In the draft permits released Monday for Bulloch and Bryan counties’ four big wells to supply water to Hyundai’s Metaplant America, the Georgia EPD makes a fully defined and application-ready mitigation fund for impacts on other wells in a five-mile radius a “must” before pumping begins.

Monday, July 8, was the first time the state Environmental Protection Division has released the draft permits for public inspection and comment, and the EPD also announced that it will hold a new meeting for public input Aug.13 from 6 p.m. to 9 p.m. in the auditorium at Southeast Bulloch High School. That was also the location of an information and input session held in late February after the EPD Watershed Protection Branch on Jan. 30 issued a list of proposed special conditions for the permits.

As now drafted, Bulloch County’s permit will be for two wells, together drawing up to 3.5 million gallons per day as a monthly average but limited to 3.125 mgd as an annual average. Bryan County’s two wells, together, will be limited to 3.5 mgd as both a monthly and annual average. So the four wells, collectively, would be allowed to withdraw up to 7 mgd in a given month but only within a 6.625 mgd average over the course of a year.

All four wells will be located within southern Bulloch County near where Interstate 16 crosses the Bulloch-Bryan County line.

Mitigation fund

The January draft of the special conditions called for the two county governments to create a “municipal managed fund … to address any potential impacts to existing … residential … or agricultural wells” in a five-mile radius of the I-16 and Georgia Highway 119 interchange.

EPD scientists, as reported from the February meeting, predicted a drop of up to 19 feet in the water level in the deep Floridan aquifer at in the center of the cone of depression nearest the wells, tapering off to a drop of 10 feet or less five miles away. So the mitigation fund would pay to make changes, such as lowering submersible pumps or possibly deepening wells, after a Georgia-licensed well driller or pump installer investigates “alleged significant impacts to existing wells,” as the permits state.

The draft permits now assert that the counties “must create” the mitigation fund. But where the Jan. 30 version of the special conditions stated that the fund “may include industrial monetary contributions and assistance,” the new draft permit version allows, more broadly, that the fund “may include contributions from other entities.”

County actions

The Bulloch County Board of Commissioners by a pair of 4-2 votes on June 27 approved both an intergovernmental agreement with Bryan County on the operation of the wells and potential county-owned water and wastewater systems and a separate memorandum of understanding, or MOU, on the well mitigation fund.

The MOU, less specific than the intergovernmental agreement, was more of a starting point, whereby Bulloch and Bryan counties “are pledging in good faith to create a well-mitigation program,” Bulloch County Manager Tom Couch said during the June 27 meeting.

But the condition in the draft permits, if adopted by the EPD in the final version, will mandate that Bulloch and Bryan counties have the detailed mitigation plan in hand and available to the public before any water is pumped.

These subsections are in both counties’ draft permits, under the “Special conditions … Addressing short-term impacts” headings:

1.   “The permittee must develop mitigation fund mechanisms with defined forms, mitigation practices, processes and protocols prior to withdrawals from the permitted groundwater wells.

2.   No groundwater withdrawals may be made until the materials approved under item …(1)  above are made readily available on the permittee’s website to the public.

3.   This mitigation fund must be implemented for the duration of the authorized groundwater usage from the permitted wells.”

The draft permits do not specify where the money for the mitigation plan will come from. But a further subsection states that each county “must submit” an annual report to the EPD by each Jan. 31 “describing the fund amounts available, the amount … distributed to each user, the total … distributed over the … preceding year,” and the “number of wells rehabilitated and how.”

Funding sources

Asked about funding sources for the mitigation program in a June 28 interview, Couch said the Development Authority of Bulloch County and the Development Authority of Bryan County had pledged $250,000 each but that he didn’t know if this would go further than “seed money.” Payments in lieu of taxes received by the four-county Savannah Harbor-Interstate 16 Joint Development Authority, or JDA, for the Bryan County Megasite where Hyundai Motor Group’s electric vehicle Metaplant is being built could be another source of funding, as could revenue from the water system fees, eventually, he said.

“But I also know that some of the people who object to the wells or the MOU have an expectation that it should come from Hyundai or its affiliates,” Couch said. “I don’t think at this time I know of a quarterback who’s willing to call a play and approach Hyundai and its affiliates; it just depends on who draws the straw to do it.”

In fact, the MOU states, under a “Funding sources” heading: “Such monetary contributions and assistance shall be primarily from industries creating the impact, but may also include local, state, federal assistance, and any other available source where prudent and necessary.”

A provision for the two counties to create an advisory committee on the well mitigation programs, with each county appointing three members, is in the MOU, but not in the EPD permits.

25 years to replace

The draft EPD permits treat the mitigation fund as a way to address “short term impacts.” To address “potential long-term impact,” another permit condition states that the counties “must expeditiously and thoroughly plan for the timely provision of surface water or other water alternatives, such as reuse water” to substitute for the groundwater being pumped from the aquifer within 25 years.

The Savannah River is the surface water source previously discussed by the counties’ consultants, and “reuse water” means treated wastewater, possibly from the factories and surrounding development.

Couch said he believes one or more alternative sources could be developed in 15 years with a concerted effort.

Although the well permits would expire after 10 years – the EPD’s standard term – unless renewed, they retain the 25-year replacement period and state: “This shall mean that at the end of the 25 years from this permit issuance, the permittee shall have fully replaced the groundwater from these … wells by surface water or an alternative water source.” But the same section states that the counties can apply to modify the permits.

Permits online

Both counties’ draft permits can be found at https://epd.georgia.gov/water-withdrawal-permitting. Related links on the page include the notice of the Aug. 13 public meeting and a summary of typical public comments from the Feb. 26 meeting and the EPD’s responses to them.

In addition to the Aug. 13 meeting, area residents or others interested can email written comments on the permits to EPDComments@dnr.ga.gov or mail them to Environmental Protection Division, Watershed Protection Branch, Suite 1470A East Tower, 2 Martin Luther King, Jr. Dr., Atlanta, GA 30334. The comment period closes Tuesday, Aug. 20. Include the words “Groundwater Applications for Bryan County Mega-Site” in the subject line.