We have two families of problems concerning proposals to use ASR in Volusia County; some of these also apply to ASR generally.
First, we note that essentially all of this
county plus parts of adjacent ones are in the Volusia-Floridan Sole Source
Aquifer, per 52 FR 44221 of 11/18/87, see Annex I. Since we were the originator
of the request for this designation, we feel that we have "a vested interest"
in actions affecting this water system. As we read the regulations, several
sections apply, including
140 and 146.
Our first family of problems relate to the
functioning of ASR in this aquifer, including short and long time effects.
1) There appears to be a marked degree of
connectivity between the upper Floridan (the main source of public supply
drinking water) and lower levels in at least some parts of the system.
An example can be seen from Annex II A and B, which shows potentiometric
levels for the shallow and deep monitoring wells at the GE plant, Daytona
Beach, for the period 955-1981. Even casual inspection shows the correlation
in the annual cycle, in both time and amplitude. The relations given show
that there is an offset in level, and an appreciable amplitude correlation.
The pumping below sea level is a separate problem, no longer present in
this area as wellfields have been moved.
2) Annex III shows the general pattern of
runoff in the County. The zero runoff at the early karst structure known
as the DeLand ridge accounts for a sizeable fraction of the recharge to
the upper Floridan. It appears that at least part of this is via sinkholes.
There are over 100 of these, some appearing in Annex IV. The high correlation
in aquifer level suggests that at least
some of these penetrate well into the lower Floridan.
3) Several sources, such as The Geology
of Florida, U Press Fla, 1997, show a fault along the St. Johns River.
It is not very active, but small earthquakes have occurred, see Annex V.
Other faults are known, see Annex VI. The limestone formation is nearly
at sea level just east of the St. Johns River, and about 100 lower at the
ocean, so the Floridan formation is tilted.
4) There are 4 large springs in the county;
the two smaller ones are now reported to us to be non-flowing in the dry
season. Water quality data suggest that the largest, Blue Springs, (and
others outside the county) is fed with water from the lower Floridan, source
depth unknown, in some fashion related to the fault system. In contrast,
DeLeon spring appears to be conduit flow from the center of the upper Floridan.
A time series projection of flow indicates that this spring
will become intermittent as aquifer level drops.
The second family of problems relates to the need
for and the timing of an ASR program. The WMD now states that there will
be aquifer water availability problems by 2020. Note that we do not agree
with this statement: the problem is more immediate. Our studies indicate
that the aquifer has been pumped by more than the recharge in 3 years out
of 4 during the period 1991- 1995, and that the recharge in the fourth
year was not sufficient to make up the loss of the other years. The fall
is clearly shown in Annex II; all monitoring wells show the same trend.
The average level of the upper Floridan has been dropped by some 12 feet
in the center of the County, and by as much as 20 feet in the eastern parts.
Despite this observed trend, the WMD has not
taken corrective action. For example, the County has over 100 miles of
drainage canals, see Annex VII. One canal is reported to us to take more
water out of the system than is used by the City of Daytona Beach uses,
average years. There is no program of canal flow control: instead, new
canals and canal deepening and widening is authorized. Wetland destruction
in many parts of the County are regularly permitted, with no requirement
for recharge mitigation. There is no native plant program, just some brochures.
"Reuse' on lawns, road media and golf courses was instituted to get sewage
effluent out of surface waters. A late action of the WMD has been to permit
addition withdrawal of aquifer water to "make up" for the fact that dry-season
demand for effluent sometimes exceeds supply. And, despite the fact that
the area has experienced severe drought, the WMD has not appreciably changed
their watering rules, and has not imposed any restrictive use measures.
There is no real study of alternates to ASR. In fact the published reports
show that the only other element amounts to further lowering of aquifer
levels, and planned drying of wetlands.
The ASR proposal is to use water from the
St. Johns River as the source. This will not be available during much of
the 7 month dry season of the area, when the flow can be backward, so the
storage must be of large quantities of water, over half of the difference
between consumption and aquifer recharge. Providing for consumption does
nothing about other needs, maintaining minimum stream flow, lake levels
and wetland life, nor of maintaining healthy vegetative species
in the land forms.
Considering these factors we request the following:
1) No permit should be issued without a showing
of the other means of making water available investigated, their value,
and the reason why ASR is necessary, and further that the extraction from
source of the water is not damaging the water system or the environment;
2) No permits should be issued for any injection into any part of the Volusia-Floridan
Sole
Source aquifer until a comprehensive EIS is prepared;
3) No permit should be issued unless requiring
locating sinkholes, other areas of high connectivity, faults, springs and
intermittent seeps in the zone of influence;
4) Permit to require modeling of the injection
plume, taking into account formation tilt and the factors in 3), with a
showing that the plume does not damage the system measurably , for at least
the life of the project, this to be accomplished and accepted as valid
prior to any drilling operations.
(For a copy of the annexes, address email to ecouncil@iag.net