The Tom Joiner and Associates Report is a “virtual” hydrological assessment, and does not include field investigation, other than minimal monitoring well assessment; 13 wells over 886 acres is inadequate to fully assess groundwater fluctuations to adjacent areas under varying seasonal conditions. No attempt was made to determine the actual subsurface in the land area other than reliance on previous geologic studies and less than 17 reported borings, or to determine its significance and/or impact to the Subject Site and surrounding properties. GPR and Electric Resistivity Tomography (ERT) have not been used to accurately map what is under the soil. (The complete analytical results of these borings has yet to be released despite numerous requests) No effort was expended to groundwater modeling to the local or regional aquifer, other than to cite references from previously published literature. No on-site dye tracing and analysis has been performed. Information detailed in the hydrology/geology which was stated as “fact” is either conjectural and/or goes beyond the available evidence which is minimal; there is no existing statistical model in Vincent to compare it to.
What should be demanded:
In order for the Vincent Hills quarry to proceed in a manner which will minimize impacts, approval should be delayed until the following data can be provided and reviewed:
1. An accurate groundwater elevation map should be developed using available static water level elevations from the new (need to be established) and existing monitoring and water supply wells in the area.
2. The means by which water management will be handled at the Site should be described in more detail. Monitoring wells should be accessible to the EPA for testing with no requisite restrictions or notification and test results should be beyond PH and turbidity, and include testing for high risk chemical contaminants such as benzene and petroleum by products. These reports should be made readily available to the public without censure and delay and not remain solely in the Vincent Water Board's control to disseminate when they deem appropriate.
3. Peak flow measurements should be made for the tributaries draining into Spring Creek both near the site and adjacent properties. These measurements will aid in developing a stormwater and sediment and erosion management plan that is based on site specific data, rather than conjecture or extrapolation.
4. Turbidity measurements should be made of all the Spring Creek tributaries that originate on and very near the WRQ site, including the unnamed tributaries that flow into Spring Creek. (ADEM recognizes that these exist.)
5. A dewatering test should be conducted to determine the effect of quarry dewatering on surrounding springs and wells. This test should include the installation of a sufficient number of extraction wells, capable of lowering the local water table to the proposed depth of quarrying.
Once a stable draw-down at the level of the quarry excavation is reached, the pumping should be continued at the appropriate rate for a minimum of 72 hours. All accessible wells and springs on the WRQ property, and within the 2 mile radius should be monitored for changes in water level, turbidity and flow.
6. A dye trace should be conducted to determine these tributaries of Spring Creek and the base flow conditions during the draw-down when water levels are at their lowest.
If the WRQ quarrying activities are not carefully controlled and managed, a steady flow of sediment-laden water may be directed towards Spring Creek and its tributaries, particularly during storm events and subsequent flooding that may accompany heavy/prolonged rain events.
The overburden risk on the known karst terrain from the settlement ponds has not been addressed at all. Should failure occur, the contents of the sediment ponds will be rapidly drawn through the karst conduits and risk contaminating the entire water supply. These ponds are represented as "clean" when in fact they contain the quarry tailings; which are by-products of the mining operations.