Tag Archives: GA EPD

Thanks to organizations for the Okefenokee Swamp, against the Titanium Mine

Thanks to the more than two dozen organizations, local, regional, statewide in Florida and Georgia, national, and international, that oppose the titanium mine that would be far too close to the Okefenokee Swamp. The Okefenokee National Wildlife Refuge (ONWR) provides boating, birding, fishing, and hunting nearby to the tune of more than $60 million a year and more than 700 jobs, making it the NWR of most economic benefit to each of Georgia and Florida. The Okefenokee Swamp is a unique ecological treasure, and is the headwaters of the Suwannee and St. Marys Rivers. The burden of proof is on the miners, and they have not met it.

[Organizations For Okefenokee Swamp, Against Titanium Mine]
Organizations For Okefenokee Swamp, Against Titanium Mine
PDF
Add your organization here: https://forms.gle/Dyqc77EBsjXBsz93A

You can still file a comment with the U.S. Army Corps of Engineers. If the Corps actually issues a permit, which they may in the next few weeks, anything filed can be used in any ensuing lawsuit.

Exactly how many organizations oppose that strip mine is hard to say, since Continue reading

Okefenokee Swamp on GWC Dirty Dozen because Titanium Mine 2019-11-14

Announced yesterday to press across Georgia and beyond, the titanium mine near Georgia and Florida’s Okefenokee Swamp proposed by Twin Pines Minerals of Alabama made the Georgia Water Coalition Dirty Dozen (see also PDF).

You can still file a comment with the Army Corps and GA-EPD asking them to reject the mine or at least require an Environmental Impact Statement. Convenience for miners is no excuse to risk the fishing, boating, and birding in the swamp and hunting and forestry nearby.

[Closeup]
Closeup of TPM equipment on mine site from GA 94 westbound.
Photo: John S. Quarterman for WWALS, November 14, 2019

2019’s
Worst Offenses Against
GEORGIA’S WATER
OKEFENOKEE SWAMP, ST. MARYS AND SUWANNEE RIVERS

Proposed 2,400-Acre Titanium Mine Threatens Signature Landscape of Georgia

INTRODUCTION:

Twenty years ago when chemical giant DuPont proposed mining titanium dioxide ore near the Okefenokee Swamp, opposition to the plan was so strong— Continue reading

Waterkeepers Florida passes resolution against titanium mine application near Okefenokee Swamp

Waterkeepers Florida asks the Army Corps to require Twin Pines Minerals to supply all the information missing from its application for a titanium mine near the Okefenokee Swamp, to prepare a full Environmental Impact Statement (EIS), to hold Public Hearings, including in Florida, and “to answer how the Corps has or will determine that the Applicant’s proposed mine would not adversely affect the Okefenokee Swamp, the St. Marys River, the Suwannee River, the Floridan Aquifer, or the State of Florida.”

You can also still comment to the Army Corps.

[TPM Equipment closeup, Wayne Morgan]
TPM Equipment closeup Photo: Wayne Morgan for Suwannee Riverkeeper on Southwings flight, pilot Allen Nodorft, 2019-10-05.

Continue reading

Floridan Aquifer withdrawals affect the Okefenokee Swamp, so how could TPM’s withdrawals not? 1995-04-11

Water withdrawals from the Floridan Aquifer affect water levels and quality in the Okefenokee Swamp, a pair of researchers concluded 24 years before Twin Pines Minerals of Alabama proposed to withdraw 2.4 4.32 million gallons per day from the Aquifer for a titanium mine within a few miles of the Swamp:

Abstract. A rapid response is observed between water level fluctuations in the Okefenokee Swamp and water levels in the underlying Floridan Aquifer. A lag of approximately one month is common, and a hydraulic diffusivity of 3.83 x 10-3 m2 s-1 best matches the calculated aquifer response to the swamp water level perturbations. The magnitude of leakage between the swamp and the aquifer is uncertain because of a lack of knowledge about the specific storage coefficient in the aquitard separating the swamp and the aquifer which has not been explicitly measured. An intermediate value of specific storage within the likely range of values results in a down- ward vertical flow of 1.2 meters of water per year. This induced recharge can significantly alter the natural water balance within the swamp. Such a large loss of water from the swamp may be responsible for observed pH and water level changes, and increased beavy metal accumulations in aquatic organisms in the swamp.

We cited that study[5] on page 4 of the Suwannee Riverkeeper comments to USACE about TPM, just after noting Twin Pines application to withdraw 4.32 million gallons per day (mgd) of Floridan Aquifer water much closer to the Swamp than any other permitted withdrawal. TPM’s own hydrology study in that withdrawal application shows a cone of depression in the Floridan Aquifer extending under the Swamp:

[Figure 8. Drawdown 2930 days]
Figure 8. Drawdown 2930 days

How could that not affect Swamp water levels and content?

As pointed out to the Corps by Okefenokee Swamp Park (OSP), any change to the water level in the Swamp would Continue reading

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: Continue reading

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

Comments: 20,338 on titanium mining near Okefenokee Swamp –USACE 2019-09-12

If this and the 27 news articles on radio, TV, and newspapers in Georgia and Florida, several of them carried by Associated Press across the country, plus the ten op-eds and three editorials, is not enough to establish controversy, I wonder what is. Maybe still more comments and news articles and social media?

[Public Notice: 20,338 comments]
Public Notice: 20,338 comments
PDF

Nedra Rhone, Atlanta Journal-Constitution, 13 September 2019, Mining proposal near Okefenokee draws more than 20K comments from public

The Suwannee Riverkeeper, on Thursday, sent 22 pages of questions to the Corps and the Georgia Department of Environmental Protection asking the agency to deny the permit. The Riverkeeper joined the SELC and other organizations and individuals in asking the Corps to prepare an Environmental Impact Statement, the highest level of analysis available when a proposed federal action may significantly affect the quality of the human environment.

Also in that AJC story:

Commenters expressed concerns ranging from the acres of wetlands that would be lost to what they considered inadequate studies conducted to determine the potential impact of the mine.

In a letter to the Corps, the Southern Environmental Law Center said Continue reading

Deny or EIS, titanium mining near Okefenokee Swamp –Suwannee Riverkeeper for WWALS 2019-09-12

Sent just now as PDF. You can still send in your comments today.

[Who wants to boat, fish, bird, or hunt next to a strip mine?]
Who wants to boat, fish, bird, or hunt next to a strip mine? PDF


September 12, 2019

To: Col. Daniel Hibner, Commander, U.S. Army Corps of Engineers, Savannah District
       Attention: Ms. Holly Ross,  holly.a.ross@usace.army.mil
       1104 North Westover Boulevard, Suite 9, Albany, Georgia  31707

Cc: 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 Colonel Hibner,

Suwannee Riverkeeper for WWALS Watershed Coalition (WWALS) asks USACE:

  • to reject the subject Application from Twin Pines Minerals (TPM), given the inappropriate location which would over the years move ever closer to the Okefenokee Swamp, which is the headwaters of the Suwannee and St. Mary’s Rivers, combined with the numerous omissions from the Application regarding the wide hydrogeologic, water quality, ecologic, and economic ramifications of the proposed mining, and the numerous other mines relevant to the proposal.

If USACE continues to process the Application, WWALS requests USACE:

  • to require a complete hydrogeological assessment and report, a full Environmental Impact Statement (EIS), and an economic analysis, with all three covering all the relevant features, mines, and applications in south Georgia and north Florida, including at least those outlined in this letter.
  • to accept comments until at least ninety days after all these documents are submitted to USACE and distributed to the public, preferably on USACE’s website, without requiring site visits to Albany to get them.
  • to hold public hearings in Georgia and Florida for further independent input and review after sufficient time (months or years) for independent third-party review.

The proposed Charlton County, Georgia, TPM mine site is hydraulically upgradient from the Okefenokee Swamp and within close proximity to the boundary of the Okefenokee National Wildlife Refuge (ONWR), with its 600,000 visits per year for boating, birding, and fishing, with more than $60 million annual economic effects including hundreds of jobs supported directly or indirectly, plus hunt clubs surrounding the Swamp. The Swamp provides ecosystem services of great economic values, including storm protection, water quality provisioning, support for nursery and habitat for commercial fishing species; and carbon storage, plus those hunt clubs depend on the Swamp. Any pollution of the Swamp or change in surface or groundwater levels could adversely affect not only ONWR and nearby areas, but also the Okefenokee Swamp Park (OSP) near Waycross, in Ware County, GA, and Stephen C. Foster State Park (SCFSP) in Charlton County, via Fargo in Clinch County. Visitors come from Jacksonville, Florida, Brunswick and Valdosta, Georgia, and from much farther away to visit the Okefenokee Swamp. The Swamp is a treasure to the entire nation and the world.

The stigma of a strip mine next to the swamp could cause people to turn away, taking their dollars with them. Who wants to boat, fish, bird, or hunt next to a strip mine?

Continue reading

Cost of reclassifying Georgia rivers from Fishing to Recreational in Triennial Review of Water Quality Standards

Recently I was asked if there would be water monitoring costs to cities or counties because of upgrading our main Suwannee River Basin waters in Georgia from Fishing to Recreational, as we have requested in Georgia’s Triennial Review of Water Quality Standards. Here’s the answer, as best I could determine. And how you can help. For those who wonder why upgrade from Fishing to Recreational, please see the previous blog post.

[Satellite Map]
WWALS Satellite Map of landing in the Suwannee River Basin in Georgia

Specifically the question was: would reclassifying rivers or swamp from Fishing to Recreational cause cities or counties to have to spend more money on water quality monitoring, specifically if a wastewater treatment plant had a spill, more money on water quality sampling afterwards?

The brief answer is: probably not.

Recently, I asked James A. Capp, Chief, Watershed Protection Branch, EPD. He said that for that case, there should be no change, because sampling after a spill is determined mostly by the number of gallons spilled.

Let me use some NPDES permits I have on hand to illustrate.

Here is the language in NPDES Permit No. GA0020222 for Valdosta’s Withlacoochee Wastewater Treatment Plant, first about number of gallons, then about the required sampling. Continue reading

Valdosta sewer spill into Onemile Branch, Drexel Park 2019-08-03

Why do we get to find out in the newspaper Tuesday about a Saturday sewage spill that just “occurred”, and didn’t even show up in GA-EPD’s online Sewage Spill Reports until after the newspaper was printed and distributed? Rest assured it’s not Valdosta’s responsibility, according to Valdosta.

[Pipe under bridge by apartments]
Pipe under bridge by apartments

Katelyn Umholtz, Valdosta Daily Times, 5 August 2019, Sewer spill occurs near Drexel Park, Continue reading