US Environmental Protection Agency Region 10
Underground Injection Control Program

AQUIFER EXEMPTION RECORD OF DECISION

Summary of Action: This Record of Decision (ROD) documents the United States
Environmental Protection Agency's (EPA's) decision to approve the request for an aquifer
exemption (AE) for the Willow Sands (Sands 3-6) within Fault Block E. This decision has been
made under the authority of the Safe Drinking Water Act (SDWA) Underground Injection
Control (UIC) program.

Under the authority of SDWA and the UIC regulations, EPA will approve SROG's request to
exempt the portion of the Willow Sands as described herein from status as an Underground
Source of Drinking Water (USDW). This decision is based on guidance and regulations,
including those set by Title 40 of the Code of Federal Regulations (CFR) §146.4.

Proposed Operator: Snake River Oil and Gas, LLC (SROG)

Date of AE Request: SROG submitted this AE request on March 4, 2020. SROG submitted
additional information on August 21, 2020.

Exemption Criteria: The portion of the Willow Sands aquifer proposed for exemption does not
currently serve as a source of drinking water, and cannot now and will not in the future serve as a
source of drinking water because it is situated at a depth or location which makes recovery of
water for drinking water purposes economically or technologically impractical. The aquifer is
also so contaminated that it would be economically or technologically impractical to render that
water fit for human consumption. See, 40 CFR §§ 146.4(a), (b)(2), and (b)(3).

Substantial or Non-Substantial Program Revision: Non-Substantial. The EPA determined that
this is a non-substantial program revision since it is associated with a Class II disposal well and
does not pose a statewide impact.

Project Name and Description: This action occurs at the Willow Oil and Gas Field. The aquifer
requested for exemption has been identified as the prospective injection interval for a Class II
Disposal well.

Well/Project Permit Number: This AE is associated with a Class II Disposal permit being
issued by EPA under a separate action. SROG has submitted a Class II Disposal Well permit
application for a single well, named DJS 2-14. The American Petroleum Institute (API) number
for this well is 11-075-20-023. The assigned permit number for this activity is ID-2D001-A.

County: Payette	State: Idaho

Proposed Well Class/Type: Class II Disposal


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Description of Proposed AE

Aquifer to be Exempted: EPA is considering approval
of the request for exemption of a portion of the Lower
Chalk Hills Formation. This AE zone is a three-
dimensional shape occuring approximately 5,000 feet
(ft.) below ground. Boundaries are summarized on this
page and further described in this document.

Areal Extent of AE: The surface projection of the AE
zone is shown in Figure 1. The size of the AE is
approximately 269 acres. The boundaries of this AE
zone are determined by geologic structure occuring at
the depth of the AE. This area overlaps Sections 11-14
of Township 8 North, Range 4 West.

Vertical Extent of AE: The aquifer sought

for exemption is contained within (lay Stone	Figure j _ The AE Area is approximately 269 acres in size, located

2/3 and Claystone 6/7. It is intersected by DJS	to the east of Little Willow Creek and to the north of the Payette

2-14 between 4,908 and 5,500 ft. True	River. Payette Co., Idaho.

Vertical Depth (TVD). Section I.E., Vertical
Confinement, provides additional information.

Summary of Aquifer Characteristics

Formation

Willow Sands 3-6 within the Lower Chalk Hills Formation.

Lithology

Sands interbedded with claystones.

Water Salinity

1,540 mg/L Total Dissolved Solids.

Depth

Approximately 4,430 ft. below ground at the shallowest point. Intersected by
DJS 2-14 at 4,908 ft.

Thickness

592 ft.

Porosity and
Permeability

Estimated Porosity is 30 - 32%, and estimated permeability is 300 millidarcies.

Current Use

No current use. The Willow Sands elsewhere in Willow Field are targeted for
hydrocarbon production.

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Proposed Willow Sands aquifer exemption area

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Decision

Based on a review of the entire record, including all written and oral comments submitted to
EPA during its public comment process, EPA finds that the exemption criteria at 40 CFR §§
146.4(a), (b)(2), and (b)(3) have been met, and EPA approves the AE request as a non-
substantial program revision.

Effective Date:	[DRAFT]

Mathew J. Martinson
CAPT, USPHS

Branch Chief, Permitting, Drinking Water and
Infrastructure

U.S. Environmental Protection Agency Region 10

(M/S: 19-H16)

1200 6th Avenue, Suite 155

Seattle, WA98101

Record of Decision: Aquifer Exemption of the Willow Sands (For Comment)

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Table of Contents

Description of Proposed AE	2

Decision	3

I.	Background Information	5

A.	Surface Description	5

B.	Regional Geology and AE Boundary	7

C.	Vertical Confinement	8

D.	Lateral Confinement	11

E.	Hydrogeology and Groundwater Flow	12

F.	Aquifer Designation under State Law	13

II.	Summary of Non-Substantial Decision	15

III.	Current Water Supply (40 CFR § 146.4(a))	15

1. Private Water Wells	16

G.	Public Water Systems	17

IV.	Future Use (40 CFR § 146.4(b))	18

1.	Cost of Accessing the Willow Sands	19

2.	Considering Alternative Sources	22

V.	Public Comment	25

VI.	References	26

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I. Background Information

On March 4, 2020, EPA received a request from SROG to exempt a portion of an aquifer from
status as a USDW. SROG's request is limited to Sands 3-6 of the Willow Sands. The aquifer
portion is further limited to Block E, a bounded reservoir formed by intersection of faults. This
zone is located at approximately 4,630 ft. below ground at its shallowest point.

This exemption request has been made in support of an application to convert an existing well,
DJS 2-14, into a Class II disposal well. DJS 2-14 would inject fluids produced associated with
natural gas and gas condensate production. Class II wells inject fluids (which are brought to the
surface in connection with conventional oil or natural gas production and may be commingled
with waste waters from gas plants) which are an integral part of production operations, unless
those waters are classified as a hazardous waste at the time of injection (See, 40 CFR §144.6,
Classification of Wells). Since the proposed injection interval for DJS 2-14 meets the definition
of a USDW, injection may not take place unless the aquifer to be impacted is first exempted
from status as a USDW.

Federal regulations define an aquifer as a geologic formation, group of formations, or part of a
formation that is capable of yielding a significant amount of water to a well or spring. Pursuant
40 CFR § 146.4, an aquifer or a portion thereof which meets the criteria for a USDW under
§146.3 may be determined under §144.7 of this chapter to be an exempted aquifer. Based on
review of the operator's request, EPA has determined that this request meets the requirements for
an exemption. The portion of the Willow Sands aquifer proposed for exemption does not
currently serve as a source of drinking water. EPA determined that it cannot now, and will not in
the future, serve as a source of drinking water because it is situated at a depth or location which
makes recovery of water for drinking water purposes economically or technologically
impractical. EPA also considered that this aquifer is situated at a depth or location which makes
recovery of water for drinking water purposes economically or technologically impractical [See,
40 CFR §§ 146.4(a), (b)(2), and (b)(3)], EPA reached this decision after reviewing information
provided by SROG along with additional relevant information. This decision is based on an
evaluation of the local hydrogeologic and geologic conditions, the current uses of groundwater in
this region, plausible future trends regarding water use by the nearby communities, level of
contamination in the aquifer, and the economic feasibility of providing this water for human
consumption.

1. Surface Description

The AE zone described herein is a group of geologic strata located at the Willow Field in Payette
County, Idaho. Throughout this document, the terms "AE boundary" or "exemption boundary"
refers to the two-dimensional lateral extent of the AE projected to the surface. These terms are
generally used when discussing the size of the boundary. "AE zone or "exemption zone" refers
to the three-dimensional shape of the aquifer portion as it occurs in the subsurface. These terms
are used when discussing hydrogeologic and geologic characteristics of the AE.

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The exemption boundary is located entirely within Payette County, Idaho and includes an area of
approximately 269 acres. This area overlaps Sections 11-14 of Township 8 North, Range 4 West
as described by the Public Land Survey System. The injection well DJS 2-14 is located at
Latitude: 44.03867, Longitude: -116.78333.

The exemption boundary is located along the northern slope of the Payette River Valley within
the most northwesterly portion of the Western Snake River Plain. The surface topography here is
dominated by rolling hills and steep bluffs. Primary uses of the land in this area include low-
density residential housing, ranching, cattle grazing, and oil and gas production activities. Sandy,
alkaline, lacustrine deposits are found at the surface, catering to the growth of shrub- and grass-
dominating vegetation described as saltbush-greasewood and sagebrush steppe (USGS Collab.).
See Figure 2.

Figure 2 — Willow Field and surrounding landscape. This photograph is pointed to the southeast. Visible are the
proposed injection well (DJS 2-14), along with two production wells (KILl-ll and 2-10) and the Little Willow
Facility-

band use types transition to semi-rural/suburban and, in some parts, agricultural, when moving to
the south of the exemption boundary and along the Payette River. Little Willow Creek is located
approximately 1V4 miles to the west of the exemption boundary at its nearest point. This creek
gives name to the nearby natural gas production facility (i.e., Little Willow Facility). This creek
flows from the northeast to the southwest where it meets the Payette River at approximately 2V2
miles from the exemption boundary at its nearest point. Low-density residential housing is

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located along the valley formed by this creek, where groundwater is the primary source of
drinking water. Wells generally withdraw from depths of approximately 100-200 ft. Below
Ground Surface (BGS). Primary drinking water sources for this region are discussed in Part III.

There are three cities located within ten miles of the AE boundary: New Plymouth, Idaho
(approximately 43A miles south); Fruitland, Idaho (approx.. 6lU miles west-southwest); and
Payette, Idaho (approx.. 7 miles west-northwest). Payette has the largest population of these
cities, though Fruitland has experienced the fastest population growth in the past ten years. The
population of the entire county, in which all three of these cities are found, is approximately
25,400.

B. Regional Geology and AE Boundary

The regional geology across Payette County falls into two separate regimes; the northern portion,
which is characterized by thick volcanic deposits, and the central/southwestern portion, which is
characterized by extensive lacustrine and fluvial sedimentary deposits. For the remainder of this
document, references to the "Snake-Payette River Basin," or "Payette River Basin," or general
claims regarding the geology in "Payette County" will refer to the geology found in the central
and southern part of Payette County. Land type and geology in this portion of the County is
representative of the surface area around the exemption boundary and the geology composing the
exemption zone, respectively.

The geologic sequence found at the site of the proposed exemption is known based on
correlation with reports from previously completed wells. Soils and shallow geologic layers have
been characterized from the construction of drinking water wells, and deeper geologic intervals
have been identified from previously drilled hydrocarbon exploration and development wells.
From shallowest to deepest, the order of geologic intervals at the location of the AE are: 1) an
unconsolidated gravel/shallow alluvium formation (in some areas called the Pierce Gulch
Formation), 2) the Glenns Ferry Formation, 3) the Chalk Hills Formation (Upper and Lower
parts). The Willow Sands is considered a member of the Lower Chalk Hills Formation.

Surficial formations at Willow Field and nearby Little Willow Creek area named either the
Pierce Gulch Formation or shallow alluvium, based on location. The Pierce Gulch Formation is
the upper-most geologic unit for areas across the Willow Field where the surface elevation is at
least 2,400 ft. above sea level. At lower elevations, shallow alluvial deposits are the upper-most
unit. This deposit is approximately 250 ft. thick at the location of DJS 2-14. Surficial deposits are
sand or sand/gravel type and contain an aquifer system that serves as a primary drinking water
source for private wells in the Payette River Basin.

The Chalk Hills and Glenns Ferry Formations are located below these shallow sediments and are
components of the Idaho Group; a sedimentary basin of Miocene-Pliocene era created by fluvial
and lacustrine deposition of sandstone and claystone. The Chalk Hills Formation (including the
Willow Sands) was formed by the deposition of sand, muds, and intercalated volcanics. This
formation deformed by tilting and faulting as the Chalk Hills lake system refilled and
transgressed. Concurrent volcanic activity resulted in basalt and ash intervals throughout portions
of the Chalk Hills Formation. The second episode of deposition into what is known as "Lake

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Idaho" resulted in formation of the Glenns Ferry Formation (Wood, 2004). The top of the Glenns
Ferry Formation eroded prior to the deposition of quaternary alluvium and outwash from the
erosion of the adjacent uplands. Identification of the Chalk Hills and Glenns Ferry Formations
can be difficult because of the interbedded and sometimes discontinuous nature of deposition,
but, overall, the Payette River Basin is underlain by over 4,000 ft. of lacustrine and fluvial
deposits of mostly clay, sand, and gravel. Total basin sedimentary and igneous fill above bedrock
may be greater than 4.4 miles (Mitchell, 1981).

The geologic structure of the Willow Field is characterized by a network of faults forming a
roughly elliptically shaped structure about three miles long in a northwest-southeast axis, and
two miles wide in a southwest-northeast direction. It is composed of interbedded sands and
claystones. Faulting in the Willow Field causes segmentation of the Willow Sands, effectively
forming compartmentalized blocks. During the exploration of this field, the naming convention
"A-E" was chosen to name these blocks. See Figure 3 for diagrams of these zones. Blocks A - D
are the target for production of hydrocarbons out of the Lower Chalk ITills Formation. DJS 2-14
was constructed into Fault Block E as an exploratory well that proved to be non-commercial. It is
now being proposed as the proposed injection interval for disposal of produced fluids via Class II
fluid disposal.

Figure 3 - Structure Map of the
Willow Sands Across Willow
Field. This diagram provides
depth contours of the top of the
Willow Sands in contact with
the claystone component of the
overlying Chalk Hills
Formation. Values indicate
subsea depth, rather than depth
below ground. Red, black, blue,
and green ribbons represent
fault lines. The lettered zones
are considered the fault blocks,
Segmenting the field into
discrete zones. Wells MI. 1-11.
ML 2-10, ML 3-10 are circled in
red. The proposed AE zone is
the entire Block E situated
directly south of Block B and
northeast of Block A. DJS 2-14
is located on the southwestern
edge of Block E.

C. Vertical Confinement

This AE request is limited to the Lower Chalk Hills Formation at Willow Field, further defined
by the boundary to Block E. The boundaries of this three-dimensional zone can be described by
vertical and lateral terms. The vertical extent of the AE zone is described by strati graphic
markers, including formations that serve as confining intervals that would prevent the movement

Letter Annotates Fault Block Name

STRUCTURE MAP
Top of Willow Sands

Depth in feet below sea level
Contour Interval: 50'

8N 4W

Figure G-1.

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of fluids outside of a designated injection zone. The applicant has identified primary upper and
lower confining zones. The applicant has also identified redundant confining zone.

The proposed AE zone is limited to only the portion of the aquifers found within Willow Sands
3-6, between Claystone 2/3 and Claystone 6/7 and contained within Block E, as displayed in
Figure 4. This zone is intersected by well DJS 2-14 from 4,908 ft. to 5,500 ft. TVD. Permeability
of this zone is approximately 300 millidarcies (mD), and porosity is approximately 30%. Since
the proposed exemption zone follows geologic strata that dip from northwest to southeast, the
depth to the proposed exemption zone varies depending on location within Block E. At the
shallowest point of the AE is found near the northwest corner of Block E, where the top of Sand
3 occurs at 4,630 ft. TVD. The deepest possible occurrence of the exemption zone is found in the
southeastern corner of Fault Block E, where the bottom of Sand 6 is at a depth of approximately
6,200 ft. TVD. Thickness of the AE zone is approximately 600 ft.

The primary upward barrier to fluid movement is a claystone interval named Claystone 2/3. DJS
2-14 passes through Claystone 2/3 between depths 4,860 ft. to 4,908 ft. TVD. Claystone 2/3 is
also encountered by nearby wells within the Willow Field, demonstrating lateral continuity.
Permeability estimates made by processed petrophysical logging data of Claystone 2/3 indicate
permeabilities to be between 0.0002 and 0.0007 mD. Lab-derived permeability (0.01-.04 mD)
and porosity values (between 10.3% to 14.6%) were taken from cores sampled from claystone
within the Willow Sands at 4,300 ft. to 4,360 ft. TVD during the drilling of DJS 2-14. Claystone
units at the location of DJS 2-14 exhibit low permeability; this indicates a lower ability for water
to move through rock and is a quality needed for a geologic unit to act as a competent confining
zone.

SROG identified a redundant confining zone above Claystone 2/3 that further separates the AE
zone from shallow USDWs. Above Claystone 2/3 is a massive block of claystone interrupted by
a basalt sill and shallower USDWs. This massive claystone block is composed of the Chalk Hills
Formation from approximately 4,910 ft. to 2,380 ft. TVD and the Glenns Ferry Formation from
approximately 2,380 ft. TVD to 250 ft. TVD in well DJS 2-141.

1 Depth values for the Chalk Hills and Glenns Ferry Formation may differ across the AE area, and the values
presented here are taken from interpretation of geophysical logging results on the DJS 2-14 wellbore.

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Fault Block "E'

Basalt Sill

2/3 Cfaystone

¦2700'

V/4 clamcm

3000"

6/7 Claystone

and 3 top) is at •2180' at shallowest point

and 3 tool is at 4908' MP (-2406' subsea) in PJS 2-14 well

sand 6 base] is at S500' MP (-2998' subsea) in PJS 214 well

8/9 Claystone

Fault Block "A"

(Subsea, ft)

1700-
DEPTH

Figure 4 - Identification of the AE zone and upper and lower confining zones, Claystone 2/3 is identified as the
upper confining interval Claystone 6/7 is defined as the lower confining inten>al. Sands labeled 3-6 are identified as
the proposed injection zone and Ah. zone.

Geophysical logs performed on nearby wells ML 3-10, Kauffman 1-9, ML 1-10, ML 2-10, and
ML 1-11 provide evidence of the continuity and thickness of both the upper confining interval
and the redundant confining interval.

The impermeable characteristic of the upper confining interval is also demonstrated by
hydrocarbon accumulation. At the Willow Field, the Willow Sands is the target interval for
hydrocarbon production. In 2019, SROG reported that six wells within the Willow Field
produced hydrocarbons from the Chalk Hills Formation: DJS 1-15, ML 2-10, ML 1-11, ML 1-3,
ML 2-3, and ML 2-10 (IOGCC, 2019). Historically, the field has produced over 11.6 billion
cubic ft. of natural gas, 438,000 barrels of condensate and oil, and 17 million gallons of natural
gas liquids. In Block A, directly adjacent to Block E, well ML 3-10 has produced hydrocarbons
from Sands 1 and 2. ML 1-11, drilled into Fault Block B, also displays evidence of hydrocarbon
accumulation in Sands 1 and 2. Sands 1 and 2 lie directly under the base of the massive claystone
block identified as a redundant upper confining interval. The fact that natural gas is trapped by
fault structures supports the determination that the claystone portion of the lower Chalk Hills
prevents upward movement of fluids.

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The primary lower barrier to downward fluid movement has been identified as Claystone 6/7.
Based on correlation with nearby wellbores, this interval occurs at a depth of approximately
5,500 ft. TVD, beyond the depth of the DJS 2-14 wellbore. Claystone 6/7 is an approximately
130 ft. claystone located across the Willow Field, present in every well drilled deep enough to
investigate the interval.

D. Lateral Confinement

The Willow Sands contains USDWs within the proposed exemption zone (Block E) and outside
of the proposed exemption zone. Naturally occuring faults separate the exemption zone from
surrounding portions of the Willow Sands. Fault location and characteristics were considered by
EPA for two reasons: 1) the fault block forms the boundary of the AE, and 2) SROG proposed
that faults would serve as barriers to fluid movement, protecting adjacent USDWs from
endangerment.

There are numerous small faults formed during the time of sedimentation (i.e., syndepositional,
or growth faults) found across Willow Field. These faults die out in the upward direction by the
Upper Chalk Hills and are relatively short (0.5-3 miles) in length. Faulting across this field has
created a network of fault blocks, together forming an elliptically shaped structure about 3 miles
long and 2 miles wide along a northwest-southeast axis. By convention, these blocks have been
named alphabetically, e.g., "Block A" though "Block E " (Figure 3, page 8). DJS 2-14 is located
within Block E. Impermeable layers within or along fault planes can serve as barriers to fluid
movement, effectively creating lateral fault boundaries. SROG has submitted evidence showing
that these faults are impermeable. A summary of the principal evidence regarding fault
confinement is provided, below:

1. Reservoir pressure data from the Willow Sands suggest that faults isolate Blocks at a

field-wide level. This is demonstrated by comparing pressure versus time data for wells
drilled into Blocks A and B of the Willow Sands. Two wells drilled into Block B of the
Willow Sands, ML 1-11, and ML 2-10, began production in August 2015. In the
following months, net fluid withdrawal from this zone created a downward trending
bottomhole pressure in both wells. Twenty-eight months after construction of ML 1-11
and ML 2-10, ML 3-10 was drilled into Block A. Initial shut-in tubing pressure in ML 3-
10 was at original formation pressure, approximately .43 psi/ft, an indication that fluid
withdrawal from Block B did not result in fluid movement from Block A. Net fluid
withdrawals from Block A resulted in reduced bottomhole pressures in Block A, but
across a significantly different pressure-versus-time profile as compared with Block B.
These data are supportive of fault sealing between Blocks A and B. The fault between
Block A and B continues to form the southwestern barrier to Block E, separating Blocks
A and E. This information supports the theory of non-permeable flow across the
southwestern fault. This information alone does not prove that this fault is impermeable
across its entire length or across all sands within the approved injection zone; rather, it
provides localized data indicating likelihood of sealing character.

Other pressure versus time data across the field provide support of fault sealing at a
regional level. SROG compared downhole pressure data across other Blocks, providing
additional assurance that faults with different orientations, and at different locations

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across the field, exhibit sealing capacity. For instance, fluid production trends from
Blocks B and C demonstrate evidence of fault sealing across east-west trending faults,
such as the one that forms the northern boundary to Block E. This information alone is
not sufficient evidence to conclude fault containment but is supportive of the notion.

2.	Hydrocarbon accumulation and vertical offset of hydrocarbon/water contact points in
Blocks other than Block E indicates that geologic structure effectively inhibits fluid
movement. Hydrocarbons are trapped against fault and claystone traps between Blocks A
and B. The presence of hydrocarbons in commercially relevant volumes against these
traps indicates impermeability across a geologic timescale. The hydrocarbon/water
contact point, where the oil and gas contact water, a denser fluid, is approximately 200 ft.
lower with respect to sea-level in ML 3-10 than wells in Block B. Trapping occurs across
faults where sand-sand juxtaposition would otherwise be present, indicating that
hydrocarbon trapping cannot be solely attributed to a facies change. Hydrocarbon
trapping and offset hydocarbon/water contacts points provide additional evidence of fault
containment.

3.	Two distinct geologic processes seen in geologic outcrops in southwestern Idaho explain
the formation of sealing faults. Clay smear, a process in which clay from the wall rock is
incorporated in a fault zone, and silica cementation, a process by which percolation of
geothermal water precipitates silica in voids of the sands, are geomechanical and
geochemical processes affecting fault sealing properties. These two processes,
individually or together along the same fault, explain the impermeable nature of the faults
at Willow Field. SROG provided examples of cementation for the Chalk Hills on the
western flank of the Western Snake River Plain (about 25 -30 miles southwest of the
project site), in the Marsing area (about 40 miles south of the project site), and the Boise
area (about 40 miles from the project site on the eastern margin of the WSRP) where
faults are exposed at the surface. The occurrence of numerous claystone/sandstone
transitions within the Willow Sands increases the likelihood of clay smear. Regional
geothermal activity increases the likelihood of silica cementation.

4.	Subsurface imaging identified syndepositional faults at Willow Field, and historic
seismic records indicate a lack of seismicity in the project area. This supports the
conclusion that the faults are inactive and have not deformed since time of formation.

This evidence demonstrates that the portions of the Willow Sands that are proposed for
exemption are laterally confined from USDWs. As further assurance that injection will not result
in fluid movement between fault blocks, EPA is requiring conditions in draft permit ID-2D001-A
meant to demonstrate that faults near the injection well behave as barriers. The Permittee is
required to prepare and submit annual Boundary Effects Analysis Reports, providing EPA
opportunities to confirm fault confinement on an ongoing basis.

E. Hydrogeology and Groundwater Flow

Groundwater occurs throughout the Payette River Basin, both in shallow and deeper geologic
intervals. The shallowest aquifer found at the location of the AE is characterized as either
shallow alluvium or Pierce Gulch Sand, depending on location within the Basin. Surficial aquifer
systems are the primary source of drinking water for private well owners in the area. This

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shallow sand is encountered by DJS 2-14 from to surface to 250 ft. TVD. Wells that access this
hydrologic unit generally do so at depths of between 150-300 ft. below ground. Groundwater
flow within these units is towards to Payette and Snake Rivers, as is movement of fluids from
deeper, confined aquifers (Parliman, 1986). From the location of the exemption zone, this
corresponds to a south-southwesterly groundwater flow direction towards the Payette River,
though no groundwater flow is expected within Block E of the Willow Sands due to reservoir
confinement.

Across the Idaho Group (i.e., Glenns Ferry and Chalk Hills Formations), regional flow systems
have residence times ranging from hundreds to tens of thousands of years (SPF Water
Engineering, LLC, 2016). Movement into and out of Block E is not expected based on geological
structure of the Block. Fault Block E is bound laterally by three faults and vertically by claystone
strata providing barriers to fluid movement. The formation fluids in the Willow Sands are
slightly-to-moderately saline. Thirteen water samples taken from various wells drilled into the
Willow Sands were analyzed for TDS. One of these samples was taken from well DJS 2-14,
which contained a TDS level of 1,540 mg/1. The average TDS value from all samples taken
across the Willow Field from the Willow Sands was 3,109 mg/1 TDS. Removing one sample
with an anomalously high TDS value, possibly caused by drill fluid contamination, the average
level of TDS within the Willow Sands was found to be 2,036 mg/1. This aquifer meets the
criteria of a USDW since it contains a quantity of water sufficient to supply a public water
system and contains fewer than 10,000 mg/L TDS (40 CFR §144.3).

EPA considered whether hydrothermal fluid circulation would impact fluid movement into or out
of Block E based on the presence of hydrothermal activity in southwestern Idaho. For example,
the Christensen A-l geothermal exploration well approximately 16 miles to the north of the
proposed AE boundary displays evidence of fluid movement caused by hydrothermal circulation.
Columbia River Basalt, found at the location of the A-l well, was identified as a possible conduit
for groundwater movement from deeper geothermal sources. This differs from the extensive
sedimentary sequences found at in the central and southern portions of Payette County, including
those specific lithologies at the location of the exemption request, where shallow basalt flows are
not found. Previous studies affirm the understanding that there is no localized upward fluid
movement driven by hydrothermal circulation at the site of the exemption (Mitchell, 1981).

/ . Aquifer Designation under State Law

This section provides background information on a governmental action taken by Idaho
regarding the aquifer found within the Willow Sands. On March 26, 2018, the Idaho Department
of Environmental Quality (IDEQ) determined that the proposed injection zone for the DJS 2-14
well could not be considered an "aquifer"2 pursuant with section 007.12 of the Idaho
Groundwater Quality Rule (IDAPA 58.01.11), because it is not "capable of yielding
economically significant quantities of water to wells and springs." In Idaho, only EPA has the

2 EPA defines an aquifer as a geologic formation, group of formations, or part of a formation that is capable of
yielding a significant amount of water to a well or spring (See, 40 CFR 144.3).

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authority to exempt aquifers associated with Class II permits from status as USDWs. Appropriate
state designations are relevant insofar as they concern separate designations under state law.

IDEQ did determine that the water in the injection zone does qualify as groundwater under
section 007.16 of the Idaho Groundwater Quality Rule since it is considered, "[a]ny water of the
state which occurs beneath the surface of the earth in a saturated geological formation of rock or
soil." This section of Idaho law allows discharges to groundwater only under certain
circumstances, including when such discharge is authorized by permit. EPA has prepared a draft
Class II permit that would allow injection into this aquifer (See, EPA Region 10 Draft Permit ID-
2D001-A).

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II. Summary of Non-Substantial Decision

Pursuant to 40 CFR § 146.4, an aquifer or a portion thereof which meets the criteria for a USDW
under §146.3 may be determined under §144.7 of this chapter to be an "exempted aquifer." The
portion of the Willow Sands under review does not currently serve as a source of drinking water
and cannot now, and will not in the future, serve as a source of drinking water. This following
two sections document EPA's evaluation under 40 CFR §§ 146.4(a), (b)(2), and (b)(3).

This process requires EPA to determine whether the proposed AE is a major or minor (i.e.
substantial or non-substantial) exemption. The process is discussed in a Federal Register Notice
Preamble at 48 Fed. Reg. 40098, 40108 (September 2, 1983); also, 49 Fed. Reg. 20138, 20143
(May 11, 1984).

EPA has determined this proposed AE is a minor exemption. This AE is associated with the
issuance of a site-specific UIC Class II permit action and is not associated with a statewide
action that would have broad effects on water use across Idaho. EPA also considered the
following facts when making this determination: the portion of the aquifer sought for exemption
is confined by faults that separate injected fluids from other portions of the USDW; the aquifer
portion is located within a field, and at a depth, where commercially-viable quantities of
hydrocarbons are found; injection approved by the draft permit would not allow injection of 3rd
party fluids; no hazardous waste would be injected under the conditions of the draft permit; and
there are no instances of drinking water wells constructed to the depth of the Willow Sands in
Payette County, Idaho. The decision to treat this AE as a minor exemption is also consistent with
the corresponding state program revision process3.

III. Current Water Supply (40 CFR §146.4(aV)

This section provides information concerning EPA's review of the current sources of drinking
water near the site of the proposed AE to determine whether the proposed AE meets the criteria
at 40 CFR §146.4 (a): "it does not currently serve as a source of drinking water." Groundwater
within the Payette River Basin supplies drinking water for both public and private well owners.
EPA considered whether either private or public sources access this aquifer.

EPA determined that the portion of the aquifer proposed for exemption is not currently serving
as a source of drinking water, nor are there any hydrologic connections between the portion of
the Willow Sands sought for exemption and aquifers currently serving as drinking water sources.

3 Guidance 34 -EPA's Guidance for Review and Approval of State Underground Injection Control (UIC) Programs
and Revisions to Approved State Programs.

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This determination has been made based on an evaluation of water well records and geologic
information.

1. Private Water Wells

EPA guidance stipulates that applicants requesting an AE should ensure that there are no
drinking water wells within a minimum of a Vi-mile of the requested AE boundary. The
applicant, SROG, conducted a search for drinking water wells within a 24 square mile area
(equal to 15,360 acres) extending at least14-niile beyond the AE boundary. Within this "Search
Area," SROG identified all drinking water wells using the "Find A Well" online database
published by the Idaho Department of Water Resources4. EPA recreated this search and
confirmed that SROG provided a complete list of all water wells located within the previously
described Search Area. See Figure 5 for a visualization of wells near the AE boundary:



' rl1

» . i.

milt: « x co

rag, »
rma



Existing water well in 24
square mile area around
proposed Aquifer Exemption

Exhibit IV-A

Existing water well

Figure 5 -Map showing the areal extent of the proposed AE boundary (in yellow) and all wells within a 24 square
mile (15,360 acres) search area around the proposed AE boundary. The proposed AE covers approximately 269
acres. Existing water wells found within the search area are shown in light-blue. The dark-blue lines designate lxl
mile sections in the Public Land Survey System. Data provided by applicant, from IDWR's well search database.

4 Idaho Department of Water Resources, Find a Well Map, https://idwr.idaho.gov/wells/find-a-well-map/

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No wells occur within the AE boundary. Thirty-seven groundwater supply wells occur outside of
the AE boundary but within this Search Area, all of which access hydrologic units much
shallower than the Willow Sands. Of these wells, 28 are domestic wells (including wells
identified as domestic, domestic and irrigation, domestic - single residence, and domestic -
replacement); 2 are irrigation wells; 4 are stock wells; 1 is a cathodic protection well; 1 dry well;
and 1 well is listed with an unknown use. Within the entire Search Area there are four water
wells deeper than 250 ft., none of which are deeper than 415 ft. All four of these wells are
located over one mile from the boundary of the AE. As discussed in the section above, Vertical
Confinement, there are multiple competent confining intervals between the Willow Sands and
shallower hydrologic units, such as those accessed for drinking water within the Search Area. As
discussed in the section Lateral Confinement, above, faults are expected to confine injected
fluids to the Block E reservoir. All water supply wells are separated vertically from the top of the
AE zone by more than 3,000 ft. of rock, predominantly claystone.

EPA reviewed state records to determine if geothermal exploration wells exist in the Search Area
to account for the possibility that abandoned deep wells may have been converted to water wells
after failing to demonstrate commercial viability. IDWR's Geothermal Resources webtool
identifies one geothermal well inside the Search Area. It is in the NE ]A of Section 16 of
Township 8 North, Range 4 West, approximately 1.7 miles south-southwest of the closet point
on the proposed AE boundary.5 The depth of the well is 975 ft. A 1981 geothermal study across
southwestern Idaho identified a geothermal well approximately 2.6 miles to the east of the
nearest point along the AE boundary, located in the northeast corner of Section 16 of Township 8
North, Range 3 West (Mitchell, 1981). This well is drilled to a depth of approximately 1,450 ft.
TVD and the lithology was described as "clay."

EPA reviewed the Search Area established by SROG for other oil and gas exploratory wellbores
that could have been converted to water use wells after proving to be non-viable as hydrocarbon
production wells. Data from the Idaho Geologic Survey and Idaho Department of Lands identify
oil and gas wells within and around the Little Willow Drainage (including wellbores outside the
Search Area). All wells were identified as either shut-in gas wells, active hydrocarbon producing
wells, plugged and abandoned hydrocarbon wells, or otherwise plugged and abandoned wells
(IDL, 2020). None have been converted to water supply wells.

G. Public Water Systems

Shallow aquifer systems are the primary source of drinking water in Payette County for both
private and public supplies. In 2015, public water supply in Payette County withdrew 1.53
million gallons per day (MGPD) of groundwater. EPA surveyed PWS records along the Snake
River-Pay ette River Basin using the State of Idaho's Source Water Assessment and Protection

5IDWR Geothermal Resources, https://maps.idwr.idaho.gov/map/geothermal

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tool.6 No PWSs exist within the Search Area defined in the prior section. The nearest PWSs to
the AE boundary are listed in Table 1.

Table 1 -List of PWSs near proposed AE zone. Listed distance is between the PWS site and the
nearest border of the AE.

PWS Number

Name

Distance (Mi.)

Direction

11)3140174

Simplol Potato

2.4

si:

ID3380037

Payette River Hunt and Fish Club,
Well #1

4.1

s

11)33X111 »2S

Seneca 1-oods Inc. Well 1

4 S

sw

ID33SUI »2S

Seneca 1-oods Inc. Well 2

4 X5

sw

11)3 3 S()( )()S

Cily of \eu Plymouth. Well 5

5

ssw

11)3380008

City of New Plymouth, Well #6

5

ssw

EPA concludes that the portions of the Willow Sands that are proposed for exemption do not
currently serve as a source of drinking water. Additionally, no drinking water wells have been
drilled into the Willow Sands within a Search Area extending beyond the boundary of the
exemption request. There are no known or suspected routes of fluid movement into or between
Fault Block E and surrounding portions of the Willow Sands. Therefore, the EPA has determined
that the portions of the aquifer proposed for exemption meet the criteria at 40 CFR § 146.4(a).

IV. Future Use (40 CFR 5146.4(b))

An applicant for an AE must show that an aquifer or aquifer portion sought for exemption cannot
and will not be used as a drinking water source in the future. Pursuant to 40 CFR § 146.4(b),
there are four ways this may be demonstrated [See, 40 CFR 146.4(b), (l)-(4)], any one of which
must be satisfied. EPA has evaluated SROG's claims under 40 CFR § 146.4(b)(2) and (b)(3) that
the aquifer portion within Willow Sands 3-6 contained to Block E ".. .cannot now and will not in
the future serve as a source of drinking water because... [i]t is situated at a depth or location
which makes recovery of water for drinking water purposes economically or technologically
impractical" [See, 40 CFR § 146.4(b)(2)] and ".. .is situated at a depth or location which makes
recovery of water for drinking water purposes economically or technologically impractical" [See,
40 CFR § 146.4(b)(3)], The following factors were considered in reaching this decision: aquifer
depth, productivity and contamination, and alternative water sources.

The estimated cost of producing water from the Willow Sands and transporting it to nearby
population centers is too high to be considered a realistic future source of drinking water. This
determination is based on several factors, including a review of current water use in Payette

6 Idaho's Source Water Assessment and Protection Tool.

https://mapcase.deq.idaho.gov/swa/default.html?SRCID=A0003823. Accessed on October 30, 2020.

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River Basin, future water demand scenarios, and an estimated cost comparison of accessing
water within Fault Block E of the Willow Sands and other sources. EPA relied upon agency-
issued guidance to evaluate this request, including Guidance for Review and Approval of State
UIC Programs and Revisions to Approved State Programs,7 and Enhancing Coordination and
Communication with States on Review and Approval of AE Requests Under SDWA.8

1. Cost of Accessing the Willow Sands

This section summarizes an estimated cost evaluation of accessing the Willow Sands for
drinking water supply and is intended to demonstrate the relative cost of accessing an aquifer at
this depth and location. This includes summarizing the cost of accessing the Willow Sands as
proposed by SROG and comparing this estimated cost with actual costs of water sources used by
nearby cities. In summary, Sands 3-6 within Block E of the Willow Sand are an economically
impractical drinking water source based on volumetric limitation of the reservoir, reservoir
depth, water quality of the aquifer, and the distance from the field to the nearest population
centers.

An aquifer's potential to serve as a drinking water source includes an evaluation of water
productivity. Reservoir characteristics of the Willow Sands 3-6 within Block E limit the
available quantity of water, impacting the viability of this aquifer portion to serve as a long-term
drinking water source. SROG estimates that 25 million barrels (approximately 3,220 acre-ft.) out
of an estimated 115 million total barrels of water (approximately 15,000 acre-ft.) would be
recoverable from within Fault Block E. This is based on water lift limitation due to gas
interference and loss of water productivity. To put this in perspective, if one assumes that this
reservoir would produce 5,000 barrels, or 210,000 gallons per day, the well system would have
an expected life of approximately 13.7 years. A supply of this volume would serve a population
of approximately 1,600 people assuming each person consumed 134 gallons per day (GPD), the
average per capita consumption rate for this region (USGS, 2015). This is approximately the
population of New Plymouth, Idaho. Serving a larger customer base would decrease the lifespan
of the source. The quantity of water available at this location and projected lifespan of the project
are factored into cost estimates contained in this section.

SROG performed a cost estimate of extracting, transporting, and treating the water within Fault
Block E for public supply. Primary expenses for producing untreated water from the Willow
Sands include well construction, pipeline construction, and ongoing operational and maintenance
costs. SROG estimated that the construction of a 5,300 foot well, electrical connections,
pipelines, pumping equipment, and all associated expenses would cost approximately
$13,270,750. Significant capital outlays include drilling costs, installation of an electronic
submersible pump and associated components, installation of electrical service, pipeline
installation, and transfer pumps and controls. After initial construction, monthly operational costs
were estimated at $41,500 per month, with the highest expense estimated to be the electrical
power costs. SROG estimated that an additional $250,000 would be spent every three years, on

7	Guidance for Review and Approval of State Underground Injection (UIC) Programs and Revisions to Approved
State Programs. Groundwater Protection Guidance #34.

8	Enhancing Coordination and Communication with States on Review and Approval of AE Requests Under SDWA.

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average, for miscellaneous repairs and maintenance. Based on these cost estimates and a total
expected recovery of 25,000,000 barrels, the unit cost of water would be approximately
$20.23/1,000 gallons, or $0.0203/gallon. This does not include the cost of extensive water
treatment that would be required prior to delivering this water to market.

EPA Region 10 reviewed the water chemistry data from a sample taken on October 22, 2014,
from the proposed injection zone. The Willow Sands aquifer would require several different
treatment processes to make it both compliant with regulations and aesthetically acceptable for
potential domestic use. Hydrocarbon contamination, such as benzene, was found in multiple
water samples taken from the Willow Sands at levels above the Maximum Contaminant Level
(MCL). Wells from which samples tested in exceedance of the MCL for benzene were: DJS 2-14
(1.5 mg/L), DJS 1-15 (3.0 mg/L), Kauffman 1-9 (2.1 mg/L), ML 1-3 (.7 mg/L), ML 1-11 (8.9
mg/L), ML 2-3 (1.65 mg/L), ML 2-10 (4.28 mg/L), ML 3-10 (2.21 mg/L). For reference, the
MCL for benzene is 0.005 mg/L. Based on the DJS 2-14 sample, the formation fluids in Fault
Block E may contain benzene at a level 300 times the MCL. Toluene and ethylbenzene are found
at levels above their respective MCLs, too.

Other water quality concerns would necessitate treatment processes to render this water usable
for drinking water purposes. The water sample taken from DJS 2-14 tested at 6.88 mg/1 for
Fluoride while the MCL is 4.0 mg/1. For this source of water to be compliant, the fluoride would
need to be removed. Lab analyses performed on these samples did not screen for all possible
contaminants, so it is possible that additional exceedances of MCLs would exist.

In addition to the enforceable water characteristics, the Willow Sands water contains substances
that would make it problematic in domestic applications. The most significant is the level of iron.
Iron levels are 25 times the EPA secondary (non-regulatory) standard. Typically, iron is viewed
as a nuisance or aesthetic concern, but at the levels present in the tested water, the water would
have to be treated. Without treatment, a myriad of issues would arise in piping systems and with
home appliances. Additionally, such levels would almost certainly involve unfavorable taste and
odor concerns. Manganese levels are also elevated, at 0.128 mg/1, which is about 2.5 times the
EPA secondary standard, but below the lifetime health advisory level of 0.300 mg/19. Design of a
water treatment plant for the removal of iron and manganese has a high lifecycle cost
(considering both construction cost and operational costs). Generally, due to the high lifecycle
cost, water utilities will invest in searching for other water sources before installing a dedicated
treatment process for removing iron and manganese - particularly when iron levels are as high as
they are with this source.

Additionally, the Willow Sands water has a relatively high alkalinity and an associated pH of
8.8. The pH is over the EPA secondary standard of 8.5, and while this would not be a compliance
concern, it would likely be an aesthetic concern. Most water utilities would attempt to treat the
water to adjust pH to 8.5 or less, further increasing the cost for the use of the Willow Sands
water as a source.

9 Manganese has cognitive developmental effects on children, and because of this recognition, in 2004, EPA
established both and acute and chronic advisory levels. Reference EPA publication EPA-822-R-04-003.

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Water taken from the Willow Sands would require treatment prior to reaching the end consumer.
A water treatment plant utilizing the Willow Sands aquifer would require multiple unit treatment
processes, and such a facility would be expensive to construct and operate. This would be a
significant challenge for a small water utility with limited financial resources and ability to make
use of the economies of scale available to cities with a larger customer base.

To consider the estimated cost of treating this water, SROG contacted twelve companies
requesting a conceptual water treatment plan and cost estimate, though only two were willing to
provide preliminary cost estimates based on the nature of the project and relatively small size of
the hypothetical plant. The lowest-cost proposal received by SROG would include an oil-water
media filter, an electrocoagulation treater, followed by two stages of filtration, and finally
processing with a reverse-osmosis unit. Total capital costs from this estimate were $1.5 million,
and operating costs were estimated at $295,000/month. Per unit costs are then found to be
$47.77/1000 gallons or $0.0477/gallon.

As stated above, the unit cost to access the Willow Sands and deliver water to market—without
considering water treatment— is approximately $0.0203/gallon. Adding the cost of water
treatment ($0.0477/gallon), the total unit cost would be approximately $0.0680/gallon.

The proposed cost of developing the Willow Sands as a drinking water source was then
compared with the current, actual costs of water available to customers in nearby cities. Fruitland
currently charges its end-users approximately $0.0054/gallon according to the City's website10.
By the same method, New Plymouth, Idaho, charges end users $0.0053/gallonu and the City of
Payette charges $0.0031/ gallon12. The estimated per-gallon costs of producing and delivering
treated drinking water from Fault Block E is approximately 12.6, 12.8, and 21.9 times greater
than the actual costs in Fruitland, New Plymouth, and Payette, respectively.

To provide additional context to the relative cost of accessing the Willow Sands, EPA compared
the estimated cost of producing water from the Willow Sands against the cost of drinking water
across the state. In 2017, a survey was sent to all members of the Association of Idaho Cities
requesting the cost of 5,000 gallons of drinking water to an end-user. Amongst responses from
all cities, regardless of population, the average cost per-gallon was 13.3 times less expensive
than the estimated cost of providing drinking water from Fault Block E; $0.0051/gallon versus
$0.068/gallon, respectively (Cities, 2017).

These cost comparisons are both estimated and simplified, made to compare the relative costs of
developing a USDW that is not actually planned for use. Cost comparisons have not incorporated

10	https://www.frui tland.org/?SEC=09918810-C121-4C8A-B511-

lDBB8F0E3538#:~:text=MontMv%20water%20rate%20is%20%2440.00.no%20water%20nsage%20is%20%2472.
00. Assuming a $40.00 base fee, marginal fee of $1.55/1000 gallons, 2.6 average household residents, and 134 GPD
usage rate.

11	https://npidaho.com/docnments/54/Water Sewer Garbage Rates.pdf Assuming a $37.20 base fee, marginal fee
of $1.75/1,000 gallons, 2.6 average household residents, and 134 GPD usage rate.

12	https://www.citvofpayette.com/?SEC=2C7B73EC-6.1.62-4ACD-Si'lo O.30B1152EAE Assuming a $6.87 base
fee, marginal fee of $02.45/1000 gallons 2.6 average household residents, and 134 GPD usage rate.

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amortization costs for the hypothetical Willow Sands well source, which, if included, would
likely increase the total cost, and subsequently increase the relative cost in comparison with
existing sources. Ongoing costs, such as power, overhead, and maintenance costs, are difficult to
estimate especially considering the limited water availability of the Willow Sands Block E.
Lastly, it does not consider whether it would be a sound investment to develop a water system
with limited water availability. As discussed above, approximately 25 million barrels of water
are available from this reservoir.

EPA contacted local cities to learn whether the Willow Sands has ever been considered as a
future drinking water source. Of the three cities contacted by EPA (Fruitland, New Plymouth,
City of Payette), none expressed that the Willow Sands was being considered as a future water
source. There is also no indication that extremely deep groundwater sources (i.e., over 4,000 ft.
deep) have ever been considered by local PWSs for drinking water needs in the Payette River
Basin. A report from 1986 stated that "only the uppermost portion of the sediments is important
with respect to groundwater development within the Payette County study area" (Deick &
Ralston, 1986).

EPA considered whether nearby cities in more populous areas of Idaho have accessed aquifers as
deep as the Willow Sands. Areas in the Treasure Valley that experience much greater water
demand than the Payette Basin primarily access groundwater from depths of less than 1,000 ft.,
even though sedimentary horizons extend to depths of over 6,000 ft. (SPF Water Engineering,
LLC, 2016). In a 1981 report, Wood and Anderson theorize that drilling costs "may limit
exploitation of' geologic units deeper than 1,500 ft. below ground in the Western Snake River
Plain, a statement referring to the Nampa-Caldwell and adjacent areas which share similar
geologic setting as the Payette River Valley (Mitchell, 1981).

Considering limited water availability and the costs of accessing Block E of the Willow Sands,
accessing this aquifer as a drinking water source is economically impractical.

2. Considering Alternative Sources

This section provides information on population change and water demand in Payette County. It
then discusses alternative water resources that could be targeted for drinking water supply prior
to the Willow Sands, Block E. The population of Payette County, though growing, remains
small, and water usage is not expected to increase dramatically in the coming decades. Were an
unforeseen event to occur resulting in a need to acquire drinking water from new sources, Block
E of the Willow Sands would not be a viable economic choice in comparison with alternative
untapped sources.

Based on data from the U.S. Census Bureau (The Bureau), population in Payette County has
grown in the previous decade, though, at a rate less than the entirely of Idaho13. A 2015 study by
the USGS demonstrated that while Idaho has seen a population growth since 1990, total water

13 U.S. Census Bureau. https://www.census.gov/programs~survevs/popest/data/data~sets.htmL Accessed November
2020.

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withdrawals have remained steady or have even declined slightly (USGS, 2015). Similar
conclusions were made in the Treasure Valley Domestic, Commercial, Municipal, and Industrial
(DCMI) Water-Demand Projection report' prepared for the Idaho Department of Water
Resources and Idaho Water Resource Board. The study area from the DCMI report included
Canyon and Ada counties, which share geologies, geographies, weather, and culture with nearby
Payette County. The DCMI report forecasts future water demand in Treasure Valley until the
year 2065. This report indicates that the per capita water use is expected to decline slightly, while
population is expected to increase. The net result is a modest (5%) increase in water demand for
those counties in the study. This conclusion considers: population growth and changes in
residential density; projected temperature increases leading to higher rates of evapotranspiration,
precipitation decreases, and higher temperatures during the summer months; water conservation
tactics, such as public education; installation of low-water-use fixtures, appliances, and
landscaping; and pricing structures that discourage excessive water use.

No known water supply and demand forecasts have been prepared for the Payette River Basin, so
to gather additional information on the current and future water needs for population centers
nearest the AE boundary, EPA conducted outreach with local water resource departments. This
occurred for the three cities closest to the proposed injection well (Fruitland, New Plymouth, and
the City of Payette) to understand PWS water source type and whether any future source
expansion is planned. These cities, and their primary drinking water sources, are all located
between 4-7 miles of the AE boundary. None of the PWSs discussed in this section extract water
from the same hydrologic unit as the Willow Sands or from any units that are hydrologically
connected to Block E of the Willow Sands.

The City of Fruitland currently relies on the Payette River for primary water supply. Seven
groundwater wells are maintained as an emergency/contingency source, all drawing from
between 60-100 ft. BGS. The City has previously investigated the use of deeper water sources
(i.e., 500-800 ft.), but abandoned those wells due to cost issues. Fruitland has made large capital
investments in their current surface water system which is thought to sustain water quantity
needs indefinitely based on expected population growth numbers14. A feasibility study from
2007 considered how the greater-Fruitland area would supply domestic water needs in the event
of a large population increase (an increase that would be equivalent to a tripling of Fruitland's
population). Based on a consideration of capital, operational, and maintenance costs, the study
determined that the best source of water for the projected new development would be an
expansion of the existing Fruitland water system, rather than considering deeper groundwater
resources (Pharmer Engineering, LLC, 2007).

The City of New Plymouth uses a three well system to supply all public water needs and
maintains a fourth well for contingency purposes. All four of these wells are shallower than 126
ft. BGS. Current wells produce enough water for the city's needs based on conversations with
City employees. Staff for the City informed EPA that additional supply was not currently
needed15.

14	Phone Conversations with staff employed by the City of Fruitland on November 5, 2018 and January 12, 2021.

15	Phone Conversation with staff employed by the City of New Plymouth, November 6, 2018

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The City of Payette relies on six active groundwater wells and two inactive wells to meet
primary municipal needs. The aquifers that feed these wells are found at depths ranging from
approximately 130 to 270 ft. BGS. Payette previously explored the idea of producing from
aquifers approximately 500 ft. BGS but found that both water availability and quality decreased
with depth16.

Under unforeseen circumstances, it is possible that supplemental water resources may be needed
in the future. In this scenario, less expensive and more easily accessible water sources would be
targeted before the Willow Sands, Block E. First, expansion of shallow groundwater resources—
nearly ubiquitous across the Payette River Basin—and surface water from the Payette River
could be further developed. Second, deeper aquifers (>500 ft. BGS), though, shallower than the
Willow Sands, may become economically viable, but those zones shallower than the Willow
Sands and closer than the site of well DJS would be far less expensive alternatives due to
inherent drilling and piping costs. For example, at the location of DJS 2-14 a sand aquifer found
between 1,350 and 1,420 ft. BGS is easier to access and contains fewer TDS than the Willow
Sands. Finally, if expansion into deep freshwater (i.e., <3,000 TDS) aquifers such as the Willow
Sands were ever to occur, water resource planners would consider the available quantity and
quality of groundwater in the target aquifer. This would include identifying deep sand intervals
elsewhere in the Western Snake River Plain containing reservoirs that are not limited in volume
by geologic structure and negatively impacted by residual contamination.

16 Phone Conversation with staff employed by the City of Payette, September 9, 2021
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V. Public Comment

Comments on this proposed AE must be submitted during the public comment period beginning
on January 14, 2022 at 9:00 AM Mountain Time (MT) and ending on February 28, 2022, at 5:00
PM MT. Due to the Covid-19 pandemic, no hard-copy comments will be accepted. All
comments must be submitted by email to osborne.evan a ena.gov AND contain:

1.	The statement "Draft Aquifer Exemption Public Comment" in the subject line of the
email,

2.	The name, address, and telephone number of the person commenting (in the body of the
email) and,

3.	A concise statement and the relevant facts forming the basis for the comment.

EPA has scheduled a public hearing on February 18, 2022, at 10:00 AM MT. The purpose of this
meeting is to collect oral comments. To attend the meeting, visit the EPA Region 10 UIC
webpage (https://www.epa.gov/uic/underground-iniection-control-region-10-ak-id-or-and-wa)
the morning of the hearing. EPA will post hearing details under the Public Notices section of this
webpage.

After the public comment period ends and all comments have been considered, the Director of
the EPA Region 10 Water Division will make a final decision regarding this AE. If no
substantive comments are received, the AE will become final, and the AE will become effective
upon issuance. If substantive comments are received, EPA will address the comments and
determine whether to issue the proposed AE. The AE will become effective upon issuance unless
an appeal is submitted. An AE approved by EPA is a final agency action that may be challenged
under Section 1448(a)(2) of the SDWA (42 USC300j-7(a)(2)). The statute of limitations for the
right of appeal regarding any determination made related to the AE request described above is
controlled by 40 CFR § 23.7 in concert with SDWA Section 1448(a)(2).

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VI. References

Cities, A. o. (2017). Municipal Utility Survey.

https://cdn.ymaws.com/idahocities.org/resource/resmgrAVater/2017_10_19_AIC_Utility
_Surve.pdf: www.idahocities.org.

Deick, J. F., & Ralston, D. R. (1986). Ground Water Resources in a Portion of Payette County,
Idaho. Idaho Water Resources Research Institute.

IDL. (2020). Southwest Idaho Oil and Gas Activity Map. Idaho Department of Lands.

IOGCC. (2019). AROG Annual Report for Active Wells to IOGCC.

Mitchell, J. C. (1981). Geothermal investigations in Idaho; Part 11 Geological, Hydrological,
Geochemical and Geophysical Investigations of the Manpa-Caldwell and Adjacent
Areas, Southwestern Idaho. Idaho Department of Water Resources.

Parliman, D. (1986). Quality of Ground Water in the Payette River Basin, Idaho. U.S.
Department of the Interior.

Pharmer Engineering, LLC. (2007). Palisades Water and Sewer Services Feasibility Study.

SPF Water Engineering, LLC. (2016). Treasure Valley DCMI Water-Demand Projections (2015-
2065). Idaho Water Resources Board.

USGS. (2015). Idaho Water Use, 2015. U.S. Geological Survey.

USGS Collab. (n.d.). Map - Characterization of Ecoregions of Idaho. Retrieved from
https://www.nrc.gOv/docs/ML1018/ML101800248.pdf

Wood, S. H. (2004). Geology Across and Under the Western Snake River Plain, Idaho: Owyhee
Mountains to the Boise Foothills. Boise State University.

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