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HomeMy Public PortalAbout100_072_2015.03.02_DRAFT Letter to EPD Requesting Approval of Wellhead Protection and Min Standards/ Nathan Deal Governor GEORGIA ENVIRONMENTAL FINANCE AUTHORITY Kevin Clark Executive Director [ ], 2015 Don Shellenberger Kirk Chase Georgia Environmental Protection Division 2 Martin Luther King Jr. Dr. Suite 1362 East Tower Atlanta, GA 30334 Re: Cretaceous Aquifer Well on Tybee Island – Wellhead Protection Application and Certain Minimum Standards for Public Water Systems Dear Mr. Shellenberger and Mr. Chase: As we have previously discussed, the Georgia Environmental Finance Authority (“GEFA”) plans to conduct a demonstration project with the City of Tybee Island that would explore the feasibility of using the Cretaceous aquifer for water supply (“Coastal Deep Well Project”). GEFA’s plans for the Coastal Deep Well Project are limited to the drilling and short-term testing of a Cretaceous aquifer well on Tybee Island, Georgia. The Coastal Deep Well Project is located at the City of Tybee Island’s (“Tybee”) Public Works Department property (see Exhibit 1), but GEFA has an easement interest in the property where the wellhead will be located (see Exhibit 2). Although Tybee is listed as the owner of the municipal drinking water system in the wellhead protection application, GEFA will own the Coastal Deep Well Project itself. GEFA will hire contractors for the design, construction and testing of the Coastal Deep Well Project. Water from testing will be discharged into the Savannah River and not into Tybee’s drinking water system. Based on the results of this testing, GEFA will prepare a report analyzing the feasibility of using the Cretaceous aquifer for water supply on a long-term basis. This information is GEFA’s primary purpose in conducting the Current Deep Well Project. After analyzing this information, it is anticipated that Tybee will lease the Cretaceous aquifer well from GEFA, and then develop whatever additional water treatment and infrastructure may be necessary to use the well for water supply (“Future Water Supply Project”). Our expectation is that Tybee will not be making the decision to pursue and permit the Future Water Supply Project until after testing and analysis of the Cretaceous aquifer water supply, which is to be conducted through the 2016. Given that the Coastal Deep Well Project will not involve the supply of drinking water, GEFA does not plan to apply for a drinking water permit, which would include the submission of a wellhead protection application. However, GEFA wants to preserve the ability of Tybee to pursue the Future Water Treatment Plant Project if it chooses to do so based on the results of GEFA’s testing and analysis. To achieve this goal, GEFA and Tybee are requesting that the Georgia Environmental Protection Division (“EPD”) review, comment and approve a Wellhead Protection Application as well as some requested exceptions to the Minimum Standards for Public Water Systems. Also, even though Tybee will have no legal right to use the Cretaceous aquifer well until it decides to lease it in the future, Tybee is requesting that EPD add this well to an updated Wellhead Protection Plan to ensure that no activities affect the potential to use the well as water supply between now and the date Tybee may choose to lease the well from GEFA. Please see the attached letter from Tybee supporting the requests outlined below. Specifically, GEFA and Tybee are requesting the following: Tybee is submitting the attached wellhead protection application for your review and approval. Please let us know if have any questions or comments and whether a site visit would be helpful. Once we’ve addressed your questions and comments, we would like a letter addressed to Tybee (a) specifying that the Cretaceous aquifer well satisfies the wellhead protection requirements and (b) authorizing Tybee to submit the letter at a later date to EPD to satisfy the wellhead protection requirements associated with a drinking water permit for the Future Water Treatment Plant Project. We have reviewed the standards in Section 5.3.2 of the Minimum Standards for Public Water Systems, May 2000, and we have attached a summary either describing how this well meets the standards or where we are requesting an exception (see Exhibit 3). Again, please let us know if you have any questions or comments and whether a site visit would be helpful. Once we’ve addressed your questions and comments, we would like a letter addressed to Tybee (a) specifying that EPD is willing to grant an exception for the standard in Section 5.3.2(e) and (j), (b) confirming that the Cretaceous aquifer well otherwise meets the Minimum Standards for Public Water Systems and (c) acknowledging that Tybee will be relying on this letter if it chooses to pursue the Future Water Treatment Plant Project. To ensure that activities of Tybee and others between now and the date that Tybee may choose to lease the Cretaceous aquifer well from GEFA, Tybee is requesting that after EPD provides the two letters outlined above that EPD work with Tybee to update its Wellhead Protection Plan. While communities do not typically include wells owned by third parties in their Wellhead Protection Plans, we believe this action is prudent to ensure that Tybee preserves its ability to use the Cretaceous aquifer well in the future for water supply should it choose to do so. The enclosed Wellhead Protection Application and summary re: Minimum Standards provide additional information, maps, diagrams and details that will be useful in your review, but please feel free to reach out to Andrew Morris at 404-584-1055. He is the Senior Program Manager at GEFA for the Current Deep Well Project, and he would be happy to assist you. Sincerely, Russ Pennington, P.E. Director of the Governor’s Water Supply Program KC:am Enclosures cc: Mary Walker, COO, EPD Jac Cap, Chief, Watershed Protection Branch Kevin Clark, Executive Director, GEFA Linda MacGregor, Water Resources Director, GEFA Andrew D. Morris, Senior Program Manager, GEFA Wayne Murphy, Project Manager, CH2M Hill