GA/EPD – Miocene Holdings Meeting Summary

I have now been given permission to publish these minutes. My thanks to Mr. Lewis of the EPD.

GA EPD – Miocene Holdings Meeting Summary
EPD Tradeport Offices Atlanta, GA – 6/11/29

Attendees:

Clay Burdette – EPD – Program Manager for the Water Withdrawal Permitting Programs (WWPP)
Bill Noell – EPD – Program Manger for Industrial Permitting Unit of Wastewater Regulatory Program (WRP)
Jane Hendricks – EPD - Program Manger for Wastewater Regulatory Program
Dr. Elizabeth Booth – EPD - Program Manager for the Watershed Planning and Monitoring Program
Ade Oke – EPD – Program Manager for the Surface Water Unit of the WWPP
Cliff Lewis – EPD – Assistant Branch Chief Watershed Protection Branch (St Marys Basin)
Michael Farmar – Miocene – applicant
Michael DeMell – Ecologist for Environmental Services Inc (on behalf of Miocene)
Dr. Stuart Stevens – Coastal Environmental Consulting Services (on behalf of Miocene)
Emmett Noblitt – Miocene
Chris Stovall – Miocene Engineer from the firm of Thomas & Hutton

1. Intro of attendees

2. Stovall and Farmar speak to the product in general, process and choice of business location
- Location chosen because of the Tannin rich swamp, but also looked at a number of other locations in other states. The site chosen was attractive because of the property location; size of property for potential future uses (i.e. blueberries or other crop production), and the existing building(s) there were right size for the operation. Additionally, “the St Marys is user ‘un-friendly’ at that location meaning little fishing, kayaking, other recreational uses, and general traffic there.”
- Product claim is that it enhances plant response and soil response. Process originated in ore leaching but this has been found to be more efficient and economically viable to get the tannins.
- Process equates to a water softener – pull H20, run through a filter that acts as an anti-ion magnet to grab tannins, mix with KLC solution, and discharge water
- Applied for 350,000 gallons per day (gpd) withdrawal but that ½ to ¾ of what they expect to actually withdraw for a number of years, as they are only beginning to grow the market for this product. When asked what they expect to actually withdraw, Mr. Farmar replied 20% of 350,000 gpd. He stated that he hopes that he would have a market for the product within about 7 years that would support his withdrawing of 350,000 gpd. In other words, he said he hoped to work up to that volume as business grows.
- Dr. Booth asked how much of the tannins they could pull out with their process. Mr. Farmar replied it is 50% efficient down to 20%.
- Mr. Farmar stated that understands that if there is no river flow then they aren’t in business.

3. Mr. Stovall presented his flow data (mostly verbally), 7Q10 data, etc.
- Upon listening to Mr. Stovall’s data explanations, Clay Burdette stated stated that the methodology (linear interpoloation) Mr. Stovall used in the 7Q10 analysis different than EPD’s methodology. Mr. Stovall also conveyed support for a single number to be used as a monthly 7Q10 number, but Mr. Burdette replied that monthly 7Q10 numbers would be a set of 12 numbers and not just one number.
- Mr. Farmar stated that he is fully prepared to take the business risk of being down for one year. That is to say that he may not be able to pump for one full year at a time. EPD explained that he needs to be prepared to not pump for longer than that because his one year idea comes from flow data results that EPD can’t reproduce at this time.
- The flow and low-flow calculation discrepancies between EPD and Miocene partially center on the fact that Miocene used a linear interpolation methodology to come up with results and EPD does not use that. Further, Clay Burdette suggested Mr. Stovall go back and recalculate their information using flow information from the Moniac gage. At this time, EPD supports Miocene using this gage as it is established and accessible and EPD believes it is representative of Miocene’s site. Basically, if the Moniac gage is reading 2 cfs, then you cannot “interpolate” that there is a site-specific flow of 5 cfs (or more), which it appears that Miocene is doing in their calculations. Mr. Stovall and Mr. Noblitt stated that there is a tributary that enters the water source just North of their proposed site and claim that flow from that tributary contributes to their calculations.

4. Mr. Stovall’s explanation and rationale for the three proposed intakes and three discharge points
- Regarding intakes, Mr. Stovall stated that withdrawal point C (out of A, B, and C) would be the main withdrawal and discharge point. Mr. Farmar pointed out that the reason for the three proposed withdrawal points was that no business goes into business without building in fail safes. Hence, withdrawal points A and B would serve as options in the event point C goes down in operation for some reason. He stated that these three points would not be used simultaneously. On the three discharge points, Mr. Stovall stated that the Army Corp of Engineers (ACE) made it a condition of their 404 permit that each withdrawal point has to have a discharge point associated with it and the discharge point must be within 100 ft of the associated intake (ACE 404 permit was produced and copies made by EPD).
- Mr. Lewis asked Mr. Noblitt if they had spoken with the GA Dept of Agriculture (DOA) about their operation and product and wanted to know of their thoughts and or support for the project. Mr. Noblitt replied that they had considered talking to the DOA, but at this time they have not.
- Mr. Lewis asked if they had already installed any infrastructure for this process on site, including storage recovery tanks, filter units, or pipe on the property. Mr. Noblitt and Stovall replied that no infrastructure has been installed and that all that is there is what existed when the property was purchased. Mr. Lewis further asked if any type of irrigation of trees, crops or other irrigation was currently or has been performed since Mr. Farmar purchased the property, to which all replied no.
- Mr. Stovall mentioned that GA EPD produces Ag water use permits that withdraw from St. Marys and have are basically 100% consumptive in their use and that Miocene has considered going the route of applying for an agricultural water use permit for this project. At that point, Mr. Burdette explained that this endeavor may not be allowed under an Ag Permit and that route would require further investigation. Miocene stated that they may be interested in that in the future for potential crop production.
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5. Regarding water chemistry
- Mr. Stovall stated that they would be adding potassium chloride to the stream from the process but that this would not harm the stream.
- Dr. Liz Booth stated she has questions and concerns about changing the calcium levels and the potential to leave metals toxic, which result in hard water. She stated that EPD needs more data from Miocene on that.
- Mr. Lewis asked if they had considered the high mercury content of the streams at that location and that area in general – specifically, what the tanning content of mercury may do their product. Mr. Noblitt replied that their tests show that the mercury does not remain contained in the product and that most of the mercury goes back via discharge.
- Jane Hendricks stated that according to something she read, Miocene reps have referenced this type of operation going on in Europe. Ms. Hendricks asked if Miocene would turn over to EPD any data they had received from that operation for our review. Mr. Farmar replied that they have talked to a consultant that is familiar with that operation in Europe but not only was Miocene unable to receive data on the operation they were denied information related to the location of the operation.
- Ms. Hendricks stated that she needs more information from Miocene on their anti-degradation analysis. If Miocene cannot produce an acceptable analysis then land application of the water would have to become a consideration again if the company was to proceed with the operation.

Action Items from Meeting

1. Miocene recalculate flows and 7Q10 information using the Moniac gage and discuss their results with EPD engineers. EPD suggests this may provide Miocene with more realistic results of what low-flow they would have to cease pumping and also how many months of the year they would not be able to pump during dry periods.
2. EPD’s Dr. Liz Booth and Jane Hendricks will pool their water quality data needs and will be sending a letter to Miocene soon conveying what further information is necessary.
3. EPD will site visit the location.

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Of note:

"Upon listening to Mr. Stovall’s data explanations, Clay Burdette stated stated that the methodology (linear interpoloation) Mr. Stovall used in the 7Q10 analysis different than EPD’s methodology. Mr. Stovall also conveyed support for a single number to be used as a monthly 7Q10 number, but Mr. Burdette replied that monthly 7Q10 numbers would be a set of 12 numbers and not just one number."

"The flow and low-flow calculation discrepancies between EPD and Miocene partially center on the fact that Miocene used a linear interpolation methodology to come up with results and EPD does not use that."

"Jane Hendricks stated that according to something she read, Miocene reps have referenced this type of operation going on in Europe. Ms. Hendricks asked if Miocene would turn over to EPD any data they had received from that operation for our review. Mr. Farmar replied that they have talked to a consultant that is familiar with that operation in Europe but not only was Miocene unable to receive data on the operation they were denied information related to the location of the operation."

It would appear that Miocene is, thus far, unable to supply accurate information and/or samples of prior application of this method (and its impacts upon water sources). Given the potential risks to the St. Marys River, this seems to be a high-stakes gamble and I am pleased that the SMRMC, the EPD and others are examining this project so closely.