HydroVisions | Spring 2021 by HydroVisions

VOLUME THIRTY SPRING 2021

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2021 Spring Issue

2020 Winter Issue

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HYDROVISIONS is the official publication of the Groundwater Resources Association of California (GRA). GRA’s mailing address is 808 R ST STE 209, Sacramento, CA 95811. Any questions or comments concerning this publication should be directed to the newsletter editor at editor@grac. org or faxed to (916) 231-2141. The Groundwater Resources Association of California is dedicated to resource management that protects and improves groundwater supply and quality through education and technical leadership Editor Rodney Fricke editor@grac.org Editorial Board Adam Hutchinson David Von Aspern Tim Parker Executive Officers President Abigail Madrone West Yost Associates Tel: 530-756-5905 Vice-President R.T. Van Valer Roscoe Moss Company Tel: 323-263-4111 Secretary John McHugh Luhdorff & Scalmanini, Consulting Engineers Tel: 530-207-5750 Treasurer Rodney Fricke GEI Consultants Tel: 916-631-4500 Officer in Charge of Special Projects Christy Kennedy Woodard & Curran Tel: 925-627-4122 Immediate Past President Steven Phillips, Retired U.S. Geological Survey Tel: 916-278-3002 Administrative Director Sarah Erck GRA Tel: 916-446-3626

Directors Jena Acos Brownstein Hyatt Farber Schreck Tel: 805-882-1427 Lyndsey Bloxom Water Replenishment District of Southern CA Tel: 562-921-5521 Erik Cadaret Water Systems Consulting Tel Office: 949-528-0960 x602 Murray Einarson Haley & Aldrich Tel: 530-752-1130 Lisa Porta Montgomery & Associates Tel: 916-661-8389 Bill DeBoer Montgomery & Associates Tel: 925-212-1630 John Xiong Haley & Aldrich Tel: 714-371-1800 John Van Vlear Newmeyer & Dillon Tel: 949-271-7127 Todd Jarvis Institute for Water & Watersheds, Oregon State University Tel: 541-737-4032 James Strandberg Woodard & Curran Tel: 925-627-4122 To contact any GRA Officer or Director by email, go to www.grac.org/board-of-directors

The statements and opinions expressed in GRA’s HydroVisions and other publications are those of the authors and/or contributors, and are not necessarily those of the GRA, its Board of Directors, or its members. Further, GRA makes no claims, promises, or guarantees about the absolute accuracy, completeness, or adequacy of the contents of this publication and expressly disclaims liability for errors and omissions in the contents. No warranty of any kind, implied or expressed, or statutory, is given with respect to the contents of this publication or its references to other resources. Reference in this publication to any specific commercial products, processes, or services, or the use of any trade, firm, or corporation name is for the information and convenience of the public, and does not constitute endorsement, recommendation, or favoring by the GRA, its Board of Directors, or its members.

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TABLE OF CONTENTS

President’s Message

Annual GSA Summit

The Geochemist’s Gallery

The 2021 WGC

2021-2023 Strategic Plan

You’re Interested in ASR?

Managing PFAS

Wells and Words

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In Memory of Edwin H.Y. Lin

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2021 “Lifetime Achievement” and “Kevin J. Neese” Awards

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Parting Shot

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THANK YOU TO OUR GRA DONORS

December 2020 - February 2021 William Sedlak, Thomas Harter, Richard Makdisi, Jason Duda, Eric Reichard, Dean Thomas, David Lipson, Mark Peterson, Julie Johnson, Mike Huggins, Nathan Hatch, Douglas Tolley, Joseph LeClaire, Gordon Osterman, Roger Masuda & Heather Jackson

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We are ready to assist you with your groundwater needs • Hydrogeologic Studies and Monitoring • Geotechnical Studies and Projects • SGMA Plans, Projects and Management Actions • ASR, Production and Monitoring Wells • Managed Aquifer Recharge Planning, Design, and Construction • Aquifer/Basin Characterization

THE GROUNDWATER RESOURCES ASSOCIATION OF CALIFORNIA

RENEW TODAY!

• Water Budget Analysis • Groundwater/Surface Water Modeling • GIS/Data Management System • Exchange, Storage and Transfer Agreements • Regulatory Compliance • Groundwater Governance • Outreach and Facilitation • Website Development and Hosting

Contact Us Today. Chris Petersen 530.304.3330 cpetersen@geiconsultants.com Rodney Fricke 916.407.8539 rfricke@geiconsultants.com

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President’s Message

ABIGAIL MADRONE

Abigail Madrone, Business Development Director with West Yost. Throughout her 20 year career, Abigail has served and supported groundwater and water resources management through groundwater monitoring and analysis, project and program management and public outreach and education.

We welcome the new year with open arms, we are optimistic, hopeful, and eager to reconnect with our groundwater community. GRA has not skipped a beat, from developing our 3-year strategic plan to lining up an impressive year of events, and we are here to support our members and continue to lead the way. We are dedicated to resource management that protects and improves groundwater supply and quality through education and technical leadership. GRA will not allow a global pandemic to diminish our commitment to our vision: sustainable groundwater for all!

President’s Message

GRA has a diverse and compelling lineup of events in 2021 to support your professional development, expand your mind and your network, from statewide events, regional branch meetings, to GRACasts; we have something for everyone.

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President’s Message

The Future of Water, chaired by John McHugh, GRA Director and Secretary, officially kicked off our 2021 event season with success. This collaborative and innovative event featured two exceptional keynote speakers: Kim Baker, Director of Innovation at Elemental Excelerator, and Rosemary Knight, George L. Harrington Professor in the School of Earth Sciences, Stanford University. The Groundwater Law and Legislative Symposium on March 24th will be an interactive virtual day of learning and discussions regarding the most current legal and legislative issues affecting California groundwater. Sponsors and exhibitors are encouraged to sign-up early to secure your spot. The 4th Annual GSA Summit on June 9th and 10th, will provide an opportunity for fellow groundwater managers, regulators, and technical experts to collaborate and work toward implementation for a sustainable future. Our marquee event, the 4th Annual Western Groundwater Congress (WGC) on September 13th – 15th, chaired by Lyndsey Bloxom, GRA Director, is a unique and must attend event for water resource and groundwater professionals. The WGC will feature diverse tracks and panels to engage and spark interest from water resource professionals of all levels and backgrounds. Visit our website grac.org, engage with us on social media or check your inbox for upcoming announcements and details on these great events and on the activities of your local GRA branch. Stay informed to the latest developments and technology though GRACasts and short courses to help advance your career. We are grateful for you, our members, sponsors, affiliates, volunteers, and leaders. Let’s make 2021 our best year yet! Best Regards,

- Abigail Madrone, 2020 GRA President

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GRA’s Fourth Annual GSA Summit: Working Toward Implementation Join fellow groundwater managers, regulators and technical experts at this year’s GSA Summit. The 2021 GSA Summit is back in its second virtual format! Come join us at the 4th Annual GSA Summit, June 9 and 10, 2021. This year’s virtual Summit will take place over two half days, including interactive networking events. Last year’s GSA Summit attracted over 130 attendees working for or with GSAs and tuning in to share input and raise the bar for all. Feedback was exceptional and we will have a more interactive platform this year.

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The Summit will feature interactive panels and round tables to review the issues GSAs are facing as they start on GSP implementation activities. You’ll have a chance to hear directly from DWR and SWRCB about initial findings from their GSP review and 1st year implementation progress.

Key reasons to attend the Summit this year: • Participate in two half-days of learning, networking, and collaboration • Exchange information, ideas and best practices for successful GSP development and implementation

GRA’s Fourth Annual GSA Summit

• Learn from other GSA managers and technical staff on what works and doesn’t work for them

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“This is the single most important conference for GSAs” – 2020 GSA Summit Attendee

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GSA SUMMIT

Key topics: • Legal challenges as GSAs move toward GSP implementation • Groundwater recharge strategies for GSP implementation • Water quality: enforcement, solutions, and intersection between SGMA and other existing programs – collaboration instead of duplication • Long term communication with stakeholders to ensure successful implementation Opportunities for registration fee waivers are available to GSA board, staff and committee members, as well as community members and not-for-profit organizations involved in GSP development.

“At the first GSA Summit, GSAs were just formed and were trying to understand the GSP regulations and identifying all the different aspects of GSP development. At our second Summit, we were working hard to put finishing touches on the first set of GSPs. The 2020 Summit allowed us to reflect on the first rounds of GSPs submitted and regroup on what we think we can do better moving forward into implementation.” – Lisa Porta, 2020 GSA Summit Chair

Why join the 4th Annual GSA Summit? Because “There are some questions that cannot be answered by Google” (so true for SGMA!) - Deanna Jackson, 2020 panel speaker Don’t miss this opportunity to share and learn from each other as you continue making progress on the SGMA journey!

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The Geochemist’s Gallery WILLIAM E. (BILL) MOTZER William E. (Bill) Motzer, PHD, PG, CHG, is a somewhat retired Forensic Geochemist

Toxic Terra PART TWO

The Geochemist’s Gallery

In the last HydroVisions (Winter 2020), I discussed a simple classification of naturally-occurring hazardous substances (NOHS). In this and future articles, I’ll pursue some of the chemistry and geochemistry associated with NOHS that are toxic to humans (also known as toxicological geochemistry of earth materials)1. NOHS includes elements such as arsenic, as discussed in detail below, chromium, lead, and mercury. For these elements, speciation plays an important role in their degree of toxicity. Arsenic (As, atomic number or Z = 33), with only one stable isotope (arsenic-75 or 75As), is 55th in Earth’s crustal abundance among the 88 to 94 (or more) naturally-occurring crustal elements (depending on which definition is used for a “naturally-occurring element”). Arsenic is classified as a metalloid element; its chemistry is predominately nonmetallic, and it’s not certain if it forms cations in solution. Arsenic is not found in high concentrations in crustal rocks, having an average abundance of 1.5 milligrams/kilogram (mg/kg) or parts per million (ppm). Igneous rocks (e.g., basalt, andesite, and granite) have average concentrations of 2.3, 2.7, and 1.3 mg/kg, respectively. However, arsenic commonly concentrates in sulfide-bearing minerals, such as pyrite (iron sulfide or FeS2) and arsenopyrite (iron arsenic sulfide, FeAsS) – both often associated with hydrothermal (hot spring) activity and gold mineralization. Pyrite is also common in sedimentary rocks (mudstones, marine shale, 1

An earlier version appeared in the California Section of the American

Chemical Society newsletter: The Vortex (February 2015 issue) at www.calacs.org.

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The Geochemist’s Gallery

Figure 1: Arsenic concentrations in C horizon soil. Note the high concentration (in red) at 12 to 193 mg/kg in Nevada (Basin and Range geomorphic province) possibly due to hydrothermal sources. Reference: U.S. Geological Survey OF 2014-1082.

and their metamorphic equivalents such as slate/phyllite); average arsenic concentrations for these rocks are: 3, 15, and 18 mg/kg, respectively. Some of the highest arsenic concentrations occur in coal, ranging from 0.3 to 35,000 mg/kg. Arsenic is also concentrated in sedimentary environments by sorption to hydrous iron oxides (e.g., iron hydroxide). Arsenic can naturally accumulate in soils, possibly contaminating surface water and groundwater, and can subsequently be taken up by plants and animals affecting the food chain. Such arsenic may be derived from the parent rocks underlying soil horizons and typically this condition is reflected in the lowermost C horizon (Figure 1). Average global arsenic concentration in uncontaminated soil is 5 to 6 mg/kg; however, variations of an order of magnitude or more may occur depending on the soil type and horizon (e.g., soil B horizons tend to concentrate arsenic because of higher iron hydroxide concentrations). Typical average baseline (uncontaminated) arsenic concentrations for terrestrial rainwater is 0.02 micrograms per liter (μg/L) or parts per billion (ppb); and is 0.83 μg/L for baseline river water with a range from 0.13 to 2.1 μg/L. Higher arsenic concentrations occur locally in waters, soils, and sediments where arsenic is associated with mineralization (i.e., ore deposits) or within active geothermal systems, which can enhance background concentrations by one or more orders of magnitude. Arsenic can be easily solubilized in groundwater from surrounding aquifer materials; speciation and concentrations depend on pH, Eh (redox), temperature, and solution composition. Generally, baseline groundwater will have concentrations CONTINUED ON NEXT PAGE

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The Geochemist’s Gallery

Speciation, Relative Toxicity, and Bioavailability: In weathering environments, arsenic and arsenic-bearing minerals (e.g., pyrite and arsenopyrite) oxidize with arsenic readily forming soluble oxyanions such as hydrogen arsenate (HAsO42–). Therefore, arsenic toxicity depends on speciation; four oxidation states are known: As(–III), As(0), As(III), and As(V). As(0) forms as native elemental arsenic, rarely occurring in nature, and is not considered poisonous (toxic). Most natural speciated arsenic occurs as As(III) and As(V) under Figure 2: Eh (redox) – pH diagram for As-O-H at 25 oC and 1.0 atmosphere. Note arsenic oxyanions, where water is stable reducing and acidic conditions (Figure 2). As(III) between the two dashed lines. Reference: Takeno, N., 2005, Atlas of Eh-pH Diagrams: Introduction of Thermodynamic generally predominates Database: Geological Survey of Japan Open File Report No., 419, 285 p. and is more mobile, while under oxidizing and alkaline conditions, As(V) predominates and is less mobile. As(V) is less toxic than As (III), which in the form of arsenite (e.g., AsO3–),is considered to be 25 to 60 times more toxic than arsenate (AsO43–). However, both As(III) and As(V) are relevant in human toxicity because As(V) reduces to As(III) and is then methylated [e.g., (CH3)3As] in the human digestive system. However, organic arsenic compounds are believed to be much less toxic and even nontoxic compared to inorganic arsenic. Therefore, ingestion of low arsenic concentrations may be tolerated.

The Geochemist Gallery

ranging up to 10 μg/L. However, geothermal waters may contain significantly higher arsenic concentrations, commonly above the drinking water maximum contaminant level (MCL) of 10 μg/L (e.g., Mexico’s Los Humeros geothermal field reported arsenic concentrations as high as 73.6 mg/L).

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Arsenic’s relative acute (poisonous or arsenicosis effect) and chronic (both long-term arsenicosis and cancer effect) toxicities in animals and humans are well known. The major exposure pathway is via absorption either by ingestion or inhalation (or both). In most animal studies, the lethal oral dose (LD50) ranges from 1 to 25 mg/kg of body weight (depending on the animal) as sodium arsenite. Numerous human epidemiological studies show that long-term acute exposure results in both chronic non-cancer effects and cancer end-points with several affected organs, including the nervous system, liver, vascular system, skin, and lungs. In humans, arsenic is most commonly ingested from naturally-occurring arsenic-contaminated groundwater. Food sources such as seafood (e.g., shrimp and fish) average 1 and 4 micrograms/ kilogram (μg/kg) or ppb, respectively; pork and chicken average 1 μg/kg. Edible plants such as fruits and vegetables do not contribute significant amounts of dietary arsenic (e.g., apple juice averages 5 μg/L. However, rice has been found to concentrate significant amounts of arsenic, averaging 100 μg/kg. In a subsequent article, I’ll discuss some world sources where arsenic contaminated groundwater poses significant problems and health effects.

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LYNDSEY BLOXOM Lyndsey Bloxom is a Senior Water Resources Analyst with the Water Replenishment District and joined the GRA Board of Directors in 2020. Lyndsey’s role with the District includes management of water supply and groundwater resiliency planning efforts, strategic planning and new program initiation, and development of project budgets and outside funding streams. Lyndsey has a BS in Geology and Environmental Science from the College of William and Mary and a MS in Hydrogeology from Virginia Tech. When not planning future WRD and GRA efforts, Lyndsey spends her time rock hounding and camping in the desert or flying kites on the beach.

The 2021 Western Groundwater Congress: The Hollywood Sequel! Please save the date and plan to join us in Hollywood September 13-15, 2021, for the 4th Annual Western Groundwater Congress (WGC)! This year’s WGC will retain many of the engaging and educational aspects of past events with the addition of a bigger, more diverse planning team and an expanded technical program that aims to look forward, focusing on innovation and emerging challenges in our industry. Key Program Components will include: • Water Resources Exploration and Development • Groundwater Management • Contaminant Assessment and Remediation • Unique Challenges and New Opportunities • Diversity, Equity, and Inclusion in Groundwater • Academic & Student Research

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Optimization of Remediation

The 2021 WGC: A Hollywood Blockbuster Sequel!

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The WGC will also include numerous opportunities for networking and learning collaboratively! Workshops, panels, receptions, and interactive lunch events will provide opportunity for you to grow your network and expand your professional horizons. Our annual health initiatives, including the Darcy 5K Dash and 7-minute break-time workouts, will keep your energy up and your mind open. Please visit the event page for more information and feel free to contact the event Chair – Lyndsey Bloxom at lbloxom@ wrd.org with any questions or interest in event participation. GroundwaterX: A Workshop for Students Calling all GRA Student Members: You are invited to join fellow students at the 2021 WGC for GROUNDWATERx - a TEDx formatted workshop comprised of energizing networking and engaging presentations! This workshop will feature student and young professional speakers, each presenting highlights of their work or research for 3 minutes. Presentations will cover a wide variety of topics related to groundwater in California and beyond. This is a unique opportunity for students and professionals to network and discuss topics presented during the session. Who knows...You might find your future employer or employee at this event! The Call for Abstracts link for GROUNDWATERx is available on grac.org.

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‘Expand, Diversify and Lead’ GRA 2021-2023 Strategic Plan 2020 was no match for the fearless GRA Board of Directors, who are comprised of a dedicated group of groundwater leaders. We believe in providing highquality education, technical leadership, and service for our members. We are pleased to announce the launch of our 3-year Strategic Plan, ‘Expand, Diversify and Lead’ and 2021 Work Plan. This strategic plan reinforces our shared vision, Sustainable Groundwater for All, and our mission dedicated to resource management that protects and improves groundwater supply and quality through education and technical leadership to move us forward together.

‘Expand, Diversify and Lead’ GRA 2021-2023 Strategic Plan

The strategic plan reflects Director and GRA Leadership interviews, feedback and priorities identified through a series of virtual planning sessions held in 2020 and includes reflections from our previous multi-year plan and progress. GRA successfully navigated the uncertainties of 2020 and is ready to refocus our organization on strategies and actions to ensure long-term success and resilience. To achieve our full potential, GRA leadership, committees, branches, and membership must use the plan to help guide our work. The plan is a roadmap to improved resilience and success and is intended to be a dynamic and integrated effort. The development of our Strategic Plan reinforced our belief in both the strength each member brings to GRA and the importance of partnership and collaboration with our affiliates. Our potential is limitless when we work together!

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GRA STRATEGIC PLAN

Strategic Priorities and Actions To Achieve Them The GRA leadership worked collaboratively to identify key actions that could be taken to achieve successful implementation of each Strategic Priority. Provided below is a summary of those actions and the Strategic Priorities that will be addressed through execution of each action.

Expand & Engage

Diversify Revenue

Expand Membership Diversity & Demographics

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Optimize Member Incentives

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Align Branches & State

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STRATEGIC PRIORITIES 2021 - 2023

Enhance GRA Website Enhance Marketing Expand Affiliate Collaboration

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Enhance Board Development & Committee Operations Enable/Encourage Direct Donations

Build Be Leaders in Organizational Groundwater Resiliency

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TREVOR KENT GEI Consultants

(530) 844-1659 | tkent@geiconsultants.com

CHRIS PETERSEN GEI Consultants

(530) 304-3330 | Cpetersen@geiconsultants.com

Considerations for developing an Aquifer Storage and Recovery (ASR) Program – lessons from operators in California Perhaps you’ve already heard of ASR but are unfamiliar with exactly how it works. Maybe you are well versed in ASR and want to hear more about the industry. Or just maybe, you’ve never heard of ASR, but are always interested in ways to increase groundwater recharge. No matter what your level of familiarity is, our goal is to improve your understanding of ASR and what to consider when developing a program. This article is the first in a series on ASR and serves as an introduction to the ideas and concepts on ASR program development to be discussed in subsequent articles.

Recharge Project

So, You’re Interested in ASR?

Before we get too far along, we want to explain what exactly ASR is. ASR stands for Aquifer Storage and Recovery and is a means by which drinking water is recharged, via a well, directly to the aquifer system. ASR is a broad water management tool but is generally used for the purposes of water supply reliability and drought management. Treated drinking water is injected into the aquifer system during the wet season or during wet years and is stored for extraction during dry periods or to meet peak demand. While the drinking water is typically treated surface water, it may come from any source that meets drinking water standards under the State Water Resources Control Board. So essentially, an ASR program needs two things: 1. Water for Injection: Must meet drinking water standards. 2. Injection Wells: Wells capable of recharging water in the aquifer system. These wells may be dual purpose, capable of extraction and injection, or extraction of recharged water may occur at a separate location via a traditional production well.

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For municipalities, ASR wells may be integrated into the City’s water distribution system to effectively convey treated drinking water to the well sites for recharge. The benefit is two-fold, as the same wells can extract water directly to the water supply network. . For a presentation of how ASR may fit into an existing water supply system, see this video by the City of Roseville on their ASR program. In 2020, a Regional ASR Information Study was conducted by GEI Consultants for the Regional Water Authority on the potential of ASR for its water-supplier member agencies in the Sacramento area. As part of this study, a survey of ASR operators across the State was conducted, focusing on each operator’s program and key considerations for developing ASR programs. This information, directly from those working and managing ASR systems, along with industry experience serves as the basis for this series. Figure 1 is a location map of active and inactive programs researched as part of this study, and operators who participated in the survey.

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ASR is not new to the State of California. The oldest known active ASR program was started by the Goleta Water District in 1979 (AWWA, 2015). Approximately two dozen agencies have established ASR programs since the 1970’s, although only seven of those programs are known to be active. Furthermore, while not ASR per se, injection wells are successfully operated as part of a seawater barrier program in southern California. These wells are run by a coalition of agencies, including the Los Angeles County Department of Public Works and Orange County Water District, and inject water to address seawater intrusion. For currently active programs, ASR may serve a variety of purposes, including: • Water supply reliability and drought management • Achieving sustainable management of groundwater resources under the Sustainable Groundwater Management Act (SGMA) • Enhancing water quality • Addressing environmental concerns (i.e. depletion of surface waters and minimum instream flow requirements)

So, You’re Interested in ASR?

With the recent development of Groundwater Sustainability Plans (GSPs) under SGMA, recharge is becoming an important aspect of sustainable groundwater management. ASR is another tool with which to effectively recharge aquifer systems. There are advantages to ASR when compared to more traditional recharge options, such as spreading basins, due to its limited footprint and ability to provide recharge below confining layers.

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ASR is not without its complications though and tends to be more expensive than other recharge methods. Injection wells require continued maintenance to manage recharge capacity and prevent clogging, and increased monitoring is a typical regulatory requirement for the initial implementation period. However, using lessons learned from previous and current ASR programs, one can make informed decisions on whether ASR is the right option for a region and how to develop a sustainable ASR program. Key considerations for any program include: Regional Hydrogeology • Is ASR compatible with the local hydrogeologic conditions? • What is the expected recharge capacity of existing wells and new ASR wells? • How will recharged water effect the local aquifer system including water quality, water levels, and groundwater gradients? Program Cost: • How much does each well cost? How does this compare to traditional wells? • What are operational costs for ASR wells? • What are regulatory costs for an ASR program? Regulatory Requirements • How does one permit an ASR well or ASR program? • What are annual reporting requirements? What monitoring is required? • Are water rights an issue with the recharged water? Successful ASR programs not only address these three considerations, but continually adapt to increase efficiency and effectiveness. ASR is not a plug & play system and adaptive management allows operators to find the right operational program to suit their local aquifer conditions. For this ASR series, we will discuss each of the three program considerations above and guidelines for adaptively managing and growing an ASR program.

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Managing PFAS in Environmental Due Diligence: The Future’s Uncertain JOHN MERRILL

NED WITTE

RULA DEEB

LYDIA DORRANCE

Current approaches for managing perand polyfluoroalkyl substances (PFAS) in environmental due diligence are widely varied, due in large part to PFAS not being listed as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA, or Superfund).

Managing PFAS

This article describes approaches currently being used to address PFAS in environmental due diligence and details current and potential future impacts of PFAS on property transactions.

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Managing PFAS

Potential Designation of PFAS as CERCLA Hazardous Substances In February 2019, the United States Environmental Protection Agency (EPA) released the PFAS Action Plan, which described the EPA’s approach for addressing PFAS in the environment. Among other planned actions, the EPA noted its intention to move through the regulatory process for listing perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS) as CERCLA hazardous substances. Following the release of the PFAS Action Plan, the U.S. Congress introduced multiple pieces of proposed PFAS-related legislation, including the PFAS Action Act (H.R. 535), which the U.S. House of Representatives passed in January 2020. The PFAS Action Act would require the designation of PFOA and PFOS as hazardous substances under CERCLA within one year of enactment, and it would require the EPA to determine whether to designate all PFAS as hazardous substances within five years of enactment. Showing signs of additional movement in this direction, the EPA issued an Advanced Notice of Proposed Rule Making (ANPRM) in January 2021, seeking input on the designation of PFOA, PFOS, and other PFAS as hazardous substances and on the regulatory process for the designation. Listing PFAS as CERCLA hazardous substances would empower government agencies and third parties to clean up PFAS-contaminated sites and then seek cost recovery from the responsible party, and responsible parties could be required to cover the costs of providing alternative drinking water supplies and repairing damage to natural resources caused by the PFOS and PFOA impacts for which they are responsible. Additionally, listing PFAS as CERCLA hazardous substances may trigger revisiting or reopening sites, including once-federally-listed Superfund sites that were closed through federal or state action. CERCLA Hazardous Substances in Environmental Due Diligence The area of environmental due diligence would also be impacted by a CERCLA hazardous substances designation for PFAS. Environmental due diligence is the process of evaluating the current and historical use and ownership of a property to ascertain the possible presence of a “release” of hazardous substances. The American Society of Testing and Materials (ASTM) International Standard E1527-13 Phase I Environmental Site Assessment (Phase I) is the gold standard in environmental due diligence evaluations. The general purpose of an ASTM Phase I is to identify “recognized environmental conditions” or RECs, a term that ASTM limits to CERCLA hazardous substances and petroleum. At present, PFAS are not included in the traditional scope of a Phase I evaluation. CONTINUED ON NEXT PAGE

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Environmental professionals have responded to this gap in ASTM Phase I coverage with a wide range of approaches to include PFAS in environmental due diligence. Precedent has been established for addressing environmental concerns outside the scope of the ASTM Phase I process. One commonly encountered example is asbestos. Many environmental consultants address gaps such as asbestos— and now, PFAS—through “non-scope considerations.” Other tools to address environmental concerns that fall outside of the scope of the Phase I process include flagging these issues as “otherwise noteworthy conditions,” or as “business environmental risks,” under ASTM parlance. Some environmental professionals have also managed PFAS concerns in environmental due diligence under an independent exercise that complements the ASTM process with a separate work deliverable to the client, sometimes in the form of a privileged communication, identifying the findings of the PFAS-specific evaluation. Incorporation of PFAS into the practice of environmental due diligence is further complicated by the following: (1) PFAS are emerging as compounds of concern; what we do not know about PFAS largely exceeds what we do know about the risks they pose to human health and the environment; and (2) the type and implementation of PFAS regulations differ state by state in the absence of a consistent federal baseline. The appetite for addressing PFAS in transactional environmental due diligence depends largely on the motivation of the party to the deal. Buyers are generally risk-averse and typically want to understand the possible presence of PFAS, whereas sellers generally do not have a desire to investigate and potentially uncover PFAS contamination. Litigation Risks Loom While the need to evaluate PFAS impacts within environmental due diligence is lacking, history informs us that potential litigation implications are likely to follow. As a recent example, vapor intrusion quickly rose from a relatively unknown environmental concern to the forefront of the minds of environmental professionals as they attempted to navigate environmental due diligence obligations in the absence of established protocols and quickly developing federal and/or state regulations and guidance. And, as federal and state regulations and guidance developed, so too did cost recovery actions and toxic tort litigation seeking personal injury and/or property damages.

Managing PFAS

For responsible parties that were already engaged in ongoing investigation and remediation of vapor intrusion impacts at sites, the litigation that followed was likely anticipated. For responsible parties associated with sites that had been considered remediated years earlier, but are now being investigated for vapor intrusion impacts, the notion of litigation risks arising several years later was likely not anticipated, and in many cases, likely not considered in subsequent transactions. This pattern may repeat itself with PFAS as state and federal regulations are developed.

Groundwater Management Managing PFAS

Current Practices to Address PFAS in Environmental Due Diligence

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Conclusion The disconnect between the proposed CERCLA listing of PFAS as hazardous substances and the ASTM Phase I process lends confusion. At present, if discovered during a transaction or otherwise, the standards for PFAS investigation and remediation—and the prospect for closure—are unclear. However, environmental professionals have previously navigated similar issues with asbestos and vapor intrusion. Building upon these past experiences, consultants and lawyers are adapting to mitigate transaction uncertainty associated with potential PFAS contamination.

Author Bios John Merrill is a senior staff engineer at Geosyntec Consultants in Oakland, CA. John works on PFAS projects nationwide involving environmental due diligence, contaminated site investigation and remediation, and litigation support. Ned Witte is a shareholder at Godfrey & Kahn in Milwaukee, WI. Ned is the Market Leader for Godfrey & Kahn’s Environmental Strategies Practice Group and represents clients on PFAS matters. Dr. Lydia Dorrance is a senior scientist at Geosyntec Consultants in Oakland, CA. As a PFAS subject matter expert, Lydia serves as the technical lead on PFAS projects across the U.S. and Europe. Dr. Rula Deeb is a senior principal at Geosyntec Consultants in Oakland, CA. Rula leads Geosyntec’s PFAS program (www.geosyntec.com/pfas) and serves on the Board of Directors.

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Wells and Words DAVID W. ABBOTT, P.G., C.HG., CONSULTING GEOLOGIST Mr. Abbott is a Geologist with 45+ years of applied experience in the exploration and development of groundwater supplies; well location services; installation and design of water supply wells; watershed studies; contamination investigations; geotechnical and groundwater problem solving; and protection of groundwater resources.

Well development programs and their importance: Part 1

Wells and Words

Often times, well development (WD) is a contractor “afterthought” and is usually a surreptitious method to reduce initial construction costs in order to secure a competitively-bid project (or to meet a project budget). However, WD is crucial for the long-term successful and economic operation of a well (test, production, or monitoring). A poorly developed well can mislead hydrogeologists (or engineers). WD removes finegrained sediments and drilling fluids adjacent to the well in order to increase the near-well permeability and to repair the damage caused by drilling procedures; this, in turn, increases well-efficiency which optimizes the pumping water level for a particular discharge. I estimate the contract-time for WD as the same amount of drilling-time that is spent to install the well. This allocation can vary and depends on the drilling method, design of the well, selection of WD methods, and geological formations encountered during drilling; rarely, some wells just don’t seem to “clean-up”. There are a variety of WD methods to chose including: mechanical (i.e., surge block [Figure 1a], swab and bail; air-lift with/without isolating packers; jetting; pump development; etc.) and chemical additives (i.e., dispersants and acids). It is recommended to begin WD with the least aggressive method (i.e., swab and bail) and then progress to the more aggressive methods; starting with the more aggressive methods can damage the well and/or filter-pack envelope.

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Wells and Words

Figure 1a: Mechanical Surging tool for Well Development

The installation/construction details should be reviewed before conducting WD; include any adjacent observation wells that can help to independently evaluate well/aquifer performance and WD effectiveness. Construction details include well/boring diameters, filter-pack dimensions, total/completed depth (TD/CD) of the well, screen length/depths, construction materials, geology encountered, drilling method, and well seal locations; and, if available, downhole video/ geophysical logs. These parameters set the framework for WD. The depth to water (DTW), the CD of the well, and the filter-pack depth should be verified before any WD work begins on the well. CD/filter-pack of the well can be measured using depth sounding techniques (a heavy weight on the end of a string, tape measure, or the WD rig tools). Hydraulic measurements (water level [WL] depths and discharge) during WD will depend upon a variety of factors, including site and WD logistics/methods; available drawdown; how much development is needed; and aquifer/well response. These measurements can be useful in designing the appropriate test pump that can be installed to polish-up WD during the pumping phase and to conduct formal pumping tests; both step-drawdown and constant discharge. CONTINUED ON NEXT PAGE

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The comparison between the SC at two or more different cycles during WD can help to evaluate the pump-size for a pumping test. The SC (related to the Transmissivity) is affected by well efficiency; if the well is fairly-efficient then the SC times an empirical constant is equal to the Transmissivity. This constant is typically 1,500 for an unconfined aquifer or 2,000 for a confined aquifer. If a nearby well is available then it may provide additional hydraulic information during WD.

Wells and Words Wells and Words

Measuring the WL that follows a highly-structured methodology can be challenging and sometimes logistically impossible during WD. Informal pumping tests (i.e., bail-drawdown using a dart valve2, [Figure 1b] or airlift) can be conducted to evaluate the initial well performance by analyzing recovery WLs. This information is used to evaluate the specific capacity (SC) of the well. The SC is the discharge divided by the drawdown at a specific time since pumping began.

Figure 1b: Types of Bailers for Well Development

Wells and Words

Depth measurements should be collected with an engineers’ tape (preferred) in feet to hundredths (0.01) of a foot. A carpenter’s tape (feet and inches) can be used but it is a nuisance to convert to tenths of a foot for analysis. The WL responses during WD are typically erratic but can be useful in selecting the appropriate-sized test pump. Measure the filter-pack depth regularly during WD via the fill pipe and top-off the filter pack as needed.

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The amount of sediment (sand and silt) removed from the well should be estimated during WD. This can be accomplished by sounding the depth of the well (estimating the volume of sediment settling to the bottom) after each surge block WD cycle. Material removal can also be measured with an Imhoff cone during airlifting/jetting. The quantity of material removed from the well “should” decrease over time and between repeated WD cycles. Estimate the discharge using a stopwatch and a known volume container (i.e., 5-gallon bucket or 55-gallon drum) or by directing the water that is removed from the well to a location for measurement with a weir. If possible, record the discharge frequently while recording the DTW. Finally, this is important, assess the hydraulic and sediment data collected during the WD program while still in the field in order to evaluate the well performance and estimate Transmissivity before departing the well site. Part 2 will discuss WD with a test pump. 1 Abbott, David W., Summer 2016, The Nexus Between Energy and Water Wells – Why Well Development Matters, HydroVisions, a publication of the Groundwater Resources Association of California, Vol. 25, No. 2, pp. 12-13. 2 National Ground Water Association (NGWA), 2003, Illustrated Glossary of Ground Water Industry Terms: Hydrogeology, Geophysics, Borehole Construction, and Water Conditioning, NGWA Press, 69 p. 3 The Roscoe Moss Company, 1990, Handbook of Ground Water Development, John Wiley & Sons, NY, 493p. 4 Campbell, Michael D. and Jay H. Lehr, 1973, Water Well Technology: Field Principles of Exploration Drilling and Development of Ground Water and Other Selected Minerals, McGraw-Hill Book Company, NY, 681 p. 5 Abbott, David W., Fall 2005, How do time and discharge affect the specific capacity of a well, HydroVisions, a publication of the Groundwater Resources Association of California, Vol. 14, No. 3, pp. 12-13. 6 Driscoll, Fletcher, G., 1986, Groundwater and Wells, published by Johnson Division, St. Paul, MN, 1089 p (see p. 1021). 7 Abbott, David W., Fall 2014, Tools in the Hydrogeologist’s field kit – Devices and methods to measure pumping rates, HydroVisions, a publication of the Groundwater Resources Association of California, Vol. 23, No. 3, pp. 11-12.

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In Memory of Edwin H.Y. Lin by Iris Priestaf and Phyllis Stanin, Todd Groundwater With great sadness, Todd Groundwater submits this memorial on the death of our coworker and friend, Edwin Lin. Mr. Edwin Lin, PG, CHG, Principal Hydrogeologist at Todd Groundwater, who passed away on November 15, 2020. Edwin dedicated his professional career to groundwater basin management based on integrity, sound science, commitment to environmental sustainability, and compassion for the people and communities relying on groundwater resources. He provided more than 20 years of service as a consultant to public water agencies and private clients and was recognized for his technical excellence, skilled project management, and responsiveness to clients. Edwin earned a bachelor’s degree at Stanford University in Geological and Environmental Sciences and joined Todd Groundwater in 2000 as staff geologist. In 2003, he moved to Adelaide, South Australia, where he attended Flinders University and earned a Master of Science degree in Groundwater Hydrology. While in Australia, he conducted scientific research on water treatment for Aquifer Storage and Recovery (ASR) wellfields. Working with Dr. Peter Dillon and Dr. Declan Page at the Australian Commonwealth Scientific and Industrial Research Organisation (CSIRO), Edwin contributed to multiple publications on aquifer storage and water quality.

In Memory of Edwin H.Y. Lin

In 2006, he returned to Todd Groundwater, specializing in basin management projects—hydrogeologic characterization and conceptual models of major groundwater basins in the Mojave Desert, percolation testing, salt and nutrient management plans, well installations and Managed Aquifer Recharge (MAR), which became his core professional focus. His work on MAR projects extended across many groundwater basins in California, utilized diverse sources of water, involved multiple techniques and monitoring, and addressed a variety of issues from overdraft to seawater intrusion to optimization of conjunctive use of surface water and groundwater. He developed expertise in

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In Memory

groundwater flow and vadose zone modeling, geochemical analyses, and application of advanced environmental statistics. Presented with opportunities to work with many water agencies, he responded with outstanding technical service and responsiveness to clients and developed longstanding relationships of shared purpose and mutual respect, trust, and friendship. A compliment from a client and friend that Edwin deserved and always remembered: “You make it easy.” Edwin shared his experience and knowledge generously with colleagues. He was a long-time member of GRA and attended many GRA meetings, symposia, and conferences. He provided presentations on MAR at various venues, including GRA and the International Symposia of Managed Aquifer Recharge, with outstanding papers: Storing water in California Desert Basins: Selection of MAR Sites in the Ames Valley Groundwater Basin (2007), Intrinsic Tracer Study for the West Coast Basin Barrier Project (2010), and Regional Water Quality Changes from Recycled Water Recharge (2013). In 2017, he became Principal Hydrogeologist at Todd Groundwater, recognized for his technical contributions, project management accomplishments and steadfast service to Todd Groundwater, particularly in his mentoring and support of up-and-coming staff. As a hydrogeologist, he was data driven and highly creative. He wanted to see and understand every technical detail; yet, while holding those details in his head, he could also see the big picture—two qualities uncommon in one person. He brought an open-minded curiosity to each scientific problem with a need to understand “why.” And he had an impish grin that he would flash when he figured it out…and he was usually the first with the explanation. He moved easily through his work and treated everyone he encountered with grace and kindness. All his co-workers admired and respected him, and we miss him every day. We now strive to add a little bit more of Ed’s approach to our work to honor his life as our Principal and friend. Edwin is survived by his wife, Phoebe Grow and his two daughters, Tasmin and Naomi. A fund has been established for Tasmin and Naomi to support their development, activities, and education.

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GRA Requests Nominations for the 2021 “Lifetime Achievement” and “Kevin J. Neese” Awards The purpose of the GRA Awards Program is to recognize exceptional individual contributions and noteworthy projects related to the understanding, protection, and management of groundwater resources.

GRA Requests Nominations for the 2021 “Lifetime Achievement” and “Kevin J. Neese” Awards

All nominations for the Lifetime Achievement and Kevin J. Neese Awards must be received by GRA no later than Friday, April 16, 2021. Nominations should be completed using the online nomination form available on the GRA website at Lifetime and KJNeese. Nominations should not exceed one page, identify the award for which the nomination is made, and include justification for the award based on the award descriptions presented below. Additional supporting documentation is welcome. GRA may contact nominators for additional information as necessary. The GRA Awards will be presented to the recipients selected by the GRA Board of Directors during the Fourth Annual Western Groundwater Congress (30th GRA Annual Meeting) in Burbank, CA, September 13-15, 2021. AWARDS

Lifetime Achievement: Presented to individuals for their exemplary contributions to the groundwater industry, contributions that have been in the spirit of GRA’s mission and organization objectives. Individuals that receive the Lifetime Achievement Award have dedicated their careers to the groundwater industry and have been pioneers in their field of expertise.

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GRA Requests Nominations

Previous Lifetime Achievement Award recipients include:

• 2020 – Dr. Graham Fogg • 2019 – Dr. Dennis Williams, PG, CHG • 2018 – Dr. Dennis Helsel • 2017 – Dr. Daniel B. Stephens • 2016 – Dr. Miguel A. Mariño (1940 - 2016) • 2015 – Dr. John A. Izbicki • 2014 – Dr. David Huntley (1950 – 2015) • 2013 – Dr. Shlomo P. Neuman • 2012 – Anne J. Schneider, Esq. (1947 – 2010) • 2011 – Joseph C. Scalmanini, PE (1945 – 2014) • 2010 – Dr. John A. Cherry • 2009 – Dr. T.N. Narasimhan, PG (1935 – 2011) • 2008 – Dr. Perry L. McCarty • 2007 – Dr. Herman Bouwer (1927-2013) • 2006 – Glenn A. Brown, PG, CEG (1924 – 2015) • 2005 – Dr. Luna B Leopold, PG (1915 – 2006) • 2004 – Dr. John D. Bredehoeft • 2003 – Rita Schmidt Sudman • 2002 – Thomas W. Dibblee, Jr., PG (1911 – 2004) • 2001 – Carl J. Hauge, P.G., CEG • 2000 – Dr. Joseph H. Birman, PG, GP, CEG, CHG (1924 – 2015) • 1999 – Dr. David Keith Todd, PE (1923 – 2006) • 1998 – Eugene E. Luhdorff, Jr., PE (1930 – 2010)

Kevin J. Neese: Established in 1999 to honor the late GRA Director, geologist, and attorney, the Kevin J. Neese Award recognizes a recent, significant accomplishment by a person, persons, or entity that fosters the understanding, development, protection, and management of groundwater. Previous Kevin J. Neese Award recipients include: • 2020 – Water Replenishment District of Southern California’s Albert Robles Center for Water Recycling & Environmental Learning • 2019 – National Aeronautics and Space Administration’s Jet Propulsion Laboratory Land Subsidence Monitoring Team for developing detailed information on land subsidence across the San Joaquin Valley during the 2012 to 2016 drought. • 2018 – Los Angeles Sustainable Water Project for a study that examines all water resources within the Los Angeles area and whether integrated management of those resources can be accomplished to achieve 100% reliance on locally sourced water by the year 2050. The study was the product of UCLA Institute of the Environment and Sustainability, the Colorado School of Mines Hydrologic Science and Engineering Program and the UCLA Sustainable LA Grand Challenge. • 2017 – Center for Groundwater Evaluation and Management (GEM) of Stanford University School of Earth, Energy, and Environmental Sciences for the application of groundbreaking surface and airborne geophysical work that is being done by this group to the application of groundwater characterizations. • 2015 – California Department of Water Resources for its significant contributions to local agencies to advance groundwater planning, management, and conjunctive use with Regional Partnerships, Integrated Regional Water Management, and Drought Grant programs. • 2014 – Governor Edmund “Jerry” G. Brown for his leadership in developing sustainable groundwater management legislation and shepherding it through the legislative process.

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GRA Requests Nominations for the 2021 “Lifetime Achievement” and “Kevin J. Neese” Awards

Recharge Project GRA Requests Nominations

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• 2013 – Santa Clara Valley Water District for implementing its unique Domestic Well Testing Program. • 2012 – David L. Orth, General Manager of the Kings River Conservation District for his leadership and dedication to the collaborative initiatives to develop the Upper Kings River Basin Integrated Regional Water Management Plan. • 2011 – Sacramento County Environmental Management Department for its Abandoned Well program, the first of its kind in California. • 2010 – Senator Fran Pavley for her leadership in the enactment of the comprehensive, statewide groundwater level monitoring legislation in California. • 2009 – U.S. Geological Survey, California Water Science Center for its development of a new 3-dimensional groundwater-modeling tool for California’s Central Valley and report “Groundwater Availability of the Central Valley Aquifer,” Professional Paper 1766. • 2008 – Orange County Water District for its Groundwater Replenishment System (GRS), a new water purification plant that became operational last January. • 2007 – University of California Cooperative Extension Groundwater Hydrology Program for its efforts to engage scientists, regulators, farm advisors, dairy industry representatives, and dairy farmers to better understand the effects of dairy operations on water quality. • 2006 – Senator Sheila Kuehl for her work to improve the production and availability of information about California’s groundwater resources. • 2004 – California Department of Water Resources for its publication in 2003 of its updated Bulletin 118: “California’s Groundwater”. • 2002 – Glenn County Water Advisory Committee for its formulating a significant groundwater management ordinance that was adopted by the Glenn County Board of Supervisors. • 2001 – American River Basin Cooperating Agencies and Sacramento Groundwater Authority Partnership for fostering the understanding and development of a cooperative approach to regional planning, protection and management of groundwater. • 2000 – Board of Directors of the Chino Basin Watermaster for delivering a remarkable OBMP that created a consensus-based approach for making water supplies in the Chino Basin more reliable and cost effective. • 1999 – Governor Gray Davis for his work and leadership in addressing MTBE.

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