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y TIM        O'GARA. R.G.
                                                                                  CONSULTING     HYDROGEOLOGIST


             February 20,2012




             J. Patrick Lucas, President
             Lehman Hot Sprints LLC
             16004 SW Tualatin-Sherwood Rd.
             Sherwood, OR 97140        .




             Re: Lehman Springs Ground Water


             Patrick,

            My name is Tim.O''Gara. I am a Registered Geologist in Oregon, California, Idaho, and
            Washington, as well as a Licensed Hydrogeologist in Washington. I have specialized in
            ground water supply, flow and cleanup for over 30 years. I was asked to visit the
            Lehman Hot Springs site and make an evaluation on whether or not the treatment ponds
            at the site were potentially the source of two springs that were discovered by DEQ
            workers that working with the landowner at this site. One of the two springs in question
            is on the northwest side of the upper pond, between the upper and lower ponds. The
            other is near the bottom of the pond berm on the northeast side of the lower treatment
            pond .

           . Location:

            The site is located within the Wallowa-Whitman National Forest and the Umatilla
            national Forest. The site is located just south of Milepost 17 on Highway 244. The
            heated water used at the site is provided by 57 separate springs and are reported to
            produce a total of 185 gallons per minute. Figure 1 shows the site location.

            Geology/ground water flow

            According to USGS Water Resources Investigations Report 87-4238 Geologic
            Framework of the Columbia Plateau Aquifer System, Washington, Oregon, and Idaho,
            the site is underlain by the Grande Ronde Basalt. This basalt is known to be very fine
            grained and aphyritic. Also, sedimentary interbeds within the formation are rare.
            Potential strike/slip faulting has been mapped in the area of the hot springs. This faulting
            most likely allows the water to rise from deep within the formation up to the surface.

            Two water wells are on record at the Oregon Water Resources Department as being
            located at the hot springs. The main well (Umat 56003) was drilled in 2007 and is




24735 South Central Point Road'   Canby, Oregon 97013        Office 503.263.7852 • Cell 503.307.8916• Fax 503.266.5974
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     Source: USGS Topographic Map, 7.5-Minute Lehman Springs Quadrangle, 1967, Revised 1983 (Lat. 45° 9' 29.34" N, Long. 118° 39' 44.83" W)




                                                                                                                                                                    Figure 1
                                                                                                                                                                    Site Location
located on a bench to the northwest of the lodge. This well is 495 feet deep, and
encountered basalt at just 30 feet below grade.

The second well may belong to one of the cabins along WarmSprings Creek. It was
drilled in 2005, and is only 135 feet deep. This well encountered basalt at just 24 feet
below grade. It should be noted that the water temperature in the resort well was
measured at 62 degrees when it was originally drilled, and the other well was measured at
63 degrees. This is much lower than the temperature of the hot springs, which indicates
that the source of the hot springs water is different than the water bearing zones that were
tapped by these wells.

Soils at the site are generally a cobbly silt loam, and are quite thin on the hillsides,
usually less than a foot thick. The soils are up to 30 feet thick in the valleys and creek
bottoms between the slopes. Rainwater and snowmelt that lands on the soil percolates
through the soil to the relatively impermeable basalts and runs down hill along the top of
the basalt until it either reaches the valley floor or it "daylights" in the form of a spring on
the valley walls. Springs can also be forced to the surface by any obstruction to the
natural flow.

As an example, if the bedrock surface that the water is running along has a rise in it, the
water will take the path of least resistance and will move around the rise. In basalt
hillsides, there are normally preferential flow paths for subsurface water that are dictated
by the surface fluctuations of the basalt flow. All water in valley around the site tends to
flow down into the creek if that is possible. The creek is fed by water coming off the
slopes on both the east and west.

Potential Problem - Are treatment ponds leaking?

There have been numerous reports on the possible problems (all since fixed) concerning
the delivery system for wastewater to the treatment ponds from the resort. That has all
been well documented. The question at hand is whether or not the treatment ponds have
been leaking, and if not, what is the source of the small seeps and springs around the base
of the ponds the surrounding area. Figure 2 shows the locations of the springs in question.

Evidence for:

The main evidence is the continuing presence of seeps at the base of the upper pond and
also from the edge of the berm on the lower pond. To my knowledge, this water has not
been tested for e. coli, which would have been a reasonable thing to do, but DEQ
personnel have stated that it "looks like" it should be wastewater from the ponds
Apparently, the water from the Tree Seep, the hot springs, and the sewage lagoons was
tested for anions and cations to allow for the development of a Piper Diagram. The Piper
Diagrams are used to determine whether or not the waters are from the same source. The
assumption by DEQ personnel is that the water in the seep is a mixture of hot spring
water and sewage water.
Figure 2
Location of Springs
Evidence against:

A piper diagram was used to compare the water quality from the faucet and spring box,
the "tree seep" the sewage lagoons, and the hot springs. The faucet water comes from a
spring that is located ~ mile upstream from the hot springs area. Water is piped to a
holding tank: that holds 30,000 gallons. The "tree seep" is located on the west side of
Warm Springs Creek, about 20 feet from the creek.

The diagrams also show that the sewage lagoons and the hot springs are separate sources
that are not similar water. The assertion that the tree seep is 85% faucet and 15% upper
lagoon is highly suspect. The same goes for the anion diagram. It clearly shows that the
tree seep is not the same water as the treatment lagoons.

Also, there has been no conclusive evidence that the seeps and springs are contaminated.
The seep water looks like the faucet and spring box water in the Piper Diagram. There is
no indication that the ponds have contributed to the water.

At one time, there was an assertion that up to 21,000 gallons of water were coming from
the spring at the base ofthe upper pond. This would be enough to fill a 55 gallon drum in
just 3.8 minutes. The video clip I have seen showing the seep looked more like 1-2 gpm.
If there had been a 14 gpm flow out of the seep, it would have eroded the top of the berm
between ponds much more than is evident. Additionally, if21,000 gallons of water was
leaking from ponds, the water level in the pond would be dropping to the point where it
could be noticed over a week or so.

No drop in the ponds was seen. It should be noted that the EPA did a dye study of the
upper lagoon and since no dye was found in the spring, it was concluded that it was really
ground water.

 Evaporation testing was completed on the pond using evaporation pans that were
floating in the pond. This showed that the minimal drop in pond elevation was
completely from evaporation. During the period when the evaporation testing was being
completed, very precise water levels in the pond and the evaporation pans were taken.
The result showed that the ponds were not leaking. Evaporation data is included as
Appendix A

One of the springs in question, at the bottom of the berm separating the upper and lower
treatment lagoon, was tested in 2009. The results of this testing showed 83 total
coliform, but less than 1 e.coli./l00 mls in the lower pond. A water sample from the
upper pond showed e. coli at 866.4 e. coli /100 mls. Lab data is included as Appendix B

In July of2006, a series of soil samples were collected by Evem Northwest from the area
near the Tree seep. These samples were analyzed for e. Coli bacterial and all were found
to be non-detect.
The liner has been tested and found to be solid, this would eliminate leakage.
Additionally, the pond has been completely drained and a detailed inspection of the liner
showed it to be intact. The liner was placed on soil that had been compacted prior to the
installation ofthe liner. Appendix C shows the installation of the liner.

After the ponds were drained in April of2009, a large "bubble" of water was found to
have pushed the bottom of the liner up from the compacted base soils. It appears that
water had entered between the compacted soils and the bottom of the liner during high
water from the previous winter. The high water was most likely caused by ponding along
the edges of the liner which percolated down between the liner and the compacted soil.
Figure 3 shows the water over the edge of the liner in the Spring of 2008.

This is important, because if the water was seeping into the soil from below, it would
have percolated out as the local water table dropped during the late spring. Instead, since
the bottom of the lagoon was essentially water tight, and the liner was not leaking, the
water remained until the liner was eventually cut to let it out. The puncture was later
repaired.

Potential spring sources - The two springs that are in question as possible "leaks" from
the treatment ponds are at the base of the upper pond and again at the base of the lower
pond. The ponds are constructed of compacted soils, most likely with a permeability of
 10-4 em/see or less, and are much less permeable than the surrounding soils. Any water
coming off the hillside and encountering the well-compacted pond walls would be
expected to take the path of least resistance and move around the side of the pond until it
could continue its journey down hill to the creek. In some cases, the water would
"daylight" when it ponded up against the treatment pond walls. The fact that the
treatment ponds are lined would only make this scenario more likely.

It should be noted that the vegetation on both sides of the creek are the same. If the
ponds were leaking, there would most likely be enhanced growth on the pond side of the
creek due to the additional nutrients that would be coming                             ,

E.Coli testing ofthe ponds by the Benton-Franklin Health District found 866.4 e.
colillOO ml in the upper pond, 43.5 in the lower pond, and just 8.4 in the seeps. The
exact location of the seep that was used for the testing was not shown.

Discussion/Conclusion:

The ponds were installed using compacted soil with a thick liner. The liner has been
tested and shown to be solid and not leaking. This included dye tests while the ponds
were filled and a visual testing after the ponds were emptied.

Evaporation pan testing has shown that the evaporation rate of the ponds matches what
should be expected given the conditions at the site. The test concluded that the ponds
were not leaking.
The seeps that were assumed by the DEQ to be sewage leaking form the ponds were
never tested for e.coli bacteria. They were just "assumed" to be leakage from the ponds.

After dye testing the upper pond, the EP A determined that the seep on the berm between
the ponds was not from pond water.

A seep along the bottom of the berm of the sewage ponds was tested by the Health
Department. That testing determined that the source of the seep was not sewage from the
treatment ponds.

In conclusion, it appears that the assumption that the treatment lagoons were leaking is
based on the location of the seeps, and not on hard data. To my knowledge, no e. coli
testing of the seeps were taken except by the Health Department, and that showed that the
ponds were NOT leaking.

Based on my 31 years of experience concerning ground water issues, along with a site
visit and a review of the evidence that I have reviewed, I do not believe that either of the
treatment lagoons at the Lehman hot Springs Resort are leaking and are the source of the
springs that were detected around them.

Respectfully, Submitted



£$
Tim O'Gara, R.G
Appendix A
Evaporation Pan Data
LEHMAN HOT SPRINGS
                            SEWER LAGOON LEAK STUDY


Need:
This study is performed   at the request of Patrick Lucas, President of Lehman
Development Corporation.

Purpose:
The purpose of this study is to determine ifthere is significant leakage from ether the
existing primary or secondary wastewater treatment lagoons. For the purposes of this
study, the primary lagoon will be referred to as the "upper pond", and tbe secondary
lagoon will be referred to as the "lower pond".

Conditions:
   •    The test period is conducted ftom. mid..day on May 27~through mid-day on June
        3, 2009, or a period of 6 full days.

   •    There is no measurable precipitation through the test period.

   •    Temperature is near or approximately normal. with high temperatures in the 70s'
        and lows in the 4Os'

   •    Wind and Humidity are approximately normal for this time of year with.no
        extremes.

   •    There is!!!. inflow to the lagoon system during the test period.

   •    Each Lagoon (pond) is hydraulically isolated.
Q6/1~/2009     15:04 FAX    54'.932.4430            FERGUSON-SURVEYING




             Methodology;

             Leakage is determined as based monitoring the water surface levels in each pond.
             Evaporation and precipitation are determined by floating standard, circular 47.S"x 10"
             evaporation pans in each pond. As stated previously, there was no precipitation during
             the test period, therefore only evaporation was accounted for.

             Evaporation is determined by measuring the water level of the pan at the begjnning of the
             test period then again at the end. Evaporation conditions are maintained as near to those
             in each pond by actually floating the evaporation pans in the pond on which evaporation
             is to be determined. (Temperature, wind, and humidity). In order to account for normal
             pan eVaporation being normally less than pond evaporation, a factor of O.7S is applied to
             the pan measurements.

             Leakage is then determined by comparing the pond water surface di1ference with the pan
             water surface difference. Pond surface difference more than pan. surface difference is
             Ieakage, It should be noted that "Oregon Department of Environmental Quality"
             Guidelines for estimating leakage from existing sewage lagoons, considers IISn per day
             or less to be normal.

             Raw Data as Measored in the Field

                      UPPER POND                                  LOWER. POND
                                     Begin Test May 27. 2009 @ 12:30 P.M.
             Evaporation Pan Depth = 0.39'               -     Evaporation Pan Depth = 0.35'
             Water Surface Elevation == 98.76'                Water Surface Elevation = 91.62'


              Change in Pan Surface = 0.08 7
                                                                          in
                                                                 Change Pan Surface = O.OS'
             Change in Pond Surface - 0.06'                     Change in Pond Surface = 0.06'

                                     End Test June 3, 2009, @ 11:30 A.M
             Evaporation Pan Depth "'" 0.31'                   Evaporation Pan Depth = 0.27'
             Water Surface Elevation = 98.70'                 Water Surface Elevation =- 91.56'
~S/t1/2009 15:04 FAX   541+932+4430             FERGUSON-SURVEVING




         Leakage:

         Upper Pond Leakage = 0.06' - 0.15(0.08') = 0
         Lower Pond Leakage = 0.06'- 0.75(0.08') = 0

         Over a 6 day period this is a pond drop of l/S" per day and an identical pan drop of 1/8"
         per day in each pond.

         It should be pointed. out that, a CQmpilationof "Oregon Evaporation Station Averages"
         taken in Ukiah (15 miles to the west) provide the following:

         Average Evaporation in May @ 3.S3 •• and Average Evaporation in June @ 4.3Stt

         This provides an average monthly evaporation for the study period. of 3.83", or lIS" per
         day as determined above.

         Cond1lSion:

         Within the scope and precision of this study or the "Oregon Department of
         EnWonmental Quality" Guidelines for estimating leakage from existing sewage
         lagoons". There jg No Signiftesnt Leakage From Ether Pond.

         BY:
         Douglas M. Ferguson, P.E.~P.L.S.
         President
         Ferguson Surveying & Engineering




                                   .,:;-.-
Appendix B
Pond/Spring Lab Data
at221l
                                                                                  "-:!    32'
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                                                                                                                            .Seep at
                                                                                                                          .i' toe of upper lagoon


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                                           7102 W. Ok011OgOnPlo(9 • Kennewidc, WA            99336   • !'bon&:   15091 A6Q..4200



                                                                         April 15~2009

                     Rob Grandinetti
                     EPA Region 10
                     309 Bradley Blvd. Suite 115.
                     Ri~WA           99352

                     Deat Mr. Grandinetti:

                     The following results are from samples submitted to our laboratory for analysis on April
                     10,2009. All analysis were performed using methods outlined in Standard Methods for
                     the Examination of Water and Wastewater, 20th edition.          If you need additional
                     information regarding these methods or results please contact David ~iIler at (509) 460-
                     4206.




                     NOTE:

                                                                                       Sincerely,

                                                                                       .!2.tJ£~
                                                                                       David E. Miller
                                                                                       Laboratory Supervisor




    ~NVJP.ONMEN1Al   HEALTH   COf>.'VUNITYtlEI'Litl ClONTERS
                              0412 w.. Cbri: Sfreet         Q 310 7th 5Iseet
                                P~"""'99301                   Ptouer, WA 99350
                                !'hens: ~    547-9737         Phone: (5OPI7I6o-16:13
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                                                                                                                                                           Ill!":,           Public Water supplies
                                                                                                                                                                                                                                 
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                                                   Month    /     Day             Year               Hour          Min
                 ORELAP
                 Method(s):              1ij] SM 9223 rgn Colilert                     Quantitray                  D Other                                                                                                                  I'
                 Check all that apply.                                                                                              -----------                                                                                             I
-1 ~.;;~iS                    Complete Oalemme
                                                                Month 1 Day 1 Year                     Hour Min                              Analyst            Reviewer                                     signatf

      I
      I
             Raw Results                         Total Coliform                              E.coli                       Final Results                                                                                                     I
      i      # Large Wells Positive                    $~                                       0                        Total Coliform                                                       ~4               MPN 1100 mls                 r
     I
     I
             # Small Wells Positive                         7                                   {)                        E.Coli                                                             <                MPN 1100 mls                 Iit
     I       MPN 1100 mls                                  p I~(,                           .c::.
     !
                                                                                       -
                                                                                                                                                                                                                                            II
                  g      Fax Results
                         Emsil Results

                   o Call Results
                                                  Fax #
                                                  Address

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                                                                                                                                              Completed           ============-_~l!l
                                                                                                                                                                                                                                            If

                                                                                                                                                                                                                                            It


               Test results relate only to the parameters tested and to the samples as received by the laboratory. Test results meet all requirements of
                   NELAC unless otherwise noted. This report shall not be reproduced, except in full, without written consent of this laboratory.
Appendix C
Liner installation Photos
Lehman Hot Springs Hydrology Report
Lehman Hot Springs Hydrology Report
Lehman Hot Springs Hydrology Report
Lehman Hot Springs Hydrology Report

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Lehman Hot Springs Hydrology Report

  • 1. y TIM O'GARA. R.G. CONSULTING HYDROGEOLOGIST February 20,2012 J. Patrick Lucas, President Lehman Hot Sprints LLC 16004 SW Tualatin-Sherwood Rd. Sherwood, OR 97140 . Re: Lehman Springs Ground Water Patrick, My name is Tim.O''Gara. I am a Registered Geologist in Oregon, California, Idaho, and Washington, as well as a Licensed Hydrogeologist in Washington. I have specialized in ground water supply, flow and cleanup for over 30 years. I was asked to visit the Lehman Hot Springs site and make an evaluation on whether or not the treatment ponds at the site were potentially the source of two springs that were discovered by DEQ workers that working with the landowner at this site. One of the two springs in question is on the northwest side of the upper pond, between the upper and lower ponds. The other is near the bottom of the pond berm on the northeast side of the lower treatment pond . . Location: The site is located within the Wallowa-Whitman National Forest and the Umatilla national Forest. The site is located just south of Milepost 17 on Highway 244. The heated water used at the site is provided by 57 separate springs and are reported to produce a total of 185 gallons per minute. Figure 1 shows the site location. Geology/ground water flow According to USGS Water Resources Investigations Report 87-4238 Geologic Framework of the Columbia Plateau Aquifer System, Washington, Oregon, and Idaho, the site is underlain by the Grande Ronde Basalt. This basalt is known to be very fine grained and aphyritic. Also, sedimentary interbeds within the formation are rare. Potential strike/slip faulting has been mapped in the area of the hot springs. This faulting most likely allows the water to rise from deep within the formation up to the surface. Two water wells are on record at the Oregon Water Resources Department as being located at the hot springs. The main well (Umat 56003) was drilled in 2007 and is 24735 South Central Point Road' Canby, Oregon 97013 Office 503.263.7852 • Cell 503.307.8916• Fax 503.266.5974
  • 2. »r ~. 1 :'.' t~ •••• j ; -- ' ;,... "'~ ". ~ -. ••.. l , .. , F 0 It i~ T J t ,., I>;" -:;. ... ) ,4... ...,.#. ..- J ,'" '" -.. ./ Iff' i -' / -.'-~-----.--- . • ,.• _ .'1. "":-I· - ~ ...;----~- --;:-,- I. " ! ...---L-= ~1 _ • .. ~- / •• ,1 I .•••• "~ •• 1~~ ,:".---. --, -, .,:: c' .. f'''- - . v' _ , II • -". tooW; •• -, /~~~i '-I /: -e- ~)->. , ... i ~ ( I l •••. __ '; ';: l ~ 11 "'"__ Source: USGS Topographic Map, 7.5-Minute Lehman Springs Quadrangle, 1967, Revised 1983 (Lat. 45° 9' 29.34" N, Long. 118° 39' 44.83" W) Figure 1 Site Location
  • 3. located on a bench to the northwest of the lodge. This well is 495 feet deep, and encountered basalt at just 30 feet below grade. The second well may belong to one of the cabins along WarmSprings Creek. It was drilled in 2005, and is only 135 feet deep. This well encountered basalt at just 24 feet below grade. It should be noted that the water temperature in the resort well was measured at 62 degrees when it was originally drilled, and the other well was measured at 63 degrees. This is much lower than the temperature of the hot springs, which indicates that the source of the hot springs water is different than the water bearing zones that were tapped by these wells. Soils at the site are generally a cobbly silt loam, and are quite thin on the hillsides, usually less than a foot thick. The soils are up to 30 feet thick in the valleys and creek bottoms between the slopes. Rainwater and snowmelt that lands on the soil percolates through the soil to the relatively impermeable basalts and runs down hill along the top of the basalt until it either reaches the valley floor or it "daylights" in the form of a spring on the valley walls. Springs can also be forced to the surface by any obstruction to the natural flow. As an example, if the bedrock surface that the water is running along has a rise in it, the water will take the path of least resistance and will move around the rise. In basalt hillsides, there are normally preferential flow paths for subsurface water that are dictated by the surface fluctuations of the basalt flow. All water in valley around the site tends to flow down into the creek if that is possible. The creek is fed by water coming off the slopes on both the east and west. Potential Problem - Are treatment ponds leaking? There have been numerous reports on the possible problems (all since fixed) concerning the delivery system for wastewater to the treatment ponds from the resort. That has all been well documented. The question at hand is whether or not the treatment ponds have been leaking, and if not, what is the source of the small seeps and springs around the base of the ponds the surrounding area. Figure 2 shows the locations of the springs in question. Evidence for: The main evidence is the continuing presence of seeps at the base of the upper pond and also from the edge of the berm on the lower pond. To my knowledge, this water has not been tested for e. coli, which would have been a reasonable thing to do, but DEQ personnel have stated that it "looks like" it should be wastewater from the ponds Apparently, the water from the Tree Seep, the hot springs, and the sewage lagoons was tested for anions and cations to allow for the development of a Piper Diagram. The Piper Diagrams are used to determine whether or not the waters are from the same source. The assumption by DEQ personnel is that the water in the seep is a mixture of hot spring water and sewage water.
  • 5. Evidence against: A piper diagram was used to compare the water quality from the faucet and spring box, the "tree seep" the sewage lagoons, and the hot springs. The faucet water comes from a spring that is located ~ mile upstream from the hot springs area. Water is piped to a holding tank: that holds 30,000 gallons. The "tree seep" is located on the west side of Warm Springs Creek, about 20 feet from the creek. The diagrams also show that the sewage lagoons and the hot springs are separate sources that are not similar water. The assertion that the tree seep is 85% faucet and 15% upper lagoon is highly suspect. The same goes for the anion diagram. It clearly shows that the tree seep is not the same water as the treatment lagoons. Also, there has been no conclusive evidence that the seeps and springs are contaminated. The seep water looks like the faucet and spring box water in the Piper Diagram. There is no indication that the ponds have contributed to the water. At one time, there was an assertion that up to 21,000 gallons of water were coming from the spring at the base ofthe upper pond. This would be enough to fill a 55 gallon drum in just 3.8 minutes. The video clip I have seen showing the seep looked more like 1-2 gpm. If there had been a 14 gpm flow out of the seep, it would have eroded the top of the berm between ponds much more than is evident. Additionally, if21,000 gallons of water was leaking from ponds, the water level in the pond would be dropping to the point where it could be noticed over a week or so. No drop in the ponds was seen. It should be noted that the EPA did a dye study of the upper lagoon and since no dye was found in the spring, it was concluded that it was really ground water. Evaporation testing was completed on the pond using evaporation pans that were floating in the pond. This showed that the minimal drop in pond elevation was completely from evaporation. During the period when the evaporation testing was being completed, very precise water levels in the pond and the evaporation pans were taken. The result showed that the ponds were not leaking. Evaporation data is included as Appendix A One of the springs in question, at the bottom of the berm separating the upper and lower treatment lagoon, was tested in 2009. The results of this testing showed 83 total coliform, but less than 1 e.coli./l00 mls in the lower pond. A water sample from the upper pond showed e. coli at 866.4 e. coli /100 mls. Lab data is included as Appendix B In July of2006, a series of soil samples were collected by Evem Northwest from the area near the Tree seep. These samples were analyzed for e. Coli bacterial and all were found to be non-detect.
  • 6. The liner has been tested and found to be solid, this would eliminate leakage. Additionally, the pond has been completely drained and a detailed inspection of the liner showed it to be intact. The liner was placed on soil that had been compacted prior to the installation ofthe liner. Appendix C shows the installation of the liner. After the ponds were drained in April of2009, a large "bubble" of water was found to have pushed the bottom of the liner up from the compacted base soils. It appears that water had entered between the compacted soils and the bottom of the liner during high water from the previous winter. The high water was most likely caused by ponding along the edges of the liner which percolated down between the liner and the compacted soil. Figure 3 shows the water over the edge of the liner in the Spring of 2008. This is important, because if the water was seeping into the soil from below, it would have percolated out as the local water table dropped during the late spring. Instead, since the bottom of the lagoon was essentially water tight, and the liner was not leaking, the water remained until the liner was eventually cut to let it out. The puncture was later repaired. Potential spring sources - The two springs that are in question as possible "leaks" from the treatment ponds are at the base of the upper pond and again at the base of the lower pond. The ponds are constructed of compacted soils, most likely with a permeability of 10-4 em/see or less, and are much less permeable than the surrounding soils. Any water coming off the hillside and encountering the well-compacted pond walls would be expected to take the path of least resistance and move around the side of the pond until it could continue its journey down hill to the creek. In some cases, the water would "daylight" when it ponded up against the treatment pond walls. The fact that the treatment ponds are lined would only make this scenario more likely. It should be noted that the vegetation on both sides of the creek are the same. If the ponds were leaking, there would most likely be enhanced growth on the pond side of the creek due to the additional nutrients that would be coming , E.Coli testing ofthe ponds by the Benton-Franklin Health District found 866.4 e. colillOO ml in the upper pond, 43.5 in the lower pond, and just 8.4 in the seeps. The exact location of the seep that was used for the testing was not shown. Discussion/Conclusion: The ponds were installed using compacted soil with a thick liner. The liner has been tested and shown to be solid and not leaking. This included dye tests while the ponds were filled and a visual testing after the ponds were emptied. Evaporation pan testing has shown that the evaporation rate of the ponds matches what should be expected given the conditions at the site. The test concluded that the ponds were not leaking.
  • 7.
  • 8. The seeps that were assumed by the DEQ to be sewage leaking form the ponds were never tested for e.coli bacteria. They were just "assumed" to be leakage from the ponds. After dye testing the upper pond, the EP A determined that the seep on the berm between the ponds was not from pond water. A seep along the bottom of the berm of the sewage ponds was tested by the Health Department. That testing determined that the source of the seep was not sewage from the treatment ponds. In conclusion, it appears that the assumption that the treatment lagoons were leaking is based on the location of the seeps, and not on hard data. To my knowledge, no e. coli testing of the seeps were taken except by the Health Department, and that showed that the ponds were NOT leaking. Based on my 31 years of experience concerning ground water issues, along with a site visit and a review of the evidence that I have reviewed, I do not believe that either of the treatment lagoons at the Lehman hot Springs Resort are leaking and are the source of the springs that were detected around them. Respectfully, Submitted £$ Tim O'Gara, R.G
  • 10. LEHMAN HOT SPRINGS SEWER LAGOON LEAK STUDY Need: This study is performed at the request of Patrick Lucas, President of Lehman Development Corporation. Purpose: The purpose of this study is to determine ifthere is significant leakage from ether the existing primary or secondary wastewater treatment lagoons. For the purposes of this study, the primary lagoon will be referred to as the "upper pond", and tbe secondary lagoon will be referred to as the "lower pond". Conditions: • The test period is conducted ftom. mid..day on May 27~through mid-day on June 3, 2009, or a period of 6 full days. • There is no measurable precipitation through the test period. • Temperature is near or approximately normal. with high temperatures in the 70s' and lows in the 4Os' • Wind and Humidity are approximately normal for this time of year with.no extremes. • There is!!!. inflow to the lagoon system during the test period. • Each Lagoon (pond) is hydraulically isolated.
  • 11. Q6/1~/2009 15:04 FAX 54'.932.4430 FERGUSON-SURVEYING Methodology; Leakage is determined as based monitoring the water surface levels in each pond. Evaporation and precipitation are determined by floating standard, circular 47.S"x 10" evaporation pans in each pond. As stated previously, there was no precipitation during the test period, therefore only evaporation was accounted for. Evaporation is determined by measuring the water level of the pan at the begjnning of the test period then again at the end. Evaporation conditions are maintained as near to those in each pond by actually floating the evaporation pans in the pond on which evaporation is to be determined. (Temperature, wind, and humidity). In order to account for normal pan eVaporation being normally less than pond evaporation, a factor of O.7S is applied to the pan measurements. Leakage is then determined by comparing the pond water surface di1ference with the pan water surface difference. Pond surface difference more than pan. surface difference is Ieakage, It should be noted that "Oregon Department of Environmental Quality" Guidelines for estimating leakage from existing sewage lagoons, considers IISn per day or less to be normal. Raw Data as Measored in the Field UPPER POND LOWER. POND Begin Test May 27. 2009 @ 12:30 P.M. Evaporation Pan Depth = 0.39' - Evaporation Pan Depth = 0.35' Water Surface Elevation == 98.76' Water Surface Elevation = 91.62' Change in Pan Surface = 0.08 7 in Change Pan Surface = O.OS' Change in Pond Surface - 0.06' Change in Pond Surface = 0.06' End Test June 3, 2009, @ 11:30 A.M Evaporation Pan Depth "'" 0.31' Evaporation Pan Depth = 0.27' Water Surface Elevation = 98.70' Water Surface Elevation =- 91.56'
  • 12. ~S/t1/2009 15:04 FAX 541+932+4430 FERGUSON-SURVEVING Leakage: Upper Pond Leakage = 0.06' - 0.15(0.08') = 0 Lower Pond Leakage = 0.06'- 0.75(0.08') = 0 Over a 6 day period this is a pond drop of l/S" per day and an identical pan drop of 1/8" per day in each pond. It should be pointed. out that, a CQmpilationof "Oregon Evaporation Station Averages" taken in Ukiah (15 miles to the west) provide the following: Average Evaporation in May @ 3.S3 •• and Average Evaporation in June @ 4.3Stt This provides an average monthly evaporation for the study period. of 3.83", or lIS" per day as determined above. Cond1lSion: Within the scope and precision of this study or the "Oregon Department of EnWonmental Quality" Guidelines for estimating leakage from existing sewage lagoons". There jg No Signiftesnt Leakage From Ether Pond. BY: Douglas M. Ferguson, P.E.~P.L.S. President Ferguson Surveying & Engineering .,:;-.-
  • 14. at221l "-:! 32' --- .Seep at .i' toe of upper lagoon ll.0 ~g.,g,323 ~ 1 IV . uMFt·.~n ". l~~ SCALE I" = 30' ~,!,""41!44441· .....-:. CQNtooR ~T'[It""'l • 1 FT ASSUMED WYAnON lliilliQ o PONOUN[II P'C PIPE AS N01EO ~FEt4CE A CONTROL POINT 970 ELEVATION CONTCliR "0 _____ LINE: or SIeHl ClOs(O LOOP TRAVERSE: TO/Lodge ~ i SURVEY HAN~rY ENGINEERING BY 101.1 tWoIlEY. PLS la17 P.O.90X1Cll i 2Q4JIMINSTREE:T BAJ(ERClTY,OR91814 (541) 523-3803 alN1RCI. POINTS SURVEY FOR PoI1'ItNo. Northin9(Y) CA$CAOEEARlliSCIE~ES I EoaLinQ(X) [I • .,,(Z) OescrLpllOl'l , I i806.124 9921.102 ,!:1259.212 l!}o9B.050 i63,'20 9~.J&O 5/8."", OPe (lrUI.Qbr.lplk. AnN: OOUGLA5 R. WAto'TA '07 ISLANO AV'ENUE lACRMI>f:. OR 978~ ~ . 9832.664 10744.148 9~9.490 1!.~led br. -.pile. 9685.911 ,ooe.s.:!12 960.670 (5.')~3-7758 QrUllClb',IIP'k, , s ae g3&4..•• 9J8~.606 10857.442 IO~36.!>73 978.050 1000.OOll drlll,db •. lplki 5/8.ebarOPC -------~ 0891.200 10549.346 959.580 5/8 ret>at ope ~1~~;(6 ~OlE AERIAL. PHOTOGRAPHY ASSlJIdEO ElEVAllON ~EYPERFORI.tEO 1JSjN{) A PEltlTrI.X 1~-10 tOTAL srA1X)H.
  • 15. J % 7102 W. Ok011OgOnPlo(9 • Kennewidc, WA 99336 • !'bon&: 15091 A6Q..4200 April 15~2009 Rob Grandinetti EPA Region 10 309 Bradley Blvd. Suite 115. Ri~WA 99352 Deat Mr. Grandinetti: The following results are from samples submitted to our laboratory for analysis on April 10,2009. All analysis were performed using methods outlined in Standard Methods for the Examination of Water and Wastewater, 20th edition. If you need additional information regarding these methods or results please contact David ~iIler at (509) 460- 4206. NOTE: Sincerely, .!2.tJ£~ David E. Miller Laboratory Supervisor ~NVJP.ONMEN1Al HEALTH COf>.'VUNITYtlEI'Litl ClONTERS 0412 w.. Cbri: Sfreet Q 310 7th 5Iseet P~"""'99301 Ptouer, WA 99350 !'hens: ~ 547-9737 Phone: (5OPI7I6o-16:13
  • 16. I ..,----. 1 I YnH' ,S MICROBIOLOGICAL ANALYSIS Ill!":, Public Water supplies i (il ~,:::~reLehVht0nrfo+ Spri t:i S II!; I LE7 Dn::::::~:o~:: 419 SW 5th Street I '1 Address: Ii :,'1' Pendleton, Oregon 97801 II u 5412760385 II City, State, Zip: ,¢f F 5412762041 il U-.. Phone: ~If J n 3D i5 SSC?3 j..J.::q,7: ?!?JfL customerse~~ices@pendletonLab.com b=~.J:'t:~ :'T;g-:::/;:::~~=F=ax=:~.~~-if-~~t-~'T~~~~,~==.~=_ ...JI =~~ __ ORI00058 I Report Address Ii II Name: ------------------ Ii QUANTITATIVECOLIFORMANALYSIS II Address: I Bottle Lot #: V- 0, 0 ~'z.. I~' State, Zip: __~b -=--_-..__-._ Sample 10#: _C):...-"..!.-=-O~CP~I:...::J..::..-!f.::L?-.::::::"'- __ . -_ I Ir- Sample Collection Date/Time: (J ~ 1 I '2.. I ~ 0 ~ : '3 <) rzr AM I II ~ ---o;y Year Hour ~ D PM II! i Collected By: ~ '" t~ _ D""~ II Sample Point: to~ of Vi ~ ~(r 19'')':~)Y --n ,I 'I If~ddress,~ I, !,I PWS#: I rinil 411 (Water Districts Only) II .1 Ii Sample Type: D Waste Water II I II Source Water 0 Flowing Stream D Reservoir / Lake 'J3J Other (specify) _L..:...o.::.....,':)~C>.:...t>_YJ-'-____ I L ----- -- .__ d Sample Received DatelTime: 0<0 Month / f:>.. Day / b~ Year CJ~ Hour :'-1-( Min ~AM DPM Initials: ~ Temp: 't °C - I Analysis Start DatelTime: 0 (; 1'2.. 0<1 ~ Ljo ~AM DPM Initials: C- I / I! Month / Day Year Hour Min ORELAP Method(s): 1ij] SM 9223 rgn Colilert Quantitray D Other I' Check all that apply. ----------- I -1 ~.;;~iS Complete Oalemme Month 1 Day 1 Year Hour Min Analyst Reviewer signatf I I Raw Results Total Coliform E.coli Final Results I i # Large Wells Positive $~ 0 Total Coliform ~4 MPN 1100 mls r I I # Small Wells Positive 7 {) E.Coli < MPN 1100 mls Iit I MPN 1100 mls p I~(, .c::. ! - II g Fax Results Emsil Results o Call Results Fax # Address P_h_o_ne_# E,,J3':: ~S'tl =r:1 2-11 -"ti7J @ 'k? rli <Corn leted com:leted Completed ============-_~l!l If It Test results relate only to the parameters tested and to the samples as received by the laboratory. Test results meet all requirements of NELAC unless otherwise noted. This report shall not be reproduced, except in full, without written consent of this laboratory.