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Environ. Forensics /2&".%"5*22/. "%*/$"1#/.*.)8%1/,/(*$2823&-2$/.3"*.*.(%*22/,5&% -"(-"3*$$"1#/.%*/7*%&Science /2&"5*22/.1*22 2/3/0&)8%1/,/(8/'5/,4-*./42$/,%201*.(2*. '1"$341&%1/$+'1/-"."$3*5&5/,$".*$1&(*/../13)&"23&1.",*'/1.*"Journal of Hydrology Hydrological Services mldh2o.com CRITIQUE OF 2014 GEOSYNTEC REPORT Daniel Axelrod 7-10-14 The 2014 Geosyntec Report “Hydrogeologic Review and Well Testing” (GR, as released in abbreviated form on the MS City website) attempts to reassure the public and local governmental bodies that the proposed Crystal Geyser plant will pose no geological hazards, and as such, does not need further hydrogeologic study. Whether this conclusion is scientifically justified is not clear from a reading of the GR, since the available report selectively omits much of the actual full report, including several important appendicies. However, even a review of the limited amount of information that has been made publicly available shows gaping holes in the scientific logic and evidence, which I will examine here. I am a Professor Emeritus of Physics at the University of Michigan, still active in research, with about 130 peer-reviewed published research papers over a 43 year career. I am not a hydrologist by training but I am familiar with the fundamental physical principles involved as well as what constitutes valid scientific and statistical statements. Unlike the Geosyntec and CH2MHILL consultants, I have no business relationship with CG or any other group and I have no position on whether this project will or will not have a noticeable environmental impact. My only interest, as a local resident and professional scientist, is in seeing that possible serious and foreseeable and possibly mitigatable impacts are discovered before the project goes forward. The discussion here generally follows the order of presentation in the GR, with relevant passages quotated. The first part of the GR reviews the 1998 study of the area by SECOR International (1) Section 2.2: Page 7, top. “A cross-section showing the geology along a section between DEX-6 and Big Springs is shown in Appendix A-Figure 7.” Neither Appendix A nor Figure 7 are provided. But Figure 7 may be the same as two slides shown in the CG PowerPoint presentation to the MS City Council on 3-24-14, copied here: Fig. a Fig. b The second figure shows a detail of three soil/rock layers underlying the vicinity of Spring Hill. Unfortunately, it is not clear that the figure was based on any geological measurements or observations at all. In fact, I asked CH2MHILL geologist Martin Barackman what data that structure was based upon during a break after his 3-24 presentation at the MS City Council meeting. He said the structure is mainly an inference, an interpolation, based on only three spots. He did not say which three spots, or how the ground structure was measured at those spots, or how they know the orientation of those subterranean layer in between those spots, or how they know that the water flows through three different layers (as shown on the right side of the figure), or how they know that water at DEX-1,2,6,and OB-3 all tap the same flow, or that this same flow emerges at Big Springs. The figure is evidently not a representation of geological actual data, but only a pictorial schematic of the conclusion that previous owner Dannon/Coca- Cola wished to support: namely, that DEX-6 is indeed “spring water”. On the other hand, reality may be far more complicated. Water (mainly snow-melt) from Mt. Shasta probably flows down in channels, partially or completely filled by fractured andesite. These channels were formed by many separate lava eruption events. As such they may cross each other at different depths, or intersect, or merge, or split from each other. A good picture would be a three-dimensional mesh of curving tubes. Some regions may pool water and fill up, with drains near the top, others may form narrow rapidly flowing channels. Any models based on a continuous single body of stagnant water soaked into sedimentary rock (an “aquifer”, typical of the Great Plains or the CA San Joaquin Valley) are probably wrong. Here is a drawing of the 3D structure of Wind Cave in South Dakota. It is shown here NOT to suggest that the water channel structures underneath the flanks of Mt Shasta are at all similar (the geological origin is very different), but only to illustrate the possible complexity of some underground channels. The different colors represent channels at different depths. Fig.c Just to make a 3D structure of underground channels more vivid, here is a computer- generated model of a hypothetical cave: Fig. d The point is not to show that Mt Shasta’s underground water channels look like this. How they look is completely unknown: that is the point. The manner in which a complicated structure transmits water is also unknown, but it is likely to be much more complicated than assuming a stagnant aquifer pool. The vastly oversimplified model in GR, based on nothing but conjecture, does not constitute a data-based scientific model nor does it yield useful predictions on water flow patterns. (2) Section 2.2: Page 7 third paragraph. “The static groundwater level in the production borehole (DEX-6) was measured at 198.000 feet below ground surface…” (in 1998). As will be discussed later, the measured level below surface in the same well had dropped 4 feet after the Dannon/CocaCola period of pumping, as measured in 2012. That may be a significant drop. (3) Section 2.2: Page 7 third paragraph. “Based on site groundwater elevations (Appendix A – Figure 8), groundwater beneath the Spring Hill Property, in the vicinity of the boreholes and wells, flows in a southwestern direction towards Big Springs.” This conclusion is unwarranted, in part because it is not known for sure in this specific case that the boreholes and wells all tap into the same single channel. In principle, the conclusion is unwarranted because water in a sealed channel can be driven from lower to higher ground water elevation in some local regions because of a pressure head from water much farther upstream in the channel. So the “southwestern direction” flow is at best a guess perhaps adopted solely because it supports the desired conclusion, i.e., that DEX-6 needs to be connected to Big Springs to legally qualify as “spring water”. Appendix A-Figure 8 are nowhere to be seen in the GR, rendering a weak case even weaker. (4) Section 2.2: Page 7 bottom. “The stable isotope results…” It is stated that the isotope composition and water quality are similar between the boreholes and Big Springs. It is implicitly suggested (and wisely, not explicitly stated) that this is evidence that the borehole water and Big Springs water are from the same channel or aquifer. However, similarity is unsurprising even if the channels were distinct because both sources are clearly from the same type of source: snowmelt on Mt. Shasta, percolating through the same type of rock. There is a reason that it is so important to know whether the channels are the same or different. If the channels are at least partially distinct, then over-pumping of DEX-6 by CG could, in principle, severely deplete its own channel while not affecting Big Springs much.