by Buford Pruitt » Mar 23, 2006 5:55 pm
Wal-Mart submitted an Environmental Resource Permit application (ERP05-0518) to the Suwannee River Water Management District on Feb 27, 2006. The District has 30 days in which to respond to the application. District staff has told me they would submit to Wal-Mart a Request for Additional Information (RAI) by Mar 29th. The District’s ability to force a re-design of the site plans is limited when an applicant complies with all the District’s rules, and until we met with the District it had no reason to turn down the ERP application. The District has very little jurisdiction over subsurface impacts.
Last week, Drew Glasbrenner, PG, Fay Baird and I met with Clay Coarsey, EIT, of the District. I met Drew through Ken Hill. Fay is the Chair of the Santa Fe Springs Working Group, composed of local volunteers (scientists, county environmental staff, consultants and a county commissioner) and funded by the Florida DEP to advise various levels of government on water quality & quantity issues of springs within its baliwick. Clay is the civil engineer reviewing the application.
Drew made a very good case that WM’s engineers did not do enough to protect Mill Creek Sink Cave or the adjacent portions of the Floridan Aquifer, and he has followed that up with a letter to the District detailing his findings and suggested mitigation. At the meeting Drew pointed out that WM had done a lot of borings, more so than many applications he had reviewed, and that they had gone down to depths that were sufficient for him to make a good assessment of the subsurface of the site (although they had not gone deep enough in some places). He demonstrated that they had done an insufficient job of pointing out potential sinkhole problems. Fortunately for the NSS, he then proceeded to show where several potential sinkholes were apparently in the process of forming and could present potential problems to the cave and the aquifer in the future.
Drew said that the geotechnical engineers had recommended wet retention for the ponds, yet the applicant's civil engineer had proposed dry retention. Drew said that wet retention would be less likely to cause sudden sinkhole collapse than would dry retention. He recommended that both storm water ponds instead be constructed with impervious liners.
I had overlain the surveyed part of the cave onto one of the applicant's large-scale drawings beforehand and walked the group through the known location of the surveyed cave, the known location of the unsurveyed cave and the presumed locations and directions of the four distributaries of the cave that extend beyond the limits of exploration. Importantly, a large room named the Terminal Room lies beneath a large sinkhole that Cindy Butler, Gene Melton and Todd Leonard had radiolocated and GPS-ed using Brian Pease’s instrumentation. The cave is known to tie into Hornsby Spring as a result of dye tracing studies done by Pete Butt and Tom Morris, via a theorized lineament connecting Alachua Sink on Payne's Prairie with Hornsby Spring. Mill Creek Sink Cave would then be tributary to this lineament.
Most of the surveyed portion of the downstream cave is under the developer’s property, with only a tiny portion being under the proposed Wal-Mart site, and the entry road will cross over the cave in two locations (contrary to the 1,200ft separation claimed by Wal-Mart). My point here is that even though the Wal-Mart site might not be directly over the cave, future development on the remainder of the total development property could jeopardize the cave even more than the Wal-Mart store.
The District has two versions of the Environmental Resource Permit (ERP). The quicker version is approved by staff, while the more delayed version must be approved by the District's appointed Governing Board. The pertinent threshold between the two is whether the project will impact >=100 acres. Although Wal-Mart is applying for the staff-approved version, I have been able to demonstrate that their 36.47-acre site is a part of a larger (>140 acres) property currently under development pressure and owned by a single development group (thanks to Annette Long for sharing the legwork with me to make that case). My letter to the District asks that the application be elevated to the Board-approval level. If this happens, the application will undergo a longer review time and receive more scrutiny by the District and commenting agencies such as DEP and the county environmental department.
Pre-existing development within the project area has a dilapidated storm water treatment system that was constructed before the advent of the modern storm water retention systems that are now so prevalent in Florida. The WM application proposes to discharge overflow from their storm water treatment system into the existing system. I have recommended to the District that WM at the very least needs to perform M&R on that system before they are allowed to use it. Better yet, the entire project area needs to be developed with Mill Creek Sink Cave in mind; that is, all future storm water treatment ponds need to be located away from the karst plain up on the adjacent clayey uplands if possible. Otherwise, they should be over-sized and lined with thick clay and/or impermeable membrane liners.
Cindy Butler has worked tirelessly in her efforts to bring attention to the potential adverse impacts to the cave from the Wal-Mart store. I hope she continues in that vein towards the entire project area, not just Wal-Mart. She has been making presentations to local groups, to Wal-Mart, and I don’t know who all. She is now working on a possible plan to conduct baseline water quality sampling in the cave. She is constantly coming up with new ideas and new activities that could help our cause.
John Moseley and Al Heck have done a fine job of surveying the cave to date, and it now looks like they are about to pass the tape and compass to Todd Leonard and his diving buddy. Ken, you’ll be happy to know that we might be able to get some free legal advice, but enough of that for now.
Pete Butt of Karst Environmental Services, Inc., has freely given of his recent dye tracing studies in Mill Creek Sink, which has definitely tied the sink to Hornsby Springs and the Santa Fe River. Pete is now working on ways to fund an upgrade to the existing storm water treatment system. Bob Cohen, PG, representing the Sierra Club and a group of local businesses, has offered the assistance of his group. Todd Kincaid has offered to place the cave map within a large Florida State maintain database of cave maps for use by any agency that might want to become involved. John Owens, Ph.D., found Mark Clark for us, and has offered to find other expertises within the University of Florida. Mark Clark, Ph.D. has offered assistance in enhanced treatment design for the storm water ponds.
Thus, Steve Ormeroid and I have been fortunate to have the assistance of at least 18 people on this threat to the only underwater cave owned by the NSS. Many of them came forward and volunteered before we even asked for assistance. Some were continuing to offer new services as late as a few minutes ago. All are concerned about the health of our cave and are willing to put their efforts where their mouths are. So, the next time you see any of these nice people, please thank them. They are working hard for you, for free.