TAC MPRWA Agenda Packet 10-02-17

Agenda
Monterey Peninsula Regional Water Authority (MPRWA)

Technical Advisory Committee (TAC)
Regular Meeting
10:30 AM, Monday, October 2, 2017

Council Chambers
580 Pacific Street, Monterey
Monterey, California
CALL TO ORDER
ROLL CALL
PLEDGE OF ALLEGIANCE
REPORTS FROM TAC MEMBERS
PUBLIC COMMENTS
PUBLIC COMMENTS allows you, the public, to speak for a maximum of three minutes on any
subject which is within the jurisdiction of the MPRWA TAC and which is not on the agenda. Any
person or group desiring to bring an item to the attention of the Committee may do so by
addressing the Committee during Public Comments or by addressing a letter of explanation to:
MPRWA TAC, Attn: Monterey City Clerk, 580 Pacific St, Monterey, CA 93940. The appropriate
staff person will contact the sender concerning the details.
CONSENT AGENDA
CONSENT AGENDA consists of those items which are routine and for which a staff
recommendation has been prepared. A member of the public or TAC Member may request that an
item be placed on the regular agenda for further discussion
***End of Consent Agenda***
AGENDA ITEMS
1. Receive, Discuss, and Provide Comments to the Water Authority Board on the Geosyntec
Report on Groundwater and Hydrogeologic Impacts, Including Modeling Issues, Raised by
the Marina Coast Water District (MCWD) in its Comments on the MPWSP DEIR/DEIS -
Cullem
2. Receive Report and Discuss the Detailed MPWSP Schedule Including Upcoming Permit
Requirements and the Status of the Test Slant Well and Installation of the Transfer
Pipeline - Cook/Crooks
ADJOURNMENT
Created date 09/28/2017 2:07 PM Monday, October 2, 2017
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Agenda related writings or documents provided to the MPRWA are available for public
inspection during the meeting or may be requested from the Monterey City Clerks Office at 580
Pacific St, Room 6, Monterey, CA 93940. This agenda is posted in compliance with California
Government Code Section 54954.2(a) or Section 54956.
2
Monterey Peninsula Regional Water Authority Date: 2 Oct 2017
Agenda Report Item No: 1
FROM: Executive Director Cullem
SUBJECT: Receive, Discuss, and Provide Comments to the Water Authority Board on
the Geosyntec Report on Groundwater and Hydrogeologic Impacts,
Including Modeling Issues, Raised by the Marina Coast Water District
(MCWD) in its Comments on the MPWSP DEIR/DEIS
RECOMMENDATION:
It is recommended that the Water Authority TAC discuss the previously agendized (Aug
8, 2017) report from Geosyntec on issues raised by MCWD with respect to the
Monterey Peninsula Water Supply Project MPWSP DEIR/DEIS, and provide comments,
as appropriate, to the Water Authority Board.
DISCUSSION:
Interested parties were required to provide comments on the MPWSP DEIR/DEIS to the
CPUC by March 29, 2017. Accordingly, the Water Authority Board approved a contract
change order with Separation Processes, Inc.(SPI) and its sub-consultant Geosyntec to
review the DEIR/DEIS and provide an independent analysis of the intake structures and
brine disposal in advance of MPRWA comments on the documents.
In April 2017 a review of the submissions to the CPUC identified a number of issues
raised by the MCWD and the City of Marina that suggested an independent analysis
would better inform the Board and the public. Accordingly, at its meeting of May 13,
2017, the Board approved change order #6 to the SPI contract to have Geosyntec
expand its analysis to conduct a "high-level review of the MCWD comments reference
groundwater/hydrogeologic impacts from the MPWMD source water wells", in particular:
1) MCWD letter pgs 1-4, 7-8, sections C.1 (pg 50-54) and C.2 pgs 55 -64
2) HGC Comments on pgs 1-8, and comments #23-28, #31, #35, #38, & #39
3) GeoHydros Comments- all
4) EKI Comments- parag #5
06/12
Geosyntec was also tasked to review and comment on the California Unions For
Reliable Energys Comments concerning the vertical infiltration rates to the source wells
at pages 38-41 of their comment letter and the supporting technical memoranda.
In addition, Geosyntec was to consider issues raised by the MCWD with respect to the
groundwater models.
For each comment on a groundwater/hydrogeologic impact or issue, Geosyntec was

tasked to explain whether:
1) it agreed with the comment/reasoning,
2) disagreed with the comment/reasoning and why, or
3) are uncertain as to the accuracy of the comment/reasoning and how greater

certainty concerning the subject could be obtained (e.g., how the issue would be further
tested for determination).
The draft results of long offset method "Aerial Electromagnetic Method" (AEM) update
of the Electrical Resistivity Tomography (ERT) analysis were presented to the Marina
Coast Water District (MCWD) on August 7, 2017. It was interpreted by MCWD
hydrogeologist Curtis Hopkins to further demonstrate damage to the Salinas Valley
basin as a result of Cal Am slant well operations. At its meeting of Sept 18, 2017, the
Water Authority Board authorized an extension of the Geosyntec contract to include an
objective analysis of the draft AEM as well as the Hopkins conclusions.
Though the AEM analysis will not be available for consideration by the TAC until a later
meeting, the TAC needs to further review the details of the revised draft Geosyntec
analysis (attached) which were initially provided to the TAC on August 7, 2017.
Note that the attached Geosyntec revised draft report is 38 pages and takes a long time
to download.
ATTACHMENTS:
A- Revised Draft Geosyntec Report

595 Market Street, Suite 610
San Francisco, California 94105
PH 510.836.3034
www.geosyntec.com
DRAFT Technical Memorandum
Date: REVISED DRAFT 30 August 2017

To: Jim Cullem, Monterey Peninsula Regional Water Authority
From: Gordon Thrupp, PhD, PG, CHG, Principal Hydrogeologist
Subject: Review of MCWD Comments on RDEIR
Monterey Peninsula Water Supply Project
Subsurface Intakes and Groundwater Modeling
Geosyntec Consultants (Geosyntec) was engaged by SPI Membrane Technology Consultants, to

review comments prepared on behalf of the Marina Coast Water District (MCWD) on the Revised
Draft Enviromental Impact Report (RDEIR, ESA, January 2017) prepared for the CalAm
Monterey Peninsula Water Supply Project (MPWSP).
The goal of the review was to specifically address the following comments that relate to
groundwater/hydrogeologic conditions and potential impacts of the MPWSP to the groundwater
resources:
1) MCWD 29 March 2017 letter pgs 1-4, 7-8, Sections C.1 (pg 50-54) and C.2 pgs 55 -64
2) HGC Comments on pgs 1-8, and comments #23-28, #30, #31, #32, #35, #36, #38, & #39
3) GeoHydros Comments- all
4) EKI Comments- parag #5
5) California Unions for Reliable Energys (CURE) Comments concerning the vertical
infiltration rates to the source wells at pages 38-41 of their comment letter and the supporting
technical memoranda.
A brief summary of my response to the comments is followed specific responses and discussion
for each of the comment letters.
REVISED DRAFT 30 Aug 2017 Review of MCWD Comments on RDEIR.docx

Review of MCWD Comments on RDEIR
Monterey Peninsula Water Supply Project RDEIR
REVISED DRAFT 30 August 2017
Page 2
SUMMARY
The comment letters submitted on behalf of MCWD claim the analysis of the potential impacts of
the proposed project pumping based on the updated model (NMGWM2016, RDEIR, ESA 2017) is
not valid because of problems with the model calibration, reliability, and uncertainty.
Updates to the NMGWM (NMGWM2016) include refinement of hydrostratigraphy and aquifer

properties that better represent conditions near the proposed project. The detailed CEMEX model
was calibrated to the test slant well pumping monitoring data, and resulting changes in aquifer
parameter values in the re-calibrated CEMEX model were incorporated in the updated NWGWM.
The model extent and properties of the Fort Ord - Salinas Valley Aquitard (FO-SVA) were refined
in the NMGWM2016, which was a key recommendation by the Lawrence Berkeley National
Laboratory review of the NGWMM2015. The FO-SVA, which hydraulically separates the Dune
Sand and 180-foot-equivalent (180-FTE), was added south of the Salinas River in the
NMGWM2016 and a transition zone was added where the FO-SVA thins toward the coast
(HydroFocus, 2016). The ocean boundary conditions were changed to represent more physically
realistic conditions.
We agree that groundwater quality (salinity) is locally variable, but detailed characterization of
groundwater quality and quantity in the Dune Sand Aquifer is not relevant to the evaluation of
feasibility and potential impacts of the project. Moreover, both quality and quantity of
groundwater in the Dune Sand varies temporally with rainfall, particularly at local occurrences of
perched groundwater.
MCWD is correct that the model does not evaluate groundwater quality, but return flow will be
based on data (salinity of the pumped water), not modeling.
Note however, that a recent geophysical survey along the Monterey Bay Coastline using electrical
resistivity tomography (ERT) indicates that while the distribution of saltwater intrusion is variable
and complex in portions of the 180-ft and 400-ft Aquifers, the saltwater intrusion is relatively
ubiquitous and uniform along the coastal margin within the Upper Alluvium including the Dune
Sand Aquifer. The only exception appears to be a prominent area of shallow fresh water within
the Fort Ord Dunes approximately 6.3 miles south of the CEMEX Plant that is attributed to
recharge from water diverted from storm water ponds (Goebel et al, 2017).
Page 3
Including water level data for areas of perched groundwater in the shallow aquifers (Dune Sand
and A-Aquifer) is a key reason for the alleged poor calibration of the NMGWM2016. Local
occurrences of perched groundwater are isolated hydraulically from the regional water table by
intervening unsaturated intervals, and MODFLOW does not simulate the flow of groundwater for
unsaturated conditions. Some of the groundwater elevations for the A-Aquifer (Dune Sand) near
Fort Ord and the County Landfill are associated with perched groundwater that are not
hydraulically connected to the regional water table and should not be included in the MODFLOW
model. This does not influence the reliability of the model simulations of the proposed project
pumping.
The comment letters for MCWD include numerous claims that the simplified superposition
modeling approach that was used to evaluate potential project impacts is not appropriate and the
results are not reliable. However, superposition modeling is a commonly used valid approach that
directly estimates the lowering of the groundwater levels associated with proposed pumping. For
example, the Arizona Department of Water Resources requires all stresses other than the proposed
pumping to be removed from models to evaluate potential impact for permitting of proposed
pumping wells. Also, routinely used type-curve analysis of aquifer testing data is superposition
modeling.
Some of the comments address differences in hydostratigraphy represented in regional Salinas

Groundwater Basin model and the NMGWM, and calibration problems associated with assigned
initial groundwater levels based the regional model. However, the inaccurate initial heads based
on the regional model has no influence on the equilibrium (steady-state) simulations of the
proposed project pumping, which apparently was recognized by GeoHydros when they used the
calibrated version of the NMGWM2016 to independently run simulations of the proposed project
pumping instead of the simplified version used by HydroFocus for the superposition modeling
presented in the RDEIR.
The claims are incorrect that the model results are not reliable because they do not include the
influence of salinity and density on groundwater flow. As is documented in the RDEIR,
accounting for variable density as a function of salinity would have negligible influence on the
model calculations of potential impacts of the proposed project pumping.
Although the NMGWM2016 was not used to evaluate portions of source water that the proposed
slant wells would pump, modeling simulations conducted by GeoHydros indicate that the total
groundwater portion would decrease to 11% after one year and remain at approximately 10% from
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2 to 32 years. This is generally consistent with previous groundwater modeling with the
NMGWM2015 reported in the DEIR, and is within the range of assumed replenishment obligations
addressed with the NGWM2016 modeling presented in the RDEIR (0 to 12%). Moreover, the
determination of the quantity of return water from the project for the groundwater replenishment
obligation will be calculated based on the salinity of the water pumped by the project wells using
a formula to calculate the portion of Ocean Water and Inland Fresh Water that was based on a
water purchase agreement between MCWD, MCWRA and Cal Am (2010). The replenishment
formula is provided in Appendix E2 to the DEIR.
As part of the review of the NMGWM2015, LBNL did their own simulations using the model files
provided by the CPUC, and compared results of their model results with those presented in
Appendix E2 of the DEIR (ESA, 2015). LBNL reported that their model runs closely replicated
the results for both the CMEX and Northern Marina Groundwater Model (NMGWM2015) that were
presented in Appendix E2 of the Draft E2 of the DEIR.
As part of the review of NMGWM2016 GeoHydros obtained the model files and ran their own
simulations of the proposed project pumping using the calibrated model boundary conditions
instead of the simplified version of the model used by HydroFocus for the superposition modeling
approach. The modeled drawdown calculated using the two different modeling approaches are
nearly identical (see Attachment 1 to this memorandum). Moreover, the difference between the
extent of drawdown calculated using the two approaches are well within the uncertainty considered
in the analysis and findings by the RDEIR based on the sensitivity analyses on the model results.
Claims that the proposed project pumping would interfere with recharge operations planned at
Armstrong Ranch are inconsistent with data and analysis.
Claims submitted on behalf of CURE that the RDIER fails to adequately analyze the vertical
infiltration rate of ocean water into the sea floor that would be induced by the pumping from
proposed slant wells are incorrect. Section 4.5.5.2 (pages 4.5-51 to 53) of the RDEIR presents
analysis of the vertical infiltration rate of water into the sea floor. The findings presented by the
RDIER are reasonable that the potential for impingement of marine organisms and organic
material on the sea floor due to the proposed project pumping is less than significant. The claims
on behalf of CURE challenging these finding are technically flawed and unsubstantiated.
Page 5
REVIEW OF SECTIONS C.1 AND C.2 OF THE MCWD LETTER
Sections C.1 and C.2 of the MCWD letter (29 March 2017) address groundwater analysis and
discussion of potential impacts. The MCWD letter indicates that the analysis and characterization
of existing groundwater conditions, and evaluation and discussion of potential impacts to
groundwater by the proposed project presented by the RDEIR, including the North Marina
Groundwater Model (NMGWM) is inadequate.
I disagree.
The RDEIR and the associated groundwater modeling to evaluate feasibility and potential impacts
of the proposed project utilizes many available sources of regional hydrogeologic data,
groundwater conditions, and environmental status. In addition to numerous reports by private
consultants that are also cited in in the RDEIR, the following public sources of information and
data were used to establish baseline conditions:
California Coastal Commission, California Department of Conservation,

California Department of Water Resources (DWR),
California Department of Fish and Game,
California Department of Fish and Wildlife,
California Division of Mines & Geology,
California State Mining and Geology Board,
California Geological Survey,
California Resources Agency, Fort Ord Reuse Authority,
Marina Coast Water District,
Monterey County Planning Department,
Monterey County Regional Water Agency,
Monterey Peninsula Water Management District,
Monterey Regional Water Pollution Control Agency,
Monterey Bay Aquarium Research Institute,
Monterey Bay National Marine Sanctuary,
National Oceanographic AtmosphEIRc Administration (NOAA),
National Research Council,
National Marine FishEIRes Service,
Pajaro Valley Water Management Agency,
Page 6
Seaside Groundwater Basin Watermaster,

Regional Water Quality Control Board,
State Water Resources Control Board,
United States Environmental Protection Agency (EPA), and
United States Geological Survey.
Geology and groundwater conditions along the coastal margin of the Salinas Valley Groundwater
Basin, as well as in communities of Marina Coast, Fort Ord, Seaside, Sand City, and Monterey
have been studied for many decades.
The conceptual hydrogeology on which the Northern Marina Groundwater Model (NMGWM) is
based is presented Section 2 of Appendix E2 to the RDEIR. The framework of the NMGWM is
based on the regional Salinas Valley Groundwater Basin models with refinements based on local
hydrogeologic data along the coastal margin and near the proposed site at the CEMEX facility.
These data and the NMGWM include estimated extent of the Dune Sand Aquifer, extent and
thickness of the Salinas Valley Aquitard, and extent of the 180-foot Aquifer.
Six exploratory borings were drilled along the coastal margin near the CEMEX Facility to
investigate hydrostratigraphy and make site-specific measurements of hydraulic properties.
Testing at the borings included
water quality samples in 15 aquifer zone locations,

grain-size analysis and calculations of hydraulic conductivity (K),
laboratory testing of horizontal hydraulic conductivity (Kh) and vertical
hydraulic conductivity (Kv) on core samples, and
geophysical logs
Detailed reporting on the CEMEX borings and testing is provided in Appendix C3 of both the
DEIR and RDEIR.
A long-term pumping test of the test slant well at 2000 gpm began 22 April 2015. Water levels
and electrical conductivity is recorded with transducers and data loggers in six monitoring wells
and reports are available from the project web-site1. The CEMEX model was used to simulate the
test slant well pumping and re-calibrated to the long-term data (Geoscience, 2016). The resulting
1
http://www.watersupplyproject.org/testwellmonitoring
Page 7
changes in aquifer parameter vales in the re-calibrated CEMEX model were incorporated in the
updated NWGWM for the RDEIR (HydroFocus, 2016).
Revisions to the updated NMGWM included refinement of the model extent and properties of the
Fort Ord - Salinas Valley Aquitard (FO-SVA), which was a key recommendation by the Lawrence
Berkeley National Laboratory review of the NGWMM2015 (LBNL, 2016, included as Appendix E1
of RDEIR). The FO-SVA hydraulically separates the Dune Sand and 180-foot-equivalent (180-
FTE). The FO-SVA was added south of the Salinas River in the NMGWM2016 and a transition zone
was added where the FO-SVA thins toward the coast (HydroFocus, 2016).
Note that as part of the review of the NMGWM2015, LBNL re-ran models using files provided by
the CPUC, and compared results of their model results with those presented in Appendix E2 of the
DEIR. LBNL reported that their model runs closely replicated the results for both the CMEX and
Northern Marina Groundwater Model (NMGWM2015) that were presented in Appendix E2 of the
Draft E2 of the DEIR.
The RDEIR shows 500 mg/l chloride threshold for the regional scale characterization of extent of
sea water intrusion (SWI) as defined by the MCWRA (every two years). 500 mg/l chloride is the
California secondary maximum contaminant level (MCL) recommended upper limit for consumer
acceptance level for potable water. Development of new water supply with water greater than 500
mg/l would require blending or treatment.
We agree that groundwater quality (salinity) is locally variable, but detailed characterization of
groundwater quality and quantity in the Dune Sand Aquifer is not relevant to the evaluation of
feasibility and potential impacts of the project. Moreover, both quality and quantity of
groundwater in the Dune Sand varies temporally with rainfall, particularly at local occurrences
of perched groundwater.
Note however, that a recent geophysical survey along the Monterey Bay Coastline using electrical
resistivity tomography (ERT) indicates that while the distribution of saltwater intrusion is variable
and complex in portions of the 180-ft and 400-ft Aquifers, the saltwater intrusion is relatively
ubiquitous and uniform within the Upper Alluvium including the Dune Sand Aquifer. The only
exception appears to be a prominent area of shallow fresh water within the Fort Ord Dunes
approximately 6.3 miles south of the CEMEX Plant that is attributed to recharge from water
diverted from storm water ponds (Goebel et al, 2017).
Page 8
Comments on the model properties, design and calibration.

Model layering, boundary conditions and properties were improved based on additional data and
comments (including peer reviews). Calibration of the NMGWM2016 model is generally improved
compared to the NMGWM2015.
The model does not simulate unsaturated flow and does not represent perched groundwater.
Shallow perched groundwater occurs locally in the Dune Sands including highland areas of Fort
Ord.
Groundwater elevation contour maps such as Hopkins Fig 6, that include elevations of perched
groundwater in the landfill and Fort Ord areas are incorrect. The areas of perched groundwater
are not hydraulically connected to the regional water table and should not be included in regional
water table elevation contour maps.
As documented in the RDEIR (Appendix E2), incorporating the influence of variable density on
groundwater flow has negligible influence on model results.
Comments that the superposition modeling is not appropriate.

The MCWD letter includes numerous claims that the superposition modeling is not appropriate.
The RDEIR explains the limitations of the modeling in general and specifically the superposition
modeling.
Superposition modeling is a common method to evaluate impact of pumping (e.g. Arizona

Department of Water Resources requires all stresses other than the proposed pumping to
be removed from models to evaluate potential impact for permitting of proposed pumping
wells).
Standard aquifer testing analysis is superposition modeling.
The superposition modeling approach directly estimates the lowering of the groundwater
levels associated with proposed project pumping.
It does not preclude prediction of changes in groundwater elevation associated with the
project.
MCWD is correct that the model does not evaluate groundwater quality, but return flow
will be based on data (salinity of the pumped water), not modeling.
Page 9
Monitoring and Mitigation Measures

My understanding is that MCWRA is planning a monitoring program. Mitigation would include
greater portion of return water
Comments on depletion of groundwater in the Dune Sand Aquifer and resulting decrease in
recharge to 180-FTE Aquifer
If groundwater in the Dune Sand was a significant resource there would be wells in it.
There are no irrigation wells in the Dune Sand because of the sporadic unreliable
presence of water.
Recharge to the 180-FTE Aquifer from water in the Dune Sand clearly has not prevented
SWI in the 180 FTE aquifer.
Lowering of water levels in the 180 FTE could enhance leakage into the 180-FTE from
Dune Sand in areas where they are hydraulically connected, but separated by a semi-
confining layer (leaky aquitard).
Page 10
REVIEW OF HGC COMMENTS

(pgs 1-8, and comments #23-28, #30, #31, #32, #35, #36, #38, & #39)
Comments and claims by Hopkins Groundwater Consultants (HGC) in his 29 March 2017 letter
are provided followed by my opinion and discussion in blue italics.
Pages 1-8
HGC claims that the RDEIR and associated updated North Marina Groundwater Model
(NMGWM2016) mischaracterizes the project and the complex hydrogeological conditions in the
project area by incorrectly suggesting, without any supporting evidence in many cases, that:
1. The intake system will induce flow vertically through the ocean floor
This is not mischaracterization. It is true the a large portion of the source water would be drawn
vertically through the ocean floor.
2. The shallow aquifers along the coastline around the CMEX site are fully intruded by
seawater
The RDEIR makes no such claim.
3. The groundwater gradient (flow) in all aquifer zones produced by the project is onshore
(inland or away from the coast) in the entire area
The RDEIR makes no such claim. In fact Figures 5.6 and 5.7 of Appendix E2 (HydroFocus, 2016)
present model results that show local flow directions from inland toward the proposed project
wells.
4. Historical studies are sufficiently complete and comprehensive in nature to document

conditions in the vicinity of the project
The RDEIR makes no such claim. In fact the updates to the NMGWM presented in the RDEIR
utilize newly acquired data from the slant well testing program. However, sufficient information
exists to provide the framework for a hydrogeologic conceptual model on which the numerical
models are based.
5. The limited exploration and testing to date sufficiently validates assumptions in the
DEIR/EISs groundwater models
The RDEIR makes no such claim. Many of the assumptions made for the groundwater modeling
analyses have nothing to do with exploration and testing, but on physical principles of
Page 11
groundwater flow. Moreover, the updates to the groundwater modeling presented in the RDEIR
do utilize results of additional testing and data compilation.
6. The DEIR/EISs superposition model is reliable and demonstrates that the projects
potential impacts on groundwater levels and groundwater quality in the Marina Subarea will
be less than significant.
Estimates of the projects impacts on groundwater levels based on the superposition model are
reasonably reliable. The superposition model does not simulate changes in groundwater quality.
7. Mitigation of the projects impacts can be accomplished through multiple methods and
means.
This comment is vague. Mitigation measures depend on specific potential project impacts.
HGC claims the calibrated NGWM2016 model was abandoned and replaced with the inferior
superposition model.
Superposition modeling is a common method to evaluate impact of pumping. For example, e.g.
Arizona Department of Water Resources requires all stresses other than the proposed pumping to
be removed from models to evaluate potential impact for permitting of proposed pumping wells.
Type-curve analysis of aquifer testing is superposition modeling.
I agree that the superposition modeling has limitations. For example, it cant be used directly for
evaluation of capture zone of the project wells. HydroFocus superimposed the regional hydrologic
gradient on the superposition model results to evaluate capture zones. Note also that GeoHydros
(discussed below) ran project pumping simulations with the NGWM2016 calibrated model and
obtained very similar results for drawdown of groundwater to HydroFocus with the simplified
superposition modeling approach.
HGC claims the perched groundwater in portions of the Dune Sand Aquifer and -2-Foot-Aquifer
beneath the County Landfill, which are not addressed by the NGWM2016, are important for
evaluating potential impacts of project pumping.
I disagree. The proposed project pumping cannot impact the local occurrences of perched
groundwater in the Dune Sands because they are not hydraulically connected to the regional water
table. Moreover, the -2-foot Aquifer, which occurs beneath the County Landfill is underlain by the
Salinas Aquiclude, which is s competent and widespread barrier that separates the shallow
perched zones from water supply aquifers including the 180-foot, 400-foot aquifers (California
Regional Water Quality Control Board, 2006).
Page 12
HGC claims the DEIR/EIS fails to evaluate the project impacts on a perched groundwater in
portions of the Dune Sand Aquifer, which are not addressed by the NGWM2016, are important for
evaluating potential impacts of project pumping.
I disagree. The proposed project pumping cannot impact the local occurrences of perched
groundwater in the Dune Sands because they are not hydraulically connected to the regional water
table.
HGC claims the DEIR/EIS incorrectly estimates capture zones of the project pumping.
This is incorrect. HydroFocus superimposed the regional hydrologic gradient on the
superposition model results to evaluate capture zones.
HGC claims that a dual density model should be used evaluate the proposed project pumping and
water quality changes.
Presumably HGC means variable density not dual density. But accounting for the influence of
density on groundwater flow due to variation in salinity is not important to evaluate the proposed
impacts of project pumping because the influence of density variation is negligible compared to
slant well pumping and uncertainties in hydraulic conductivity. This is discussed and
demonstrated by (HydroFocus, 2016, Appendix E2 to the RDEIR). Seawater is only 2.5% more
dense than freshwater.
HGC Comment 23
HGC claims the slant well screens are not beyond the jurisdictional boundaries of the County.
Apparently this pertains to the relationship between the location of the wells screens and the
coastline. Presumably it also depends on the location of the source water pumped by the wells.
I defer to legal counsel on this issue.
However, please note that the freshwater/seawater interface is not a distinct boundary beneath the
coastline and in many settings, the fresh groundwater/sea water transition beneath the ocean floor
is well beyond the coastline. The distinction between fresh groundwater and sea water is based
on salinity, not location.
HGC claims the updated model (NMGWM2016) presented in the RDEIR relies on the CEMEX
Model Update (Geoscience, 2016), which HGC says makes unsupported assumptions.
Page 13
The CEMEX model was used to simulated the test slant well pumping and re-calibrated to the
long-term data (Geoscience, 2016). The resulting changes in aquifer parameter vales in the re-
calibrated CEMEX model were incorporated in the updated NWGWM2016 as presented in the
RDEIR (HydroFocus, 2016). The NWGWM2016 incorporates results of updates to the CEMEX
model, but does not rely on the CEMEX model. Not possible to address the unsupported
assumptions claimed by HGC because HGC does not describe them.
HGC Comment 24
HGC claims that baseline water levels were not established prior to the testing of the slant well.
HGC also claims there was no information regarding tidal, seasonal, or climatic variations, and
that it was unclear what was considered as pre-pumping conditions.
I disagree. Baseline monitoring of water levels and water quality were recorded for seven weeks
prior to the initiation of the test well pumping. Moreover, monitoring was continued when the test
well pumping stopped for regulatory review or maintenance, including approximately four months
in 2015 and several weeks in 2016. The hydrographs presenting monitoring data recorded for
prior and during test well pumping program clearly illustrate baseline conditions and tidal
influence. Rainfall data are also included to facilitate assessment of influence on groundwater
levels.
Monitoring reports are prepared on a weekly basis for the California Coastal Commission and
monthly monitoring reports are prepared for Cal Am. The monitoring reports are available from
the project web site: https://www.watersupplyproject.org/test-well
HGC expresses concern that project impact in terms of drawdown of groundwater levels assessed
during pumping in drought conditions when groundwater levels were low are not representative
of typical conditions when groundwater levels are higher.
Higher water level conditions after the drought increases transmissivity, which results in less
drawdown impact of the test well pumping in the unconfined surficial aquifers. Assessing influence
of test well pumping on groundwater levels for drought conditions provides a conservative
assessment of project impact.
Page 14
HGC claims the degree of uncertainty in the groundwater modeling is intolerable.
I disagree. The degree of uncertainty is typical and acceptable. Results of sensitivity analyses are
presented to illustrate the uncertainty.
The modeling is intended to evaluate the potential impacts of the proposed project pumping, not
other potential future changes in pumping.
HGC Comment 25
In Comment 25, HGC again claims the degree of uncertainty in the groundwater modeling is
intolerable. HGC also states the superposition modeling used to evaluate potential drawdown of
groundwater levels by the proposed project pumping cannot be used to evaluate potential impacts
to groundwater quality or water budget (different sources of water).
I disagree that the degree of uncertainty in the groundwater modeling is intolerable. The degree
of uncertainty is typical and acceptable. Results of sensitivity analyses are presented to illustrate
the uncertainty.
The superposition model was not used to evaluate potential impacts to groundwater quality. Nor
was it used to estimate portions of sources of water pumped by the proposed project.
I agree that the model does not simulate changes to local occurrences of perched groundwater in
the dune sands. This is nothing to do with superposition. MODFLOW only simulates saturated
flow conditions, and unsaturated conditions exist below perched groundwater. Perched
groundwater is not hydraulically connected to the aquifers that would be pumped by the project
wells, and therefore cannot be impacted by the project pumping.
HGC also again claims the assessment of potential impacts of the project pumping are based on
inadequately defined baseline conditions and that the modeling is fatally flawed.
I disagree.
Page 15
HGC Comment 26
In Comment 26, HGC again claims baseline conditions are not investigated, the modeling is
flawed, does not utilize best available information, and that potential interference with
groundwater recharge is not evaluated.
I disagree with all these claims. Note also that the model updates use most current information
on groundwater conditions including ongoing monitoring data for the test slant well pumping.
HGC Comment 27
In Comment 27, HGC claims the that Figure 4.4-13 of the RDEIR is simplistic and somehow
erroneous?
Figure 4.4.-13 shows the modeled worst-case drop in groundwater levels (drawdown) in the
180-FTE aquifer caused by continuous project pumping for 63 years with no delivery of return
water to replenish the inland aquifers. The superposition model provides the estimated impact
on groundwater levels only of the project pumping, which is the objective of the analysis. Other
unknown potential changes in pumping are not included.
Based on the analysis, which includes the groundwater modeling, the project pumping would have
less than significant impact on water quality, depletion of storage, and on groundwater dependent
ecosystems.
The analysis for the RDEIR also includes assessment of influence of projected rise in sea level,
because this is expected to occur. Higher sea level will result in a slightly greater portion of sea
water flowing to the slant wells and thus a decrease the portion of inland groundwater. Figures
4.4-14 16 of the RDEIR show the range of the extent of greater than 1-foot-drawdown in the
Dune Sand, 180-FTE, and 400-ft Aquifers for current sea level and with sea level rise after 63
years and with a return water range of 0 to 12%.
flawed, and does not utilize best available information.
I disagree.
Page 16
HGC Comment 28
In Comment 28, HGC comments that the superposition model cannot quantify the amount of
seawater and fresh groundwater that the project wells would pump.
Although the superposition is not used to quantify portions of seawater and groundwater from
inland aquifers pumped by the proposed wells, it could be.
flawed, and does not utilize best available information. HGC also claims the hydraulic
conductivity values assigned to the superposition model are not reliable.
I disagree.
In Comment 28, HGC claims that the proposed slant wells would be within the jurisdictional
boundary of County Ordinance 3709.
I defer to legal counsel on this issue. However, my understanding is this is correct and is the
reason that the portion of fresh groundwater pumped by the project will be returned to the
groundwater basin. My understanding is the plan to return water from the project to the
groundwater basin is conditionally acceptable to the State Water Board (2013, included as
Appendix B2 of RDEIR).
HGC Comment 30
In Comment 30, HGC refers to additional modeling of the project pumping conducted by
GeoHydros using the re-calibrated NMGWM2016, and points out that the model indicates that the
initial portion of groundwater pumped by the project wells would be 30%.
The same modeling indicates that the total groundwater portion would decrease to 11% in one
year and remains at approximately 10% from 2 to 32 years. This is generally consistent with
previous groundwater modeling with the NMGWM2015 reported in the DEIR and is within the
range of assumed replenishment obligations addressed with the NGWM2016 modeling presented in
the RDEIR (0 to 12%). Note that a greater groundwater replenishment obligation lessens potential
inland impacts of the project pumping.
Page 17
HGC also claims that the project would reduce groundwater storage.
I agree. The modeled drawdown of the water table, which is addressed in the RDEIR, shows this
HGC claims that the amount of return water needs to be indicated and analyzed.
The RDEIR evaluates potential project impacts for a range of return water (0, 3, 6, and 12%)
based on groundwater replenishment obligations estimated by previous modeling. The updated
modeling for the RDEIR does not re-evaluate the portions of ocean water and inland groundwater
water pumped by the project wells. However, as discussed above, the additional modeling
presented with comments by GeoHydros indicates that the groundwater portion would be
approximately 10% (Ocean Water 90%) after approximately 2 years of pumping. The portion of
fresh groundwater would be less than 10% because most of groundwater in the coastal margin
aquifers has been impacted by sea water intrusion.
More importantly, based on a water purchase agreement between MCWD, MCWRA and Cal Am
(2010), the determination of the quantity of return water from the project for the groundwater
replenishment obligation will be calculated based on the salinity of the water pumped by the
project wells using the following formula to calculate the portion of Ocean Water and Inland Fresh
Water that was provided in Appendix E2 to the DEIR:
X = (FS-IS)/(OWS-IS)
Where,
X is Proportion of Ocean Water in Intake Water,
(1-X) is Proportion of Fresh Water,
OWS is Ocean Water Salinity = 33,500 mg/L TDS
FS is Feedwater Salinity, and
IS is Inland Water Salinity (Fresh Water) = 440 mg/L TDS, which is based on
inland Salinas Basin groundwater that is not impacted by sea water intrusion.
For example, Feedwater with salinity of 32,000 mg/L consists of 95.5% Ocean Water and 4.5%
Inland Fresh Groundwater. Based on the NMGWM pumping simulations presented in the DEIR,
over the long term, the average intake water consists of 94.5% ocean water, and 5.5% inland fresh
groundwater, which require replenishment of 1,458 AFY (1.3 mgd) for the proposed project
pumping of 24 mgd.
The RDEIR states that a mathematical formula will be used to calculate the quantity of water to
be retuned the groundwater basin each year (pg 4.4-49), but does not seem to provide the formula.
Page 18
Note that based on the salinity of water pumped by the test slant well, the calculated portion of
ocean water using the above formula was initially approximately 75%, but approached the
estimated range of 93 to 96% based on NMGWM2015 modeling, after a few months of pumping.
However, the last several months the salinity has been generally decreasing and based on salinity
reported for a sample collected 21 June 2017 (Geoscience, 2017), the Ocean Water Portion has
decreased to 84%. Presumably the change is due to dilution of salinity in the shallow coastal
aquifers associated with recharge of fresh water associated with the abundant rainfall this year.
In Comment 30, HGC comments that groundwater that is degraded by seawater intrusion is useable
because it can be treated.
I agree that brackish or saline water can be treated to potable water standards. Indeed, this is the
plan of the proposed project. HGC is correct that the States TDS threshold is 3,000 mg/L for
designation as potentially suitable for municipal or domestic water supply.2 However, the State
Water Resources Board secondary maximum contaminant levels for TDS in drinking water are
500 mg/L TDS (recommended) and 1000 mg/L TDS (upper limit)3.
In Comment 30, HGC claims the modeling needs to consider cumulative drawdown.
I disagree. The purpose of the analysis for EIR is to assess potential impacts of the project
pumping, not unknown other possible future pumping.
I agree that drawdown of groundwater levels in the range of 1 to 5 feet is less than significant
impact to existing production wells. Typical seasonal variations of groundwater levels are
greater.
HGC Comment 31
In Comment 31, HGC again claims the modeling needs to consider cumulative drawdown.
I disagree. The purpose of the analysis for the EIR is to assess potential impacts of the project
pumping, not unknown other possible future pumping.
2
https://www.waterboards.ca.gov/board_decisions/adopted_orders/resolutions/2006/rs2006_0008_rev_rs88_63.pdf
3
http://www.waterboards.ca.gov/gama/docs/coc_salinity.pdf.
Page 19
In Comment 31, HGC states that the reported findings regarding potential project impacts to
Tembladero and Elkhorn Sloughs are inconsistent in Sections 4 and 5 of RDEIR.
I disagree. As explained by the excerpts from the RDEIR included in HGCs Comment 31, the
alternative project, which would be pumping from slant wells at Potrero Road, would have greater
potential impact on Elkhorn Slough because of the proximity of the slant wells to the Slough.
HGC Comment 32
In Comment 32, HGC states again that the reported findings regarding potential project impacts to
Tembladero and Elkhorn Sloughs are inconsistent in Sections 4 and 5 of RDEIR.
I disagree. As explained above for HGC Comment 31.
In Comment 32, HGC states that the evaluation of the slant well pumping with surface water at
the CEMEX facility is inadequate, and the therefore the modeling presented in the RDEIR is
subject to intolerable uncertainty.
I disagree. Moreover, the CEMEX dredge pond is hydraulically connected to the ocean and is
simply a window into the water table beneath the sand. The Pacific Ocean is the source of water
to the CEMEX dredge pond. I agree that the potential impact of the project pumping on recharge
to the Dune Sand Aquifer and sand mining operations is less than significant.
HGC Comment 35
In Comment 35, HGC states again that the evaluation of potential impacts to groundwater
resources reported in the RDEIR and the proposed measure 4.4-3 for groundwater monitoring are
inadequate.
I disagree. Moreover, my understanding is that MCWRA will oversee developing a groundwater
monitoring program to evaluate if the project pumping impacts the performance of local
production wells.
HGC Comment 36
In Comment 36, HGC expresses concern that the project could result in fresh and brackish
groundwater becoming hypersaline, and that the RDEIR fails to address this possibility. Also,
HGC states again that the modeling must be updated to address project impacts to water quality.
Page 20
It is not possible that project would cause groundwater to become hypersaline as HGC claims.
Hypersaline means salinity greater than ocean water.
Local temporal and spatial variations in salinity of groundwater along the coastal margin where
there are no production wells are not relevant to evaluation of potential impact of the project
pumping.
Model calculations (particle tracking presented by Figure 4.4-17 of the RDEIR) show that the
project has insignificant influence on the inland extent of sea water intrusion.
The determination of the quantity of return water from the project for the groundwater
replenishment obligation will be calculated based on the salinity of the water pumped by the
project well. My understanding is the plan to return fresh water from the project to the
groundwater basin is conditionally acceptable to the State Water Board (2013, included as
Appendix B2 of RDEIR).
HGC Comment 38
In Comment 38, HGC expresses concern that additional evaluation is needed of potential influence
of the proposed project pumping on contamination beneath the Fort Ord remediation site using a
revised and calibrated or a new dual density model.
I disagree. The RDEIR adequately address potential impact of the proposed project pumping on
contaminated groundwater including the plumes at Fort Ord. The main plume of contaminated
groundwater is called the Operable Unit Carbon Tetrachloride Plume (OUCTP), although it also
includes trichloroethene (TCE) (Mactec, 2006). The larger extent of contamination is within the
A-Aquifer, which is within recent dune sands. The A-Aquifer is separated from the 180-FTE
Aquifer by the regional Fort Ord Salinas Valley Aquitard (FO-SVA).
As stated by the RDEIR the A-Aquifer is a shallow inland aquifer above the 180-Foot Aquifer and
is not known to be hydraulically connected to the Dune Sand Aquifer at the proposed slant well
locations. Stability in groundwater elevations in the A-Aquifer (Plate 12, Mactec, 2006) support
that this aquifer is hydraulically isolated from pumping from irrigation wells in the underlying
180-foot and 400-foot aquifers to the east in Salinas Valley (pg 12, Mactec, 2006). Moreover,
hydrographs for monitoring wells in the upper and lower portions of the 180-ft aquifer beneath
Fort Ord show seasonal variation in groundwater levels of greater than 5 and 10 feet, respectively
Page 21
(Plates 13 and 14, Mactec, 2006), which is likely due to variable influence of pumping from
irrigation wells. The potential influence of the project pumping at Fort Ord in the 180-FT aquifer
would be much less.
Moreover, accounting for variable density based on salinity (not dual density) would have
negligible influence on the model calculations in the vicinity of the Fort Ord plumes.
HGC Comment 39
In Comment 39, HGC expresses concern that the evaluation presented in the RDEIR only
addresses potential impacts of the project pumping.
Indeed, the intent is to evaluate potential impact of the proposed project pumping. There is no
basis to simulate future potential changes in pumping associated with unknown other projects.
Sensitivity analyses were conducted that provide a range of estimated project impacts, and the
potential impacts with compensation for projected sea level rise.
Page 22
REVIEW OF GEOHYDROS COMMENTS
Claims and comments by GeoHydros (GH) in their 27 March 2017 letter are followed by my
opinion and discussion in blue italics.
Section 2. NMGWM
GH (page 1) says updates to the NMGWM2016 include structural changes that favored the
conceptualized flow from the Pacific Ocean into the aquifers.
GHs statement implies that the updates were intended to result in a larger portion of ocean water
flow to the model slant wells. But the changes by HydroFocus to the offshore boundary conditions
and initial conditions were improvements to the model. These changes are listed below:
Changed Layer 1 (ocean specified head) to represent actual thickness. 2015 used uniform
1-ft thickness.
Activated all cells in ocean with specified heads. In the NMGWM2015 version, the offshore
cells were inactive resulting in offshore no-flow boundaries, which inappropriately
lessened connection to the seaparticularly for steady-state model runs.
Added equivalent fresh-water heads used for offshore boundary conditions. The water
levels represent hydraulic potential, or hydraulic head, and are corrected for density
differences between the high saline, denser ocean water relative to the less saline, less
dense inland groundwater. These corrected water levels are referred to as equivalent
freshwater heads.
GH (page 2): The model boundaries are arbitrary and do not represent natural hydrologic divides
therefore the model simulates flow across the external boundaries that cannot be verified from
data.
Presumably GH means the model extent is arbitrary. The model extent is not arbitrary, but is
based on the geography and hydrogeology of the project vicinity and utilizes information from
more regional models. The NMGWM covers nearly 150 square miles; the boundary conditions
are acceptably far-removed from the location of proposed project pumping. The model would
need to cover the entire Salinas Valley and portions of adjacent highlands for the inland
boundaries to represent physical hydrologic divides. The extent of the model domain is
appropriate for the purposes of the analysis and consistent with standard practice.
GH (page 2): GH criticizes the use of equivalent freshwater heads for the ocean boundary
conditions, but no use of equivalent freshwater heads for inland groundwater with elevated salinity
Page 23
due to saltwater intrusion. They claim that a dual-density model such as SEAWAT or FEFLOW
would be the appropriate way to simulate saltwater intrusion.
The use of equivalent freshwater heads for ocean boundary conditions is common practice and
reasonable. We agree that a variable density (not dual-density) model such as SEAWAT could be
used to simulate variable salinity distribution and potential change in salinity distribution due to
the project pumping. However, the objective of the modeling was not to specifically simulate sea
water intrusion and salinity distribution.
Moreover, as reported in the RDEIR (pg 26 of Appendix E2), model simulations were conducted
using SEAWAT to evaluate the error associated with neglecting to account variable density in the
NMGWM2016. The results demonstrated that accounting for the influence of density on
groundwater flow due to variation in salinity is not important to evaluate the proposed impacts of
project pumping because the influence of density variation is negligible compared to slant well
pumping and uncertainties in hydraulic conductivity. This is discussed and demonstrated by
(HydroFocus, 2016, Appendix E2 to the RDEIR). Seawater is only 2.5% more dense than
freshwater.
GH (page 2-3): GH comments that interconnectivity between the regional Salinas Valley Model
(SVIGSM) and the NMGWM model are problematic.
I agree. But, the regional Salinas Basin model and NMGWM model are not intended to be
interconnected. They are of different scales and detail. As discussed in the RDEIR (Appendix
E2, HydroFocus, 2016), the differences between the models influence the large calibration errors.
Note however, that much of the calibration error is a consequence of inaccurate initial heads
particularly in the Dune Sand aquifer. The 180-FT aquifer is the uppermost aquifer system in
which horizontal groundwater is simulated by SVIGSM. SVIGSM was not designed to simulate
horizontal groundwater flow in the shallow Perched A or Dune Sand Aquifer. So, it is not
surprising that the boundary conditions and initial heads derived from SVIGSM for the Dune Sand
Aquifers were not accurate.
It seems that GeoHydros recognizes that the inaccurate initial heads based on the SVIGSM have
little influence on the equilibrium (steady-state) simulations of the proposed project pumping,
which is why they used the calibrated version of the NMGWM2016 to independently run simulations
of the proposed project pumping instead of the simplified version used for the superposition
modeling.
Page 24
Another key factor regarding the poor calibration is that the groundwater within the Dune Sand
locally is perchedhydraulically not connected to the regional water table. MODLOW does not
simulate unsaturated flow of groundwater.
GH (page 3): GH Figures 8 and 9 show contours of groundwater levels for their 32 transient runs
of the calibrated version of NMGWM2016 for the 400-ft and 900-ft aquifers. GH claims the model
overestimates the inland directed hydraulic gradient in these aquifers.
Apparently GH Figures 8 and 9 are for model runs without the proposed project pumping. Seems
to me the differences between the initial time step and result at 32 years is simply a consequence
of equilibration groundwater levels between the assigned initial heads and the solved heads, which
are mainly controlled by the boundary conditions. Inaccuracy of initial heads assigned to the
model for starting conditions has no relevance to the reliability of steady-state simulations of the
project pumping. Evidence of extensive sea water intrusion into the 400-ft aquifer indicates that
inland from the ocean has and is occurring. Moreover, the low groundwater elevation in the 400-
ft aquifer near the northeast extent of the model are based on measured water levels.
I agree that the model results depicted for the 900-ft aquifer by GH Figure 9 may overestimate
inland flow of groundwater from the ocean, but this would have little if any influence on the
reliability of the model simulations of the project pumping in the shallow aquifers.
GH (page 3-4): GH discusses the model calibration and points out the model fails the stated
calibration test in the Dune Sand Aquifer.
Some of the groundwater elevations for the A-Aquifer (Dune Sand) are for occurrences of perched
groundwater that are not hydraulically connected to the regional water table and should not be
included in the MODFLOW model, which cannot simulate flow of perched groundwater. This
does not influence the reliability of the model simulations of the proposed project pumping.
In most respects, the NMGWM2016 model is improved compare to the NMGWM2015, particularly
with respect to aquifer properties and geometry near the project.
GH (page 4): GH claims the sensitivity analyses conducted by HydroFocus on the NMGWM2016
(Figures 6.1 & 6.2, Appendix E2) show a five-fold increase in horizontal hydraulic conductivity
(Kh) coupled with five-fold decrease in vertical hydraulic conductivity (Kv) nearly doubles the
size of the modeled cone of depression in the Dune Sand Aquifer.
Page 25
GH is incorrect. Hydrofocus Figure 6.2 shows that the sensitivity with maximum anisotropy (five-
fold increase in Kh coupled with five-fold decrease in Kv) decreases the modeled extent of
groundwater drawdown due to the proposed pumping. But, minimum anisotropy (five-fold
decrease in Kh coupled with five-fold increase in Kv) increases the modeled extent of groundwater
drawdown. I agree that improvement of model calibration is possible, but the range of potential
drawdown based on the sensitivity analyses is considered in the evaluation of potential impacts of
project pumping presented in the RDEIR.
Section 3. Superposition Model
GH (page 5) discuss the simplified superposition modeling approach that HydroFocus used to
evaluate potential drawdown of groundwater levels due to the proposed project pumping. GH
states that though superposition modeling is a valid technique, it isnt necessary or appropriate
for these evaluations.
I agree that the simplified superposition modeling approach isnt necessary. But it is appropriate
for evaluating potential impacts of the proposed project pumping.
GH claims that superposition modeling precludes evaluation of impacts to the water budget
associated with the proposed pumping, and that superposition modeling precludes prediction
of measurable changes associated with the proposed pumping (i.e. predicted groundwater
elevations and gradients).
I disagree. Water budget information from superposition modeling can be used to estimate
portions of source water associated with the proposed project pumping. It also can be used to
predict changes in groundwater elevations and hydraulic gradient.
GH obtained the model files and independently ran simulations of the proposed project pumping
with the calibrated (unsimplified) version of NMGWM2016. GH claims that comparison of the
results of the model runs they did with the calibrated (unsimplified) version of NMGWM2016 show
that the superposition model approach used by HydroFocus underestimates the extent of
groundwater drawdown by the proposed project pumping (GH Figures 10-13).
GH Figures 10-13, which are included as Attachment 1 to this memo, provide a comparison of the
results of the two modeling approaches. The modeled drawdown calculated using the two
Page 26
different modeling approaches are nearly identical. Moreover, the difference between the extent
of drawdown calculated using the two approaches are well within the uncertainty considered in
the analysis and findings by the RDEIR based on the sensitivity analyses on the model results.
Section 4. Evaluation of Potential Impacts
GH (page 5-6) states that the calibration and boundary condition problems render predictions
dEIRved from the NMGWM unreliable particularly with respect to the Dune Sand Aquifer
I disagree. In fact, as discussed in the previous comment above, the additional modeling runs
conducted by GH support that the results of the simplified superposition model presented in the
RDEIR are reasonable, and that the superposition modeling approach is valid.
GH (page 7-8) report and discuss water budget calculations of source water to the slant wells based
on their model simulations of the project pumping.
The model runs by GH and their presentation of source water calculations are helpful. The model
results by GH indicate that source water is approximately 30% inland groundwater after one
month of pumping, but groundwater contribution decreases to 11% in one year and remains at
approximately 10% from 2 to 32 years. The portion of fresh groundwater would be less than 10%
because most of groundwater in the coastal margin aquifers has been impacted by sea water
intrusion
The results of the water budget calculations based on the model runs by GH are generally
consistent with previous groundwater modeling with the NMGWM2015 reported in the DEIR and
are within the range of assumed replenishment obligations addressed with the NGWM2016
modeling presented in the RDEIR (0 to 12%). Note that a greater groundwater replenishment
obligation lessens potential inland impacts of the project pumping.
Page 27
Section 5. Conclusions
GH (page 8) concludes that the NMGWM2016 is poorly calibrated in the Dune Sand Aquifer, the
quality of model calibration of the NMGWM2016 is not as good as for the NMGWM2015, and the
reliability of predicted impact of the project pumping is undermined by the poor calibration.
The poor calibration is a consequence of including data for areas of perched groundwater in
the shallow aquifers (Dune Sand and A-Aquifer). Local occurrences of perched groundwater are
isolated hydraulically from the regional water table by intervening unsaturated intervals and
MODFLOW does not simulate the flow of groundwater for unsaturated conditions.
I agree that data are limited for calibration of model properties for the shallow aquifer (Dune
Sand Aquifer), however, the hydraulic conductivity properties assigned for the Dune Sand are
reasonable, and the variation in hydraulic conductivity for the sensitivity analyses provides a
conservative assessment of potential impact of the proposed project pumping.
GH (page 9) states that the model results indicate that 2.8% or 756 acre-feet per year is predicted
to come from the 400-ft and 900-ft aquifers, which will contribute to overdraft in those aquifers.
GH Table 3 indicates 1.9% and 0.9% from the 400-ft and 900-ft aquifers, respectively. The
potential impacts to the 400-ft and 900-ft aquifers of the proposed project pumping are evaluated
by the RDEIR and found to be less than significant.
GH (page 10) states that The sensitivity analyses performed by HydroFocus with respect to
hydraulic conductivity indicate that the predicted impacts could be substantially understated,
which demonstrates the importance of achieving better calibration.
This statement is misleading. The sensitivity analyses show a range of potential impacts of the
project. The range of potential impacts is considered by the RDEIR. The level of uncertainty is
acceptable for the purpose of evaluating the potential project impacts as presented by the RDEIR.
GH (page 10) states that Based on the findings presented in this report, we believe that the Draft
EIR/EISs conclusions regarding the MPWSPs groundwater impacts are not scientifically
supportable and that they conflict with available information.
I disagree. The model findings are scientifically supportable are consistent with abundant
information. The model approximates subsurface conditions and is not intended replicate complex
heterogeneity of subsurface properties. The model is a reasonable screening tool designed to
evaluate potential project impacts.
The other bullet points by GH in their conclusion section are addressed above.
Page 28
REVIEW OF COMMENTS BY EKI
Nearly all the comments and concerns by EKI (29 March 2017) are essentially the same as by
Hopkins and GeoHydros, which are addressed above.
EKI states that the Project will preclude MCWD from utilizing the Dune Sand Aquifer for storage
and/or augmentation of groundwater supplies through surface water recharge at Armstrong
Ranch, and that the RDEIR needs to address this.
I disagree that the project would preclude the MCWD from utilizing the Dune Sand Aquifer for
storage and/or augmentation of groundwater supply by recharge at Armstrong Ranch. Moreover,
the RDEIR does address potential impacts of project pumping including estimated drawdown of
groundwater levels in the vicinity including Armstrong Ranch.
Armstrong Ranch is thousands of feet beyond the estimated extent of groundwater capture by the
proposed project pumping. The capture zone envelopes for the proposed project pumping of 24.1
mgd were calculated by HydroFocus for the Dune Sand and 180-FTE Aquifers (Figure 5.6
Appendix E2, RDEIR) for a range of hydraulic gradients. These capture zones are also shown on
EKI Figures 11 and 12.
Figure 137 of Appendix E2 from the DEIR, which is included as Attachment 2 to this memo, also
shows the capture zone in the 180-FTE Aquifer associated with the project pumping, based on the
NMGWM2015 for the proposed pumping of 24.1 mgd. Figure 137 (see Attachment 2 to this memo),
also shows groundwater flow pathlines both with and without the project pumping. The pathlines
on the attached figure help to show that with the project pumping would reverse the groundwater
flow direction inland of the capture zone, so groundwater would flow towards the coast instead of
inland.
As is recognized and addressed by the RDIER, the proposed project pumping may increase salinity
in the Dune Sand and 180-FTE Aquifers within the extent of hydraulic capture by the project wells.
However, further inland, beyond the capture zone in locations such as Armstrong Ranch, the
proposed project pumping should result in a long-term decrease in salinity the Dune Sand and
180-FTE Aquifers due the reversal of groundwater flow direction (flow toward the coast instead
of away from the coast). Note, however, that any change in flow direction and water quality, due
the project pumping, that could occur thousands of feet away from the extent of hydraulic capture
would be minor and take many decades if not centuries.
The model simulations of the proposed project pumping show that the potential extent of 1-foot
drawdown of groundwater levels in the Dune Sand and 180-FTE Aquifers (Figures 4.4-14 and
4.4-15, RDEIR; Figures 9 and 10, EKI) reaches the vicinity of Armstrong Ranch. However, these
Page 29
small changes in groundwater elevation would not influence water quality or feasibility of
enhanced recharge projects. Moreover, seasonal variation in groundwater elevation and
hydraulic gradients due to variation in pumping and rainfall are much more significant, as
discussed above in response to HGC Comment 38.
Note also, that the Fort Ord-Salinas Valley Aquitard (FO-SVA), which hydraulically separates the
Dune Sand and 180-foot equivalent (180-FTE) aquifers from greater than about 2 km east of the
proposed MPWSP project site, limits recharge benefit from Dune Sand to 180-FTE Aquifer at
Armstrong Ranch.
Page 30
REVIEW OF COMMENTS ON BEHALF OF CALIFORNIA UNIONS FOR RELIABLE

ENERGYS
On behalf of California Unions for Reliable Energy (CURE) Linda Sobczynski with the law firm
of Adams Broadwell Joseph & Cardozo submitted a letter dated 28 March 2017 (the CURE letter)
to the CPUC and MBNMS with comments on the DEIR/EIS for the proposed MPWSP. I was
asked to specifically review pages 38-41 of the CURE concerning the vertical infiltration rates to
the source wells.
Page 38 of the CURE letter states: The DEIR/EIS fails to adequately analyze and mitigate
potential significant impacts related to marine resources, particularly as those impacts are caused
by the subsurface slant well technology. More specifically, the letter claims that factors
influencing vertical infiltration rates are not adequately analyzed including:
location of the submersible pump in the slant wells;

sediment profile for the existing 19o slant wells and proposed 14o slant wells;
packers in the slant wells; and
clogging in the seabed.
I disagree that the RDIER fails to adequately analyze the vertical infiltration rate of ocean water
into the sea floor that would be induced by the pumping from proposed slant wells. Section 4.5.5.2
(pages 4.5-51 to 53) of the RDEIR presents analysis of the vertical infiltration rate of water into
the sea floor, and potential resulting impingement of marine organisms and organic material on
the sea floor.
The basis for the calculated vertical infiltration rate of ocean water into the seafloor is provided
on page 4.5-52 of the RDIER. The calculation assumes that infiltration of ocean water would
occur within a 1,000,000 sq ft. area of the seafloor: 2000 ft long along the coast, by 500 ft long
perpendicular to the coast (offshore distance). If all 24.1 mgd (3,221,925 ft3/d) flows into the
seafloor within this area, the average infiltration velocity of ocean water into the sea floor would
be 3.22 ft/d, which equates to velocity of 0.011 mm/sec.
As discussed in the RDIER, this calculated ocean water velocity into the seafloor is much lower
than swimming speeds of marine organisms, and much lower than currents associated with waves
and thus potential impingement of organisms and organic material on the sea floor due to the
proposed project pumping is less than significant.
I suggest that the infiltration velocity calculations should also include effective porosity of the sea
floor sediment. Because water only flows through the connected void space (effective porosity)
within the sediment, the velocity of water flowing within the sediment is faster. The lower the
Page 31
effective porosity, the higher the velocity. Assuming an effective porosity of 0.25 (25 percent) for
the sea floor sediment, the velocity in the sediment would be four times higher: (0.011mm/sec
divided by 0.25 = 0.0455 mm/sec). However, this more conservative velocity is still much lower
than swimming speeds of marine organisms, and much lower than currents associated with waves
and thus potential impingement of organisms and organic material on the sea floor due to the
proposed project pumping is less than significant.
Moreover, the calculated velocity of ocean water infiltration into the sea floor is conservative
because not all the water pumped by the project wells would infiltrate through the assumed 2000
by 500 ft area of seafloor. A portion of the source water would come from inland groundwater
and the area of seafloor through which ocean water would infiltrate would be larger than 2000 by
500 ft.
I disagree that the location of the submersible pump is an important factor in the vertical
infiltration velocity of ocean water through the sea floor. The location of the pump within the well
will have little influence on the flow profile and negligible influence on vertical infiltration rate of
ocean water into the sea floor. Note the that the depth of the slant wells where they would
approach the coastline would be a couple hundred feet, and consequently the ocean water drawn
into the slant wells would come from a large area.
The detailed stratigraphy (sediment profile) for the existing test slant well, which is based on the
boring log is depicted Figure 4c in Appendix E2 of the DEIR (ESA, 2015). The sediment profile
for the proposed shallower angle slant wells (14 degrees instead of 19 degrees) will be similar and
can be estimated from the stratigraphy shown by Figure 4c in Appendix E2 of the DEIR (ESA,
2015). Moreover, the hydrostratigraphy is approximated by the NMGWM2016, which includes
updates based on specific information from borings logs in the project site vicinity. The
distribution of inflow to the slant wells may influence salinity, but will have negligible influence
on vertical infiltration rate of ocean water into the sea floor because of the large distance between
the well screens and the sea floor and anisotropy of hydraulic conductivity within the sediments
(Kh > Kv).
I am not aware of any packers in the test slant well, or plans for packers in the proposed slant
wells. Packers, which could be used to focus flow from portions of the well, could influence
salinity, but would have negligible influence on vertical infiltration rate of ocean water into the
sea floor for the same reasons discussed above.
As discussed above and presented in the Section 4.5.5.2 of the RDEIR, the vertical velocity of
ocean water entering the sea floor would be too low relative to the cleaning effects of the water
energy to cause clogging.
Page 32
REFERENCES
EKI, 28 March 2017, Comments Regarding California America Water Monterey Peninsula Water
Supply Project Draft Environmental Impact Report/Environmental Impact Statement,
Released 13 January 2017, Memorandum to Marina Coast Water District.
ESA, April 2015, Cal Am Monterey Water Supply Project, Draft Environmental Impact Report,
prepared for California Public Utilities Commission.
ESA, January 2017, Cal Am Monterey Water Supply Project, Draft Environmental Impact Report,
prepared for California Public Utilities Commission.
GeoHydros, 27 March 2017, Review of the 2016 North Marina Groundwater Model, prepared
for Marina Coast Water District.
Goebel M, A Pidlisecky, R Knight, 2017, Resistivity imaging reveals complex pattern of saltwater
intrusion along Monterey coast, Journal of Hydrology, vol. 551, pp 746-755.
http://www.sciencedirect.com/science/article/pii/S0022169417301154?via%3Dihub
Geoscience, 8 July 2014, Monterey Peninsula Water Supply Project Results of Test Slant Well
Predictive Scenarios Using CEMEX Area Model, DRAFT, prepared for Cal Am Water,
Appendix E1 of DEIR.
Geoscience, 8 July 2014, Technical Memorandum (TM1) Summary of Results Exploratory

Boreholes, Monterey Peninsula Water Supply Project Hydrogeologic Investigation,
DRAFT, prepared for Cal Am Water and RBF Consulting, Appendix C3 of DEIR
Geoscience, 17 April 2014, Monterey Peninsula Water Supply Project Groundwater Modeling and
Analysis, prepared for Cal Am Water, Appendix E2 of DEIR.
Geoscience, 20 April 2014, Technical Memorandum, Monterey Peninsula Water Supply Project
Baseline Water and Total Dissolved Solids Levels, Test Slant Well Area, submitted to the
Hydrogeologic Working Group.
Geoscience, 16 June 2015, Test Slant Well Long Term Pumping Monitoring Report No. 7, 3
June 15 to 10 June 15, prepared for Cal Am Water
http://www.watersupplyproject.org/testwellmonitoring
Page 33
Geoscience Support Services Inc., 2016, DRAFT Monterey Peninsula Water Supply Project
Hydrogeologic Investigation Technical Memorandum (TM2) Monitoring Well
Completion Report and CEMEX Model Update, prepared for Cal Am Water, 15 July 2016.
Geoscience Support Services Inc., 2017, Monterey Peninsula Water Supply Project Test Slant
Well Long Term Pumping Monitoring Report No. 114 5-July-17 12-July-17, prepared
for Cal Am Water, 18 July 2017. https://www.watersupplyproject.org/test-well
Guo, W. and C.D. Langevin, 2002. Users Guide to SEAWAT: A Computer Program for
Simulation of Three-Dimensional Variable-Density Ground-Water Flow. U.S. Geological
Survey Techniques of Water-Resources Investigations 6-A7.
Harbaugh, A.W., 2005, MODFLOW-2005, The U.S. Geological Survey modular ground-water
model the Ground-Water Flow Process (TM 6-A16) (see also
http://water.usgs.gov/ogw/modflow/).
Hopkins, 29 March 2017, letter to Marina Coast Water District, re: CalAm Monterey Peninsula
Water Supply Project, Draft Environmental Impact Report/Environmental Impact
Statement, Prepared for California Public Utilities Commission and Monterey Bay National
Marine Sanctuary, January 2017
HydroFocus, 2016, North Marina Groundwater Model Review, Revision, and Implementation for
Slant Well Pumping Scenarios, 23 Nov 2016, Appendix E2 of RDEIR.
LBNL, 2016, Peer Review of Groundwater Modeling for the Monterey Peninsula Water Supply
Project (MPWSP) April 2015 Draft EIR, Lawrence Berkeley National Laboratory, LBNL-
1006421, 31 Oct 2016, included as Appendix E1 in the RDEIR.
Marina Coast Water District (MCWD), Monterey County Water Resources Agency (MCWRA),
and California-American Water Company (Cal-Am), 2010. Water Purchase Agreement.
Dated April 6, 2010.
Mactec, 2006, Final Operable Unit Carbon Tetrachloride Plume Groundwater Remedial
Investigation/Feasibility Study, Former Fort Ord, California, Volume 1 Remedial
Investigaiton, prepared for the US Army Corps of Engineers, May 19.
http://fortordcleanup.com/reference-documents/ouctp/
Page 34
Montgomery Watson, 1994, Salinas River Basin Water Resources Management Plan task 1.09,
Salinas Valley Ground Water Flow and Quality Model Report, prepared for MCWRA.
Regional Water Quality Control Board, Central Coast Region, State Water Resources Control
Board, California Environmental Protection Agency, (RWQCB, 2011), Water Quality
Control Plan for the Central Coastal Basin, Dated June.
Regional Water Quality Control Board, Central Coast Region, Revised Waste Discharge
Requirements Order No. R3-2006-0017, Waste Discharger ID No. 3 270303001 for
Monterey Regional Waste Management District, Monterey Peninsula Class III Landfill
Monterey County.
Sobczynski, L., 2017, Comments on the Draft Environmental Impact Report/Draft Environmental
Impact Statement for the Proposed Monterey Peninsula Water Supply Project, letter from
the law firm of Adams Broadwell Joseph & Cardozo on behalf of California Unions for
Reliable Energy (CURE) to the California Public Utilities Commission and Monterey Bay
National Marine Sanctuary. March 28.
State Water Resources Control Board, 2013, Final Review of California American Water
Companys Monterey Peninsula Water Supply Project, 31 July, included as Appendix B2
to RDEIR.
ATTACHMENT 1 page 1
Review of the NMGWM 2016 Version
Figure 10.
Comparison of simulated drawdown in in the Dune Sand Aquifer (Layer 2) derived from the calibrated version of the
2016 version of the NMGWM (top) and the Superposition model (bottom).
GeoHydros 21 | P a g e
ATTACHMENT 1 page 2
Figure 11.
Comparison of simulated drawdown in in the 180-FT Aquifer (Layer 4) derived from the calibrated version of the
NMGWM-2016 (top) and the Superposition model (bottom).
ATTACHMENT 1 page 3
Figure 12.
Comparison of simulated drawdown in in the 400-FT Aquifer (Layer 6) derived from the calibrated version of the
NMGWM-2016 (top) and the Superposition model (bottom).
ATTACHMENT2
ArmstrongRanchlocation,flowarrows,andnotesaddedtoDRAFTFigure137fromAppendixE2ofDEIR
With project
pumping. Local
reversal of flow
direction toward
the coast.
Existing conditions. Inland flow

direction in coastal aquifers.
Armstrong Ranch
Armstrong Ranch is well beyond

extent of capture by the proposed
project pumping.
Monterey Peninsula Regional Water Authority Date: 2 Oct 2017
Agenda Report Item No: 2
FROM: Executive Director Cullem
SUBJECT: Receive Report and Discuss the Detailed MPWSP Schedule

Including Upcoming Permit Requirements and the Status of the
Test Slant Well and Installation of the Transfer Pipeline
RECOMMENDATION:
It is recommended that the Water Authority TAC receive a report from Cal
Am on the latest "Detailed" MPWSP schedule including upcoming permit
requirements and receive a report on the test well operation and Installation
of the Transfer Pipeline.
DISCUSSION:
Cal Am will present the most recent "Detailed" MPWSP schedule and the
status of test slant well operations. In addition, Cal Am will provide an
update on the installation of the Transfer Pipeline and any issues arising
from the pending closure of the CEMEX facility.
ATTACHMENTS:
None
06/12

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Agenda

Monterey Peninsula Regional Water Authority (MPRWA)

10:30 AM, Monday, October 2, 2017

REPORTS FROM TAC MEMBERS

***End of Consent Agenda***

FROM: Executive Director Cullem

3) GeoHydros Comments- all

4) EKI Comments- parag #5

For each comment on a groundwater/hydrogeologic impact or issue, Geosyntec was

1) it agreed with the comment/reasoning,

2) disagreed with the comment/reasoning and why, or

3) are uncertain as to the accuracy of the comment/reasoning and how greater

A- Revised Draft Geosyntec Report

DRAFT Technical Memorandum

Date: REVISED DRAFT 30 August 2017

Geosyntec Consultants (Geosyntec) was engaged by SPI Membrane Technology Consultants, to

3) GeoHydros Comments- all

4) EKI Comments- parag #5

REVISED DRAFT 30 Aug 2017 Review of MCWD Comments on RDEIR.docx

Updates to the NMGWM (NMGWM2016) include refinement of hydrostratigraphy and aquifer

Some of the comments address differences in hydostratigraphy represented in regional Salinas

REVIEW OF SECTIONS C.1 AND C.2 OF THE MCWD LETTER

California Coastal Commission, California Department of Conservation,

Seaside Groundwater Basin Watermaster,

water quality samples in 15 aquifer zone locations,

Comments on the model properties, design and calibration.

Comments that the superposition modeling is not appropriate.

Superposition modeling is a common method to evaluate impact of pumping (e.g. Arizona

Monitoring and Mitigation Measures

REVIEW OF HGC COMMENTS

4. Historical studies are sufficiently complete and comprehensive in nature to document

I defer to legal counsel on this issue.

HGC claims the degree of uncertainty in the groundwater modeling is intolerable.

REVIEW OF GEOHYDROS COMMENTS

Section 3. Superposition Model

Section 4. Evaluation of Potential Impacts

REVIEW OF COMMENTS BY EKI

REVIEW OF COMMENTS ON BEHALF OF CALIFORNIA UNIONS FOR RELIABLE

location of the submersible pump in the slant wells;

Geoscience, 8 July 2014, Technical Memorandum (TM1) Summary of Results Exploratory

Existing conditions. Inland flow

Armstrong Ranch is well beyond

FROM: Executive Director Cullem

SUBJECT: Receive Report and Discuss the Detailed MPWSP Schedule

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End of Consent Agenda