Water_Right_Application
DRAFT REPORT OF EXAMINATION FOR WATER RIGHT APPLICATION
STATE OF WASHINGTON
FINAL
REPORT OF EXAMINATION
FOR WATER RIGHT APPLICATION
WR Doc ID 6802694
PRIORITY DATE WATER RIGHT APPLICATION NUMBER
January 24, 2020 G2-30759
NAME AND MAILING ADDRESS SITE ADDRESS (IF DIFFERENT)
YMCA of Greater Seattle
909 4th Ave
Seattle, WA 98104
Total Rate and Quantity Authorized for Withdrawal
WITHDRAWAL RATE (gpm) ANNUAL QUANTITY (ac-ft/yr)
100 17.75
gpm = Gallons per Minute; ac-ft/yr = Acre-feet per Year
Purpose(s)
PURPOSE
WITHDRAWAL RATE (gpm) ANNUAL QUANTITY (ac-ft/yr)
PERIOD OF USE ADDITIVE NON-ADDITIVE ADDITIVE NON-ADDITIVE
Domestic Supply 100 16 1/1 – 12/31
Irrigation 100 1.75 5/15 – 9/15
IRRIGATED ACRES PUBLIC WATER SYSTEM INFORMATION
ADDITIVE NON-ADDITIVE WATER SYSTEM NAME and ID CONNECTIONS
1 TBD TBD
SPECIAL REMARKS:
Because of the capital costs and complex funding strategies for a camp of this scale, Camp Mineral Lake
will be phased over a period of up to 20 years. The proposed buildout schedule is presented in Table 2.
Source Location
COUNTY WATERBODY TRIBUTARY TO WATER RESOURCE INVENTORY AREA
Lewis Groundwater N/A 11
SOURCE NAME PARCEL WELL TAG TOWNSHIP RANGE SECTION QQ Q LATITUDE LONGITUDE
Well 1 038931011002 BBN 866 14 N 05 E 04 NW NE 46.731884 -122.178019
Well 2 038931011002 TBD 14 N 05 E 04 NW NE TBD TBD
Well 3 TBD TBD 14 N 05 E 05 S ½
NW TBD TBD
QQ Q = Quarter Quarter Datum: NAD83/WGS84
DRAFT REPORT OF EXAMINATION 2 G2-30759
Place of Use
LEGAL DESCRIPTION OF THE AUTHORIZED PLACE OF USE
LOTS 1 THROUGH 33, INCLUSIVE OF TRACTS A, B and C of SEGREGATION SURVEY, RECORDED JUNE 7,
2012, UNDER AUDITOR’S FILE No. 3379875, IN VOLUME 28 OF SURVEYS, PAGE 219, AS AMENDED BY
SURVEY RECORDED JUNE 22, 2012 UNDER AUDITOR’S FILE NO. 3380676 IN VOLUME 28 OF SURVEYS,
PAGE 224, RECORDS OF LEWIS COUNTY, WASHINGTON, BEING LOCATED WITHIN SECTIONS 2, 3, 4 AND
10, TOWNSHIP 14 NORTH, RANGE 5 EAST, W.M., AND SECTIONS 26, 27, 28, 33, 34 and 35, TOWNSHIP
15 NORTH, RANGE 5 EAST, W.M., LEWIS COUNTY, WASHINGTON.
Proposed Works
Well 1 (BBN-866) is 249 feet deep and is completed in a fractured bedrock aquifer. A 6-inch-diameter
steel casing extends from the surface to 54 feet below ground surface (bgs). A 4-inch-diameter PVC
liner was installed from 29 to 249 feet bgs with perforations between 239 and 249 feet bgs.
Development Schedule
BEGIN PROJECT BY THIS DATE COMPLETE PROJECT BY THIS DATE PUT WATER TO FULL USE BY THIS DATE
Started September 1, 2032 September 1, 2042
Attention: These dates represent deadlines that must be met or risk cancellation of this authorization.
Submittal of formal documentation for each stage is required. Extensions may be requested.
Measurement of Water
HOW OFTEN MUST WATER USE BE MEASURED AND RECORDED? Monthly
HOW OFTEN MUST WATER USE DATA BE REPORTED TO ECOLOGY? Annually by January 31
WHAT QUANTITY SHOULD BE REPORTED? Total annual quantity in acre-feet
WHAT RATE SHOULD BE REPORTED? Annual peak rate of withdrawal in gpm
Provisions
Progress Reports
The permittee is required to provide Ecology progress reports every five (5) years beginning November
1, 2022. Progress reports will consist of describing efforts made on project in the previous five (5) year
period and if the project is progressing on schedule. Any changes in point of contact must also be
updated.
Measurements, Monitoring, Metering, and Reporting
An approved measuring device must be installed and maintained for each of the sources identified by
this water right in accordance with the rule “Requirements for Measuring and Reporting Water Use”,
chapter 173-173 WAC, which describes the requirements for data accuracy, device installation and
operation, and information reporting. It also allows a water user to petition the Department of Ecology
(Ecology) for modifications to some of the requirements.
Water allocations for domestic supply and irrigation will need to be metered separately.
DRAFT REPORT OF EXAMINATION 3 G2-30759
Recorded water use data shall be submitted electronically by January 31 each year. To set up an Internet
reporting account, contact the Southwest Regional Office. If you do not have Internet access, you can
still submit hard copies by contacting the Southwest Regional Office for forms to submit your water use
data.
Proof of Appropriation
Consistent with the development schedule given in this report (unless extended by Ecology), the water
right holder must file a Notice of Proof of Appropriation (PA) of Water with Ecology. The PA documents
the project is complete and all the water needed has been put to full beneficial use (perfected). In order
to verify the extent of water use under this permit, an inspection of water use is typically required,
known as a “proof exam”.
Schedule and Inspections
Department of Ecology personnel, upon presentation of proper credentials, shall have access at
reasonable times, to the project location, and to inspect at reasonable times, records of water use,
wells, diversions, measuring devices and associated distribution systems for compliance with water law.
Findings of Fact and Order
Upon reviewing the investigator’s report, I find all facts, relevant and material to the subject application,
have been thoroughly investigated.
Therefore, I ORDER APPROVAL of Application No. G2-30759, subject to existing rights and the provisions
specified above.
Your Right To Appeal
You have a right to appeal this Order to the Pollution Control Hearings Board (PCHB) within 30 days of
the date of receipt of this Order. The appeal process is governed by chapter 43.21B RCW and chapter
371-08 WAC. “Date of receipt” is defined in RCW 43.21B.001(2).
To appeal, you must do the following within 30 days of the date of receipt of the Order:
• File your appeal and a copy of this Order with the PCHB (see addresses below). Filing means
actual receipt by the PCHB during regular business hours.
• Serve a copy of your appeal and this Order to Ecology in paper form - by mail or in person (see
addresses below). E-mail is not accepted.
You must also comply with other applicable requirements in chapter 43.21B RCW and chapter 371-08
WAC.
Street Addresses Mailing Addresses
Department of Ecology
Attn: Appeals Processing Desk
300 Desmond Drive SE
Lacey, WA 98503
Department of Ecology
Attn: Appeals Processing Desk
PO Box 47608
Olympia, WA 98504-7608
DRAFT REPORT OF EXAMINATION 4 G2-30759
Pollution Control Hearings Board
1111 Israel RD SW, Ste 301
Tumwater, WA 98501
Pollution Control Hearings Board
PO Box 40903
Olympia, WA 98504-0903
For additional information, visit the Environmental Hearings Office Website: http://www.eho.wa.gov. To find
laws and agency rules, visit the Washington State Legislature Website: http://www1.leg.wa.gov/CodeReviser.
Authorizing Signature
Signed at Olympia, Washington, this 8th day of November, 2021.
Michael J. Gallagher, Section Manager
Water Resources Program/Southwest Regional Office
Department of Ecology
DRAFT REPORT OF EXAMINATION 5 G2-30759
INVESTIGATOR’S REPORT
Water Right Application No.: G2-30759 (YMCA of Greater Seattle)
Investigator: Jill Van Hulle, Aspect Consulting, CWRE
Reviewed by: Tammy Hall, Department of Ecology, LH.G.
BACKGROUND
This report serves as the written findings of fact concerning Water Right Application Number G2-30759.
This application was filed by the YMCA of Seattle for the water supply needs of a new camp located at
Mineral Lake in Lewis County, Washington. A site map of the camp and proposed point of withdrawal
are shown on Figure 1.
Table 1. Summary of Requested Water Right
Applicant Name YMCA of Greater Seattle
Priority Date January 24, 2020
County Lewis
WRIA 11
Water Source 3 Wells
Place of Use LOTS 1 THROUGH 33, INCLUSIVE OF TRACTS A, B and C of SEGREGATION
SURVEY, RECORDED JUNE 7, 2012, UNDER AUDITOR’S FILE No. 3379875, IN
VOLUME 28 OF SURVEYS, PAGE 219, AS AMENDED BY SURVEY RECORDED JUNE
22, 2012 UNDER AUDITOR’S FILE NO. 3380676 IN VOLUME 28 OF SURVEYS, PAGE
224, RECORDS OF LEWIS COUNTY, WASHINGTON, BEING LOCATED WITHIN
SECTIONS 2, 3, 4 AND 10, TOWNSHIP 14 NORTH, RANGE 5 EAST, W.M., AND
SECTIONS 26, 27, 28, 33, 34 and 35, TOWNSHIP 15 NORTH, RANGE 5 EAST, W.M.,
LEWIS COUNTY, WASHINGTON.
Purpose Instantaneous Rate
(gpm)
Annual Quantity
(ac-ft/yr) Begin Season End Season
Domestic Multiple 100 16 Continuous
Irrigation of 1 acre 100 (non-additive) 1.75 04/01 10/31
Source Name Parcel Well Tag Township Range Section QQ Q Latitude Longitude
Well No. 1 038931011002 BBN 866 14 N 05 E 04 NW NE 46.731884 -122.178019
Well No. 2 TBD TBD 14 N 05 E 03 S ½ NW TBD TBD
WRIA = Water Resource Inventory Area; gpm = Gallons per Minute; ac-ft/yr = Acre-feet per Year; QQ Q = Quarter Quarter Datum: NAD83/WGS84
Cost Reimbursement
This application is being processed under a cost reimbursement agreement between the applicant and
the Department of Ecology. This report has been prepared by Aspect Consulting, LLC (Aspect) and
reviewed by Tammy Hall with the Department of Ecology’s Water Resources Program.
INVESTIGATION
The applicant, Greater Seattle YMCA, proposes to develop and operate a year-round youth and family
camp on the property. The camp will be part of the Greater Seattle YMCA’s regional youth and family
DRAFT REPORT OF EXAMINATION 6 G2-30759
camp system. Camp Mineral Lake will allow the YMCA to expand the region and population that it can
serve. The YMCA regional youth and family camps serve individuals and families from all backgrounds
and walks of life living in Western Washington.
In consideration of this application, Aspect Consulting reviewed available documents and public
information pertaining to the applicant’s site conditions, and the potential effect on existing water right
holders and proposed minimum instream flows. This included review of the information submitted by
the applicant and pertinent Ecology records including well logs, water rights records, and well
construction and design documents. Aspect also conducted a site visit in February 2020 and pumping
test of Well No. 1 in March 2020.
Proposed Use and Basis of Water Demand
The YMCA of Seattle plans to develop a new camp facility on properties adjacent to Mineral Lake. The
property is currently owned by the Forecastle Timber Company and under contract to the YMCA to
purchase and protect. The YMCA proposes to develop several hundred acres of pristine forestland into
an educational facility.
Mineral Lake is located near the Mount Rainier National Park in Lewis County, just south of the Pierce
County border. The site is forested, quite steep in areas, and surrounds the lake on three sides.
The YMCA’s plans for development of the Project are in the preliminary stages, but water is vital, and we
anticipate the following key parameters:
Approximately 100 buildings, including cabins, 3 single-family dwellings, a lodge, classroom
buildings, maintenance shed, etc.
Capacity to serve up to 20,000 campers a year.
Limited irrigation for small play and assembly areas – if needed.
Estimated “peak” water usage of 49,500 gallons per day.
Approximate 20-year timeline for development of camp.
Site Description
The subject property is located in north-central Lewis County, generally to the northeast of the town of
Mineral and to the east of Mineral Hill Road. The property is comprised of several parcels and
encompasses approximately 2,118 acres. The property extends around the northeastern half of Mineral
Lake and has approximately 9,500 feet of lake frontage. The northern portion of the property extends
along the Nisqually River and has approximately 5,100 feet of river frontage. A portion of the Nisqually
River flows through the northern part of the property. The eastern portion of the property extends
along Mineral Creek and has approximately 2,500 feet of creek frontage. A portion of the Nisqually
River flows through the northern part of the property.
In addition to these waterbodies, the subject property is characterized by a steep ridge that runs
generally east-west through the northern half of the property. The ridge rises from an elevation of
approximately 1,770 feet along Mineral Lake to approximately 2,600 feet at the top of the ridge. Steep
slopes are associated with the ridge and other geologic formations on the property.
Several non-fish bearing streams flow from the top of the ridge through a series of drainages. These
streams flow variously into Mineral Lake, the Nisqually River, Mineral Creek and East Creek. As several
of the streams flow into Mineral Lake and the Nisqually River on the property, they become fish bearing.
DRAFT REPORT OF EXAMINATION 7 G2-30759
Mineral Lake is situated within the drainage of the Nisqually River, WRIA 11. Inflow to the lake is via an
unnamed tributary that enters the lake on the north end and is believed to be perennial. Outflow from
the lake occurs via an unnamed channel which is regulated by flashboards (Data on Selected Lakes in
Washington, Part 3). Water drains to the south entering Roundtop Creek which makes a steep turn to
the north to join Mineral Creek. Mineral Creek is a tributary to the Nisqually River.
Based on our preliminary review, Mineral Creek and other tributaries to the Nisqually are not closed to
new appropriations under WAC 173-511, however the basin is subject to instream flows and accordingly
we understand that tributary water is part of the watershed. Mineral Creek enters the main stem of the
Nisqually River several miles downstream of the USGS gauge at National, which is only gauge on the
Nisqually River above Alder Lake. Minimum Instream Flows for the Upper Nisqually River are set by
WAC at the National Gauge and range between 300 to 650 cfs. In comparison the mean flow of the river
at the National gauge fluctuates between 429 cfs to 1,050 cfs, we further note that Nisqually River flows
during the camp’s primary period of operation (May to September) is generally well above minimum
instream flows.
Water System Description
An existing well (Well 1) will be used for water supply in the early development of the camp. The well is
in the NW ¼ NE ¼ Section 4, Township 14 N., Range 5 E.W.M (Ecology ID BBN-866; see Figure 1). Based
on review of the Ecology well log, the well is 249 feet deep and interpreted to be completed in a
fractured bedrock aquifer. A 6-inch-diameter steel casing extends from the surface to 54 feet below
ground surface (bgs). A 4-inch-diameter PVC liner was installed from 29 to 249 feet bgs with
perforations between 239 and 249 feet bgs. The static water level was reported at 26 ft bgs at the time
of completion in June 2010.
Proposed Use
The applicant intends to develop a water system that can supply the YMCA’s domestic needs.
A Group A community water system will be developed for the camp. Based upon existing water use at
other regional camps, daily usage could be up to 49,500 gallons per day on a peak day. Significant
efforts will be made through design and construction of the camp buildings and facilities to reduce
water usage well below that level. Fire sprinklers will be required in some of the buildings based upon
assembly and transient congregate living facility occupancies, and a water storage tank will be
constructed to provide sufficient fire flows and durations.
Because of the capital costs and complex funding strategies for a camp of this scale, Camp Mineral Lake
will be phased over a period of up to 20 years. The buildings and physical improvements for Camp
Mineral Lake will be clustered in the flat areas to the south of the ridge and to the north and northeast
of Mineral Lake.
The plan is to develop the camp in three phases, the latter two of which will be constructed in
increments or sub-phases. The phasing plan is summarized in Table 2 below:
Table 2. Summary of Phased Camp Expansion
Phase Years Camp Program Description Participants
Annually
Design and Development Actions
1 2021-2021 Primitive camping 128 campers Develop Master Plan
DRAFT REPORT OF EXAMINATION 8 G2-30759
“Building camp” with youth
building primitive structures
Obtain land use approval and
permits
Construct site improvements
to support primitive camping
2 2022-2027
Primitive camping
“Building camp” with youth
building primitive structures 2023: 723,
increasing to
2,002
campers by
2028
Refine Master Plan
Program development
Phased construction of
infrastructure for permanent
camp facilities
Phased construction of
recreational facilities,
including dock, trails, rope
course, and fields
3 2027-2040
Expansion of camp
programs to full capacity as
permanent facilities are
developed
14,000
campers
Phased construction of
lodges, cabins, activity
buildings, staff housing and
utility buildings
Water use will primarily be for domestic purposes with limited seasonal irrigation occurring on 1 acre.
At full buildout, the camp will include:
A dining lodge capable of serving up to 500 people. The lodge will include a kitchen, food
preparation and storage area, toilets, and laundry facilities.
Group handwashing stations
Staff housing consisting of 12-15 two person bunkrooms, communal kitchen/living area and
shared bathrooms
A waterfront area with toilets, showers, and office space
A range of camper housing options (including small individual cabins, tent areas, and traditional
camp-style bunkhouses)
Projected water use for the camp assumes a peak visitor capacity of 1,100 campers and staff each year,
divided roughly between the needs of the youth and family camps:
• Youth Camp will support up to 500 heads at peak season – 400 campers + 100 staff.
• Family Camp will support up to 600 heads at peak season – 525 campers + 75 staff.
Anticipated monthly visitor and water use projections are summarized in Table 3 below for a full
buildout scenario. Water use calculations assume 45 gallons per day (gpd) per person.
Table 3. Monthly Visitor and Water Use Projections
Month
Family Camp Youth Camp Total
People/Day Water Use
(GPD)
People/Day Water Use
(GPD)
People/Day Water Use
(GPD)
Water Use
Gal/Month1
January Closed - Closed - Closed -
February Closed - Closed - Closed -
March 30 1350 Closed - 30 1350 16200
April 30 1350 Closed - 30 1350 16200
May 300 13500 250 11250 550 24750 297000
June 600 27000 500 22500 1100 49500 1485000
July 600 27000 500 22500 1100 49500 1534500
DRAFT REPORT OF EXAMINATION 9 G2-30759
August 600 27000 500 22500 1100 49500 1534500
September 300 13500 250 11250 550 24750 297000
October 30 1350 Closed - 30 1350 16200
November 30 1350 Closed - 30 1350 16200
December Closed - Closed - Closed - -
Total (ac-ft/year) 16
1This calculation assumes that the camp is occupied 12 days per month during non-peak months (i.e. March, April, May,
September, October, and November)
In addition to the 16 ac-ft needed for domestic supply, the YMCA is also requesting 1.75 ac-ft/year for
seasonal irrigation of one acre of lawn. This request is intended to be very minimal and limited to setting
up sprinklers in areas that get a lot of foot traffic or spaced that are used as assembly area. In total,
17.75 ac-ft/year will be needed to support camp operations at full buildout.
The applicant is advised that the final certificate may be reduced based on actual water use patterns.
Hydrologic Setting
Mineral Lake is located within the heavily forested foothills of Water Resources Inventory Area (WRIA)
11, approximately 20 miles southwest of Mount Rainier. The lake is positioned upstream of Alder Dam
on the Nisqually River, which was completed in 1945 to impound flows for recreation and hydroelectric
production. Development is generally sparce with small settlements are located at Mineral and at
Paradise Estates, with a large number of the homes used for seasonal or vacation purposes.
The Nisqually Watershed has two primary broad geological structures and, as a result, two types of
streams. The first, located in the Ohop, Mashel and Upper Nisqually sub-basins in the upper part of
WRIA 11, consists of hills, low mountains and Mount Rainier underlain primarily by bedrock. Moisture-
rich masses from the Pacific Ocean and orographic effects result in heavy precipitation on the western
side of Mount Rainier. In most years even the lower elevations of these uplands receive snow, with
significant snow accumulations in upper elevations. Annual precipitation ranges from 3-8 feet, with
snowfall ranging from approximately 5-30 feet, depending on elevation (National Oceanic and
Atmospheric Administration, 2011). Maximum snow depths are generally reached by early March
(Czuba et al., 2012). Conversely, summer months are characterized by warm, dry weather.
Tributaries to the upper Nisqually are primarily high elevation, snow melt dominated streams. The river
itself originates from the Nisqually Glacier on the southern side of Mount Rainier. Surface water is
primarily sourced by snow melt and groundwater from fractured volcanic and quaternary
unconsolidated sediment aquifers that fill the lowlands between volcanic ridges. Streams in the upper
watershed can flow with high volume and velocity, especially following rain on snow events.
The United State Geological Survey (USGS) maintains several flow gauges along the Nisqually River and
one on Mineral Creek, an outflow tributary from Mineral Lake to the Nisqually River. Flows on Mineral
Creek are flashy and rise dramatically following winter and spring snow and rain events but are generally
highest in the spring following snowmelt and lowest during summer baseflow.
The second broad geological area is west of the Eatonville/Route 161 line and includes almost all of the
Thurston County portion of the watershed and parts of Pierce County. This is the area of the county that
was impacted by the Continental glaciers, commencing over 100,000 years ago until the most recent
Vashon Stage of the Fraser Glaciation began approximately 15,000 years ago. As the glaciers advanced
DRAFT REPORT OF EXAMINATION 10 G2-30759
and then retreated, many times over thousands of years, they left geological layers of alternating
outwash sand and gravel, and layers of thick glacial till and other low-hydraulic conductivity. The sand
and gravel layers contain water and these layers are generally referred to as aquifers. The glacial till
layers wholly or partially confine portions of the aquifers. However, there is typically some degree of
hydraulic connection (continuity) between the aquifers. These deposits differ dramatically in
composition and thickness in each of the sub-basins, resulting in some areas with prolific supplies of
groundwater while others have minimal supply.
Hydrogeologic Evaluation
The geology and streamflows of various Nisqually sub-basins have been described in detail in the 2003
Watershed Plan and numerous other studies (Golder, 2003; Pringle, 2008). Aspect reviewed available
studies, well logs, cross-sections, geologic maps, and geologic reports of Lewis County to develop a
conceptual hydrogeologic model. An existing well on the YMCA property was also tested by Aspect in
March 2020 to further evaluate aquifer characteristics and limitations.
Geologic Setting and Units
The geology of the Upper Nisqually sub-basin is volcanic in origin, containing the remnants of ancient
volcanoes. Volcanic ridges composed of tertiary andesite and basalt flows surround the lake, while
quaternary glacial deposits fill the lowland between ridges. The YMCA’s camp is located within Lewis
County’s portion of the Upper Nisqually sub-basin and is primarily characterized by forestry land uses.
Within the study area, two principal aquifer systems were identified and are described further below.
Bedrock (Mva)
Bedrock of the Upper-Nisqually is dominated by Miocene aged volcanics, primarily composed of
andesitic and basaltic flows, intermixed with flow breccias. Bedrock is exposed at ground surface on
ridges surrounding the lake. The depth to bedrock at the YMCA’s proposed well, located generally on
the northwest corner of the lake, is estimated to be approximately 35 feet below ground surface,
overlain by glacial sediments.
Bedrock is typically described in well logs as “crumbly” or “fractured” likely due to its age and extensive
tectonic deformation. Wells completed in bedrock where not exposed at the surface typically
demonstrate static water levels above the top of the aquifer, indicating locally confined conditions.
Quaternary Glacial Deposits (Qap)
Quaternary glacial sediment deposits fill the lowlands surrounding the lake and ridges. These deposits
typically consist of till (a low permeability unit consisting of sands and gravels suspended in a silty
matrix) and outwash sands and gravels. The YMCA well penetrates approximately 35 feet of
unconsolidated deposits before reaching bedrock.
Many domestic wells on the western flank of the lake, closer to the town of Mineral, are completed in
these shallow deposits.
Groundwater Flow Direction and Recharge
Bedrock and unconsolidated sediment aquifers are both recharged by percolation of precipitation and
snowmelt. Near the lake, groundwater flows radially inward toward the lake where it discharges. Ridges
DRAFT REPORT OF EXAMINATION 11 G2-30759
surrounding the lake likely act as groundwater divides, directing groundwater flow to discharge directly
to the Nisqually or one of its tributaries.
ANALYSIS
Under Washington State law (RCW 90.03.290), each of the following four criteria must be met for an
application for a new water right permit to be approved:
Water must be available for appropriation.
Water withdrawal and use must not cause impairment of existing water rights.
The proposed water use must be beneficial.
Water use must not be detrimental to the public interest (public welfare).
Water Availability
For any new appropriation, water must be both physically and legally available.
Physical Availability
For water to be physically available for appropriation, water must be present in quantities and quality
and on a sufficiently frequent basis to provide a reasonably reliable source for the requested beneficial
use or uses. An analysis of physical availability is required for both surface water and groundwater
applications.
The existing YMCA well was tested in March 2020 by an Aspect hydrogeologist to estimate aquifer
parameters and assess well efficiency. Analysis of testing data was used to determine physical
availability of water for beneficial use. The Cooper-Jacob method (1946) was used to analyze drawdown
data from the final step of the pumping test. Aquifer transmissivity was estimated to be about 310
square feet per day (ft2/d), which is consistent with the lithology described in the well log.
Estimated water levels during long-term continuous pumping at the test well were predicted by
incorporating estimated aquifer parameters into a Theis analysis (Krusemann and de Ridder, 2001). The
predicted drawdown for the test well assumes that the well screen remains fully saturated and that
pump assemblies are not installed within the screened interval in a manner that restricts flow. The
drawdown from pumping at 40 gpm is predicted to be approximately 79 feet which places the pumping
level around 100 feet bgs. This leaves approximately 100 feet of head above the assumed pump intake,
suggesting that the well had additional capacity not utilized during the step-rate test. However,
pumping this additional capacity may be limited by the 4-inch diameter liner in the well restricting the
size of pump that may be installed.
For the primary Phase 1 buildout of the camp, the YMCA assumes water will be required for 400
campers and 100 staff members for a total of 500 people. If an average demand of 45 gpd is assumed
per person, a total of 22,500 gallons will be needed each day.
The existing well can support pumping of at least 40 gpm, which if pumped for 12 hours each day, will
provide sufficient supply for the Phase 1 buildout. We note however that the existing well includes a
smaller diameter liner, which may limit the pump choices. If the existing well’s construction problems
restrict its usability, the YMCA may elect to drill a second well near the first well. This well will be added
to this permit administratively through filing a Showing of Compliance.
Given the challenges of the steep terrain and the YMCA’s desire to develop separate areas for the family
and youth camp areas, a third well will be constructed for the youth camp area located generally in the S
DRAFT REPORT OF EXAMINATION 12 G2-30759
½ of the NW ¼ of Section 3 and adjacent to Mineral Lake. Spacing the wells out over the large project
site will improve redundancy.
Legal Availability
To meet the legal availability test, the proposed appropriation may not withdraw and use water that is
already “spoken for,” such as water from sources that are protected by administrative rule or court
order.
The project site is in WRIA 11 of the Nisqually River drainage basin. Under the provisions of WAC 173-
511, instream flows have been established at various control points in the watershed to regulate and
protect instream flows. The instream flows established in this chapter are based on the
recommendations of the WRIA planning unit; consultation with the Departments of Fish and Wildlife,
Agriculture, and Community, Trade, and Economic Development (now the Department of Commerce);
and public input received during the rule-making process. The planning unit recommended these
instream flow levels by unanimous vote.
Minimum instream flow regulations have been established in WRIA 11 by Ecology under the Instream
Resource Protection Program (IRPP) and are described in Chapter 173-511 of the Washington
Administrative Code (WAC). Instream Flows and closures in the Nisqually Watershed have a priority date
of February 1981, when they were adopted as administrative rule.
Flow regulations in WRIA 11 consist of minimum instream flow levels and sub-basin closures to further
consumptive use. In WAC 173-511, instream flow levels were set for four segments of the Nisqually
River, each with a specific flow control or measuring site (above Alder reservoir, below the LaGrande
Powerhouse, the bypass reach and below the Centralia Powerhouse) and for the Mashel River,
measured at the USGS gauge on the Mashel River. Additional minimum instream flow requirements are
in place year-round for the bypass reach, the reach below LaGrande Powerhouse, and the reach below
the LaGrande Dam, established by the Federal Energy Regulatory Commission (FERC) as license
requirements for the Tacoma Public Utilities Nisqually Hydroelectric Project and the City of Centralia’s
Yelm Hydroelectric Project.
In addition to these minimum flows, 20 tributaries and lakes and two segments of the Nisqually
mainstem have been closed, at least seasonally, to further allocation.
Much of the Nisqually Watershed is administratively closed to new water appropriation due to the
establishment of instream flows under WAC 173-511-030 and closures established under WAC 173-511-
040. The Nisqually River segment above Tacoma’s hydroelectric project and tributaries to that segment
(the Upper Nisqually sub-basin of this plan) were not closed to further appropriation by the IRPP.
Instead the 1981 IRPP established instream minimum flows for the Upper Nisqually River but did not
close it for future surface water appropriations.
The IRPP placed no explicit restriction on future groundwater withdrawals. Because regulatory instream
flows are set on the upper reach of the Nisqually, any new future permit-exempt well use or water right
appropriation would be subject to interruption in the case that actual flows fall below regulatory flows.
The YMCA’s project is located such that any impacts it would have on the Nisqually River would occur at
a point below the Mineral gage and above Alder Lake. Figure 2 below is useful in that it depicts a river
DRAFT REPORT OF EXAMINATION 13 G2-30759
system where instream flows tend to be highest during the summer months when water use at the
camp will be the highest. Note that the National gauge is located over three miles upstream from the
confluence of Mineral Creek and the Nisqually River, and thus does not depict instream flow conditions
downstream of the gauge. There are several tributaries that enter the Nisqually between the National
gauge and Mineral Creek that increase flow in the mainstem, the largest of which is Reese Creek. Flow
are expected to be significantly higher near the project site.
Figure 2. USGS Nisqually River Gauge (12082500)
Below Alder Lake at USGS gauge 12086500 (La Grande, WA station) flows are reliably met by the TPU’s
releases. This is due to TPU requirement to manage the discharge of water from Alder Lake into the
middle reaches of the Nisqually River.
Impairment
In analyzing impairment, Ecology must make a determination as to whether existing water rights,
including adopted instream flows, may be impaired by the withdrawal and proposed use. The analysis
will predict impacts that may occur if the proposed change is authorized. There are three concepts that
must be considered when making this determination. These concepts are defined as follows:
DRAFT REPORT OF EXAMINATION 14 G2-30759
1. Impairment is an adverse impact on the physical availability of water for a beneficial use that is
entitled to protection (i.e., water rights that are both senior and junior in priority to the right the
applicant seeks to change).
2. Qualifying groundwater withdrawal facilities are defined as those wells which in the opinion of
Ecology are adequately constructed. An adequately constructed well is one that (a) is
constructed in compliance with well construction requirements; (b) fully penetrates the
saturated thickness of an aquifer or withdraws water from a reasonable and feasible pumping
lift (WAC-173-150); (c) the withdrawal facilities must be able to accommodate a reasonable
variation in seasonal pumping levels; and (d) the withdrawal facilities including pumping
facilities must be properly sized to the ability of the aquifer to produce water.
3. Well interference may occur when several wells penetrate and withdraw groundwater from the
same aquifer. Each pumping well creates a drawdown cone. When several wells pump from the
same aquifer, well density, aquifer characteristics, and pumping demand may result in individual
drawdown cones that intersect and form a composite drawdown cone. At any point in an
aquifer, the composite drawdown caused by pumping wells will be greatly influenced by the
transmissivity (T) of the aquifer and the storage coefficient (s). In aquifers with high Ts,
composite drawdown will generally be much less than in aquifers with similar properties but
with low Ts. Transmissivity is related to hydraulic conductivity (K) and the saturated thickness (b)
of an aquifer by the relationship T=Kb.
At full buildout, the camp would require a maximum withdrawal of 100 gpm or an annual volume of
17.75 ac-ft/year (which equates to an average annual pumping rate of 11 gpm). To determine the
magnitude of potential well interference to other users within the fractured bedrock aquifer, a Theis
(1935) distance-drawdown analytical model was used. The following estimated aquifer parameters were
applied:
Aquifer transmissivity (T) is 310 square feet per day; this is estimated from pumping test data
The aquifer storage coefficient is 0.00001; this is estimated from textbook values and is well
within the typical range for fractured bedrock
A recharge boundary is assumed to exist 1,000 feet southeast of the existing YMCA well where
the bedrock outcrops at the lake; this boundary was modeled for this investigation using image
well analysis of the Theis (1935) equation, as described by Ferris et al. (1962).
The output from the analytical model for one year of continuous pumping at the annual authorization
requested in the subject applications are summarized in Table 4 for an array of distances away from the
YMCA well (distances are considered in a direction opposite the recharge boundary for conservatism).
The table also summarizes the impacts from 10 days of pumping the proposed instantaneous (Qi)
authority at the well. Although it is unlikely that the right would simultaneously exercise the maximum
Qi at the well for 10 consecutive days due to infrastructure limitations, the analysis was conducted to
demonstrate that impacts from pumping the maximum Qi should not prohibit water right processing.
Results from this analysis suggest that up to approximately 17.3 feet of drawdown could occur to nearby
users (however, no users were identified within 1,000 feet of the well).
DRAFT REPORT OF EXAMINATION 15 G2-30759
Table 4. Predicted Aquifer Drawdown from Pumping Proposed Water Right Quantities
Distance from the Well (feet)1
Pumping Rate (gpm) 500 1,000 2,500 4,000
11 gpm2 2.4 1.7 0.9 0.6
1Results consider increasing distance in a direction away from the recharge boundary assumed at Mineral Lake.
2Average annual pumping rate needed to satisfy the requested Qi; model predicts drawdown after 1 year of pumping.
3Proposed instantaneous water right capacity after 10 days of pumping.
Table 5 summarizes water well logs in Ecology’s database that were identified within about 4,000 feet of
the well and completed in the bedrock aquifer (shallower wells or wells completed in the sand and
gravel were excluded under the assumption that they tap the overlying unconsolidated aquifer). The
closest known well known to exist near the proposed well under the subject application is located
approximately 400 southwest. Like the proposed well, this well is also owned by Mineral Lake Forest,
LLC and is within YMCA property (Well Log ID BBN865). The well is not operated and currently serves as
a monitoring well. Because no other wells are known to exist within about 1,000 feet of the well,
interference from the proposed request is expected to be less than 2 feet as drawdown within the
bedrock aquifer is expected to diminish with increased distance away from the well. Based on the
available water columns determined for nearby wells, no impairment is reasonably expected to occur
from approval of the proposed request.
Table 5. Well Construction Details for Nearby Water Wells
Well Log ID Owner
Static Water
Level (feet bgs)
Upper Open
Interval (feet bgs)
Well Depth
(feet bgs)
Available Water
Column (feet)
N/A Joseph Krolczyk 38 95 125 57
AKB482 Michael Heinz 17 145 175 128
BBN865
Mineral Lake Forest
LLC +2 (ags) 97 160 99
N/A Dennis Christianson 13 115 175 102
ABE766 Donavan Larson 52 Unknown 300 Unknown
BJM726 Emil Markovitch 6 40 150 34
N/A Ernest Dresher 128 138 180 10
N/A Jack Vanning 60 79 400 19
N/A Lester Panush Unknown 115 180 Unknown
The closest surface water regulated under chapter 173-511 WAC is the Nisqually River, but the closure
only applies to the reaches and control points downstream from Alder Dam. Therefore, no impairment
to surface water is reasonably likely to occur from approval of the changes requested by the YMCA’s
current request.
Beneficial Use
The proposed appropriation must be for a beneficial use of water. Domestic supply is considered a
beneficial use of water under RCW 90.54.020(1).
DRAFT REPORT OF EXAMINATION 16 G2-30759
Public Interest
The withdrawal and associated use must not be detrimental to the public interest. At a minimum, the
following are considered when making this assessment.
Notification to the Washington Department of Fish and Wildlife
Per RCW 90.03.280 and 77.57.020, Ecology must give notice to the Washington Department of Fish and
Wildlife (WDFW) of applications to divert, withdraw, use, or store water.
WDFW was provided notice of this water right application and on March 12, 2021, Steve Boessow of
WDFW responded in a letter to Ecology that stated that based on impacts to fish and wildlife that they
did not object to the issuance of this permit. Mr. Boessow, however indicated that the project needed
to also be consistent with the findings of the 2018 Streamflow Restoration Act, and recommended direct
consultation with the Nisqually Tribe.
State Environmental Policy Act (SEPA)
Under chapter 197-11 WAC, a water right application is subject to a SEPA threshold determination (i.e.,
an evaluation of whether there will be significant adverse environmental impacts) if any of
the following conditions are met:
It is a surface water right application for more than 1 cfs, unless that project is for agricultural
irrigation, in which case the threshold is increased to 50 cfs, so long as that irrigation project will
not receive public subsidies;
It is a groundwater right application for more than 2,250 gpm;
It is an application that, in combination with other water right applications for the same project,
collectively exceed the amounts above;
It is a part of a larger proposal that is subject to SEPA for other reasons (e.g., the need to obtain
other permits that are not exempt from SEPA);
It is part of a series of exempt actions that, together, trigger the need to do a threshold
determination, as defined under WAC 197-11-305.
This requested withdrawal is less than the categoric exemption provided in the SEPA regulation thus this
water right request does not trigger a threshold determination.
Public Notice
RCW 90.03.280 requires that notice of a water right application be published once a week, for two
consecutive weeks, in a newspaper of general circulation in the county or counties where the water is to
be stored, diverted, and used. Notice of this application was published in the Chronicle on March 16th
and 23rd, 2021.
Other Public Interest Concerns
RCW 90.03.290 requires that a proposed appropriation not be detrimental to the public interest. RCW
90.54 (Water Resources Act of 1971) provides the most comprehensive list of legislative policies that
guide the consolidation of public interest in the allocation of water. These policies generally require a
balancing of the state’s natural resources and values with the state’s economic wellbeing. Specifically,
the policies require allocation of water in a manner that preserves instream resources, protects the
quality of water, provides adequate and safe supplies of water to serve public need, and makes water
available to support the economic wellbeing of the state and its citizens.
DRAFT REPORT OF EXAMINATION 17 G2-30759
On August 17, 2021 the Nisqually Indian Tribe provided comments to Ecology expressing their support
of this project and expressing their finding that the project is consistent with the watershed planning
recommendations. Specifically:
“The Nisqually Indian Tribe supports the development of an education youth camp AND we find that this
project is consistent with the WRIA 11 Watershed Management Plan (adopted in October 2003) and the
development of the subsequent Plan Addendum. The main objective of both planning documents share
is to “develop a comprehensive strategy for balancing competing demands for water, while at the same
time preserving and enhancing the future integrity of the watershed.” The scope of the 2003 Plan was
focused on examining and presenting recommendations on five key issues: growth and land use,
groundwater resources and supply, water rights, instream flow and surface/groundwater continuity, and
water quality., and in 2018, the Washington State Legislature, acting in ESSB 6091, mandated that the
Nisqually Planning Unit acting under authority of RCW 90.82, must update the Nisqually Watershed
Management Plan to address future permit-exempt domestic groundwater withdrawals, potential
impacts of these withdrawals on minimum streamflows and other senior water rights, and develop
mitigation strategies as deemed appropriate by the Planning Unit.”
The Tribe’s support is based on the following elements:
The Instream Flow Protection Plan for the Nisqually Watershed (WAC 173-511-050) provides
that future groundwater withdrawal proposals will not be affected by this chapter unless it is
verified that such withdrawal would clearly have an adverse impact upon the surface water
system contrary to the intent and objectives of this chapter.
We have reviewed this project and do not believe that the project conflicts with the stated
intent of WAC 173-11. Groundwater and surface water in this region on the watershed are not
closely coupled and based on the previous hydrogeological work that was done to characterize
the Upper Nisqually Watershed there will be no direct impacts to surface water in Mineral Lake,
or it’s tributary Mineral Creek.
The YMCA’s project is largely non-consumptive, and is already proposed to use less water than
comparable residential development of the property. Water will be used for domestic needs
only, and will be returned to the hydraulic system either via septic systems or a potentially more
advanced treatment methods regardless we understand that domestic supply is usually less
than 10% consumptive and represents flows of only a few gallons per minute.
Mineral Creek and other tributaries to the Nisqually River above Alder Lake are not closed to
new appropriations under WAC 173-511, and the Watershed Plan does not recommend the
regulation of water upstream from Alder Lake unless there is a direct impact to habitat being
proposed.
Flows below the Alder Lake reservoir are managed by Tacoma Public Utilities so as to maintain
instream flows in the Nisqually River’s mainstem. We see no potential scenario where the
YMCA’s limited used of deep groundwater will have adverse impacts on surface flows in the
watershed.
The Watershed Planning Groups addendum, which was adopted in February of 2019 included a suite of
mitigative options that have been proposed as mechanisms to offset the consumptive portion of water
DRAFT REPORT OF EXAMINATION 18 G2-30759
use. While the plan addendum is specific to the requirement to offset impacts caused from permit-
exempt wells, it also serves as an outline for the types of projects that has been vetted by Ecology as
acceptable to offset impacts to instream flows. These same “tools” may be useful in the structuring of
mitigation for the effect that Park’s well might have on surface water in the Nisqually River Watershed.
These tools include:
1. Hydraulic modeling that accounts for planned preservation of mature forest
2. Shifts in targeted production zones for existing public water systems
3. Habitat restoration that results in favorable changes to groundwater – surface water
interactions
4. Water right acquisition
5. The Tribe has been working closely with the YMCA on option to preserve and maximize the
potentially 1,000 acres that will ultimately be incorporated in the new camp. Given the fact
pattern surrounding the camp project, coupled with the interest of the Nisqually Tribe and
larger planning group, we feel that taken as a whole, changes to forest management ie. allowing
this property to return to a mature forest, will have passive benefits that more than outweigh
the project’s minor water use.
6. Our research, which is based on the USGS’s Visualizing Ecosystem Land Management
Assessments (VELMA) ecohydrological model, shows that in the Nisqually watershed that each
forested acre that is left unharvested can mitigate 0.13 acre-feet per year of streamflow deficit.
The ramification of this work is that by permanently protecting just 154 acres of forest, the
entire 20 acre-feet of total camp water demand will be offset. This calculation is highly
conservative however, because most of camp’s water use will be non-consumptive with 90
percent of total withdrawals being returned to the shallow groundwater system where it is
more likely to provide direct flow augmentation.
In short, the Nisqually Tribe likes this project and supports the issuance of a permit to the YMCA to allow
them to carry out this important work. We have found in the protection of our resources there is no
better way to foster the support of future generations than to expose them as children to the wonders
to nature.
Therefore, this proposed appropriation is not detrimental to the public interest.
Conclusions
I find that:
Water is physically and legally available.
The appropriation will not impair existing rights.
The proposed domestic supply is a beneficial use.
Approval of this application will not be detrimental to the public interest.
RECOMMENDATIONS
Based on the above investigation and conclusions, I recommend this request for a water right be
APPROVED in the amounts and within the limitations listed below and subject to the provisions listed
above.
DRAFT REPORT OF EXAMINATION 19 G2-30759
Recommended Quantities, Purpose of Use, and Project Location
The rate and quantity of water recommended are maximum limits. The permit holder may only
withdraw water at a rate and quantity within the specified limits that are reasonable and beneficial:
Table 6. Recommended Limits and Location
Maximum Instantaneous Rate (gpm) 100
Maximum Annual Quantity (ac-ft/yr) 17.75
Purpose(s) of Use Domestic Supply and Irrigation
Point of Withdrawal NE ¼, NE ¼, Section 04, Township 14 North,
Range 05 E.W.M.
Place of Use LOTS 1 THROUGH 33, INCLUSIVE OF TRACTS A, B
and C of SEGREGATION SURVEY, RECORDED JUNE
7, 2012, UNDER AUDITOR’S FILE No. 3379875, IN
VOLUME 28 OF SURVEYS, PAGE 219, AS
AMENDED BY SURVEY RECORDED JUNE 22, 2012
UNDER AUDITOR’S FILE NO. 3380676 IN VOLUME
28 OF SURVEYS, PAGE 224, RECORDS OF LEWIS
COUNTY, WASHINGTON, BEING LOCATED WITHIN
SECTIONS 2, 3, 4 AND 10, TOWNSHIP 14 NORTH,
RANGE 5 EAST, W.M., AND SECTIONS 26, 27, 28,
33, 34 and 35, TOWNSHIP 15 NORTH, RANGE 5
EAST, W.M., LEWIS COUNTY, WASHINGTON.
November 8, 2021
Jill Van Hulle, Aspect Consulting Date
November 8, 2021
Mathew Lewis, Aspect Consulting Date
DRAFT REPORT OF EXAMINATION 20 G2-30759
November 8, 2021
Tammy Hall, Department of Ecology Date
To request ADA accommodation including materials in a format for the visually impaired, call Ecology Water Resources Program at 360-407-6872.
Persons with impaired hearing may call Washington Relay Service at 711. Persons with speech disability may call TTY at 877-833-6341.
References
Cooper, H.H. and C.E. Jacob, 1946, A Generalized Graphical Method for Evaluating Formation Constants
and Summarizing Wellfield History, Am. Geophys. Union Trans., Vol. 27, pp 526-534.
Czuba, J.A., Olsen, T.D., Czuba, C.R., Magirl, C.S., and Gish, C.C., 2012, Changes in sediment volume in
Alder Lake, Nisqually River Basin, Washington, 1945–2011: U.S. Geological Survey Open-File
Report 2012–1068, 30 p.
Ferris, J.G., D.B. Knowles, R.H. Brown and R.W. Stallman, 1962. Theory of aquifer tests, U.S. Geological
Survey Water-Supply Paper 1536 E, 174p
Kruseman, G.P., and N.A. de Ridder, 2001, Analysis and Evaluation of Pumping Test Data, ILRI Publication
47, 2nd addition, ISBN 90 70754 207.K-D, 2000.
National Oceanic and Atmospheric Administration, 2011, Climate of Washington: Western Regional
Climate Center website accessed October 5, 2011, at
http://www.wrcc.dri.edu/narratives/WASHINGTON.htm.
Theis, C.V., 1935. The relation between the lowering of the piezometric surface and the rate and
duration of discharge of a well using groundwater storage, Am. Geophys. Union Trans., vol. 16,
pp. 519-524.
DRAFT REPORT OF EXAMINATION 21 G2-30759