June 8, 2018
Subject: Response to Pacific Groundwater Group’s letter of findings, dated June 1, 2018, regarding the proposed use of UIC Wells at the Madrona Elementary School in Edmonds, Washington
Lynne Danielson, General Manager
Olympic View Water and Sewer District
8128 228 Street SW
Edmonds, WA 98026
Dear Lynne,
Robinson Noble has reviewed the recent report prepared by Pacific Groundwater Group (PGG), dated June 1, 2018, which was completed to provide an assessment of the Edmonds School District’s (ESD) proposed use of underground injection control (UIC) wells to manage storm water at the Madrona Elementary School in Edmonds, Washington. A copy of the PGG report is attached with this letter for reference.
Background
The Olympic View Water and Sewer District (OVSD) has expressed on-going concerns regarding the proposed use of UIC wells at the Madrona Elementary School site. This concern is based on the fact that school site is located within the wellhead protection area (WHPA) of OWWSD’s Deer Creek Springs water supply source, and that the proposed UIC wells will bypass a protective 100-foot thick layer of glacial till (Qvt) to inject both treated and untreated storm water directly into the primary sand aquifer (Ova) that feeds the spring. After continued and unresolved debate between the ESD and the O V S D (and their respective consultants), the two parties tentatively agreed to jointly hire a third-party consultant to review various disputed issues. Robinson Noble (OVWSD’s primary hydrogeologic consultant) suggested several prominent area hydrogeologic consulting firms including PGG, whom the two parties initially agreed to hire jointly. However, there was disagreement on the issues that PGG would be hired to review, and in the end the ESD hired PGG independently to assess what they perceived were the primary unresolved issues. This letter provides Robinson Noble’s a s s e s s m e n t of PGG’s final report to the ESD regarding the use of UIC wells at the Madrona Elementary School site.
General Comment
PGG was hired solely by the ESD to review and assess their concerns (independent of OVWSD). We do not consider this an independent third-party review as initially intended. In reviewing PGG’s report, it did not appear that any of OVWSD’s major concerns were addressed in the report. The PGG report is intentionally limited to answering six very basic questions. These six questions were answered in a limited sense to show general compliance by the ESD, and it is our opinion that the PGG report does not really consider fully the ultimate protection of the Deer Creek Springs source (the primary concern of the OVWSD).
Link to full letter: