April 30 2017 / Monterey Bay Partisan
Cal Am's Scientific Methodology Can be a Little "Crooked"
By Michael Baer
On April 13, Cal Am wrote a letter to the Peninsula Mayors Water Authority, responding to a letter from Public Water Now and other parties citing “alarming deficiencies” on the Monterey Peninsula Water Supply Project (MPWSP). The letter from Public Water now cited lack of water rights and poor science surrounding the slant well ocean intakes proposed for the Cal Am desalination plant.
The Cal Am letter was signed by desal project manager Ian Crooks. An excerpt follows:
“The most definitive and best science to determine the feasibility of slant wells is to drill and operate an actual slant well in the proposed project location and observe its performance. Cal Am’s test slant well at the CEMEX property in Marina has accomplished just that and proven unequivocally over its 480 days of pumping that slant wells are a feasible technology for our project. The important indices are yield, reliability and water quality, and results in all three areas are outstanding.” (Italics and bold added)
I wish to rebut this statement as vigorously as I can.
Traditional “scientific method” would support Mr. Crooks’ first sentence. Scientific method requires a hypothesis, and the hypothesis of this “experiment” is that a slant well can sustain a continuous extraction rate of 2,000 gallons per minute (gpm) from the proposed location without harming the groundwater. Extensive modeling by notorious hydrogeologist Dennis Williams, president of GeoSciences, was presented in the first environmental impact report iteration in 2015, and was modified by HydroFocus and Lawrence Livermore Labs in the recirculated version now pending. This extensive modeling “finds” that the hypothesis is correct and therefore that the damage to the existing surrounding coastal aquifers of the Salinas Valley River Basin is “insignificant.”
This is where a test slant well comes into play: To test the modeling work with a field test. This is also sound experimental design based on the scientific method. However, it is at this point I must diverge from Mr. Crooks and his statement highlighted in bold above. Let’s examine the “outstanding” results of the thre indices, one at a time: Reliability, yield and water quality.
Reliability
The long-term pumping test began on April 22, Earth Day, 2015, which was 722 days before Mr. Crooks’ letter to the mayors. Assuming he accurately represents that the pumping had continued for 480 days as of April 13, that means the pump had been idle for 242 days, or just over 33 percent of the total time. Who in their right mind would rate a 67 percent reliability performance as outstanding? When I was going to public high school that rate of performance was known as “a D.”
Yield
CalAm has consistently made claims, widely reported in the local papers and public meetings, that the slant well yield has “exceeded expectations,” steadily drawing between 2,000 and 2,200 gallons per minute (gpm) when it is operating. But here is the problem. There is no evidence or data to support the claim within the public sphere. The current EIR presents no such information. The Hydrological Working Group (HWG), a team of hydrogeologists including Dr. Williams, monitor and measure the well’s performance as required by its permit issued by the California Coastal Commission. The HWG is required to post weekly reports on the public website www.watersupplyproject.org and submit monthly reports to the acting director of the Coastal Commission, which are also posted on the website. The monthly reports are nearly 1,000 pages, reporting minutiae gathered electronically every five-15 minutes about the groundwater and salinity levels at the monitoring wells. Yet the yield results about how many gallons of brackish water are being sucked through the slant well and tossed out to sea through the existing outfall pipe appear nowhere in any of the documentation of these lengthy reports.
As far as “yield exceeding expectations,” you will just have to take Cal Am’s word for it, and surprisingly, everyone seems to (and are damned jolly that it is going so well!) However, in my experience, I have learned to never take Cal Am’s word for anything. Except when they tell us our rates are going up. I always believe them then.
Water Quality
Cal Am reports about water quality are focused solely on the level of salinity of the water drawn through the slant well. The company hopes for a salinity percentage as high as possible. The higher the seawater percentage (i.e. the percent salinity of the brackish water), the lower the percentage of fresh water coming from the landward aquifers and the less water that has to be delivered to Castroville to satisfy the agency act in the “return water agreement.” The agreement is a ridiculous plan cobbled together by politicians, bureaucrats and lawyers that could cost ratepayers millions of additional dollars annually and would require an entire essay to describe its stupidity in detail.) These folks are relatively pleased that the salinity was recently measured at 92 percent seawater. However, the percolating winter deluge will likely dilute that percentage, pumping even more freshwater out to sea this spring. They predict and hope that salinity at the slant well will rise to the target level 96 percent seawater or higher once they install sevem more production slant wells, and start sucking out groundwater at over 10 million gallons per day.
You might be wondering how such a volume of pumping could be expected to have “insignificant impact” on the surrounding aquifers and so do I. It seems like magic, and I suspect magical thinking here regardless of what the extensive modeling in the EIR predicts. Fortunately, the test slant well experiment has provisions to collect data on this aspect. Monitoring wells in the area help determine what is going on in the groundwater near the slant well pump.
So, what has happened at the threshold monitoring well in the 480 days out of 722 of the long-term pumping test as of April 13, 2017? The answer is that the salinity has steadily and “very slightly” risen by over 25 percent in that time. That is an alarming number! This result is further accentuated by the fact that in the 26 days prior to the beginning of any slant well pumping (the only baseline there is at the site) the salinity at the threshold well actually dropped by 2.2 percent.
Rising salinity at this spot indicates significant rising seawater intrusion into the basin. Mr. Williams and the HWG claim that these results are unrelated to the impact of a single test slant well operating only 67 percent of the time. They say it is for other reasons, but they do not quantify nor verify those claims with data.
The science is poor because the scientists have a predetermined outcome that goes beyond normal bias. But what can you expect when you are examining science reports from Cal Am and its Crooks?
Michael Baer is a retired public school science teacher, a 30-plus year resident of the Monterey Peninsula, and a local water activist.
January 14, 2016
Test Slant Well Has Extraordinary Conflict of Interest, Maybe More than One
Cal Am's desal project proposes intake wells near Marina. Research by Public Water Now discovered a conflict of interest. Dennis Williams and his company Geoscience owns international patents for slant well design and installation. Williams subcontracted to Cal Am AND the CPUC for evaluating the substance of test well modeling, data collection, and evaluation. Cal Am did not disclose to CPUC, nor the other members of the Hydrogeologic Working Group, nor the Mayors Water Authority, that Williams had these patents.
Cal Am initially denied, then admitted, that it was using the patents.
The CPUC agreed that there was a conflict, terminated its involvement with Williams/Geoscience and ordered Cal Am and Geoscience to reveal all their contract relationships. Cal Am and Geoscience also signed a new “no fee” agreement for the patents. The CPUC has made no statement whether its investigation continues, or has concluded.
This conflict is extremely serious because the company that can profit the most by a successful slant well test is the very same helping to determine if the test is successful. A more astonishing conflict of interest is hard to find.
This conflict of interest is extraordinarily important because the success of the slant well experiment is being closely watched statewide. Major state agencies want a successful subsurface intake, as it tries to restrict open ocean intake for environmental reasons. The state has ordered that subsurface intakes be tested and pursued, if feasible, before considering other options. If conflicts of interest reveal a bias toward success, then the test will not be legitimate. Professional opinion arising from a conflict of interest must always be questioned for bias and ulterior motives.
Cal Am also plans on a short test period of about one year before the CPUC is asked to approve the project. That means less data over less time will be subject to greater influence by key opinion makers. Ulterior motivations by any party could carry more weight when the data trail is short and less robust. It is a fool's game to defend the short test period to ward off problems with the Cease and Desist Order. A speedy schedule is an expensive risk, and it falls on ratepayers. .
A second potential conflict of interest involves the agreement between Williams/Geoscience and the slant well driller – Bourt Longyear. The patents are world wide. Bourt Longyear is an international driller. Does this potential for their joint future financial gain by sharing in royalties give them a vested stake in this test being successful? Are there ulterior motives that could influence their work and opinions, to be exploited to their advantage? Are there unknown financial incentives for “success”? Could self-serving interpretations exaggerate or falsify feasibility, cost effectiveness and therefore improperly suggest “success” of the test well?
The tainted and low credibility test well has these impacts:
1. Ratepayers pay for others to make millions.
2. Ratepayers pay for an experiment that serves state interests.
3. Ratepayers take the financial risk for failure and stranded costs.
4. A shortened test period serves only those who may profit. It does not answer the state's question of 'feasibility”, nor generate facts for future use and guidance.
5. Mandated expensive testing throws all risks on local ratepayers.
The CA Public Utilities Commission (CPUC) and the California Coastal Commission (CCC) should investigate this second potential conflict of interest. Furthermore both should be extremely doubtful over a bias of Geoscience based on proven conflict of interest.
August 7, 2015 / Monterey Bay Partisan
Coastal Commission Must Be Cautious in Assessing Desalination Test Well
By George Riley
The following is my Aug. 7 letter to the California Coastal Commission’s executive director, Charles F. Lester, regarding the Cal Am test well:
Dear Mr. Lester,
Public Water Now (PWN) is the group that discovered the patents owned by Dennis Williams and Geoscience. PWN alerted the public about potential conflicts of interest. PWN is also the group that has harped on the phrase issued by the State Water Resources Control Board about pursuing subsurface intakes, “if feasible”, prior to pursuing other options.
I am writing to alert you to related issues that I hope you consider in the review of an amended permit for Cal Am, and the follow up monitoring and evaluation of data and circumstances re this test slant well.
PWN is well aware of the desire by you, the State Water Resources Control Board, California Public Utilities Commission, and others in the state that want a successful subsurface intake for desal facilities. PWN is also aware of the environmental reasons, and we do not disagree.
But PWN strongly objects to several factors that are in play, and you have a role in considering them.
How does the CCC remain objective and focused on the facts when it has a obvious public policy to support subsurface intake? PWN questions the depth of objectivity CCC will bring if the overlying policy goal is a successful subsurface intake for desal. Will CCC go the extra mile to guarantee its objectivity and interest in validated data and analysis? Is the CCC open to looking beyond the face value of the data it receives?
The patent royalty relationship between Dennis Williams/Geoscience and the driller – Bourt Longyear – has not been queried. Is it possible that substantive financial relationships exist between these two that could cause the data to be skewed to serve ulterior motives? Will CCC look into the contract relationship between Williams and Boart Longyear? Will CCC determine there are no royalty and shared self interests in the contracts or in the actual test well operations that could skew their reports?
Will CCC question the financial relationship of these key sources of data and opinion?
PWN has felt for some time that the specific test period got cavalier treatment by the CCC. I made this very point at your hearing in November 2014 on the initial permit. Since slant wells are not in use anywhere in the world, how can CCC not absolutely insist on a valid test period?
Not knowing what is a valid period, surely sophisticated professional attention is required. What is a valid test period? Will CCC opine on this? Will CCC prescribe a valid duration for the test period?The only known subsurface intakes for desal have occurred in California – Dana Point and Sand City.
1) Dana Point results after 18 months of test slant well pumping are these: no conclusions on viability; some sand infiltration problems; and pumping efficiency declined from over 90% to about 55% over 18 months.
2) The data from the Sand City vertical subsurface wells for a small 300 acre foot/year plant shows actual pumping efficiency over 4 year of operation to be in serious decline:
From Sand City Public Works, calendar year:
2011 96.8%
2012 69.6%
2013 64.8%
2014 60.8%
From Monterey Peninsula Water Management District, water year
2011 91.9%
2012 80.7%
2013 62.3%
2014 59.5%
This data on Sand City tells a very negative tale about reliability, and therefore viability. Why does pumping efficiency with subsurface intake decline so significantly over a few years? Dana Point and Sand City data clearly make this point! Has the CCC considered this? This is why a valid test period is critical. Experience so far does not dictate a “full speed ahead” mentality. In fact it screams out for caution. And to be skeptical about any optimism about short term data. The telling will be in the testing, and in the duration, not the first data available.
Will CCC require a legitimate test period of two years or more? Remember, Cal Am originally proposed a two year test period. But with unexplained lower performance at Sand City, is two years adequate?
Every diagram example in all sources describe slant wells as penetrating far enough under the sea floor to extract water from beneath the sea floor. The intent is clear – to avoid aquifer interference, and perhaps to avoid related water rights claims. But the Cal Am test well does not penetrate the vertical line at the mean high tide line. It stops landward of that line. Would this “test well” meet your normal standard for a test of under sea floor intake? The fact that it did not extend under the sea floor area should raise questions about design or engineering?
Was the drilling length too risky or difficult? Was the drilling capacity limited in some way? Is this an issue for feasibility? Was the design under the patents too limiting? Should horizontal directional drilling still be an option? Are there more experiments that should take place? Did the insistence on the removable casings create engineering demands that were excessive? Could the guidelines from the State Water Board have established too high a level of outcome that was too expensive for success? The fact of a shorter test well length than intended (by the proponent, the patent holder and the public promotion) must get questioned regarding its use as a “test”?
Furthermore the plan of Cal Am to proceed directly from a short test period into a development permit for nine production wells makes a farce of all the publicity about the “test well” being a legitimate test well! The plan of Cal Am is based on assumptions, not tests. There are enough questions about long term performance reliability and cost acceptability that should ring alarm bells at the CCC, and elsewhere.
Working out the details and the costs of this experiment should not fall on the ratepayers. This is a state-sponsored requirement, and should have significant state funding. I doubt you have access to funding assistance. At least you might acknowledge the unfairness of the state, and the corporate utility, foisting this unproven and little scrutinized experiment on ratepayers.
The CCC, having jurisdiction over the efficacy of slant well impacts, and having a deep interest in the long term success of subsurface intakes, should have a particular interest in seeing that it is done right. This is too new for the CCC to feel comfort in self-interested promoters and contractors.
Whatever happened to the precautionary principle?
If there is to be a successful test, there must be conscientious and professional attention to the fact that slant wells have never been successfully constructed and become operational anywhere in the world.
Costs can become astronomical, and should not fall exclusively on local ratepayers. State resources must be made available, since it is a policy goal of several state agencies for subsurface intakes. And the facts of declining pumping efficiency should also raise alarms.
We sincerely hope you will take these issues into account during deliberations and analysis of Cal Am’s amended permit.
Respectfully, George T. Riley, Managing Director Public Water Now
July 11, 2015 / Monterey Herald
George Riley: Potential Conflict of Interest, Ratepayers Beware
By George Riley
The following is my Aug. 7 letter to the California Coastal Commission’s executive director, Charles F. Lester, regarding the Cal Am test well:
Dear Mr. Lester,
Public Water Now (PWN) is the group that discovered the patents owned by Dennis Williams and Geoscience. PWN alerted the public about potential conflicts of interest. PWN is also the group that has harped on the phrase issued by the State Water Resources Control Board about pursuing subsurface intakes, “if feasible,” prior to pursuing other options.
I am writing to alert you to related issues that I hope you consider in the review of an amended permit for Cal Am, and the follow up monitoring and evaluation of data and circumstances re this test slant well.
PWN is well aware of the desire by you, the State Water Resources Control Board, California Public Utilities Commission, and others in the state that want a successful subsurface intake for desal facilities. PWN is also aware of the environmental reasons, and we do not disagree.
But PWN strongly objects to several factors that are in play, and you have a role in considering them.
How does the CCC remain objective and focused on the facts when it has a obvious public policy to support subsurface intake? PWN questions the depth of objectivity CCC will bring if the overlying policy goal is a successful subsurface intake for desal. Will CCC go the extra mile to guarantee its objectivity and interest in validated data and analysis? Is the CCC open to looking beyond the face value of the data it receives?
The patent royalty relationship between Dennis Williams/Geoscience and the driller –Boart Longyear – has not been queried. Is it possible that substantive financial relationships exist between these two that could cause the data to be skewed to serve ulterior motives? Will CCC look into the contract relationship between Williams and Boart Longyear? Will CCC determine there are no royalty and shared self interests in the contracts or in the actual test well operations that could skew their reports?
Will CCC question the financial relationship of these key sources of data and opinion?
PWN has felt for some time that the specific test period got cavalier treatment by the CCC. I made this very point at your hearing in November 2014 on the initial permit. Since slant wells are not in use anywhere in the world, how can CCC not absolutely insist on a valid test period? Not knowing what is a valid period, surely sophisticated professional attention is required. What is a valid test period? Will CCC opine on this? Will CCC prescribe a valid duration for the test period?
The only known subsurface intakes for desal have occurred in California – Dana Point and Sand City.
1) Dana Point results after 18 months of test slant well pumping are these: no conclusions on viability; some sand infiltration problems; and pumping efficiency declined from over 90% to about 55% over 18 months.
2) The data from the Sand City vertical subsurface wells for a small 300 acre foot/year plant shows actual pumping efficiency over 4 year of operation to be in serious decline:
From Sand City Public Works, calendar year:
- 2011 96.8%
- 2012 69.6%
- 2013 64.8%
- 2014 60.8%
From Monterey Peninsula Water Management District, water year
- 2011 91.9%
- 2012 80.7%
- 2013 62.3%
- 2014 59.5%
This data on Sand City tells a very negative tale about reliability, and therefore viability. Why does pumping efficiency with subsurface intake decline so significantly over a few years? Dana Point and Sand City data clearly make this point! Has the CCC considered this? This is why a valid test period is critical. Experience so far does not dictate a “full speed ahead” mentality. In fact it screams out for caution. And to be skeptical about any optimism about short term data. The telling will be in the testing, and in the duration, not the first data available.
Will CCC require a legitimate test period of two years or more? Remember, Cal Am originally proposed a two year test period. But with unexplained lower performance at Sand City, is two years adequate?
Every diagram example in all sources describe slant wells as penetrating far enough under the sea floor to extract water from beneath the sea floor. The intent is clear – to avoid aquifer interference, and perhaps to avoid related water rights claims. But the Cal Am test well does not penetrate the vertical line at the mean high tide line. It stops landward of that line. Would this “test well” meet your normal standard for a test of under sea floor intake? The fact that it did not extend under the sea floor area should raise questions about design or engineering?
Was the drilling length too risky or difficult? Was the drilling capacity limited in some way? Is this an issue for feasibility? Was the design under the patents too limiting? Should horizontal directional drilling still be an option? Are there more experiments that should take place? Did the insistence on the removable casings create engineering demands that were excessive? Could the guidelines from the State Water Board have established too high a level of outcome that was too expensive for success? The fact of a shorter test well length than intended (by the proponent, the patent holder and the public promotion) must get questioned regarding its use as a “test”?
Furthermore the plan of Cal Am to proceed directly from a short test period into a development permit for nine production wells makes a farce of all the publicity about the “test well” being a legitimate test well! The plan of Cal Am is based on assumptions, not tests. There are enough questions about long term performance reliability and cost acceptability that should ring alarm bells at the CCC, and elsewhere.
Working out the details and the costs of this experiment should not fall on the ratepayers. This is a state-sponsored requirement, and should have significant state funding. I doubt you have access to funding assistance. At least you might acknowledge the unfairness of the state, and the corporate utility, foisting this unproven and little scrutinized experiment on ratepayers.
The CCC, having jurisdiction over the efficacy of slant well impacts, and having a deep interest in the long term success of subsurface intakes, should have a particular interest in seeing that it is done right. This is too new for the CCC to feel comfort in self-interested promoters and contractors.
Whatever happened to the precautionary principle?
If there is to be a successful test, there must be conscientious and professional attention to the fact that slant wells have never been successfully constructed and become operational anywhere in the world.
Costs can become astronomical, and should not fall exclusively on local ratepayers. State resources must be made available, since it is a policy goal of several state agencies for subsurface intakes. And the facts of declining pumping efficiency should also raise alarms.
We sincerely hope you will take these issues into account during deliberations and analysis of Cal Am’s amended permit.
Respectfully,
George T. Riley
Managing Director
Public Water Now
Emailed to: tom.luster