TTM groundwater withdrawal and use permit application to GA-EPD 2019-07-24

At 4.32 million gallons per day (mgd) monthly average, Twin Pines proposes to withdraw more Floridan Aquifer water than almost anything in the surrounding six southeast Georgia counties: 4.32 times the City of Folkston, and almost four times the notorious Nestlé withdrawal request for Ginnie Springs on the Santa Fe River in Florida. You can still comment to the U.S. Army Corps of Engineers about the TPM mining application. Or to GA-EPD about this water withdrawal permit.

[4.32 mgd, 1.44 mgd from each of three wells]
4.32 mgd, 1.44 mgd from each of three wells

The only things bigger nearby are the City of St. Marys (6 mgd) and the Rayonier paper mill at Jesup (74 mgd).

For comparison, Kingsland 4, Waycross-Ware County Industrial Park 3.4, Waycross 3.16, Jesup 3, Kings Bay Submarine Base 2.9 + 1 for irrigation, Satilla Regional Water and Sewer Authority 2.2, Folkston 1.0. Even Chemours in Wayne County only wants 0.605 and Southern Ionics only 0.504 in Charlton County and another 0.504 in Pierce County.

All the permitted withdrawals in Charlton County add up to less than half what TPM wants for its titanium mine near the Okefenokee Swamp:

Permitteemgd average per month
Homeland 0.150
Martin Marietta St. Mary’s Sand Company 0.2
Southern Ionics 0.504
Folkston 1.0
Total 1.85

For further comparison, the 1.152 mgd Nestlé wants from Ginnie Springs on the Santa Fe River in Florida is barely more than a quarter of what TPM wants from the same Floridan Aquifer. Each of the three wells TPM proposes would draw more water than Nestlé has applied for.

That Nestlé application is getting national and international coverage. This TPM withdrawal application should, as well.

This TPM water withdrawal application would, according to TPM’s own application, affect the Floridan Aquifer under the Okefenokee Swamp.

[Figure 5. Drawdown 365 days; Potentiometric Surface, Floridan Aquifer]
Figure 5. Drawdown 365 days; Potentiometric Surface, Floridan Aquifer

As pointed out in the Suwannee Riverkeeper comments to the U.S. Army Corps of Engineers, the Swamp already interchanges water with groundwater. As pointed out to the Corps by Okefenokee Swamp Park (OSP), any change to the water level in the Swamp would affect the whole Swamp, as far as OSP on the north and Stephen C. Foster State Park on the west. The Swamp is the headwaters of the Suwannee and St. Mary’s Rivers, so anything that affects the Swamp can affect those rivers.

How to Comment

The comment deadline was May 28, 2020, according to SAS-2018-00554 Twin Pines Minerals, Published April 13, 2020, Expiration date: 5/28/2020.

“The Savannah District will hold a virtual Public Meeting for the Twin Pines project on May 13, 2020 from 2:00 PM to 5:00 PM EDT. The meeting will consist of a formal presentation followed by a question and answer session. The meeting will be recorded and published to the Savannah District public website. To allow time for the public to submit questions and RSVP to the public meeting, as well as comment on any information presented at the meeting, additional public comments will be accepted and the original public notice will remain open until May 28, 2020, 15 days after the virtual public meeting.”

However, you can write to your elected officials. And the Corps apparently actually continues to read comments after the deadline, right up until they make a decision. While you are at home because of the novel Coronavirus (COVID-19), you have a great opportunity to write a comment, and to You can also post your comments on social media, as op-eds, etc.

You can ask the Corps and other elected and appointed officials to deny the application, or to require an Environmental Impact Statement (EIS) to consider wider areas the mine may affect, especially the entire Okefenokee Swamp, the Suwannee and St Marys Rivers, and the rest of Trail Ridge in Georgia. You can ask for the EIS to include other mines relevant to this one, especially the four Chemours titanium strip mines in north Florida for which TPM, along with Chemours, is under a Florida Consent Order for a range of violations. You may want to ask for inclusion of the existing phosphate mine in Hamilton County, Florida, next to the Suwannee River, as well as the one proposed in Union and Bradford Counties, Florida, next to the New and Santa Fe Rivers, tributaries of the Suwannee. All those mines affect the Floridan Aquifer, which is the main source of water for drinking, agriculture, and industry for everyone in south Georgia and north Florida.

To comment, or to request a public hearing, you can write to
Commander, U.S. Army Corps of Engineers, Savannah District,
Attention: Ms. Holly Ross, 1104 North Westover Boulevard, Suite 9, Albany, Georgia, 31707,
or by email to CESAS-SpecialProjects@usace.army.mil or holly.a.ross@usace.army.mil.
In your comments please refer to:
Applicant: Twin Pines Minerals, LLC, Application Number: SAS-2018-00554.

For the requested state permit regarding Section 401 of the Clean Water Act, you can send a comment or request for public hearing to
Stephen Wiedl, Wetlands Unit, stephen.wiedl@dnr.ga.gov
Georgia Department of Natural Resources, Environmental Protection Division, Water Protection Branch, 7 Martin Luther King, Jr. Drive, Atlanta, Georgia 30334.

For the Georgia Coastal Management Program certification, you can send a comment to
Federal Consistency Coordinator, Ecological Services Section, Coastal Resources Division,
Georgia Department of Natural Resources, One Conservation Way, Brunswick, Georgia 31523-9600
Telephone 912-264-7218.

The public announcement says: “The applicant may also require assent from the State of Georgia, which may be in the form of a license, easement, lease, permit, or other appropriate instrument.”

You can write to your Georgia state representative or senator or governor or lieutenant governor and ask them to refuse any such instrument.
To find your legislator you can type in your ZIP code here: http://openstates.org/find_your_legislator/

You can also write to your U.S. Representative or Senator and ask them to urge the Corps to reject this mine or at least require an EIS, like Rep. Al Lawson (FL-05) already did.

You can also write to the Georgia DNR board, asking them to refuse any such instrument.
Georgia Board of Natural Resources
2 Martin Luther King Jr. Drive, SE, Suite 1252, Atlanta, GA 30334

You can write to the U.S. Environmental Protection Agency (EPA) asking them to ask the state of Florida to comment.

To: Mary S. Walker, Regional Administrator, walker.mary@epa.gov
Jeaneanne Gettle, Director, Water Division, gettle.jeaneanne@epa.gov
Blake Ashbee, Chief of Staff, ashbee.blake@epa.gov,
Carol Kemker, Director, Enforcement & Compliance Assurance Division, kemker.carol@epa.gov
Region 4, U.S. Environmental Protection Agency (EPA)

Cc: Gregory J. Strong, Director, Northeast Division, Greg.Strong@dep.state.fl.us
Noah Valenstein, Director, Noah.Valenstein@dep.state.fl.us
Florida Department of Environmental Protection (FDEP)
 
Col. Daniel Hibner, Commander, U.S. Army Corps of Engineers,Savannah District
Attention: Ms. Holly Ross, holly.a.ross@usace.army.mil,
CESAS-SpecialProjects@usace.army.mil
1104 North Westover Boulevard, Suite 9, Albany, Georgia 31707
 
Stephen Wiedl, Wetlands Unit, stephen.wiedl@dnr.ga.gov
Georgia Department of Natural Resources, Environmental Protection Division,
Water Protection Branch, 7 Martin Luther King, Jr. Drive, Atlanta, GA 30334

Re: Applicant: Twin Pines Minerals, LLC, Application Number: SAS-2018-00554

Dear Administrator Walker and Director Gettle,

Here is the pithy request sent by Waterkeepers Florida:

We request EPA to determine, according to 33 CFR § 325.2(b), whether the mining activities of the applicant may affect the quality of the waters of the state of Florida and to notify the state of Florida, the district engineer, and the applicant that Florida therefore “has 60 days from receipt of EPA's notice to determine if the proposed discharge will affect the quality of its waters so as to violate any water quality requirement in such state, to notify EPA and the district engineer in writing of its objection to permit issuance, and to request a public hearing.”

To submit a letter to the editor of the Charlton County Herald, you can email editor@charltonherald.com.
Or write to your local newspaper.
You can also contact radio, TV, and of course post on social media.

Sources

This TPM permit application was first published by Mary Landers, Savannahnow.com, 9 September 2019, updated 11 September 2019, For Okefenokee supporters, proposed mine too close to refuge, as 7-24-19 Final Application for Industrial Groundwater Withdrawal Permit Uploaded bysavannahnow.com Date uploadedon Sep 06, 2019.

It is now on the WWALS website.

The other withdrawal figures for the six southeast Georgia counties were obtained from GA-EPD thanks to MarthaJane Winkler.

Much more about the proposed TPM mine is here:
http://www.wwals.net/pictures/2019-07-12–tpm-usace/

 -jsq, John S. Quarterman, Suwannee RIVERKEEPER®

You can join this fun and work by becoming a WWALS member today!

1 thought on “TTM groundwater withdrawal and use permit application to GA-EPD 2019-07-24

  1. Kate gallagher

    Please protect the Florida. Aquifer from mining and bottle water extractions. Our rivers and springs are in decline and need help

Comments are closed.