WWALS Watershed Coalition

WWALS Watershed Coalition, Inc. (WWALS) is Suwannee RIVERKEEPER® WWALS advocates for conservation and stewardship of the surface waters and groundwater of the Suwannee River Basin and Estuary, in south Georgia and north Florida, among them the Withlacoochee, Willacoochee, Alapaha, Little, Santa Fe, and Suwannee River watersheds, through education, awareness, environmental monitoring, and citizen activities.

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Permit application deficiencies; water modeling, monitoring, and management, mercury, spills, slimes, Florida --WWALS to GA-EPD, TPM TiO2 mining 2024-04-09 [Up]

 -jsq, John S. Quarterman, Suwannee RIVERKEEPER®

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MMM

[Application deficiencies in TPM TiO2 mining permits: Modeling, mercury, spills, slimes, Florida --WWALS to GA-EPD 2024-04-09]
Application deficiencies in TPM TiO2 mining permits: Modeling, mercury, spills, slimes, Florida --WWALS to GA-EPD 2024-04-09

[Application deficiencies in TPM TiO2 mining permits: Modeling, mercury, spills, slimes, Florida --WWALS to GA-EPD 2024-04-09]
Application deficiencies in TPM TiO2 mining permits: Modeling, mercury, spills, slimes, Florida --WWALS to GA-EPD 2024-04-09

Maps

[Little Swannee Creek and Cypress Creek draining the southwest region of the Okefenokee Swamp, in the WWALS map of All Landings in the Suwannee River Basin]
Little Swannee Creek and Cypress Creek draining the southwest region of the Okefenokee Swamp

[A circle of radius approximately 44,608 feet around the TPM mine site reaches the Middle Prong of the St. Marys River to the southwest, Cross Creek to the Northwest, and Boone Creek to the northeast, with parts of two Florida counties and two Georgia counties inside it, as well as Moniac, the Cherokee of Georgia Tribal Grounds, and St. George.]
A circle of radius approximately 44,608 feet around the TPM mine site reaches the Middle Prong of the St. Marys River to the southwest, Cross Creek to the Northwest, and Boone Creek to the northeast, with parts of two Florida counties and two Georgia counties inside it, as well as Moniac, the Cherokee of Georgia Tribal Grounds, and St. George.

[Figure 6. Drawdown (ft) in the Floridan Aquifer after 4 years of pumping in 3-GW-Extraction-Permit-Application-10.2.2023]
Figure 6. Drawdown (ft) in the Floridan Aquifer after 4 years of pumping in 3-GW-Extraction-Permit-Application-10.2.2023

WC

[WWALS comment on Twin Pines Minerals Permit Applications]
WWALS comment on Twin Pines Minerals Permit Applications
PDF

[Water Quality and Quantity Modeling and Monitoring]
Water Quality and Quantity Modeling and Monitoring
PDF

[Since we do not know where that divide is, and it may move, how can this recommendation by Dr. Jackson be supported, especially considering Cypress Creek and Little Swannee Creek drain the southwest region of the Okefenokee Swamp into the Suwannee River?]
Since we do not know where that divide is, and it may move, how can this recommendation by Dr. Jackson be supported, especially considering Cypress Creek and Little Swannee Creek drain the southwest region of the Okefenokee Swamp into the Suwannee River?
PDF

[While I applaud Dr. Zeng and Dr. Jackson for attempting to model with insufficient information, their models are also too simplified, so how can we depend on them to prove no harm by the mine?]
While I applaud Dr. Zeng and Dr. Jackson for attempting to model with insufficient information, their models are also too simplified, so how can we depend on them to prove no harm by the mine?
PDF

[Mercury]
Mercury
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[Since those methods are different, how can we depend on the low results for mercury from the preliminary sampling?]
Since those methods are different, how can we depend on the low results for mercury from the preliminary sampling?
PDF

[Spills]
Spills
PDF

[Since rain and high winds from Hurricane Irma caused wastewater release for days and failure to settle sediment in these incidents on Trail Ridge in Florida, why should we expect the same problem not to happen during hurricanes on Trail Ridge in Georgia, near the Okefenokee Swamp?]
Since rain and high winds from Hurricane Irma caused wastewater release for days and failure to settle sediment in these incidents on Trail Ridge in Florida, why should we expect the same problem not to happen during hurricanes on Trail Ridge in Georgia, near the Okefenokee Swamp?
PDF

[Since even a TiO2 mine operator with decades of experience in many mines on Trail Ridge still has wastewater spills, including one only a few months ago that traversed state-owned and private land, why should permits be issued to a company with no experience in such mining, which also proposes to use multiple untried techniques such as draglines?]
Since even a TiO2 mine operator with decades of experience in many mines on Trail Ridge still has wastewater spills, including one only a few months ago that traversed state-owned and private land, why should permits be issued to a company with no experience in such mining, which also proposes to use multiple untried techniques such as draglines?
PDF

[More generally, and without using the term slimes, how does prevalence of all the sand, clay, and soil designations in the “SUBSURFACE LITHOLOGY OF THE SURFICIAL AQUIFER AT TWIN PINES MINE” compare to prevalence of the same categories at other TiO2 mine sites in Georgia and Florida?]
More generally, and without using the term slimes, how does prevalence of all the sand, clay, and soil designations in the “SUBSURFACE LITHOLOGY OF THE SURFICIAL AQUIFER AT TWIN PINES MINE” compare to prevalence of the same categories at other TiO2 mine sites in Georgia and Florida?
PDF

[Aquifer pumping effects into Florida]
Aquifer pumping effects into Florida
PDF

[Why should the model assume there are no discontinuities in the Floridan Aquifer under the St. Marys River, the North Prong, Moccasin Bay, St. George, Boone Creek, etc.?]
Why should the model assume there are no discontinuities in the Floridan Aquifer under the St. Marys River, the North Prong, Moccasin Bay, St. George, Boone Creek, etc.?
PDF

[The ONWR provides more economic benefit to each of Florida and Georgia than any other NWR.]
The ONWR provides more economic benefit to each of Florida and Georgia than any other NWR.
PDF

[Will GA-EPD require the miners to address actual and potential effects of the mine on Florida?]
Will GA-EPD require the miners to address actual and potential effects of the mine on Florida?
PDF