Tag Archives: groundwater

WWALS Public Comments on Mining Land Use Plan of Twin Pines Minerals, LLC, too near the Okefenokee Swamp 2023-03-17

March 17, 2023

Land Protection Branch,
4244 International Parkway,
Atlanta Tradeport- Suite 104,
Atlanta, Georgia 30354

twinpines.comment@dnr.ga.gov

RE: WWALS Public Comments on Mining Land Use Plan of Twin Pines Minerals, LLC (PDF)

Dear EPD,

This letter recommends denying the permit applications by Twin Pines Minerals, LLC (TPM) to mine for titanium dioxide (TiO2) near the Okefenokee Swamp, based on specifics of the Mining Land Use Plan,1 as requested in the Notice of the Opportunity for Public Comment.2

[Please deny the mining permits]
Please deny the mining permits

Why this decision is important far away

First, we present some context for why this decision is important far away from the Okefenokee Swamp.

Any lowered water level or dewatering of the surface around the Swamp increases the risk of fires. The 2007 Bugaboo fire spread smoke west across the Suwannee River Basin, causing respiratory distress 80 miles away in Quitman, continuing 450 miles to Meridian, Mississippi. Southwards the smoke closed I-75 and went 370 miles to Fort Lauderdale, Florida. North it went 250 miles to Atlanta.

During the 2017 West Mims fire, Lowndes County Fire (along with Valdosta and its other cities, and nearby counties) sent assistance from 75 miles away. They were among 900 firefighters from across the country.3 “There’s nobody Continue reading

GA Suwannee-Satilla RWPC Meeting 2022-03-09

Water gaps and water quality: the Georgia Suwannee-Satilla Regional Water Planning Council meets 10-15 AM to 2 PM, Wednesday, March 9, 2022 at Coastal Pines Technical College, 1701 Carswell Ave, Waycross, GA 31503. There is an online method of attendance, unfortunately via Microsoft Teams.

Unlike Florida’s Suwannee River Water Management District, SSRWPC has no paid staff, no budget to speak of, and no taxing, permitting, or fining ability. Its Council is all volunteers, assisted by a few staff from the Georgia Environmental Protection Division (GA-EPD) and sometimes a consultant or two.

[Region, Public Notice]
Region, Public Notice

SUWANNEE-SATILLA

REGIONAL WATER PLANNING COUNCIL MEETING

Announcement Date: February 2, 2022

TO ALL INTERESTED PERSONS AND PARTIES:

The Suwannee-Satilla Regional Water Planning Council

will hold a meeting at the following date, time and location:

Wednesday, March 9, 2022

Registration: 10:15 A.M. – 10:30 A.M.

Meeting: 10:30 A.M. – 2:00 P.M.

Note: This Meeting may be attended In-Person (with Social Distancing Measures in place) or Virtually via the MS Teams Link with Call-In Information Provided Below

Coastal Pines Technical College
1701 Carswell Ave
Waycross, GA 31503

If you are planning to attend the meeting in-person please send your RSVP notice to woodsh@cdmsmith.com so we can ensure we do not exceed the venue capacity.

For Virtual Attendance use this link: Continue reading

Supreme Court ruling on underground water could affect proposed titanium strip mine too near the Okefenokee Swamp

Here’s yet another reason you can cite when you ask the Georgia Enviromental Protection Division (GA-EPD) to stop the mining proposal by Twin Pines Minerals (TPM) to strip mine near the Okefenokee Swamp, above the Floridan Aquifer.

David Pendered, Saporta Report, January 3, 2022 5:13 pm, Okefenokee Swamp mining proposal could be affected by Supreme Court ruling,

The proposal to mine sand near the Okefenokee Swamp could be affected by a groundbreaking ruling on water rights issued by the U.S. Supreme Court.

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

For the first time, justices have determined the same laws that apply to water flowing above ground apply to water in multi-state underground aquifers.

“This court has never before held that an interstate aquifer is subject to equitable apportionment,” Chief Justice John Roberts wrote in a unanimous opinion issued Nov. 22, 2021. This doctrine “aims to produce a fair allocation of a shared water resource between two or more States,” according to the ruling.

The ruling sets a legal foundation to manage future disputes over the usage of interstate groundwater. This issue is expected to arise more frequently as drought and climate change poise to alter the United States’ traditional water supplies and challenge agreements among governments to share water.

This ruling could be brought into play at the proposed mine near the Okefenokee, in part because of the amount of water to be extracted for mining operations from the four-state Floridan Aquifer. For that to happen, a party that has standing to file a lawsuit would have to do so on behalf of one or more of the four states that are above the Floridan Aquifer — Florida, Alabama, Georgia and South Carolina. Two of these states have previously litigated Georgia’s use of water from the Chattahoochee and Flint rivers. The Supreme Court ruled against Florida’s claim in April.

Continue reading

More questions about strip mine near Okefenokee Swamp –GA-EPD to miners 2021-09-10

GA-EPD last Friday sent another request for clarifications to the miners about their proposed strip mine far too near the Okefenokee Swamp.

Meanwhile, you can ask GA-EPD to reject the five permit applications from Twin Pines Minerals for that strip mine, or at least to thoroughly study with independent review potential effects of that mine on the Okefenokee Swamp, the Suwannee River, and the Floridan Aquifer.
https://wwals.net/?p=55092

[Rivers, Swamp and mine site, GA-EPD cover letter]
Rivers, Swamp and mine site, GA-EPD cover letter

Most of the new questions are about how bentonite clay will be used. The Georgia Environmental Protection Division (GA-EPD) has actually been asking about that since December 5, 2019.

A question GA-EPD did not ask is what if the clay gets into waterways with fish? Bentonite in small particles can get into the gills of fish and suffocate them, and bentonite can also deplete oxygen: see Identification of Oxygen-Depleting Components in MX-80 Bentonite, Torbjörn Carlsson and Arto Muurine, Cambridge University Press, 01 February 2011.

GA-EPD also asked about water draining into the Floridan Aquifer or into rivers, or water moving in the other direction.

Exhibit I Modeling the GW Flow System Comments James L. Kennedy Ph.D., P.G.

Continue reading

Twin Pines Minerals supplied more documents to GA-EPD about mining near Okefenokee Swamp 2021-06-25

The miners finally responded to GA-EPD’s questions from April about more information for the five permit applications to strip mine titanium far too near the Okefenokee Swamp.

Checking today with Georgia Environmental Protection Division Deputy Director John Eunice, it will probably take several weeks for EPD’s Mining group to review the documents. If EPD finds documents or information still missing, they may ask Twin Pines Minerals, LLC, for more. When at some point EPD finds enough information to call it a complete application, they will announce a Public Hearing with a public comment period.

You can go ahead and ask GA-EPD to reject the permit applications, or at least thoroughly evaluate them:
https://waterkeeper.org/news/help-suwannee-riverkeeper-save-okefenokee-swamp/

The miners’ recent documents contain plenty of reasons to reject the permits, including they say themselves they didn’t answer all the questions, and they keep sending maps including land owned by TIAA as part of their mine site after TIAA rejected that many months ago.

[Upon completion; Okefenokee Swamp, Suwannee and St Marys Rivers; TIAA land still in mining site maps]
Upon completion; Okefenokee Swamp, Suwannee and St Marys Rivers; TIAA land still in mining site maps

I’d say the miners themselves said their responses were incomplete in items 5 and 6 on page 12 of their Response to Comments: Continue reading

GA-EPD permit process for Twin Pines strip mine too near Okefenokee Swamp 2021-02-08

This fact sheet from a month ago says the Georgia Environmental Protection Division (GA-EPD) will hold “a public meeting” and “Comments will also be accepted at TwinPines.Comment@dnr.ga.gov. It’s not clear what they will do with comments if you go ahead and send them to that address. Since any such correspondence would be public record, retrievable via open records request, it would be odd if GA-EPD did not consider those comments in their permit review process.

[GA-EPD Fact Sheet, TPM Mine, and Okefenokee NWR]
GA-EPD Fact Sheet, TPM Mine, and Okefenokee NWR

Checking with GA-EPD this morning, the public hearing is not expected to be scheduled for several months yet, because they’re still waiting for documents that the miners did not previously supply. Plus they are communicating with the Army Corps about documents the Corps received before abdicating responsibility. Apparently the GA-EPD Land Division is taking the lead, perhaps because this is a mining project, near the Okefenokee Swamp, which is the headwaters of the Suwannee River.

It’s good GA-EPD is being thorough, although this last paragraph casts some doubt on that: “ Any additional mining operations not included in the demonstration area will be considered new and unique and will require a new set of permits and a full permitting process.”

[Map: Twin Pines Minerals land and Okefenokee NWR]
Map: Twin Pines Minerals land and Okefenokee NWR
in the WWALS map of the Suwannee River Wilderness Trail and the Okefenokee NWR Canoe Trails.

Sure and if that happens the miners will claim they have sunk costs and they’ll sue if they don’t get further permits. So expansion should be considered along with the original permit applications. And it’s much better to nip this whole thing in the bud.

Here are four of the five permit applications to GA-EPD from Twin Pines Minerals, LLC:
https://wwals.net/2020/11/05/twin-pines-minerals-permit-applications-to-ga-epd/

Since GA-EPD has confirmed they did actually receive an Air Quality permit application, I guess it’s time for me to request that one again.

GA-EPD has a Twin Pines Minerals, LLC web page, whic currently has a link to this one one-page PDF fact sheet.

[Twin Pines Minerals LLC Permitting Fact Sheet]
Twin Pines Minerals LLC Permitting Fact Sheet
PDF


GEORGIA
DEPARTMENT OF NATURAL RESOURCES   
Environmental Protection Division

Twin Pines Minerals, LLC
Permitting Fact Sheet
 

Twin Pines Minerals, LLC has submitted environmental permit applications to the Environmental Protection Division (Division) proposing a demonstration project for mining heavy minerals sands near St. George, Charlton County, Georgia. The northern boundary of the site is located approximately 2.9 miles southeast from the nearest boundary of the Okefenokee National Wildlife Refuge.

How many permit applications have been submitted?

Twin Pines Minerals, LLC has applied for environmental permits from all branches of the Environmental Protection Division (Division). These permits are the same as those that may be required for any surface mine: NPDES Industrial Stormwater, NPDES Industrial Wastewater, Groundwater Withdrawal, Air Quality, and Surface Mining Permit. The Division is early in the process of conducting a thorough review of each of the applications received.

How will the Division ensure the Okefenokee is being protected?

The Surface Mining Land Use Plan (MLUP) will require an addendum detailing the environmental provisions for protection of the environment and resources of the State. Once this environmental provision addendum is received, the Division will conduct an initial review and ensure it is complete and adequate, with a focus on how the project’s proximity to the National Wildlife Refuge may impact the area’s groundwater hydrology.

Will public be able to provide comments?

Yes. After the Division has reviewed the MLUP and the environmental provisions addendum, a public meeting will be held to receive comments on these documents and to provide an update on the permitting process. Comments will also be accepted at TwinPines.Comment@dnr.ga.gov. We will then consider all public comments and request the applicant make any necessary changes to address those comments. Please note, the Division may be unable to respond individually to each comment received. However, we will post a collective response to comments on our website after the official comment period closes.

Once the MLUP and the environmental provisions addendum are finalized, the Division will proceed with the draft permit process, including a public notice and comment period on the Surface Mining permit as well as any additional public comment periods required for the other permits. These permits are for the proposed 740-acre demonstration mining area.

Will the mine be able to expand after it is permitted?

Any additional mining operations not included in the demonstration area will be considered new and unique and will require a new set of permits and a full permitting process.

February 8, 2021


 -jsq, John S. Quarterman, Suwannee RIVERKEEPER®

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

GA-EPD: Twin Pines massive submittals short on analysis, incomplete, not sufficient, and wetland impacts not temporary 2019-12-05

“We reiterate our concern and position that an appropriate project review for 401 water quality certification is not yet possible since complete substantive and important information about the proposed hydrogeologic effects of this project relative to the surrounding landscape has not yet been submitted by the applicant. …So substantial, so massive, so transformative is the effect to wetlands contemplated at the Twin Pines site that you no longer have in place the original wetland to be impacted.” The Georgia Environmental Protection Division (GA-EPD) wrote that to the U.S. Army Corps of Engineers (USACE) in response to the thousands of pages of low-level data but only a few pages of analysis that Twin Pines Minerals (TPM) has sent those agencies.

Twin Pines Minerals is still failing to hoist its burden of proof that its propsosed titanium strip mine would not jeopardize this national treasure, the Okefenokee Swamp, the headwaters of the Suwannee and St. Marys Rivers.

[Tribal Grounds west along GA 94 to TPM equipment, 12:38:38, 30.5257540, -82.0411100]
Photo: John S. Quarterman for WWALS, of Tribal Grounds west along GA 94 to TPM equipment, 12:38:38, 30.5257540, -82.0411100, on Southwings flight, pilot Allen Nodorft, 2019-10-05.
See also pictures from that flight by Wayne Morgan.

Maybe the City of Folkston and Charlton County Development Authority (CCDA) might want to rethink its assertion in the Charlton County Herald that “We would not support anything that would jeopardize this national treasure.” GA-EPD’s opinion is much like what U.S. EPA said, that the mine would have “substantial and unacceptable impact”.

CCDA wrote, Continue reading

VSU Geology and ASA at Land Between the Rivers 2019-11-26

Two Geology Professors visited The Land Between the Rivers and wrote a letter about many projects they and their students can do there, at the site of Troupville Boat Ramp. This is more in-kind match for the GOSP grant pre-application.

[Prof. Don Thieme & Can Denizman, 13:30:33, 30.8515417, -83.3452859]
Prof. Don Thieme & Can Denizman, 13:30:33, 30.8515417, -83.3452859

Letter from Donald M. Thieme, Associate Professor, Geology, Valdosta State University (VSU):

[Donald M. Thieme, Associate Professor, Geology, VSU]
Donald M. Thieme, Associate Professor, Geology, VSU
PDF

I am very pleased and excited about the proposal by WWALS to develop the Troupville River Camp. The property in question is Continue reading

Suwannee Riverkeeper asks Georgia EPD to require Valdosta to do better about its record sewage spill 2019-12-17

FOR IMMEDIATE RELEASE

Hahira, Georgia, December 19, 2019 — Compelled by the severity of Valdosta’s record raw sewage spill and the expenses and stigma incurred nearby and downstream, Suwannee Riverkeeper for WWALS Watershed Coalition has sent a letter requesting ten enforcment actions to the Georgia Environmental Protection Division (GA-EPD). WWALS member Deanna Mericle of Hamilton County, Florida, summed it up: “As a person living downstream on the Withlacoochee River in Florida, I feel shat upon by Valdosta over and over. I cannot drink the water from my well. I worry about the health of the river itself and the animals that live in it and drink from it. We in Florida were patient while Valdosta was improving their wastewater plant, which apparently was not adequate since we still have spills when it rains heavily. But this time it was not a rain event. It was gross negligence. I am out of patience. I believe it is time for legal action.”

The Suwannee Riverkeeper letter notes GA-EPD already has a legal action against Valdosta, a Consent Order. WWALS asks GA-EPD to use its enforcement power to require notification, water quality testing, education, and plans and procedures not only for preventing such spills but also for tracking them as they travel down our creeks and rivers and for remediation of effects on wells and reputation.

[2019-12-17--WWALS-GA-EPD-Valdosta-sewage-0001]
2019-12-17–WWALS-GA-EPD-Valdosta-sewage-0001

“Valdosta says it does what GA-EPD tells it to do, so we’re asking GA-EPD to tell them,” said Suwannee Riverkeeper John S. Quarterman. “Today we’re forwarding the letter to Continue reading

U.S. EPA still finds Twin Pines mine will have a substantial and unacceptable impact 2019-10-03

U.S. EPA still finds that “the proposed project will have a substantial and unacceptable impact on aquatic resources of national importance.”

That’s about “the permit application submitted by Twin Pines Minerals, LLC” for a titanium strip mine. “The proposed 2,414-acre mine area lies in proximity to the Okefenokee National Wildlife Refuge (NWR), and the potential secondary effects of the mine on the NWR have not been demonstrated by the permit applicant.”

You, too, can still comment to the USACE, and all comments they receive before the Corps announces a decision can be used in any potential lawsuits.

[the proposed project will have a substantial and unacceptable impact on aquatic resources of national importance.]
the proposed project will have a substantial and unacceptable impact on aquatic resources of national importance.

The previous letter from EPA to USACE, of Continue reading