drinking water, and was controlled only at these levels. This resembled a crisis management
strategy, with no opportunity for preventative efforts. More significantly, there was no well
monitoring required, so no initial chloride readings or trends were known.
In the SWRO, a similar proviso was used, again setting the action level at 250 mg/1 chloride.
In cases where wells had not yet been drilled, a proviso was included that encouraged
applicants to site wells as far inland as reasonable to minimize the potential for seawater
intrusion. Some permits required that pump intakes be set above mean sea level.
Opinions rendered in two PCHB hearings have been formative in the evolution of Ecology's
seawater intrusion policy. PCHB Hearing No. 80-193 (1981) considers an application for
ground water withdrawal by Harbor Vista Association (Maury Island, King County). The
Board decided that pumping must cease when chloride reached 150 mg/l, and that chloride
monitoring results be sent to Water Resources. PCHB Hearing No. 82-193 (1983) considered
a local citizen's appeal of a water right permit approval granted to Prairie Management, Inc.
(Whidbey Island, Island County). In this situation, Water Resources had issued a permit with
the proviso: "If the chloride concentration exceeds 250 mg/l, the withdrawal rate shall be
reduced or the pump setting raised to reduce the chloride level to below 250 mg/l" (PCHB,
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1983). The citizen, Harry Wilbert, appealed the permit on the basis that the proviso lacked
stringency appropriate to the ground water conditions. The Board's opinion involved two
conditions:
1. The permittee or its successors) shall report to Department of Ecology, in
April or August of each year or at such times as the department determines to
be appropriate, the chloride concentration and static water level6 of the well(s)
authorized by this permit.
2. The withdrawal of ground water under this permit may be limited, or other
appropriate action may be required, by Washington Department of Ecology in
order to prevent seawater intrusion notwithstanding whether chloride
concentration exceeds 250 mg/1 in the well(s) authorized by this permit
(PCHB 82-193, 1983, p. 7)
Urgency created by these cases, a growing awareness of widespread intrusion in select
regions, as well as an increasingly aware and vocal public, compelled Ecology to develop
formal seawater intrusion policy. The Seawater Intrusion Team, created in the late 1980's
was Ecology's first coordinated response to the problem. The Team is composed, on the '
primary level, of individuals representing the Policy and Management Section, the
Coordination and Hydrology Section, the NWRO, the SWRO, the Shorelands and Coastal
Zone Management Section (interested essentially in incidents of sea level rise), and the Water
Quality Program. Playing an advisory role are individuals representing federal, local, and
other state agencies and organizations. Tribes, consultants, the general public, and the
environmental community were invited to participate.
The major product of the Seawater Intrusion Team, to date, is the Seawater Intrusion Policy
implemented in January 1992. Though this policy has not been codified, and faces further '
review and possible amendment, it has been completed for practical purposes, and is being
applied in water rights administration in both the NWRO and the SWRO.
Seawater Intrusion Policy
The Seawater Intrusion Policy provides a guide for Water Resources in the administration of
water rights in seawater intrusion prone areas, with the goal of preventing intrusion in regions
where the risk exists, and controlling or reversing the situation in areas where it has occurred.
It is a pivotal document in that it provides a standardized and conservative response to
seawater intrusion, and requires Ecology to take a more proactive and coordinated role in
minimizing aquifer degradation. As defined in the Policy, seawater intrusion is "the
infiltration of marine salt water into fresh water aquifers, resulting in chloride concentrations
•Static water level refers to the water level in a well when it is not being pumped.
20
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above background levels [i.e. greater than 15-25 mg/1]" (Ecology, 1992, p. 5). This Policy
uses 100 mg/1 as a level at and above which more stringent regulation must be enforced. The
use of this somewhat arbitrary level as an indication of seawater intrusion is supported by
USGS studies (1985), which suggests that chloride levels below 100 mg/1 could be due to
other sources of contamination (e.g. relict seawater or surface contamination). As may be
surmised, there is some discrepancy in opinion as to what chloride level clearly indicates
seawater intrusion, although 100 mg/1 is generally used.
The Policy establishes risk categories as a basis for controlling intrusion, and sets forth action
to be taken by Ecology as well as the water right applicant as defined by the existing risk
level.
Risk categories:
• Low: 25 mg/1 < Chloride < 100 mg/1 based on data from an existing well, a test well,
or general ground water basin conditions (if the basin is not geologically
delineated, a half-mile radius from a well with these chloride levels is used.)
• Medium: 100 mg/1 < Chloride < 200 mg/1 based on data from sources outlined in low
risk areas. In addition, an area with chloride levels classified as low risk, but
where data show a trend towards increasing levels, falls in the medium risk
category.
• High: Chloride > 200 mg/1 based on data from sources outlined in low .risk areas. In
addition, an area with chloride levels classified as medium risk, but where data
show a trend towards increasing levels, falls in the high risk category.
Responses vary depending on the level of risk and whether it is defined in a new or existing
well. In low risk areas, Ecology can require design, operation, and monitoring controls for
new wells. Ecology will deny a water permit in a medium or high risk area unless the
applicant can show that further intrusion would not result from the proposed withdrawal.
Ecology may also advocate, though not legally require, that local governments deny or
withhold building permits in medium and high risk areas (pursuant to growth management
legislation) unless the applicant can show that the water use associated with the building
would not increase the risk of intrusion. In medium and high risk areas, water permit holders
must monitor well chloride levels in April and August of each year and submit these to
Ecology, as well as report annually to Ecology on the amount of their water use. This is
written as a condition of the water permit approval. It is critical to remember that many of
these requirements are enforced through the water right application process; as withdrawals of
less than 5000 gpd or for irrigation of less than one-half acre are exempt from the water
right application process, many well users avoid these requirements. Drillers of exempt wells
are required only to notify Ecology as to well location and type of water use intended, and to
submit a well drilling log.
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In addition, the Policy stresses the need to coordinate water rights administration with land
use and water system decisions. To that end, Ecology has begun to work with the DOH,
county health and planning departments, local building departments, and Indian tribes. Please
see Appendix B for a complete copy of Ecology's Seawater Intrusion Policy.
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Chapter Seven. The Water Right Process
Criteria for Evaluating Applications
Water Resources employs four criteria in making a water right determination; a right may
only be granted when all conditions are met (RCW 90.44.060).
• The water desired for appropriation is available.
Can the aquifer supply the water required at an acceptable rate?
The water is intended for a beneficial use.
Beneficial use, as defined in RCW 90.14.031 (2) "shall include, but not be limited to,
use for domestic water, irrigation, fish, shellfish, game and other aquatic life,
municipal, recreation, industrial water, generation of electric power, and navigation."
• The desired water use will not impair existing water rights.
Those with existing rights in the area have seniority and must be protected,
• The public interest will not be negatively impacted.
The public interest, in this case, refers to the need for sustainable and non-deteriorative
development of ground water, so that future uses will not be impaired or prevented.
Since water rights are issued in perpetuity, a long range perspective is crucial, as well
as careful review of each application.
Application Process
In order to determine whether these four conditions will be met, Water Resources has
developed an exhaustive application process. In obtaining a water right, an applicant must
follow a prescribed set of steps outlined below. (See Figure Five for a generalized flow chart
depicting this process.)
1) The individual requesting a water right should fill out an application provided by
Water Resources, including source and point of withdrawal, the quantity requested,
and the proposed beneficial use. Applications are required for new wells, change in
amount or point of use, and increase in appropriation. There is a ten dollar minimum
examination fee required with this application.
2) Water Resources reviews the application for completeness. If the application is
accepted, an identification number is assigned to it, and the information included
therein is entered on a computer database. If the application is rejected, it is returned
to the applicant with an explanation.
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Return to Applicant
t
Application Filed with Ecology
(Date stamped upon receipt)
Application Rejected
Application Reviewed
Complete Information
Application Accepted
' Number assigned
• Into into computer
Prepare Public Notice
' Mail to applicant
Evaluation of Application
For New Wells:
• Preliminary Permit Issued
(not in all cases)
• Start card and well drilling log
submitted to Ecology
• Field Investigation
• Aquifer test (not in all cases)
• Four criteria evaluated
• Report of Examination
L
For Existing Wells:
• Field examination
• Aquifer test (not In all cases)
• Four criteria evaluated
• Report of Examination
Appeal—Denial
Approval—Appeal
Permit Issued
Development and Perfected Use
• Beginning construction
• Completion of construction
• Proof of Appropriation
Certificate of Water Right Issued
Figure Five. General steps in the water right application process
Source: Adapted with permission from Washington State Department of Ecology; Report on Water Right
Administration: Assessment of Issues/Action PI'OPI am. Department of Ecoloev 1991
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3) Water Resources will then send the applicant a legal notice regarding the proposed
withdrawal which must be published once a week for two consecutive weeks in a legal
newspaper with circulation in the county where the withdrawal would occur. The
notice contains information regarding the desired withdrawal, and grants citizens a 30
day period to protest the water use provided they feel it does not satisfy (any of) the
four criteria.
4) After final publication of the notice, the applicant sends Water Resources an Affidavit
of Publication as well as the original notice in order to confirm publication. Ecology
will take no further action until the Affidavit is received (at which point the
applicant's file is considered active), and the 30 day protest period has expired. If the
proposed withdrawal is appealed, Water Resources factors these concerns in their
decision regarding the water right. The appeals must be cited in the report of
examination (discussed in Step 7).
5) After the protest period, Water Resources staff (often a Report Writer) will conduct a
field examination to confirm the accuracy of application information and that the
project is in the public interest. In seawater intrusion prone areas (as indicated in
Figure Three), Water Resources staff will also examine existing ground water rights in
the immediate vicinity, and chloride levels in those wells. Where the applicant is
proposing a new well, a preliminary permit must usually be obtained in order to drill
and test this well. In the SWRO, a preliminary permit is issued only if staff does not
have enough information to approve or deny an application outright, and is used as a
data collection mechanism only. As part of this permit, an aquifer test is performed
during which the well is pumped at the maximum design rate7 for which the well
source would be used. The pump test must be performed for a minimum of 4 hours
of stabilized draw down (this is a DOH requirement), though 24-72 hours is more
standard in seawater intrusion prone areas. This longer test is designed to yield
information about an aquifer's ability to transmit and store water. It is required by the
SWRO only for larger projects or in critical supply areas. In seawater intrusion prone
areas, Water Resources grants a standard preliminary permit subject to the following
conditions beyond the normal requirements:
• Chloride and conductivity8 analyses to be performed from samples taken at these
intervals: one during 30 to 60 minutes after the start of pumping, one mid-way
through the pumping, and one within the last 15 minutes of pumping.
'Maximum design rate refers to the maximum withdrawal rate for which the pumping system is designed.
"Conductivity analysis refers to the electronic measurement of dissolved solids in the water. Chloride
represents a significant portion of the dissolved solids; there is often a positive correlation between chloride
concentrations and conductivity.
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• Two chloride and conductivity analyses conducted on samples from an observation
well preferably located between the tested well and the coast; one sample should be
collected prior to the aquifer test and one within 30 minutes of completion of the test.
This is generally not required from the SWRO. Staff in this office has found that only
very rarely has this short term pumping of observation wells resulted in increased
chloride levels, except in extreme conditions.
• A report submitted to Water Resources based on analysis of aquifer test data shall
include these two elements: 1) data on tidal fluctuation and its effect on chloride
levels and 2) a copy of all laboratory test results.
These elements are part of a standardized preliminary permit letter used in seawater
intrusion prone areas in order to streamline the permit process.
6) Three days before drilling the test well, the well drilling specialist must submit a start
card notifying Water Resources of his or her construction plans. This gives the well
drilling coordinator at Water Resources the option of going to observe the drilling to
ensure that construction regulations are fulfilled. Within 30 days following well
drilling, the well drilling specialist is required to submit a well drilling log to Water
Resources detailing drilling information and aquifer characteristics.
7) Based on the results of the aquifer test and the field examination, a Report Writer
(with assistance from a hydrogeologist working in the same region if the case is
technically complex) will issue a Report of Examination, recommending either
approval or denial of a water right permit. A consideration of other ground water
rights generally within a half-mile radius of the subject well will be included in the
examination. The applicant and others have 30 days to appeal the Report Writer's
decision to the Environmental Hearings Office of the state PCHB.
8) In instances where there are no protests to the proposed withdrawal, and where the
proposed project satisfies the four criteria, Water Resources issues a Permit to
Appropriate Public Waters which may include certain provisions or stipulations for
use. While this is not a certificated water right, it allows the applicant to begin
construction on the withdrawal facility and to use the water resource. It includes a
construction timeline, and a date by which the water must be beneficially used.
If an application is denied, the applicant may either continue to withdraw within
exemption limits, or abandon the project. The Report of Examination will include
conditions for proper well abandonment according to WAC 173-160. It is the report
writer's responsibility to ensure that the applicant has taken measures for proper
abandonment.
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9) When the water is put to beneficial use, the applicant must submit a Proof of
Appropriation detailing the amount, purpose and location of use, equipment employed,
and verifying that all permit conditions have been met
10) Water Resources may examine the project to verify information provided in Step 9.
11) Provided all regulations have been complied with, and fees have been paid, Water
Resources will issue a Certificate of Water Right to the applicant. The appropriation
amount is based upon the extent to which the applicant's water use has been
developed, and cannot exceed the amount requested in the application. Water
Resources retains the authority to reduce permitted uses if necessary for resource
protection.
While the initial four steps can be completed in several weeks, evaluation of applications and
aquifer testing can take several months. Protested applications may take even longer, as they
require additional evaluation regarding the elements protested. Though the goal is a six to
nine month turn around time on applications, in practice it has ranged from six months to
several years. This has been due in part to inefficiencies in Water Resources' review process,
in part to resource limitations, and in part to applications being appealed. These issues will
be explored further in Chapter Nine.
Water Permit Exemption
As mentioned earlier, a water permit is not needed for a ground water appropriation of less
than 5000 gpd or for irrigation of less than one-half acre; this is commonly called a "domestic
exemption" as it applies often to a single or group domestic water supply*. Though these
users are exempt from the permit process outlined above, their water right is of equal value to
one obtained through this permit process, and their priority of right dates to the time that they
initially put the water to beneficial use. In addition, these users are not exempt from
regulation in favor of senior rights. If a senior right were unable to be fulfilled, a junior
exempt user's appropriation may be (temporarily) decreased. Exempt wells may also be
monitored by Water Resources as deemed necessary. Except for the permit process (which
exempt users may voluntarily undergo), exempt wells are theoretically subject to the same
degree of regulation as non-exempt wells.
'As a rule of thumb developed by county planning and health departments, group domestic water supplies
serving fewer than seven households do not require a water right unless the total lawn irrigation for the
development exceeds one-half acre.
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Chapter Eight Regional Office Policy and Practice
Daily decisions are made on water right applications, many of which request ground water
withdrawals in seawater intrusion prone areas. The Seawater Intrusion Policy is implemented
on the regional level. The balance of this report will focus on decisions made on the
regional level, as this focus provides the most valuable insight on seawater intrusion
management practices.
The Northwest Regional Office
Many of the areas in which there is high risk or actual occurrence of seawater intrusion are
under the NWRO's jurisdiction. The counties within this office's domain are: San Juan,
Island, Whatcom, Skagit, Snohomish, King, and Kitsap. See Figure Six for regional
definitions. Though
all of these counties
have documented
incidents of elevated
chloride levels in
ground water, San
Juan and Island
Counties have the
most widespread and
chronic occurrences.
It is no coincidence
that both counties are
comprised of islands
whose residents
depend almost solely
on ground water as
their water supply
(75% of Island County
residents depend
exclusively on ground
water (Island County
Planning Department,
1991)). In addition,
both counties are
experiencing surges in
population and
concomitant
development.
Southwest
Region
Figure Six. Washington Department of Ecology northwest
and southwest regions
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Water Resources' work with Island County towards the control of seawater intrusion has been
prototypical. This is due to myriad factors, including the acknowledged widespread nature of
the problem, extensive citizen awareness and pressure for corrective action, and a large and
growing population (population is expected to grow by more than 20% between 1990 and
2000 (Island County Planning Department, 1991)). According to Island County's Ground
Water Area Management Plan (the County was designated a Ground Water Management Area
by Ecology pursuant to WAC 173-100), seawater intrusion is the most widely recognized
ground water problem in Island County, with Whidbey and Camano Islands experiencing the
highest impact. The balance of this section will examine Water Resources efforts in Island
County, including a review of several case studies highlighting the water right application
decisions in seawater intrusion prone areas.
Memorandum of Understanding
In December 1990, a Memorandum of Understanding (MOU) was signed by Water Resources
and Island County Commissioners as an important step towards cooperative water resource
management. It is Water Resources' hope that this agreement will eventually be modeled by
other counties. A similar agreement is currently being designed in Kitsap County. The MOU
represents an attempt by both state and local officials to adopt a proactive, preventative stance
with regard to water resource problems in an effort to avoid crisis or remedial action. The
MOU came about because of two problems: 1) delays in Water Resources permit decisions
were confounding the local decision making process and 2), state and local decisions were
often inconsistent (Walsh, 1992). For example, Water Resources would sometimes approve
projects which conflicted with local land use plans, or conversely, counties would approve
projects where adequate water supply was unavailable. Though the MOU does not address
seawater intrusion specifically, it is directly supportive of prevention efforts. Agencies
involved in implementation of this MOU are Water Resources and Island County Health and
Planning Departments. Island County has nearly 700 public water systems (Marincic, 1992);
this number does not include exempt wells. When the Seawater Intrusion Policy was
implemented, there was a water permit application backlog of approximately 100 for Island
County, over a third of which were more than four years old (Fritzen, 1992). Clearly, a
coordinated plan was needed simply to deal with regulation of existing water systems, and
current and incoming applications.
The goals of the MOU are as follows:
• Develop a water permit review process which is standardized, expedient, and clear to
the public.
• Prevent overappropriation of water and aquifer degradation
Accumulate technical information (hydrogeologic and well history data are lacking and
are necessary for more confident and credible decisions)
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• Develop a mechanism for dealing with application backlog
• Enhance education and conservation efforts
Ecology's focal strategies in fulfilling these goals include 1) analysis of applications on an
areal basis, 2) implementation of the Seawater Intrusion Policy, 3) creation of a map of
existing water rights (based on this and existing hydrogeologic data, water availability would
be more quickly discernible), 4) requirement of flow meters for all new (and eventually,
existing) permitted wells, 5) implementation of a well identification system for new (and
eventually, existing) wells, and 6), ongoing well monitoring in problem areas. Action has
been taken on all of these strategies, though most extensively on numbers 1 through 3.
Officials from Water Resources, state and county health, and county planning engage in
monthly meetings to coordinate water management in Island County. These meetings have
been a critical forum for sharing information on the status of water right applications, and for
achieving consensus. Water Resources has gained a knowledge of local concerns and
conditions which has enabled it to make more informed water right decisions.
Water Permit Decision Case Studies
Water permit decisions in seawater intrusion prone areas, while facilitated by the cooperative
spirit of the MOU, are finally governed by the Seawater Intrusion Policy. Outlined below are
cases representing three different applications for water rights and the decisions Water
Resources made in light of the evidence provided. The process used in making these
decisions is outlined in Chapter Seven.
Public Water Company A
In June 1981, a public water company submitted an application for additional water supply to
an existing water system in Oak Harbor, Whidbey Island. The source was to be a well drilled
1150 feet from the coast, to a depth of nearly 100 feet below sea level. The absence of a
seawater intrusion policy in the face of a potential problem led to inaction on the part of
Water Resources. The company drilled and operated the well illegally for several years,
exceeding the appropriation allowed in its water right for the prior three wells in the system.
In 1991, exactly ten years following application submission, the application was readdressed
by the Island County report writer. On the basis of multiple site inspections in which he
tested chloride levels in the subject and neighboring wells, office research into case history
and surrounding water rights, and a phone conversation with the applicant, the application
was denied. Chloride readings taken in August 1991 indicated 140 mg/1 in the subject well,
and 120 mg/1 and 65-70 mg/1 on two other wells within a half-mile radius. The following
statement fed the report writer's conclusion:
The Department of Ecology's Seawater Intrusion Policy specifies that wells with
greater than 99 mg/1 of chloride are in medium to high risk areas. It also states that
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preventive efforts will be approached from a regional perspective wherever possible
and that, in the absence of hydrogeologic information to the contrary, a minimum half-
mile radius around these elevated chloride wells will be used to delineate medium to
high risk areas. The Policy specifically states that, "In medium to high risk areas, new
water rights applications shall be denied, unless the applicant can show that additional
withdrawal of ground water will not increase the risk of seawater intrusion." Well #4
[subject well] has been determined to be in a medium risk area at this time.
However, because of Water Resources' extreme delay in addressing the application, and the
fact that the water served current uses and cutting it off posed health and safety risks, Water
Resources granted a three year temporary authorization during which the company could use
water at existing levels while attempting to decrease chloride levels. As part of this
authorization, Water Resources required the installation of water meters and monthly reading
reports, conservation efforts, and experimentation with altering pumping rates and/or raising
pumping levels. Water Resources has also worked with Island County to prevent the issuance
of further building permits to this company during this time.
This type of decision is unprecedented according to the Island County report writer. He is
hoping that the company will make a concerted effort to bring chloride levels down during
the three year authorization, at the end of which Water Resources can assess progress and
either issue a permit if chloride concentrations have been brought into the low risk category,
or grant an extension if a good faith effort towards this goal is being made.
Public Water Company B
In June 1990, a public water company submitted an application for nine service connections
to be used in a community on south Camano Island. No protests were made to the
application. The report writer investigated the application through a field examination,
consideration of nearby water rights, and conversations with the applicant Eight chloride
readings on the subject well during the pump test ranged from 15 to 21 mg/1. However,
several exempt coastal wells within a half-mile radius had exhibited chloride levels within the
medium and high risk ranges, therefore placing the applicant's well within a high risk area.
On the basis of the Seawater Intrusion Policy, it seemed that the application should be denied.
The application is predicated on the abandonment of three intruded coastal exempt wells,
however, and the cancellation of a planned coastal well; given this, Water Resources granted
the permit on the premise that eliminating these seawater intruded exempt wells in exchange
for the operation of an un-intruded well which they could more directly control through
permit restrictions was the desirable option. The permit was conditioned on the following
provisos:
1) Issuance of the [water right] certificate will be dependent upon the proper
abandonment of the three existing coastal wells (WAC 173-160). The 'planned well'
must also not be drilled. If these conditions cannot be met, the permit will become
null and void.
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2) An approved measuring device shall be installed and maintained.... Meter readings
shall be recorded monthly and this data shall be maintained and be made available to
the Department of Ecology upon request.
3) Static water level (SWL) shall be measured at least once each month. Measurements
shall be taken after the pump has been shut off and the water level in the well has
been stabilized. The data shall be maintained and made available to Ecology upon
request. However, Ecology's Water Resources Section shall be notified if the SWL is
determined to be below the level normally recorded at that time of year.
4) The permittee or its successors) shall provide data on chloride concentrations for the
well authorized by this permit with analysis performed by a state certified laboratory.
Sampling shall occur April and August of each year and permittee shall submit by
October 15th of the same year written results for both sampling events to the
Department of Ecology.... Depending on the results of this data collection, withdrawal
of ground water under this permit may be limited or other action required.
5) If pumping of the well authorized by this permit causes chloride concentrations to
exceed 99 mg/1, the permittee shall be required to take immediate action to prevent
concentrations from increasing. If corrective measures fail to prevent chloride
concentrations from exceeding said level in the future, permittee shall relinquish the
option to perfect additional allocated quantities regardless of the stage of development.
6) A certificate of water right shall not be issued until a final investigation is made.
Public Water Company C
In July 1988, a public water company applied for ground water to supply a community
development in south Whidbey Island. The production well is located 1700 feet from the
coast, and is drilled to a depth of approximately 40 feet below sea level. The application was
not addressed until February 1992 due to the fact that a Seawater Intrusion Policy was not in
place until this time. Investigation of the application consisted of a field examination during
which chloride levels were measured, office research including review of existing water rights
within a half-mile radius of the production well, and information supplied by the applicant
Chloride levels measured in the well between 1984 and 1992 ranged from 110 mg/1 to 140
mg/1. Wells within a half-mile radius, though not exhibiting high risk chloride levels, have
shown readings of over 99 mg/1. The Seawater Intrusion Policy indicates that the subject well
lies within a medium risk area; on this basis, the report writer recommended in April 1992
that the permit be denied.
In May, following a conversation with the applicant, the report writer agreed to an extension
of time on an application decision during which the applicant had the opportunity to alleviate
high chloride levels. Water Resources granted the extension on the basis that the applicant
had not exceeded 5000 gpd during the application period, the maximum allowable withdrawal
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without a permit. Water Resources staff also believed that the applicant's proposed appeal of
the decision would result in an extension. The report writer allowed the applicant until
October 1992 to re-sample the well and submit an August chloride reading to Water
Resources, at which time an amended report of examination would be issued.
These cases are representative of the current challenges of and decisions made in the NWRO
in handling water rights in seawater intrusion risk areas. In Island County, approximately
20% of the water right applications in seawater intrusion prone areas have been denied,
though about half of the applicants in these cases have been granted opportunities to alleviate
high chloride problems (as outlined in public water companies A and C, for example)
(Fritzen, 1992). Most of these applications are several years old and were submitted before a
seawater intrusion policy had been developed. As new applications are received, the Island
County report writer is able to notify the applicant immediately as to whether the application
is in a medium or high risk area based on other chloride readings in the area. The applicant
knows from the outset of a probable denial, thereby avoiding unnecessary effort and
aggravation.
Standardized Procedure
The NWRO uses the Seawater Intrusion Policy and standardized provisos (numbers 2 through
5 listed above) in water permits for intrusion prone areas. In addition, the NWRO developed
other standard procedures for handling applications with greater fairness and expedience. In
two cases where the report of examination recommends that the permit be denied and in
which the applicant has been waiting a number of years for Water Resources to make a
decision, the Island County report writer has granted an extension on application review until
the following August when a new chloride reading can be taken. August, as the month of
highest water use and lowest ground water recharge, is assumed to be the time of year when
chloride levels peak. This gives the applicant a chance to lower chloride to allowable levels
in the intervening time, renewing his or her prospects for application approval. A standard
"August chloride" letter is sent in this case. During this time, the applicant must not pump in
excess of water permit exemption limits.
A preliminary permit letter to be used for wells within seawater intruded basins in Island
County has also been developed. In addition to fulfilling the conditions outlined in Step 5 of
the application process, the applicant must also submit a report detailing information required
in "Criteria for Establishing Lack of Influence of Proposed Withdrawals With Respect to
Seawater Intrusion Within Island County." This document explains that, in attempting to
prove that granting a water right to the applicant will not increase the risk of seawater
intrusion in the basin, the applicant must supply the following (Department of Ecology,
1992):
1) Copies of available water well reports for wells located within a half-mile radius of
both the proposed withdrawal point and the high chloride well. Information on surface
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elevations and a map indicating well locations for wells within this half-mile radius
should also be included.
2) Two geologic cross sections passing within relevant distance of the applicant's well,
with section lines tending roughly 90 degrees to one another. These section lines
should extend a minimum of one mile (or to the coast if this distance is less than a
mile) from both the proposed withdrawal point and the high chloride well. These
sections should depict subsurface geology at least as deep as the deepest well in the
area and should also attempt to delineate the boundary between fresh and saline water
(this is defined as water with 100 mg/1 of chloride).
3) Chloride and static water level data compiled for at least two wells withdrawing water
from the same aquifer as the proposed point of withdrawal. These wells should be
located within a half-mile radius of both the proposed withdrawal point and the high
chloride well. A trend analysis of the data should be performed in order to
demonstrate that chloride levels have not increased and static water levels have not
decreased significantly over time. The data should also be presented in hydrograph
form.
4) A hydrogeologic interpretation including:
a. A discussion of trends of both chloride and static water levels within the
aquifer proposed for further withdrawal. Additionally, static water levels for
the area should be analyzed in order to determine any ground water gradients.
b. A water balance analysis indicating the relationship of recharge versus
consumption in the area.
c. Convincing arguments that granting of the water right will not lead to seawater
intrusion. This might include a discussion of supporting evidence that indicates
that the area is underlain by two or more discrete aquifers.
Standardization of procedures has made the NWRO's application process more rapid and
efficient. Historically, there has been a tendency to handle each case independently; while
this certainly allowed a tailored response to each applicant, it has proven ultimately infeasible
given the number of applications received combined with limited staff resources.
The Southwest Regional Office
The Southwest Regional Office has jurisdiction over the following coastal counties: Clallam,
Jefferson, Grays Harbor, Mason, Pacific, Thurston, and Pierce. (See Figure Six.) Evidence '
of seawater intrusion has been documented in areas such as Marrowstone Island (Jefferson
County), Horsehead Bay and Gig Harbor (Pierce County), and Johnson Point (Thurston
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County). This Office does not receive the volume of applications received in the NWRO.
The population in these counties is less than half the population in the counties covered by
the NWRO (Department of Commerce, 1991). As might be expected, the SWRO encounters
fewer ground water applications in seawater intrusion prone areas. As of July 1992, the
office had a backlog of approximately 70 applications in intrusion prone areas, which are two
years old on average (Davidson, 1992). From receipt of application, it takes an average of
fourteen months to make a water right decision; the evaluation of the application, including
aquifer test, takes between six months and one year.
The following case study is fairly representative of the Office's response to applications in
seawater intrusion risk areas. Though the Seawater Intrusion Policy is used, it is not cited as
heavily as in the NWRO.
Water Permit Decision Case Study
In October 1990, a public water company in Gig Harbor applied for a water right to withdraw
more than 11,000,000 gpd from three wells for a community development. A preliminary
permit was issued in March 1991 allowing construction of one of the wells with stipulations
outlined in Step 5 in the application process. Field investigations were conducted in
December 1991 and January 1992 and included a pump test of the subject well, during which
chloride levels were measured at 5 mg/1, though a pre-existent well in the system has
manifested chloride levels of 146 mg/1. In addition, monitoring of pre-, post- and during test
water levels in nearby wells was performed. Given a number of neighboring wells and
existing water rights, well interference was considered a potential (and in one case, actual)
problem. Because of the potential for elevated chloride levels as well as interference with
other wells, strict monitoring of the subject and planned wells was recommended in the report
of examination as a condition of approval. The application was approved in May 1992 with
the following seawater intrusion-related provisos:
1) Installation and maintenance of an access porL..is required.... Water levels shall be
measured and recorded using a consistent methodology, in accordance with accepted
industry standards. Such measurements shall be made at least monthly. The length of
the pumping period or recovery period prior to each measurement shall be constant,
and shall be included in the record.
2) An approved metering device shall be installed and maintained.... Meter readings shall
be recorded at least monthly.
3) A certificate of water right will not be issued until a final investigation is made.
4) Testing will be required of both Well #1 and Well #2, and withdrawal quantities may
be reduced commensurate with testing results, prior to certification of this permit.
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5) Quarterly monitoring is required as a provision of this permit; any increases from the
current chloride of 5 mg/L.will be considered significant and management of the
production rate through reduction of pumping rate, or raising of the pump intake, will
be required.
6) The applicant is reminded of the responsibility towards other water users in this area,
and advised that regulation of the withdrawal and pumping rate will be required if
existing rights are injuriously affected.
With regard to pending applications for ground water withdrawals in high risk areas, staff
indicated that many would be denied on the basis of the Seawater Intrusion Policy.
Other Standard Provisos
In the SWRO's list of standard provisos, there are two which deal specifically with intrusion
prone areas, one called the "Chloride Concentration" proviso and the other called the
"Seawater Intrusion" proviso. They are both modifications on Proviso 5 listed immediately
above. Both require quarterly monitoring in conjunction with DOH sampling by a lab
accredited by Ecology. Interestingly, one proviso lists 50 mg/1 as a corrective action level,
and the other lists 125 mg/1 as an action level. Staff in the office was unable to explain the
reason for this, though suggested it might be due to a disparity in opinion as to what
constitutes a problem level, or perhaps to the fact that the provisos have not be reviewed and
amended recently.
One other directly relevant proviso used in the SWRO is the "Water Resources Act" proviso:
The Water Resources Act of 1971 specifies certain criteria regarding utilization and
management of the waters of the State in the best public interest. Favorable
consideration of this application has been based on sufficient waters available, at least
during portions of the year. However, it is pointed out to the applicant that this use of
water may be subject to regulation at certain times, based on the necessity to maintain
water quantities sufficient for preservation of the natural environment.
Because of the low volume of applications for public water supply in seawater intrusion prone
areas relative to that of the NWRO, and the comparatively low backlog, the SWRO has not
developed as many standardized procedures for handling these applications, though the Office
did provide the model for the standard preliminary permit letter (Step 5 of the application
process). The Seawater Intrusion Policy, the preliminary permit letter, and provisos provide
the basis for response to applications in intrusion prone areas.
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Chapter Nine. Analysis and Recommendations
The foregoing chapters have attempted an objective description of Water Resources' historic
and current seawater intrusion prevention efforts as well as supportive legislation. This
chapter presents a more critical look at those efforts in light of resource, organizational,
policy, and political considerations. Specifically, while Water Resources has made large
strides in intrusion control efforts, its Seawater Intrusion Policy not least among them, there
are well-defined obstacles to its continued and ultimate success in this area.
Resource Constraints
Primary among the resource constraints is a lack of dedicated or consistent funding. In the
1991 legislative session, for example, Water Resources received a 30% increase in funding,
which was spent primarily to salary additional report writers and hydrogeologists in the
regional offices. Soon after, Ecology as a whole experienced a 2.5% funding decrease, also
determined by the legislature. While the new staff was retained, temporary help, interns, and
the Washington Conservation Corps (six individuals in the SWRO) were lost; these people
had provided invaluable assistance in examining water right applications and, due to their
departure, many of these functions returned to the report writers and hydrogeologists. A
similar number of temporary positions and interns was lost in the NWRO. Thus, the financial
assistance provided initially was undermined by a later contrary decision. This deficiency in
dedicated, consistent funding has been a chronic problem in Ecology historically, and has
resulted in projects which are not fully realized, and staff with unrealistic workloads. This
leads to inefficiency and incomplete efforts.
Because of inadequate staffing support, staff involved in reviewing and deciding on water
right applications have had scarce time for follow-up on regulatory practices with regard to
water permit approvals. Though staff issues provisos which provide appropriate and critical
guidelines which applicants are to fulfill in developing and perfecting their ground water
withdrawal, the goals of which are sustainable development and protection of the aquifer,
staff is unable to monitor compliance with these provisos. The report writer for Island
County is only able to perform the minimum necessary level of field work for project
examinations during the application process, and is not able to perform follow-up monitoring.
The applicant is like a speeding motorist who, on seeing the roadside police car, slows down,
but speeds up again when out of sight Though state and (in some cases) county health
departments perform monitoring, these agencies are monitoring for public health concerns (at
which an action level for chloride concentration is 250 mg/1), not for aquifer degradation
concerns (at which action levels are considerably sooner, as set forth in the Seawater
Intrusion Policy). More significantly, these efforts are not comprehensive: the DOH
monitors approximately 13,000 public water systems with two or more service connections in
the state (Deem, 1992). Island County Health Department monitors only ten wells for
seawater intrusion on a routine basis, and these through a grant from Ecology (Deem, 1992).
While Island County attempts to monitor its public water systems in a fairly consistent way, it
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does not have the staff resources to enter and track this data. Most county health departments
have no on-going well-monitoring program. One potential solution is to have dedicated
citizen volunteers perform monitoring activities, as well as computer entry of the results.
This raises a host of issues such as training, equipment, scientific viability of the results, and
bias in testing. There are citizens willing to do this testing (Abbott, Sinclair, 1992), and it
may be preferable to insufficient monitoring.
Data management also suffers due to lack of staff. While many appropriators submit
quarterly or semi-annual chloride readings and monthly static water levels, many of these data
are never entered on Water Resources' database. This database was created in 1989 with
information provided from the USGS, the DOH, Island County Health Department, and Water
Resources and provides the basis for a data management system. Unfortunately, there is little
time to actually enter the data, so that as a tracking tool, the database is not particularly
useful. Tangentially, a Water Resources Data Management Task Force was created in 1990
to evolve a strategy for successful data management; progress towards this goal has been
fairly consistent since the Task Force's inception. A major weakness in Water Resources'
approach to seawater intrusion is that the Program has not made a sustained commitment to
developing a water quality, water level, or water use monitoring program for seawater
intrusion prone areas. Without consistent and reliable data, it is very difficult, if not
impossible, to forge a defensible and proactive water management and allocation program.
It is also not uncommon for appropriators to use more water than was granted them (as in the
case of "Public Water Company A"); alternately, Water Resources has little knowledge of
relinquished rights, cases where appropriators are no longer using the amount originally
granted. (If allocated water has not been put to a beneficial use, the state has the authority to
rescind the water right)
In another example of staffing inadequacy, there is only one well drilling coordinator in each
of the Northwest and Southwest Regional Offices. In the SWRO, that translates to one
person monitoring well construction (for permitted and exempt wells) for twelve counties, in
which there are approximately 120 well drillers. The well drilling coordinator in the NWRO
indicated that he receives approximately 400 start cards per month, and is able to observe
construction on about 3% of these wells (Thompson, 1992). Because of this glaring lack of
staff in well construction compliance monitoring, the effort has lost public credibility
(Thompson, 1992). Wells are at times drilled illegally or their locations are inaccurately
reported on the well drilling reports. It is difficult to know how often this occurs, but a 20%
incidence rate is estimated (Thompson, 1992). Most of the well drilling coordinators' site
visits are motivated by complaints or "tattling" by other well drillers. In addition, there is no
enforcement of well construction standards in seawater intrusion prone areas; WAC 173-160-
020(1) stipulates additional construction standards in these areas. For example, non-
corrodible casing should be used, yet this is not enforced.
To make matters worse, both the NWRO and the SWRO are experiencing an increase in
applications submitted. This is due to a number of factors, the most obvious of which is
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increased population growth in many coastal and island regions. Additionally, two thirds of
the growth occurring in Washington in the last decade is situated in rural settings (Ecology,
1991). These settings offer few municipal suppliers, the result being more applications for
smaller systems. The current drought has also motivated more applications, as well as the
need for report writers to perform more enforcement activities. Finally, growth management
legislation has increased the number of applications filed. The combined effect of these
factors has been an increase of approximately 50% in ground water applications from 1985 to
1991 (Ecology, 1991), an irritated public, and an overwhelmed staff.
It is obvious that resources for staffing must be increased, because workload certainly is
increasing. The laudable goals and policies of Water Resources mean very little if practice
does not reinforce them. One solution is to increase application processing fees, which are
abysmally low compared to the Water Quality Program's waste water discharge permit fees, or
the DOH system approval fees, for example. Water Resources application fees currently
shoulder less than one percent of administrative costs (Walsh, 1992).
Organizational Constraints
Internal Organization
The internal organization of Ecology should be improved in order to support Water
Resources' efficiency and administrative success. In making a water right decision, there are
potentially (too) many reviews which the application must undergo; the application may get
stalled at one of these reviews, thus increasing decision time. A shift should be made
towards greater decentralized control, vesting the report writer with more decision making
authority. Certainly this individual should not operate in a vacuum, though over-control
should be avoided. One might consider the regional offices at the DOH as an example of a
more decentralized operation.
Secondly, there is very little information sharing between the NWRO and the SWRO. Both
offices are in the process of implementing the Seawater Intrusion Policy. It makes infinite
sense that they share information and methods in a more continual way in order to develop
greater efficiency, consistency of response, and agency camaraderie and morale. The
standardized preliminary permit letter is an example of the NWRO building on something
developed in the SWRO. This type of sharing should be the norm, not the exception.
Seawater intrusion is an issue which, though its cause is a resource shortage, has as its effect
a water quality problem. Because of this, seawater intrusion is a concern of both the Water
Resources and the Water Quality Programs in Ecology. Unfortunately, Water Resources'
staff attempts to involve Water Quality in an ongoing way have met with no real success. As
mentioned in Chapter Five, Water Quality's purview is in large part to issue waste discharge
permits for industries and municipalities, and chloride is one of the water quality elements the
Program reviews. Recently, Water Quality has begun to monitor ground water in wastewater
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discharge areas. This information could be shared with Water Resources to augment its
knowledge of regional aquifers, and to notify Water Resources as to discharge sites and
quality issues within these areas. This overlap in Program responsibility touches on a more
formidable question: Should Water Resources be issuing ground water permits and therefore
implying a clean source of water, yet with no actual knowledge of ground water quality?
This is a potentially very dangerous situation for Ecology, though has not yet proven
problematic. For example, what if a permit was issued for a seemingly pure source of ground
water, yet the source contained toxic contaminants? Greater coordination between the two
Programs would at least mitigate the potential for this very serious problem.
Inter-Aeencv Coordination
The DOH's Drinking Water Division is responsible for public water system approval in the
state. As such, its role fits snugly with Water Resources' water permit approval role. Until
recently, there was little coordination of efforts between the two agencies. What occasionally
happened was that the DOH would issue a system approval, the development would be built,
and the developers would apply for a water right only to find that there was no water
available. In late 1991, the DOH reinforced existing policy by stating that it would not
consider a public water system approval until the applicant had been granted a water permit,
thus water availability and water system approval are now more closely coordinated. While
Water Resources has an ideal turn around time of six to nine months (as mentioned, it has
historically been quite a bit longer), the DOH's Northwest Drinking Water Division has an
actual turn around time of six to eight weeks (Deem, 1992). This causes frustration among
applicants, and greater pressure for Water Resources.
Additionally, the two agencies have recently agreed on a unified aquifer test According to
this agreement, the applicant would only need to do one aquifer test to satisfy both
departments' requirements. When Water Resources sends its preliminary permit letter, the
elements required by the DOH are also included. If the period between the time of the
aquifer test and the time that the applicant applies for system approval is great (i.e. if water
right application review is lengthy), water quality conditions may change and the aquifer may
have to be re-sampled. This has not yet been a problem, and hopefully, with Water
Resources attempt to expedite the water right decision process, will not be.
This progress in Water Resources-DOH coordination is quite positive, however, due to a
different agency mission, the DOH has chosen not to help directly with seawater intrusion
control. In practice, the DOH will only deny a public water system approval if chloride
levels exceed 250 mg/1, the point at which they cause an aesthetic (i.e. taste) problem; the
Department will not typically deny project approval at levels at which Water Resources has
determined as medium to high risk (i.e. 100 mg/1 and above).
The EPA has a role in regulating seawater intrusion through its Wellhead Protection and Sole
Source Aquifer programs, as explained in Chapter Five. However, this control is fairly
minimal. Through its Sole Source Aquifer Program, the Agency has the power to deny
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federal financial assistance for a project in EPA designated Sole Source Aquifer areas. The
preponderance of private funding, few Sole Source Aquifers, and the probability that many
projects are not sent to the EPA for review limits the Agency's role in preventing seawater
intrusion. The EPA has even less regulatory control through its Wellhead Protection
Program. In this instance, localities are encouraged to address seawater intrusion concerns in
their wellhead protection plans, though there are no strict requirements or parameters set
forth. It is also important to recognize that both of these programs are intended to protect
public health. Natural resource protection in and of itself is not the primary concern. In
areas threatened by seawater intrusion, aquifer protection is tied to appropriate resource
allocation; since allocation is expressly a state responsibility, the EPA cannot be directly
involved at the most useful level.
Primary responsibility for seawater intrusion control, in as much as it finds its cause in over-
allocation of ground water, rests with Ecology. Other state, federal, and local agency support
is, however, absolutely necessary to the success of this effort.
Policy Constraints
Water Permit Exemption
RCW 90.44.050 provides for an exemption from the permitting process for ground water
withdrawals of less than 5000 gpd or for irrigation of less than one-half acre. In areas where
increased aquifer protection is necessary (e.g. seawater intrusion risk areas), this exemption
has proven particularly troublesome and is sometimes referred to as the "5000 gpd loophole."
In practice, Water Resources has much less regulatory control over these wells; for instance,
no ongoing monitoring or report submission is required of the well user in these cases.
Though RCW 90.44.250 grants Ecology the authority to make periodic investigations
concerning these wells, in practice, it typically only happens when these wells lie within a
half-mile radius from a water right applicant's well. In addition, Water Resources sometimes
has inaccurate or no records regarding these wells. According to one report writer, there are
"zillions" of exempt wells of which Water Resources has no knowledge. WAC 173-160-
205(2) stipulates that wells not be located within certain distances of contaminants, yet Water
Resources has little control over this in many cases. In short, Water Resources' charge to
properly allocate and manage the ground water resource is undermined by this exemption.
To complicate matters, county health departments (which approve smaller water systems)
have a coincident exemption whereby, in most counties, single and double unit wells are
exempt from monitoring practices, and, in some cases, exempt from the well site approval
process. No county or state agency has an organized plan to monitor these wells at this point
in time. While one may argue that county health departments should amend their policies to
include regulation of these wells, because the motivation is aquifer protection, it is really
more appropriate for Ecology's policy to be revised.
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A number of responses have been developed to this problem as follows:
Lower or eliminate the exemption
Given the large number of exempt wells coupled with the already large number of
applications, this change would increase workload and counteract Water Resources'
current efforts towards efficiency.
Eliminate the exemption in island settings
This again would be an unrealistic workload increase given Water Resources' limited
staffing levels.
Close certain areas to further ground water development through regulation
This has actually been done in certain sub-basins of the Methow Valley and in two
basins within Kitsap County, however the processes were quite lengthy and
cumbersome.
Close areas with certain characteristics to further ground water development
through the Seawater Intrusion Policy
It has been suggested that the Policy be amended to prevent new wells from being
allowed within half-mile radii of certain critical risk intrusion areas (to be defined
based on current development in area, chloride levels, etc.), or that only in-house or
septic uses be allowed. This would give Water Resources direct and continuing
control in these decisions; this is preferable to applying to the state legislature on a
repeated basis.
Seawater Intrusion Policy
While creation and implementation of the Seawater Intrusion Policy was certainly a
progressive step, the Policy has shortcomings. Although it provides a regulatory mechanism
for seawater intruded areas, and a half-mile sphere of influence radius, it lacks a
comprehensive focus. For example, at the same time that it may prevent operation of a
coastal well, the Policy never directly addresses or provides guidelines to control the potential
causes for the coastal contamination such as inland development and the paving of ground
water recharge areas. In the Johnson Point area of Thurston County, high chloride levels
have been observed around the peninsula concurrent with inland development (Sinclair, 1992)
To the extent that the Policy deals with an effect (i.e. elevated chloride levels) and does not
specifically address the potential causes, it is a band aid solution, or, at best, an initial step.
Along similar lines, the Policy sets forth no plan for distinguishing among different types and
volumes of use in its guidelines. In a case where an industry and a municipality are both
applying for a limited supply of ground water, who has precedence? In short, there is no
prioritization of beneficial uses. Perhaps an industry and a smaller domestic user are
competing for ground water, who has precedence in this situation? A water right denial made
without consideration of this imbalance may constitute an inequitable denial. These questions
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pertain not only to cases of seawater intrusion, but to water right decisions in general. With
increasing hydrogeologic data, the perception of ground water as an "unlimited" resource is
shifting, and questions of prioritization must be addressed. Washington water law does
provide a means for prioritizing uses through a "maximum net benefits" test (RCW
90.54.020); however, Ecology has not exercised this authority (Walsh, 1992).
A third concern is that, as applicants are denied permits based on the Seawater Intrusion
Policy, they will increasingly turn to exempt wells, building the number of exempt wells
needed to fulfill the demands of their project (as long as the connections to these wells are
not interned, this is legally permissible). This response counteracts the purpose of water
rights, which are used to properly allocate the ground water resource. Also, if a denied
applicant opts to build a number of exempt wells, then Water Resources loses ongoing and
programmatic control over these wells. This is a good argument for either eliminating
exemptions in certain areas, or closing areas to further ground water development. Otherwise,
or until this happens, granting a permit in an effort to maintain more direct control is perhaps
the preferable option. Finally, the building of exempt wells undermines the coordinated water
supply plan of several counties (including Island County) to have larger, more centralized
water systems.
Growth Management Legislation
Growth management legislation, the intent of which is to coordinate land use and water
availability, is welcome and overdue. RCW 19.27.097 stipulates that "each applicant for a
building permit of a building necessitating potable water shall provide evidence of an
adequate water supply for the intended use of the building." This is good as far as it goes,
however there is no seawater intrusion provision. In determining potability, at least regarding
chloride levels, concentrations below 250 mg/1 typically fulfill this requirement. While
Ecology's Seawater Intrusion Policy may preempt this guideline in uses requiring a permit (a
permit is deemed one method of showing adequate water supply), it does not apply when the
permit applicant's water needs fall into the exempt category. Some mechanism is needed for
employing the Policy in exempt situations.
One possible vehicle is the implementation of the Seawater Intrusion Policy on the county
level This could be applied either in the planning department, where building permits for
smaller developments are issued, or in the health department, where well site review for
single unit domestic needs is conducted.10 As part of growth management legislation, Water
Resources may currently notify counties of problem ground water areas and advise zoning
limits in these areas. There is no enforcement clout behind this, however. A second option,
at least in Island County, is to implement the Seawater Intrusion Policy in the Ecology-Island
County Memorandum of Understanding.
10Not all counties perform this function. Island County is a notable exception and, hopefully, a model.
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Political Context
The political environment ultimately determines which policies are enacted and the success of
their implementation. Seawater intrusion prevention or control is, in practice, a politically
difficult policy, for its implementation may curb growth in tremendously desirable areas. It is
particularly difficult for a county to enforce this type of policy, especially if (and this is not
unusual), a majority of its commissioners have land development or real estate interests
(Abbott, 1992). Additionally, counties are caught directly in the cross-fire between no growth
and development advocates. On the state level, Ecology is in a sensitive position;
implementation of the Seawater Intrusion Policy (synonymous for some with denying growth)
will cause some undeveloped properties to have significantly higher costs for securing
alternative water supplies, whereas existing properties will be protected. However, not
implementing the Policy would negatively impact every piece of property eventually.
Ecology is charged with overregulation by one faction, and with not doing enough, by
another. Though this has not (yet) happened, the Department could be charged with
"wrongful taking" of land, in the same way that "wise use" groups are charging that the
Endangered Species Act restricts their private land use. Ecology walks a thin tightrope, and
must be sensitive and deliberate in its seawater intrusion policy.
General Recommendations
Coupled with the recommendations implicit in the foregoing analysis, more general
recommendations deserve mention. Though this may seem obvious, education and
conservation efforts should be increased. Statements such as "we don't need to ration, we're
on ground water" are particularly troublesome, though not uncommon, especially in the
current drought In addition, newspaper articles speculating a potential enormous (as to imply
unlimited) ground water source in an, as yet, untested aquifer are misleading at best (Seattle
Post-Intelligencer, 1992).
Water Resources' current educational efforts with regard to seawater intrusion includes a
staff-presented slide show, and a brochure entitled "Seawater Intrusion - What Does it Mean
to us?" Solicitation of other agencies' assistance in this effort is a natural next step; the EPA,
for example, could sponsor a regional seawater intrusion educational conference or provide
printed educational materials (Mullen, 1992). On a local level, concerned citizen groups
could hold informal workshops. As a conservation measure, water meters should be required
for all existing wells (though they have recently been required for new wells, a plan for
retrofitting existing wells has not been implemented). Monthly water use charges might also
be considered as an effective method for inducing conservation practices among users
(Bowen, 1992). Water Resources' current conservation projects (such as water reuse) could
be enhanced through coordination with other state and federal water conservation programs.
For example, the EPA has a section working on water use efficiency and reuse which could
assist in Water Resources' efforts. This type of cooperation on every level, from land use
planners to water system reviewers to public utilities to concerned citizens, is crucial; without
this cooperation, the most well-meaning policy will fall on its face.
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Chapter Ten. The Importance of Seawater Intrusion Prevention
It is critical that Ecology, with the assistance of appropriate agencies and other groups, works
to overcome the obstacles discussed in the foregoing chapter in order to adequately prevent or
control seawater intrusion. Otherwise, there may be serious consequences. Once an aquifer
has been contaminated by seawater, a vast water supply has been compromised and the clean-
up process is incredibly costly, as well as lengthy. On a human time scale, aquifer
contamination by seawater is an irreversible condition (Custodio, 1987). The aquifer must
first be flushed of salt water. Then, any salts trapped in half shut pores must be extracted.
Large quantities of fresh water and sophisticated equipment are required for this process.
Planning
The best time to engage seawater intrusion prevention efforts is before intrusion occurs. This
may seem obvious, yet historically, aquifer development plans have often been implemented
with little thought to this potential problem. It is critical that knowledge of aquifer geology is
obtained before the aquifer is exploited. From this, a plan for preventing salinization and
seawater intrusion should be created as well for maximum exploitation of the aquifer without
promoting intrusion. Several guidelines should be observed in developing these plans
(Custodio, 1987):
• Concentrated withdrawals should be avoided in coastal aquifers.
• In all cases, aquifer mining should be avoided.
• In cases where a shallow fresh water layer or lens floats atop underlying salt water,
withdrawals should be minimal.
• For aquifers below sea level, avoid localized and consistent depletion of the aquifer.
• Where there is considerable tidal fluctuation, a "pump and rest" schedule should be
implemented.
• When semipervious or impervious layering protects the aquifer, this should be
maintained to the extent possible.
• Well construction should be conducted with a minimum of damage to protective
layering, and wells should not allow vertical leakage from one aquifer to another.
Well casing should be made of materials resistant to salt water corrosion.
• Leaky wells should be repaired immediately; cement or some other impermeable
material should be used to plug the holes.
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When a well is abandoned, it should be plugged with bentonite clay or cement to
avoid salt water upwelling.
Chloride should be monitored during the life of the well.
In all cases, recharge sources must be protected.
Corrective Actions
Artificial Recharge
Corrective actions taken once seawater intrusion has become a widespread problem can be
tremendously costly and, in some cases, infeasible. One method that is used to mitigate
seawater intrusion is the recharge of the aquifer by artificial means. Possible sources of
recharge include wells, flood and river water, flood control structures, imported water, and
treated sewage water. In considering this method, an immediate question arises: Should the
new water be applied for recharge or go directly to fill demand? The answer to this depends
on several factors such as duration of need, location of water source, water quality, and means
of transportation and storage.
If it is feasible, artificial recharge by surface spreading is preferable to well injection
(Custodio, 1987). As the surface water filters through the unsaturated zone towards the
aquifer, soil and underlying material attenuate some contaminants, protecting the aquifer from
certain pollutants. Surface spreading is also generally an easier method. It becomes
problematic when the aquifer surface area is small, or when there are semi-pervious layers
between the ground surface and the top of the aquifer. In considering aquifer recharge, data
on the specific characteristics of the aquifer must be obtained; information from one aquifer
cannot necessarily be transferred to another.
Barrier Walls
Creating underground barriers is a more direct method for correcting seawater intrusion. This
option allows the maintenance of existing exploitation levels while at the same time
alleviating intrusion. This barrier extends the vertical length of the aquifer on the coastal
side, and can be made from clay, cement, sheet piles, concrete, or asphalt It can also be
made by pressure injection of these materials into existing consolidated or unconsolidated
material. In either case, the process is quite expensive. Maintenance costs must also be
weighed, especially when the area is subject to earthquake shock. There are no existing
examples of these types of barriers; all such proposals have been abandoned following a
benefit-cost analysis and feasibility study (Custodio, 1987). Additionally, barriers are not
feasible in island settings given that seawater intrusion can be omni-directional (Walsh, 1992).
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The injection hydraulic barrier is a second type of corrective device. A series of wells is
established along the coast, and these are injected with fresh water to maintain a sufficiently
high fresh water head to alleviate intrusion. A procedure of withdrawing salt water is often
used in combination with fresh water injection. In confined aquifers, or those with semi-
pervious layering, hydraulic injection barriers may be the only method available. This too
can be a costly method given the expense of wells and accessories, as well as the fact that
water for injection must be clean since any impurities will clog the wells.
There are several critical factors to review before choosing an injection hydraulic barrier
(Custodio, 1987). The quantity and quality of water needed for the project must first be
determined; the amount of water needed to create and maintain this barrier must be
established as well as the adequacy of the water quality for the method chosen. Assuming
that the water needed is available, one must decide whether to apply this water to directly
meet existing uses and consequently reduce ground water withdrawals, or whether it should
be injected into the aquifer. It is then important to consider the operational life of the facility
and potential maintenance problems. Finally, benefit-cost and feasibility analyses should be
performed. A pilot field test is helpful to understand and anticipate the complexity of the
system.
A third option is the pumping hydraulic barrier. This is somewhat similar to an injection
hydraulic barrier, though without an injection of fresh water, the purpose of the wells in this
case is to withdraw seawater as it approaches land. In this scenario some fresh water is lost
as it mixes with the extracted salt water, and the aquifer becomes completely salty between
the pumps and the ocean. This is best as a temporary solution in aquifers where intrusion has
occurred; the wells are normally drilled in the intruded area. Once the situation is somewhat
ameliorated, it is best to switch to another method such as artificial recharge or reductions in
extraction. Possible violation of coastal water rights must be considered in reviewing this
option.
One last method addresses prevention of upconing. In this case, a second well is created at
the site of the fresh water well for the purpose of pumping salt water, thus creating a delicate
balance of the salt water/fresh water interface. There are few existing examples of this, the
main drawbacks being the cost of the second well, the energy required, the great amount of
salt water extracted and dealing with its safe disposal. In addition, small pumping
irregularities can lead to the contamination of the fresh water. The costs and high risks make
this option undesirable.
Costs of Remedial Efforts
There are also powerful economic effects of seawater intrusion. For example, the
abandonment of a current project generates the need to access other water sources. This may
involve the building of new and possibly longer canals and pipes to carry the water. In
addition, there is a higher energy cost involved because the new sources are often at deeper
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levels, thus pumping costs are greater. Developing new sources, wherever they may be, is an
expensive business. A development of approximately 175 lots on Center Island in San Juan
County, for example, had a reverse osmosis unit for its contaminated water system installed
several years ago (Bankson, 1992). The unit pumps seawater directly, then removes the salts
to make it potable. The installation costs of the reverse osmosis unit, pump, and filter were
roughly $40,000 (Bankson, 1992). Each lot owner of the approximately 40 lots currently
served by the system has agreed to pay $100 extra per year towards the capital and operating
costs of this system. In addition, every lot owner in the development dedicates $35 per year
of his or her yearly dues to a water fund for eventual expansion of the reverse osmosis unit,
or development of other water sources (Bankson, 1992). Because of the costs associated with
this unit, these individuals are paying $.01 per gallon for water which would normally cost
them $.00001 per gallon. A number of families are installing reverse osmosis units in San
Juan and Island Counties. Given the associated costs, it is clear that these are affordable to
only a small segment of the population in these areas. An important philosophical question is
raised: should clean water be the privilege of only those who can afford it, and at the
expense of the less fortunate?
On a larger scale, Whidbey Island (Island County) has for several years considered extending
to the central island the pipeline currently providing water to Oak Harbor from Anacortes.
According to a 1990 study regarding a pipeline extension, the capital costs alone on such a
project would be over $3,000,000 (Economic and Engineering Services, Inc., 1990). Given
current population estimates of the area to be serviced by such an extension, the cost per
person would be more than $700. Certainly the question of cost justification arises. A
second, and possibly more central, issue also needs to be addressed. The water carried by the
pipeline comes from the Skagit River, the majority of which is already appropriated; would
there be enough water if the pipeline were extended, and how long would it last? Further,
Island County's potential dependence on a resource outside of its jurisdiction would carry a
relatively low reliability factor given the many competitors for the Skagit River resource.
In Orange County, California, the Orange County Water District manages an injection
hydraulic barrier supplied by a combination of reclaimed wastewater, demineralized
wastewater, and deep well water. The capital costs alone for this system, in 1973-74 dollars,
were nearly $21,000,000 (Orange County Water District, 1987). In a county of this size, in a
consistently arid environment, this cost is perhaps justified; a project of this scope in coastal
Washington is not economically viable.
In extreme cases of seawater intrusion, actions such as those outlined above may become
necessary. The high cost of such remedial actions underscores the need for immediate and
sustained preventative action. It is critical that Ecology manage ground water resources in
order to minimize, and hopefully prevent, the need for such remedial actions.
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Chapter Eleven. Conclusions
The Department of Ecology has made great strides over the last decade in addressing an issue
which has become a major environmental concern. Ecology has developed and adopted a
seawater intrusion policy, and its regional offices have standardized and expedited their
response to this problem as well as initiated coordination efforts with local counties. This is
just a beginning; the policy must be refined through practice at the same time as broadened to
adopt a more comprehensive scope. Through careful examination of this problem in policy
and political contexts, one realizes that there are no easy solutions to seawater intrusion,
though abundant possibilities. This report, in laying out Ecology's policies and practices in
this area, has hopefully made this clear. One caution: however difficult seawater intrusion
policy implementation is, non-implementation is far worse. In island contexts especially, the
costs of remediation may be astronomic and economically infeasible; pumping hydraulic
barriers, water importation, or other remedial measures may be economically unworkable.
More importantly, a region which is experiencing chronic and extreme seawater intrusion has
ceased to live sustainably with its available resources. Once this happens, it becomes
dependent on unreliable external resources and loses direct control of its own viability. And,
as we have seen in countless national and global situations, this is serious indeed.
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Appendix A: Ground Water Equations
Darcy's Law:
Q = KA(dh/dx)
where Q = aquifer discharge, A = cross-section of aquifer area through which water flows, K
= hydraulic conductivity of aquifer material, and dh/dx = hydraulic gradient
Ghyben-Herzberg Relation:
z =
where pf = density of fresh water, ps = density of salt water, hf = elevation of fresh water
above sea level (or potentiometric surface in confined aquifers), and z = the depth of the
fresh-saline interface below sea level. Given that the density of salt water is 1.025 g/cm3 and
the density of fresh water is 1.000 g/cm3, the relation can be simplified as
z = 40hf
Hubbert's Equation:
where hf = height of water level in a fresh water well of density pf and terminated at point z,
h, = height of water level in a sea water well of density p, and terminated at point z
Relative salinity (SR) of an aquifer:
SR(%) = 100[(c-cf)/(c,-cf)]
where c = salinity at a specific depth in the transition zone, cf = salinity of fresh water, and c§
= salinity of salt water
Schmorak and Mercado equation:
z = Q/27cdk(Ap/pf)
where z = rise of salt water-fresh water interface, Q = pumping rate, Ap = p,-pf, k = hydraulic
conductivity, and d = distance from the well bottom to the sea water-fresh water interface
Critical rise above which the interface will accelerate towards well:
(.3 < z/d < .5)
Model developed to define maximum pumping level (the level at which water may be
pumped without salt water entering the well, adapted from Schmorak and Mercado equation):
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Appendix B: Washington Department of Ecology Seawater
Intrusion Policy
Preamble
Groundwater is a finite and precious resource; in many coastal areas of Washington
State, it is a critical source of water which cannot be readily replaced.
Seawater intrusion is both a water resource and a water quality management issue,
potentially affecting coastal aquifers throughout Puget Sound, the Strait of Juan de
Fuca and the outer coast of Washington. Seawater intrusion poses aesthetic, public
health, and environmental risks, as well as economic impact to public resources.
The technical and economic feasibility of reversing seawater intrusion is uncertain, at
best. Therefore, this policy calls for prudent management of the state's water
resources via prevention of seawater intrusion for areas currently unaffected and
control (i.e. stabilization and reversal) for areas where the problem has occurred.
Ecology shall uphold the principles of resource conservation and sustained yield
through its administration of water rights (Chapters 90.03 and 90.44 RCW). If a
determination cannot be made with available information, Ecology shall direct the
applicant to obtain the necessary data in order for the water right application to
receive further consideration.
Seawater intrusion is a complex problem to diagnose and resolve due to the fact that,
in many cases, baseline data is lacking or not organized. Furthermore, the effects of
seawater intrusion may not be evident where it is caused. Through this policy,
Ecology seeks to improve the information base upon which water right decisions are
based. In addition, Ecology will evaluate water right applications, to the extent
possible, from the perspective of the overall hydrogeologic system.
Water resource decisions need to be made in coordination with local governments and
tribes, especially in consideration of water availability and land use provisions of the
Growth Management Act.
I. Policy Purpose
The objectives of this policy are as follows:
1. To provide the Department of Ecology with a common definition of seawater
intrusion.
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2. To clarify Ecology's authority/role with regard to the seawater intrusion issue
(including Chapter 173-150 WAC).
3. To prevent seawater intrusion in areas which are at risk.
4. To stabilize or reverse seawater intrusion in areas where the problem already exists.
5. To guide Ecology's administration of water rights vis-a-vis seawater intrusion.
6. To provide a technically sound and informed basis for decision making.
7. To ensure state/local government consistency with regards to implementation of water
availability and planning provisions of the Growth Management Act.
n. Legal and Administrative Authority
The Department of Ecology has clear statutory authority to prevent and control seawater
intrusion under the following codes:
• Water Well Construction Act - Chapter 18.104 RCW
Provides the Department of Ecology with authority to establish and enforce well
construction and maintenance standards, license well drillers, require reporting of well
construction, and restrict well drilling in sensitive areas to protect the groundwater
resource.
Associated regulations:
Minimum Standards for Construction and Maintenance of Wells -
Chapter 173-160 WAC
!.(*-.
• Regulation of Public Ground Waters - Chapter 90.44 RCW
Extends prior appropriation doctrine to groundwater withdrawals. Requires a permit
for groundwater withdrawals. Stock-watering, lawn or noncommercial garden, and
single or group domestic uses (in an amount not to exceed 5,000 gallons per day) are
exempt. Establishes Ground Water Management Area Program.
Associated regulations:
Ground Water Management Areas and Programs - Chapter 173-100 WAC
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Protection of Withdrawal Facilities Associated with Ground Water Rights -
Chapter 173-150 WAC
• Water Pollution Control - Chapter 90.48 RCW
Establishes state policy with regards to groundwater quality, i.e. to retain and secure
high quality for all waters of the state. Regulations (173-200 WAC) adopted pursuant
to this statute define secondary maximum contaminant level (MCL) for chloride at
250 mg/1 and provide for the establishment of an early warning value. The
groundwater quality standards also articulate an antidegradation policy.
Associated regulations:
Water Quality Standards for Ground Waters - Chapter 173-200 WAC
Water Quality Standards for Surface Waters - Chapter 173-201 WAC
• Water Resources Act of 1971 - Chapter 90.54 RCW
Sets forth fundamentals of water policy to ensure that state waters are protected and
fully utilized for the greatest benefit of the people. Broadly defines beneficial uses of
water. Prescribes maximum net benefit test to be applied to allocation of water
among potential uses and users. Emphasizes water use efficiency and conservation in
the management of the state's water resources, recognizing potential to meet future
needs.
The purpose of this policy is to supplement, not supersede, these authorities.
In addition to the aforementioned laws and regulations, Ecology has responsibilities or plays
an advisory role under the following:
• State Building Code - Chapter 19.27.097 RCW
Requires applicants for a building permit to provide evidence of an "adequate water
supply". The county or city may impose conditions on building permits requiring
connection to an existing public water system where the existing system is willing and
able to provide safe and reliable potable water to the applicant with reasonable
economy and efficiency. Under this statute, an application for a water right does not
constitute sufficient proof of an adequate water supply. (Note: This amendment to the
State Building Code has origins in the Growth Management Act)
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Associated regulations:
Ecology may adopt rules to implement this section of the State Building Code.
Growth Management Act - Chapter 36.70A RCW
Requires state agency actions to be in compliance with local government plans
prepared pursuant to the Growth Management Act. In terms of water right
administration, Ecology must review and make permit decisions consistent with local
government plans which establish urban growth boundaries and capital facilities.
Although Ecology has extensive authority, prevention and control of seawater intrusion will
require a concerted effort with other state and local agencies, (especially the Washington
Department of Health, local health departments, and planning departments) which have
additional statutory and regulatory authorities. Ecology staff shall work in cooperation with
these entities.
EH. Application of Policy
This policy applies to withdrawals of groundwater in areas where a seawater-intrusion
problem has been documented (e.g. through the Ground Water Management Area Program
or through studies by the U.S. Geological Survey, Ecology or consultants) or in areas where
natural conditions are such that groundwater withdrawals may create or aggravate seawater
intrusion. This includes all groundwater systems which interconnected with saltwater bodies.
This policy may be applied to coastal aquifers or groundwater supplies within any of the
state's IS coastal counties, especially those counties which are experiencing population
increases and development.
This policy is intended to address seawater intrusion which is suspected to be or is caused by
human activity only. In some cases, wells have been drilled in such proximity to saline
groundwater mat intrusion is unavoidable, regardless of steps taken to mitigate the problem.
In other cases, seawater intrusion caused by natural processes, such as daily tidal or seasonal
climactic changes, is cyclical and/or uncontrollable by human endeavors. In these situations,
the only solution is relocation of the well or substitution of another water source.
Ecology's Water Resources Program regional staff shall refer to this policy for guidance in
administration and regulation of water rights whenever a seawater intrusion risk has been
identified.
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IV. Definition of Related Terms
For purposes of this policy, a number of terms have been so defined:
Adaptive Management - A flexible management system which is applicable in situations
where there is a lack of information or certainty about the causes or effects of a
particular action or process. Essentially, hypotheses are tested and results evaluated.
Management techniques are then adjusted to achieve the desired result.
Aquifer - Geologic materials capable of yielding a sufficient amount of groundwater to wells
or springs for commercial or domestic purposes.
Ground Water Basin - a ground water reservoir that is more or less separate from
neighboring ground water reservoirs. The ground water reservoir consists of an
aquifer or system of aquifers that has reasonably well-defined geologic and/or
hydrologic boundaries and more or less definite areas of recharge and discharge.
Public-Water System - Any water-supply system intended to provide water for human
consumption or other domestic uses, including source, treatment, storage,
transmission, and distribution facilities where water is furnished to more than one
single-family residence or facilities, or is made available to the public for human
consumption or domestic use. '
Saline Contamination - Occurrence of chloride in groundwater supplies at concentrations
which exceed the specified maximum contaminant levels set forth by the U.S.
Environmental Protection Agency.
Seawater Intrusion - Also known as "salt-water intrusion" is the infiltration of marine salt
water into fresh water aquifers, resulting in chloride concentrations above background
levels.
Single-Domestic Wells - Wells which are used to withdraw less than 5,000 gallons of water
per day for single domestic use, including irrigation of up to 1/2 acre of non-
commercial garden and/or lawn.
V. Problem Definition
Seawater intrusion, also known as "salt-water intrusion" is the movement of marine seawater
into freshwater aquifers or other geologic formations capable of yielding groundwater. If
1 Source: State Board of Health - Drinking Water Regulations
(September, 1989).
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unchecked, seawater intrusion can lead to saline contamination of coastal groundwater
supplies.
Seawater intrusion can be caused or exacerbated by human activity, i.e. via increased
consumption of groundwater or a reduction of aquifer recharge. In coastal areas, growing
consumption of groundwater associated with economic development and increasing
population are increasing the risk of contamination of groundwater by seawater. Global
wanning and associated sea level rise are expected to compound the problem.
Increasing levels of chloride and specific conductivity are indicators of seawater intrusion.
The Department of Ecology's Ground Water Quality Standards establish chloride as a
secondary chemical contaminant at levels of 250 mg/1 or more.
VI. Establishment of Risk Categories
For purposes of this policy, seawater intrusion risk shall be defined by water quality and
hydrogeologic factors which are intended to guide the Department of Ecology's
administration of water rights.
Since all wells within an island or coastal setting generally contribute to seawater intrusion to
some degree, seawater intrusion risk is hereby approached from an areal perspective
wherever possible. Where the ground water basin cannot be defined due to lack of
hydrogeologic information, a minimum 1/2-mile radius will be used to delineate the ground
water basin. These areas will be categorized as low, medium or high risk areas according to
the following criteria. (Note: Where two or more risk areas overlap, the higher risk will
take precedence. In island settings, all water wells will be assumed to be included in one of
the risk categories.)
The risk categories and criteria for each are as follows:
Low-Risk Areas
a. A history of chloride analyses from the water well showing concentrations >25 mg/1
and < 100 mg/1 (existing systems); or
b. Chloride concentrations from a test well >25 mg/1 and < 100 mg/1 based upon a state
certified lab test; or
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c. Located within a ground water basin2 where chloride concentrations are >_25 mg/1
and < 100 mg/1.
Medium-Risk Areas
a. A history of chloride analyses from a water well showing concentrations .>_100 mg/1
but <200 mg/1 (existing systems); or
b. State certified lab tests from test well showing chloride concentrations J>_100 mg/1 but
<200 mg/1; or
c. Located within a ground water basin3 with chloride concentrations _>_100 mg/1 but
<200 mg/1; or
d. Chloride concentration levels which are _>25 mg/1 but < 100 mg/1, yet show evidence
of an increasing trend as indicated through yearly monitoring or an aquifer test.
High Risk Areas
a. A history of chloride analyses showing concentrations .X200 mg/1 (existing systems);
or
b. State certified lab tests from test well showing chloride concentrations .>_200 mg/1; or
c. Located within a ground water basin4 with chloride concentrations _>200 mg/1; or
d. Chloride concentration levels which are .>_100 mg/1 but <200 mg/1, yet show
evidence of increasing trend as indicated through yearly monitoring or an aquifer test.
2 Where a ground water basin has not been delineated, within a minimum
1/2-mile radius of a water well with a known chloride concentration >25
mg/1 and <100 mg/1.
3 Where a ground water basin has not been delineated, within a minimum
1/2-mile radius of a water well with a known chloride concentration
>100 mg/1 but <200 mg/1.
* Where a ground water basin has not been delineated, within a minimum
1/2-mile radius of a water well with a known chloride concentration
>200 mg/1.
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VII. Policy Coordination
Through this policy, Ecology shall strive for consistency with ongoing planning processes to
be accomplished through participation in planning efforts, consultation, and review and
comment on proposed policies and plans. Ecology actions shall be consistent with approved
Ground Water Management Area and Growth Management Plans.
Ecology shall strive to coordinate its water right decisions with land use, water right and
water system decisions with other governmental entities via memoranda of agreement, data
collection, and information sharing. Under this provision, Ecology shall work in cooperation
with the Washington Department of Health, affected Indian tribes, county health
departments, county planning departments, and local building departments.
Vin. Education
Ecology shall educate the public about the causes and effects of seawater intrusion and
inform the public about what steps can and are being taken. In addition, Ecology shall
educate purveyors, potential water purveyors, well drillers, local governments, legislative
committees, and citizens about the risk categories and requirements for each as established
under this policy. Ecology will provide technical assistance and guidelines to local
governments for review of single-domestic wells.
IX. Conservation
Since water conservation is recognized as one of the best defenses against seawater intrusion,
Ecology shall require conservation plans and implementation measures for new or expanding
developments within groundwater areas that are at risk. For instance, low-flow fixtures,
lawn watering schedules, artificial recharge basins, and in-house use only restrictions are
among the options to be considered. In addition, retrofitting existing facilities to offset new
withdrawals or redesign of proposed system shall be considered as possible mitigation
measures for new developments.
In order to improve our understanding of the human impact on the hydrologic cycle, to
identify potentially wasteful practices, and to determine the effectiveness of conservation,
metering shall be recommended for all wells within a seawater intrusion risk area.
Ecology shall provide technical assistance on water conservation to well owners and water
users and work in cooperation with local government to develop innovative approaches for
voluntary participation by the public. In order to curb wasteful practices, Ecology shall
advise local government on water efficiency standards for building codes and encourage the
use of progressive rate structures.
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X. Water Right Administration - Policy Directive
The Department of Ecology shall seek to make informed decisions about seawater intrusion
through its administration of the water right program. When hydrogeologic information is
lacking, however, this policy defers to risk categories and requirements as specified under
each. The unequivocal goals of this policy are to prevent seawater intrusion in areas where
it has not occurred and to control seawater intrusion in areas where the problem already
exists. Mitigation is appropriate provided that these goals are not compromised.
In areas where a seawater intrusion risk has been identified, data collection shall be required
to determine the risk and to monitor changes in the hydrologic system. The onus shall be on
the water right applicant or water right holder to provide-this information. In recognition of
the cumulative effects of groundwater withdrawals, Ecology shall evaluate water right
applications from a hydrologic system perspective.
Ecology has a variety of options available to prevent and control seawater intrusion.
Conservation plans and standards can be sanctioned. Innovative approaches such as requiring
new applicants to retrofit existing facilities to offset the impact of additional withdrawals will
also be considered.
Since our understanding of how to effectively control seawater intrusion is evolving, and
given the variability of hydrogeologic conditions and the lack of groundwater information in
many areas, this policy encourages the use of adaptive management techniques for
controlling the problem in known seawater intrusion areas. Participants in adaptive
management shall include, but not be limited to: Washington Department of Health, local
health departments, Washington Department of Ecology (Water Resources and Water Quality
Programs), Washington Department of Wildlife, U.S. Environmental Protection Agency,
U.S. Fish and Wildlife Service, environmental and citizen groups, consultants, water right
holders, and purveyors.
For existing wells in areas where the risk of seawater intrusion has been identified, Ecology
shall provide technical assistance, require monitoring, and review water plans as required by
the Department of Health.
For new water right applications in low-risk areas, Ecology shall require stringent
monitoring, operation, and design controls. In medium and high risk areas, new water right
applications shall be denied unless the applicant can show that additional withdrawal of
groundwater will not increase the risk of seawater intrusion.
Pursuant to the Growth Management Act, Ecology may also recommend to local government
that building permits be withheld or denied in medium and high risk areas for any new or
expanding developments which propose to increase ground water withdrawals above their
existing water right unless the applicant can show that additional withdrawal of ground water
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will not increase the risk of seawater intrusion.
XI. Water Right Administration - Policy Requirements
Based upon the risk categories defined in Section VI, this policy establishes the following
requirements:
A. NEW WELLS- LOW RISK AREAS
1. Public Water Supply, Irrigation, and Industrial Wells
o monitor water use (via source meter)5
o chloride and conductivity test for each water well required at least once each year
during August and analysis by a state certified laboratory - annual reporting to
Washington Department of Health
o water conservation practices are required to be incorporated into the operation and
maintenance agreement
o minimum aquifer test, as needed
2. Exempt Wells
o report to Ecology well location, status, type of use, and number of households
served (at time of construction)
o water conservation fixtures and measures encouraged
B. NEW WELLS - MEDIUM RISK AREAS
1. Public Water Supply, Irrigation, and Industrial Wells
o a current hydrogeologic report, including a hydrogeologic evaluation of the
potential for seawater intrusion, is required
5 As specified in publication prepared by Washington Department of
Ecology, Washington Department of Health, and Washington Water
Utilities Council - Interim Guidelines for Public Water Systems
Regarding Water Use Reporting, Demand Forecasting Methodology, and
Conservation Programs.
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o minimum 24-hour aquifer test
o sampling for chlorides and conductivity in April and August of each year and
analysis by a state certified laboratory - annual reporting to Washington
Department of Health
o water conservation practices are required to be incorporated into the operation and
maintenance agreement
o source and individual meters required - annual reporting to Ecology of water use
o appropriate design modifications are likely to be required (e.g., raising pump
intake or reducing pumping rate and increasing storage)
o phased development is likely to be required
o future degradation of water quality or elevation of chloride concentrations in
water well may halt development at current levels, even if system is approved for
additional connections
o mitigating measures are required and defined in approval
2. Exempt Wells
o report to Ecology well location, status, type of use, and number of households
served (at time of construction)
o request local government to require installation of water conservation fixtures
o advise well owner of possible water use restrictions
C NEW WELOS ^ HIGH RISK AHEAS
1. Public Water Supply, Irrigation, and Industrial Wells
o a current hydrogeologic report, including a hydrogeologic evaluation of the
potential for intrusion, shall be required
o aquifer test protocol
o sampling for chlorides and conductivity in April and August of each year and
analysis by a state certified laboratory - annual reporting to Washington
Department of Health
o water conservation practices are required to be incorporated into the operation and
maintenance agreement
o source and individual meters required - annual reporting to Ecology of water use
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o appropriate design modifications are likely to be required (e.g., raising pump
intake or reducing pumping rate and increasing storage)
o phased development is likely to be required
o future degradation of water quality or increasing chloride concentrations in water
well may halt development at current levels; water right permittee shall relinquish
the option to perfect additional allocated quantities regardless of the state of
construction
o retrofitting existing facilities to offset new withdrawals shall be considered
2. Exempt Wells
o report to Ecology well location, status, type of use, and number of households
served (at time of construction)
o advise owner that water system is subject to water use restrictions including
in-house use only
D. EXISTING WELLS - LOW RISK AREAS
1. Public Water Supply, Irrigation, and Industrial Wells
o monitor water use (via source meter) - annual reporting to Ecology
of water use
o chloride and conductivity test for each water well required once each year during
August - annual reporting to Washington Department of Health
2. Exempt Wells
o report to Ecology well location, status, type of use, and number of
served (at time of construction)
households
E. EXISTING WELLS - MEDIUM RISK AREAS
1. Public Water Supply, Irrigation, and Industrial Wells
o monitor water use (via source meter) - annual reporting to Ecology of water use
o sampling in April and August of each year and analysis for chlorides and
conductivity by a state certified laboratory - annual reporting to Washington
Department of Health
o recommend analysis of problem and investigation of solutions - Ecology is
available for technical assistance
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o institute rigorous water conservation measures
2. Exempt Wells
o report to Ecology well location, status, type of use, and number of households
served (at time of construction)
JF. EXISTING WELLS v HIGH RISK AREAS
1. Public Water Supply, Irrigation, and Industrial Wells
o monitor water use (via source meter)
o sampling for chlorides in April and August of each year and analysis for chlorides
and conductivity by a state certified laboratory - annual reporting to Washington
Department of Health
o annual reporting to Ecology of monthly source meter readings required
o require investigation and implementation of possible mitigation measures
o moratorium placed on new hook-ups for systems with chloride concentrations
greater than 250 mg/1
o institute rigorous water conservation measures (e.g., in-house water use only)
o relinquishment of unused water right
2. Exempt Wells
o report to Ecology well location, status, type of use, and number of households
served (at time of construction)
o advise well owner of possible water use restrictions
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