TESTIMONY, Tom Allen, Former Assistant Chief of Division of Drinking and Ground Water, Ohio EPA, Retired 2010

Tom Allen’s Statement

Ohio EPA, February 1, 2018 Public Meeting
Enon Sand and Gravel proposed mine project.

My name is Tom Allen. I am retired from Ohio EPA, following 32 years of service, where I was the assistant chief of the Division of Drinking and Ground Water (DDAGW) and oversaw the ground water program statewide. I appreciate the opportunity to provide input on Enon Sand and Gravel’s proposal to discharge storm water, ground water and gravel washing process wastewater.

First, let me say that I am not against mining for sand and gravel or limestone, as these materials are important resources for building our communities. But, the scale of this proposed project far exceeds the small family operations that have been in operation in this area for over 100 years. The operation is proposed in a beautiful and unique area, which is very sensitive to quality and quantity impacts of ground and surface water resources from this type of land use activity. Today, the land use in the proposed mine area includes single family homes that have been developed alongside family farms, some run by 3rd and 4th generations.

The reason this proposal is even being considered as potentially approvable for mining is the inadequacy of rules and regulations. The ODNR and Ohio EPA permitting processes do not sufficiently require site specific data and information, as it relates to protecting the environment and water resources. The regulatory requirements for siting and operation of the mine should prevent impacts or issues that will be a burden or cost to citizens and the community.

I realize the focus of this public meeting is the Ohio EPA authority of the Clean Water Act, as it relates to the discharge of water from the mine area, but it is difficult to understand how this decision can be made or that other Clean Water Act requirements are being met, such as protection of wetlands, with limited information.

Many of the potential impacts to water resources are dictated by the geologic and hydrogeologic conditions, such as the shallow, highly fractured bedrock. To eliminate or minimize impacts, the following studies and evaluations should occur:

– conduct a complete water budget of ground and surface water resources from the point on Mud Run below the proposed mine area, up both branches of Mud Run to the upper boundary of the watershed;

– in this defined area, identify all ground water discharges in the form of springs and seeps and their current water quality;

– determine the relationship of ground water on surface water quality and quantity, including from springs and seeps;

– identify all wetlands, including those associated with springs and seeps;

– define current water quality in Mud Run above and below the proposed mine area, especially during periods of low flow in the stream;

– based on proposed operations, including excavation, pumping of excess water and blasting, determine potential quality and quantity impacts to surface and ground water resources; and

– determine the measures necessary to assure that the water discharged from the mine site, estimated to be 720,000 gallons per day on average, will not impact surface water quality or quantity, along with addressing other potential impacts, such as destruction of the riparian area, physical changes to the stream channel and flood plain and increased sedimentation and erosion.

I have fond memories of this area from days at Oak Grove School and of my youth fishing, hunting, hiking and exploring. I would hate for this beautiful area to be destroyed. But, the most important point I hope I made is that this kind of land use is incongruent with the current land use and will negatively impact both social and environmental resources for the citizens in this area and all of Ohio.

Thomas M. Allen
Lewis Center, Ohio 43035