Since September, GA-EPD has twice more asked the miners for more information on their permit applications to strip mine for titanium dioxide too near the Okefenokee Swamp. We have more questions beyond those. You can ask GA-EPD questions, and to deny the mining permit applications.

On October 20, 2021, the Georgia Environmental Protection Division (GA-EPD) asked more questions about water: retention, disposal, reclamation. The miners’ answer on November 19th apparently was not satisfactory, because on December 7, 2021, GA-EPD asked more water questions.

TPM Ponds and Another GA-EPD Letter

I’ve got another: how can Twin Pines Minerals (TPM) with a straight face promise “zero discharge of wastewater” and in the next paragraph say “Overflow from the process water primary overflow pond may occur due to heavy rain events.” That’s exactly what happened after Hurricane Irma at three north Florida Chemours mine sites where TPM was processing tailings, resulting in TPM still being under a Florida Consent Order. What if wastewater overflows into the Okefenokee Swamp during a hurricane or other “heavy rain event”? What stops wastewater even in TPM’s proposed retention ponds from seeping down into the Floridan Aquifer, from which we all drink?

And another: TPM still shows piezometers for water monitoring on property it does not own, with a disclaimer that it has no access to. So how will TPM monitor that area, which is downhill towards the Okefenokee Swamp, which is the headwaters of the St. Marys and Suwannee Rivers?

You can ask GA-EPD for a moratorium on mining permits, or to deny the permits, or at the very least to examine them very thoroughly and produce the equivalent of the Environmental Impact Statement that the Army Corps should have been working on.
https://wwals.net/?p=55092

You can also use Protect Georgia form to end a message to your Georgia statehouse delegation.

Floridians, this mine site is upstream from Florida, and you can also use these forms.

All of this GA-EPD correspondence with the miners and the permit applications is on the GA-EPD website. These most recent documents are also on the WWALS website.

Twin Pines Minerals, LLC Permit Coordination Comments, December 7, 2021

Without liners, what would keep the wastewater out of the Floridan Aquifer?

Page 2
PDF

Twin Pines Permit Coordination Document
Charlton County: Saunders Demonstration Mine
December 7, 2021

1. Sheet 6, Pond Design and Details and Notes:
   Please provide design characteristics (gates, valves and spillway) for the Emergency Overflow
   Spillways (spillway), which include a cross section of the spillways with liners and riprap.
   Please provide a contingency plan if an overflow discharge were to occur.
   Please provide pump capacity and pipeline size.
   Please provide berm construction details including the placement of the liner.
   Please provide liner system specifications and geometry.
   Please provide the liner support base material and thickness.

SHEET 6: POND DESIGN DETAILS & NOTES
PDF

Zero discharge of wastewater?

TPM makes a bold claim of zero discharge of wastewater in its November 19, 2021, SUPPLEMENTAL NARRATIVE (page 17) of the SURFACE MININNG LAND USE PLAN, SAUNDERS DEMONSTRATION MINE (MINE ID NO. 2073). boldface emphasis added.

5.1.2 Excavation, Processing, and Backfilling

…

Humates and clays will also be separated from the process water as slimes within the PCP [Pre-Concentration Plant]. The slimes will be separated from the process water in a thickener. The underflow from the thickener will be dewatered and temporarily stored before being transported back to and placed in the mined pit area for reclamation. The facility will operate with zero discharge of wastewater.

A claim made dubious by the next paragraph.

Process water for the mineral separations will be withdrawn from the process water ponds (Sheet 3 – Mining Plan Sheet – Site Layout) TPM will utilize three lined process water ponds and one lined primary process water overflow pond to maintain the adequate volume needed to operate the PCP/WCP [Wet Concentration Plant]. Overflow from the process water primary overflow pond may occur due to heavy rain events. Such overflows will be routed to the sand processing area water management pond. Water in the water management pond will be stored until it can be routed back to the process water ponds and used for process make-up water. Two water wells installed in the Upper Floridan Aquifer will be used to supply makeup water as needed to maintain adequate process water reserves.

At the end of the section again we see a rosy scenario disrupted by heavy rain.

The tailings from the PCP/WCP area will be temporarily stockpiled. Tailings and slimes will then be loaded onto the mainline tails conveyor system. The mainline tails conveyor system will convey material onto a reclamation conveyor. The reclamation conveyor will deposit the tailings back into the mined pit area for reclamation. The mainline tailings conveyor will also be used to transport the blended bentonite/sand mixture to the pit.

Water within the active mining pit is anticipated to be withdrawn only during upset conditions (i.e., equipment maintenance/failure), installation of the soil amendment layer, or due to a heavy rain event. This water will be pumped from the mine pit to the mine pit water management pond and subsequently used for process make-up water or dust control.

So these same slimes (tiny toxic particles of clay and titanium dioxide) that we’ve been complaining about since 2019 could get loose during heavy rain, along with air-deposited coal plant mercury stirred up by the mining.

TPM is still under a Florida Consent Order for “silt fence … overwhelmed with sand, process water and tailings fill deposited in a wetland without permit authorization” while processing tailings at Chemours titanium strip mines in north Florida.

Four times spelled out, on four different pages

The only pollution spills related to Hurricane Irma in the Suwannee River Basin in Florida that were not due to vehicular accidents were from those same Chemours mine sites in north Florida:

Follow this link for the interactive google map.

On 18 September 2017, there were three reports from Baker and Bradford County by The Chemours Company:

• Chemours North Maxville Mine
  09/18/2017 03:46:42 EDT
  The Chemours Company – North Maxville Mine PO Box 753; 7775 S CR 228; Starke, FL; 32091
  State Watch office has not yet assigned incident Number. Due to the significant rain event associated with Hurricane Irma, Stormwater and process water was released from the emergency spillways at at one mining cell (turbid water – no hazardous materials or chemicals). Discharge from the emergency spillways ceased over the course 2 dyas days. , ,

• Chemours Maxville Mine
  09/18/2017 03:25:31 EDT
  The Chemours Company – Maxville Mine PO Box 753; 780 Hwy 301, Maxville; Starke, FL; 32091
  State Watch office has not yet assigned incident Number. Due to the significant rain event associated with Hurricane Irma, Stormwater and process water was released from the emergency spillways at 4 of the ponds on the site (turbid water – no hazardous materials or chemicals). Discharges from the emergency spillways ceased over the course of a few days. , , Additionally, turbid water was released from NPDES point (D001). Due to high winds, sediment was not able to be settled from the water column., , , ,

• Chemours – Trail Ridge
  09/18/2017 04:04:05 EDT
  The Chemours Company – Trail Ridge PO Box 753; 5222 Treat Road; STARKE, FL; 32091
  State Watch office has not yet assigned incident Number. Due to the significant rain event associated with Hurricane Irma, Stormwaterwas released from the emergency spillway at the West Levee.

Water monitors on land TPM does not own or have access to

Meanwhile, TPM’s SHEET 14: GROUNDWATER & SURFACE WATER MONITORING PLAN (2) shows Piezometers clearly in the TIAA tracts west of the Trail Ridge Minerals tracts.

SHEET 14: GROUNDWATER & SURFACE WATER MONITORING PLAN (2)
PDF

Reading closely in the previous SHEET 13: GROUNDWATER & SURFACE WATER MONITORING PLAN (1) we find: “TWIN PINES MINERALS, LLC (TPM) NO LONGER HAS ACCESS TO THE TIAA-OWNED PROPERTY WEST OF THE MINE.”

SHEET 13: GROUNDWATER & SURFACE WATER MONITO
PDF

So TPM has no way to measure contamination heading west from its demonstration site into the River Styx and the Okefenokee Swamp.

Please ask GA-EPD for a mining moratorium, or to reject the mine, or at least to examine the permit applications as thoroughly as an Environmental Impact Statement.
https://wwals.net/?p=55092

 -jsq, John S. Quarterman, Suwannee RIVERKEEPER®

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

Short Link: