Professional Documents
Culture Documents
THURSTON COUNTY, WA
SUPERIOR COURT
July 24, 2017
Linda Myhre Enlow
1 EXPEDITE (if filing within 5 court days of hearing) Thurston County Clerk
No hearing is set.
Hearing is set:
2 Date: September 1, 2017
Time: 9:00 a.m.
3 Judge/Calendar: Carol Murphy - Civil The Honorable Carol Murphy
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IN THE SUPERIOR COURT OF THE STATE OF WASHINGTON
7 FOR THURSTON COUNTY
8 WASHINGTON STATE DEPARTMENT OF
TRANSPORTATION,
9 No. 16-2-00980-34
Plaintiffs,
10 (Consolidated with Cause No.
v. 16-2-04826-34)
11 SEATTLE TUNNEL PARTNERS, a joint DECLARATION OF
venture,
12 PAUL VAN HORNE IN
SUPPORT OF WSDOTS MOTION FOR
Defendants.
13 PARTIAL SUMMARY JUDGMENT
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HITACHI ZOSEN U.S.A. LTD.,
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Plaintiff,
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v.
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WASHINGTON STATE DEPARTMENT OF
16 TRANSPORTATION and SHANNON &
WILSON, INC.,
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Defendants.
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SEATTLE TUNNEL PARTNERS, a joint
19 venture,
20 Plaintiff,
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v.
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SHANNON & WILSON, INC., a Washington
23 corporation; and WSP USA, INC., formerly
known as PARSONS BRINCKERHOFF,
24 INC., a New York corporation,
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Defendants.
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15 This tells us that TW-2 was installed before the 2009-2010 timeframe and that TW-2 was a
16 pumping well as opposed to an observation well. This information is confirmed in Subsection
17 2.5.8.1:
Three wells, designated PW-252, PW-254, and PW-255, were installed and
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developed for use in the pumping tests. . .
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In addition to the newly installed pumping wells, a test well (TW-2)
20 installed in 2002 . . . was incorporated into the pumping test program.
21 In a pumping test, water is pumped out of one or more wells (pumping wells) and groundwater
22 levels are measured in surrounding wells (observation wells). The behavior of the observation
23 wells provides information about subsurface conditions. For example, if during a pumping test
24 the water level goes down in an observation well, it can be concluded that the pumping well and
25 observation well are connected by a soil layer that allows water movement.
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6 These passages are describing pumping tests that involved four pumping wells, three of
7 which were newly installed (PW-252, PW-254, and PW-255) and one which had been installed
8 in 2002 (TW-2). Water was pumped out of the pumping wells, and various monitoring points
9 (observation wells and VWPs) were observed to see how their water levels changed. With
10 respect to these tests, TW-2 is clearly and repeatedly identified as a pumping well as
12 8. The GEDR appendices provide additional information about TW-2. Figure C.4-1
13 identifies TW-2 as a pumping well (a half-black circle) surrounded by monitoring points
14 (circles with dots). A true and correct copy of that figure is attached in Exhibit B to this
15 Declaration. Report C.4-1 sets forth the Pumping Test Work Plan and includes Table 1 with
16 information about the pumping wells. TW-2 in particular is listed as having an eight-inch
17 diameter casing. A true and correct copy of that table is attached in Exhibit C to this
18 Declaration.
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9. The GEDR provides the following information about TW-2:
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TW-2 was a pumping well installed in 2002.
21 TW-2 was used as a pumping well in March 2010.
22 TW-2 was located in the path of STPs tunnel boring machine.
TW-2 had an eight-inch diameter casing.
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24 All of this information is accurate. The actual condition of TW-2 did not differ from what these
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2 2009-2010 was to install three pumping wells, designated PW-252, PW 254, and PW-255.
3 These are identified in GEDR Section 2.5.1 as pumping wells with eight-inch steel casings. All
4 three are shown with blue symbols in Figure 2. PW-252 is on page 2 of 12, PW-254 is on page 7
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of 12; and PW-255 is on page ,8 of 12.
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I make the statements in this Declaration under penalty of perjury under the laws of the
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State of Washington.
8
ise
9 SIGNED at _.S_e__t_tr.,_e,___ , Washington this day of _:ri_tA_l+-y
__ _
10 2017.
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Paul Van Home
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