Category Archives: EPA

GA-EPD cites Suwannee Riverkeeper and US EPA against TPM titanium mine near Okefenokee Swamp 2019-09-12

GA-EPD told USACE the mining application is incomplete, asked for comments to be reopened, and cited Suwannee Riverkeeper and Georgia River Network:

“Understanding that groundwater hydrologic effects associated with the Twin Pines project have been a central concern expressed by federal resource/regulatory agencies, NGOs (e.g. the Suwannee Riverkeeper and Georgia River Network), and the public at large, we respectfully submit that the 404/401 permit application as submitted thus far is not complete since it lacks full information and findings regarding hydrogeologic factors on site and post-project effects to hydrogeology/groundwater. We feel that it is inappropriate and premature to close the project comment window when such notable elements of the environmental documentation for this project have not yet been made available. documentation which we at GaEPD judge to be important to our review of this project.”

[the 404/401 permit application as submitted thus far is not complete]
the 404/401 permit application as submitted thus far is not complete

This was revealed by USACE in a Public Notice of September 17, 2019. So far, this is the only update posted by the Corps since it closed comments on September 12, 2019.

It also includes comments by U.S. EPA, also saying the application is incomplete, and also cited by GA-EPD. EPA cites cumulative effects and notes numerous lacking documents and studies. EPA concludes:

“Due to the potential for the proposed Twin Pines Minerals mine to adversely affect the hydrology of the Okefenokee NWR, the EPA believes that there is the potential for this project as proposed to cause adverse effects to water quality and the life stages of aquatic life or other wildlife dependent on aquatic systems. The EPA finds that this project, as proposed, may result in substantial and unacceptable impacts to aquatic resources of national importance, as covered in Part IV. paragraph 3(a) of the August 1992 Memorandum of Agreement between the EPA and the Department of the Army regarding CWA Section 404(q).”

Apparently USACE is at least listening to the public and the public and NGOs such as Suwannee Riverkeeper.

You can still send in comments. The Corps won’t say they will read them, but they explicitly won’t say they won’t read them, so keep sending them in, and publish them on social media, as op-eds, etc. Continue reading →

Excluding groundwater makes no sense above the Floridan Aquifer –WWALS to EPA 2019-04-15

Approved at the Sunday WWALS board meeting and filed last night via regulations.gov as PDF.

April 15, 2019

U.S. Environmental Protection Agency
EPA Docket Center
Office of Water Docket
Mail Code 28221T
1200 Pennsylvania Avenue, NW
Washington, DC 20460

Re: Docket ID No. EPA-HQ-OW-2018-0149,
       Revised Definition of Waters of United States

To Whom it May Concern:

WWALS Watershed Coalition, Inc. (WWALS), also known as Suwannee Riverkeeper, submits the following comments on the United States Environmental Protection Agency (“EPA”) and Department of Defense, Department of the Army, Corps of Engineers (“Corps”) proposed rule entitled “Revised Definition of Waters of United States,” 84 Federal Register 4154-01 (February 14, 2019) (hereinafter “Proposed Rule”).

In addition to supporting the comments of Waterkeeper Alliance and the Southern Environmental Law Center (SELC), WWALS adds these comments on groundwater.

The Proposed Rule’s categorical exclusion of groundwater makes no sense here above the Floridan Aquifer where surface water and groundwater constantly interchange, and pollutants travelling through groundwater are a frequent source of health, environmental, and economic problems.

[2019-04-15--WWALS-to-EPA-0001]
2019-04-15–WWALS-to-EPA-0001

This proposed exclusion of groundwater is called out repeatedly in the Proposed Rule, starting with this:

Continue reading →

EPA kicks PFAS regulation a year down the road

Yesterday’s EPA PFAS plan does nothing except to study for a year or more what has already been studied. Where are the limits on amounts of these firefighting chemicals in water that would enable EPA or GA-EPD to test private wells, for example for the PFAS that got into groundwater from Moody Air Force Base’s Wastewater Treatment Plant, causing Moody’s report to say be careful eating fish caught in Beatty Branch or Cat Creek, upstream from the Withlacoochee River? Where are the funds and methods to remediate the problem and to stop it getting worse?

[Figure 25 Waste Water Treatment Plant (AFFF Area 8) PFBS, PFOA, and PFOS in Soil and Sediment]
Figure 25 Waste Water Treatment Plant (AFFF Area 8) PFBS, PFOA, and PFOS in Soil and Sediment

U.S. Environmental Protection Agency (EPA), 14 February 2018, EPA’s Per- and Polyfluoroalkyl Substances (PFAS) Action Plan, Continue reading →

Health costs of firefighting foams

It’s time for the state of Georgia and the U.S. Congress to set limits, and appropriate funds for testing and remedial actions, as the evidence and lawsuits pile up about those firefighting chemicals spilled from Moody AFB and many other places.

What is the price of fire safety? As lawsuits pile up and government pressure rises, firefighting-foam makers reconsider the environmental cost of fluorosurfactants, by Marc S. Reisch, Chemical and Engineering News (c&en), JANUARY 14, 2019 | APPEARED IN VOLUME 97, ISSUE

Photo: Large Atmospheric Storage Tank Fires project; Firefighters spray fluorine-free foam on a hydrocarbon test fire at Dallas Fort Worth Airport.
Photo: Large Atmospheric Storage Tank Fires project
Firefighters spray fluorine-free foam on a hydrocarbon test fire at Dallas Fort Worth Airport.

Testifying to Congress in September 2018 before it passed the legislation allowing civilian airports to use fluorine-free foams, Timothy Putnam, a 24-year civilian firefighter for the navy, said he recalled using fluorine-containing foam—in the days before scientists raised safety flags—“as a substitute for vehicle soap to wash fire department vehicles. We also used [it] to clean the fire station floors.”

Now, Putnam said, he is worried about “human impacts” of the exposure. And he didn’t accept the argument that Continue reading →

Testing for firefighting chemicals in wells and waterways 2019-01-18

Those firefighting chemicals that leaked from Moody Air Force Base are on the front page of the Valdosta Daily Times today:

Moody recommends private well owners contact their county representatives for information on testing personal wells.

Paige Dukes, Lowndes County clerk and public information officer, said this is an opportunity for county residents such as Tann to have their water tested. Not only for PFAS but for any other contaminants that might be there.

Indeed, and Lowndes County operates the Moody AFB wastewater treatment plant that spilled into Beatty Branch and Cat Creek. So it’s an opportunity for Lowndes County to help organize testing for these per- and polyfluorinated alkyl substances (PFASs), because testing for them isn’t nearly as simple or inexpensive as testing for other contaminants.

[Suwannee Riverkeeper John S. Quarterman, nearby resident Debra Tann, VDT reporter Thomas Lynn and photographer Derrek Vaughn, at Beatty Branch, January 7, 2019. Photo: John S. Quarterman for WWALS.]
Suwannee Riverkeeper John S. Quarterman, nearby resident Debra Tann, VDT reporter Thomas Lynn and photographer Derrek Vaughn, at Beatty Branch, January 7, 2019. Photo: John S. Quarterman for WWALS.

Debra Tann and I were back at Beatty Branch on January 7, 2019, this time with the VDT, about the firefighting chemical issue that was in the Atlanta Journal-Constitution the first week of January. This time it was for local reporters. Moody neighbor wants water tested, Continue reading →

SELC against proposed suspension of Clean Water Rule 2017-12-13

Yesterday, the Southern Environmental Law Center (SELC) submitted a sixteen-page letter against the EPA’s proposed suspension of the Clean Water Rule, on behalf fifty-six organizations including WWALS.10

Struggling to eliminate, Letter Much of that letter could as easily apply to today’s foregone vote to eliminate the FCC’s net neutrality rule. FCC Chairman Ajit Pai’s “‘unalterably closed’” views should have been enough for him to recuse himself. The three FCC Commissioners for the elimination of net neutrality made it clear they were not paying attention to the millions of public comments, despite requirements of the Administrative Procedure Act to do so. Chairman Pai with perhaps unintentional irony even argued that there was no need to hold public hearings since far more people commented online, which of course is only possible through an open Internet. Nevermind that the FCC appears to be ignoring those comments.

Similarly, the EPA does not seem to be paying attention to the “more than 680,000 public comments” on the Clean Water Rule repeal beyond taking only six days to come up with a two year delay in implementation of that rule.

The SELC letter to the EPA even cites two cases against the FCC when it says: Continue reading →