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

February 20,2012

J. Patrick Lucas, PresidentLehman Hot Sprints LLC16004 SW Tualatin-Sherwood Rd.Sherwood, OR 97140 .

Re: Lehman Springs Ground Water

Patrick,

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

. Location:

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

Geology/ground water flow

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

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

24735South Central Point Road' Canby, Oregon 97013 Office 503.263.7852 • Cell 503.307.8916• Fax 503.266.5974

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Figure 1Site Location

located on a bench to the northwest of the lodge. This well is 495 feet deep, andencountered basalt at just 30 feet below grade.

The second well may belong to one of the cabins along WarmSprings Creek. It wasdrilled in 2005, and is only 135 feet deep. This well encountered basalt at just 24 feetbelow grade. It should be noted that the water temperature in the resort well wasmeasured at 62 degrees when it was originally drilled, and the other well was measured at63 degrees. This is much lower than the temperature of the hot springs, which indicatesthat the source of the hot springs water is different than the water bearing zones that weretapped by these wells.

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

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

Potential Problem - Are treatment ponds leaking?

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

Evidence for:

The main evidence is the continuing presence of seeps at the base of the upper pond andalso from the edge of the berm on the lower pond. To my knowledge, this water has notbeen tested for e. coli, which would have been a reasonable thing to do, but DEQpersonnel have stated that it "looks like" it should be wastewater from the pondsApparently, the water from the Tree Seep, the hot springs, and the sewage lagoons wastested for anions and cations to allow for the development of a Piper Diagram. The PiperDiagrams are used to determine whether or not the waters are from the same source. Theassumption by DEQ personnel is that the water in the seep is a mixture of hot springwater and sewage water.

Figure 2Location of Springs

Evidence against:

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

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

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

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

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

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

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

In July of2006, a series of soil samples were collected by Evem Northwest from the areanear the Tree seep. These samples were analyzed for e. Coli bacterial and all were foundto be non-detect.

The liner has been tested and found to be solid, this would eliminate leakage.Additionally, the pond has been completely drained and a detailed inspection of the linershowed it to be intact. The liner was placed on soil that had been compacted prior to theinstallation ofthe liner. Appendix C shows the installation of the liner.

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

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

Potential spring sources - The two springs that are in question as possible "leaks" fromthe treatment ponds are at the base of the upper pond and again at the base of the lowerpond. The ponds are constructed of compacted soils, most likely with a permeability of10-4 em/see or less, and are much less permeable than the surrounding soils. Any watercoming off the hillside and encountering the well-compacted pond walls would beexpected to take the path of least resistance and move around the side of the pond until itcould continue its journey down hill to the creek. In some cases, the water would"daylight" when it ponded up against the treatment pond walls. The fact that thetreatment ponds are lined would only make this scenario more likely.

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

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

Discussion/Conclusion:

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

Evaporation pan testing has shown that the evaporation rate of the ponds matches whatshould be expected given the conditions at the site. The test concluded that the pondswere not leaking.

The seeps that were assumed by the DEQ to be sewage leaking form the ponds werenever tested for e.coli bacteria. They were just "assumed" to be leakage from the ponds.

After dye testing the upper pond, the EPA determined that the seep on the berm betweenthe ponds was not from pond water.

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

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

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

Respectfully, Submitted

£$Tim O'Gara, R.G

Appendix AEvaporation Pan Data

LEHMAN HOT SPRINGSSEWER LAGOON LEAK STUDY

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

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

Conditions:• The test period is conducted ftom. mid..day on May 27~through mid-day on June

3, 2009, or a period of 6 full days.

• There is no measurable precipitation through the test period.

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

• Wind and Humidity are approximately normal for this time of year with.noextremes.

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

• Each Lagoon (pond) is hydraulically isolated.

Q6/1~/2009 15:04 FAX 54'.932.4430 FERGUSON-SURVEYING

Methodology;

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

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

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

Raw Data as Measored in the Field

UPPER POND LOWER. PONDBegin Test May 27. 2009 @ 12:30 P.M.

Evaporation Pan Depth = 0.39' - Evaporation Pan Depth =0.35'Water Surface Elevation == 98.76' Water Surface Elevation = 91.62'

Change in Pan Surface = 0.087

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

Change in Pond Surface =0.06'

End Test June 3, 2009, @ 11:30 A.MEvaporation Pan Depth "'" 0.31' Evaporation Pan Depth = 0.27'Water Surface Elevation = 98.70' Water Surface Elevation =- 91.56'

~S/t1/2009 15:04 FAX 541+932+4430 FERGUSON-SURVEVING

Leakage:

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

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

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

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

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

Cond1lSion:

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

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

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Appendix BPond/Spring Lab Data

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Northin9(Y)i806.1249921.1029832.6649685.911g3&4..••ae9J8~.6060891.200

at221l"-:! 32'---

.Seep at.i' toe of upper lagoon

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alN1RCI. POINTSEoaLinQ(X) [I • .,,(Z),!:1259.212 i63,'20l!}o\9B.050 9~.J&O10744.148 9~9.490,ooe.s.:!12 960.67010857.442 978.050IO~36.!>73 1000.OOll10549.346 959.580

OescrLpllOl'l5/8."", OPe(lrUI.Qbr.lplk.1!.~led br. -.pile.QrUllClb',IIP'k,drlll,db •. lplki5/8.ebarOPC5/8 ret>at ope

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1SCALE I" = 30'

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ASSUMED WYAnON

lliilliQo PONOUN[II

P\'C PIPE AS N01EO

~FEt4CE

A CONTROL POINT

970 ELEVATION CONTCliR

_____ LINE: or SIeHl ClOs(OLOOP TRAVERSE:

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SURVEY FORCA$CAOEEARlliSCIE~ESAnN: OOUGLA5 R. WAto'TA'07 ISLANO AV'ENUElACRMI>f:. OR 978~(5.')~3-7758

~1~\~;(6~OlEAERIAL. PHOTOGRAPHYASSlJIdEO ElEVAllON~EYPERFORI.tEO1JSjN{) A PEltlTrI.X 1~-10tOTAL srA1X)H.

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

April 15~2009

Rob GrandinettiEPA Region 10309 Bradley Blvd. Suite 115.Ri~WA 99352

Deat Mr. Grandinetti:

The following results are from samples submitted to our laboratory for analysis on April10,2009. All analysis were performed using methods outlined in Standard Methods forthe Examination of Water and Wastewater, 20th edition. If you need additionalinformation regarding these methods or results please contact David ~iIler at (509) 460-4206.

NOTE:

Sincerely,

.!2.tJ£~David E. MillerLaboratory Supervisor

~NVJP.ONMEN1Al HEALTH COf>\.'V\UNITYtlEI'\Litl ClONTERS0412 w.. Cbri: Sfreet

P~"""'99301!'hens: ~ 547-9737

Q 310 7th 5IseetPtouer, WA 99350Phone: (5OPI7I6o-16:13

I \YnH' ,S MICROBIOLOGICAL ANALYSIS \I ..,----. 1 Ill!":, Public Water supplies i

(il~,:::~reLehVht0nrfo+ Spri t:iS II!; LE7 Dn::::::~:o~:: I

1I 419 SW 5th Street

\' Address: Ii 97801:,'1' Pendleton, Oregon

II u 5412760385II City, State, Zip: ,¢f\ F 5412762041

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\I Report Address IiII Name: ------------------ Ii QUANTITATIVECOLIFORMANALYSIS

II Address: I Bottle Lot #: V- 0, 0 ~'z..

I~' State, Zip: __~b Sample 10#: _C):...-"..!.-=-O~CP~I:...::J..::..-!f\.::L?-.::::::"'- __-=--_-..._-__-._ I

Ir-Sample Collection Date/Time: (J ~ 1 I '2.. I ~ 0 ~ : '3<) rzr AM I

III ~ ---o;y Year Hour ~ D PM

i Collected By: ~ '"t~_D""~ III! Sample Point: to~ of Vi ~ ~(r 19'')':~\)Y\ --n,I 'IIf~ddress,~ I,

!\,I PWS#: I411 rinil (Water Districts Only) II.1 III i Sample Type: D Waste Water III Source Water 0 Flowing Stream D Reservoir / Lake 'J3JOther (specify) _L..:...o.::.....,':)~C>.:...t>_YJ-'-____ IL ----- -- .__ d

Sample Received DatelTime: 0<0 f:>.. b~ CJ~ :'-1-( ~AM Initials: ~DPMMonth / Day / Year Hour Min

-I~ Ljo ~AM C-Analysis Start DatelTime: 0 (; 1'2.. 0<1 Initials:

Month / /DPM

Day Year Hour Min

Temp: 't °C

II!I'

ICheck all that apply.

ORELAPMethod(s): 1ij] SM 9223 rgn Colilert Quantitray D Other ------------1 ~.;;~iSComplete Oalemme

Month 1Day 1Year Hour Min Analyst Reviewer signatf

II Raw Results Total Coliform E.coli Final ResultsI

ri # Large Wells Positive $~ 0 Total Coliform ~4 MPN 1100 mls

I # Small Wells Positive 7 E.Coli < \ MPN 1100 mls IiI{) t

I MPN 1100 mls p I~(, .c::.\ II!

-IfFax Results Fax # ~S't\l =r:1 @ 'k? <Corn letedgEmsil Results Address E,,J3'::2-11 -"ti7J rli com:leted It

o Call Results P_h_o_ne_# Completed============-_~l!lTest results relate only to the parameters tested and to the samples as received by the laboratory. Test results meet all requirements of

NELAC unless otherwise noted. This report shall not be reproduced, except in full, without written consent of this laboratory.

Appendix CLiner installation Photos