Analysis and Extent of Santa Fe River Flooding in North Florida Attributed to Rainfall and Wind Damage Associated with Hurricane Irma

The Santa Fe River (SFR) is within the north Florida area of the regional Floridan aquifer system. The extent of recent flood damage in the SFR and tributaries in Bradford County has been attributed to rainfall and wind damage to trees associated with Hurricane Irma, September 2017. Implications of the determined cause of a disaster can include the allocation of disaster relief funds. Bradford County, Florida obtained approximately $2.5 million from the United States Department of Agriculture’s (USDA) Natural Resources Conservation Service (NRCS) for emergency flood abatement assistance and $255,875 from the Suwannee River Water Management District (SRWMD), combined with $13,750 in-kind match provided by the county, based on the attributed cause of that damage to rainfall and winds from Hurricane Irma. On January 2, 2018, Bradford County commissioners also approved grant applications to the SRWMD for $2.2 million for Alligator Creek Flood Mitigation and for $90,250 for Hampton Lake Canal to Santa Fe River Flood Mitigation, requiring in-kind matches from the county of $110,000 and $4750, respectively. Our study analyzed historical precipitation data for the SFR Basin and headwaters from 1895 through 2017 and recorded discharge and gage heights from the United States Geological Survey (USGS) to evaluate that presumed cause of flood damage in that basin and to provide a better understanding of historical relationships between precipitation, gage data and flooding in that basin. Recorded USGS peak gage height and Digital Elevation Models (DEMs) also were used to illustrate the lateral extent and relative depth of flooding associated with an extreme precipitation event in the lower SFR vicinity of O’Leno State Park. Finally, we evaluated the condition of the trees in the SFR Basin as an indicator of long-term anthropogenic groundwater alterations. Those data and analyses did not support the conclusion that Hurricane Irma was the only cause of the magnitude and extent of SFR flooding How to cite this paper: Bernardes, S., Manglass, L., Bacchus, S. T., & Madden, M. (2019). Analysis and Extent of Santa Fe River Flooding in North Florida Attributed to Rainfall and Wind Damage Associated with Hurricane Irma. Journal of Geoscience and Environment Protection, 7, 253-310. https://doi.org/10.4236/gep.2019.711019 Received: January 8, 2019 Accepted: November 26, 2019 Published: November 29, 2019 Copyright © 2019 by author(s) and Scientific Research Publishing Inc. This work is licensed under the Creative Commons Attribution International License (CC BY 4.0). http://creativecommons.org/licenses/by/4.0/

Flooding of the Santa Fe River (SFR) and tributaries, and associated fallen trees in Bradford County, Florida during that time have been attributed to rainfall (precipitation) and wind damage from Hurricane Irma. Those  Based on that additional information, we also considered the locations and approximate magnitudes of long-term Trail Ridge mining and discharges of heavy mineral mining wastewater to the SFR Basin, initially by DuPont and currently by Chemours, as a potential contributing factor regarding the flooding and tree fall associated with Hurricane Irma in the SFR Basin. The causal role of anthropogenic alterations of natural hydroperiods from excessive groundwater withdrawals, as well as from mining, has been established within the regional karst Floridan aquifer system and has been described by Bacchus (1990Bacchus ( , 1997aBacchus ( , 1997bBacchus ( , 1999Bacchus ( , 2006Bacchus ( , 2007; Bacchus, Archibald, Britton, & Haines (2005); Bacchus, Hamazaki, Britton, & Haines, (2000); Bacchus et al. (2003Bacchus et al. ( , 2011Bacchus et al. ( , 2014; and Bernardes et al. (2014). Adverse environmental impacts from those alterations of natural hydroperiods include premature decline and death of trees, as described in detail in those publications.

Preferential Flow through Fractures
An extensive network of fractures is characteristic of the regional Floridan aquifer system and has been mapped throughout Florida (FDOT, 1973;Vernon, 1951). Preferential flow through those fractures, in response to excessive groundwater withdrawals, aquifer injections, and mining, also has been described (Bacchus et al., 2011;Bacchus & Barile, 2005;Bacchus, Bernardes, Xu, & Madden, 2015;Bernardes et al., 2014;Lines et al., 2012;Xu, Bernardes, Bacchus, & Madden, 2016). Adverse impacts from pirated water via preferential flow through fractures can include induced saltwater intrusion and induced recharge,  (Bacchus, 2000;Bacchus et al., 2011;Krause & Randolph, 1989;Lewelling, Tihansky, & Kindinger, 1998;Metz & Lewelling, 2009;Watson, Stedje, Barcelo, & Stewart, 1990). Bernardes et al. (2014) conducted analyses of previously mapped fractures in Baker and Clay Counties, including fractures associated with Trail Ridge mining and groundwater withdrawals by DuPont in those counties associated with dewatering of relict sinkhole lakes and wetlands, in addition to premature decline and death of native trees. The dewatering of relict sinkhole lakes in the vicinity of DuPont's initial mining activities in that vicinity was referenced in a personal account that "two lakes in town mysteriously dried up" in 1948 or 1949, "shortly after DuPont began mining at a site across the border at Starke, Fla.", That account was included in an article by Gordon Jackson, published in the Florida Times Union on April 4, 1997 (Jackson, 1997 The premature decline and death of native trees described in Bernardes et al. (2014) predated the occurrence of Hurricanes Irma and Hermine by several years, and was consistent with the signs of long-term chronic water stress that had persisted in that area for years prior to that publication due to large-scale anthropogenic alterations of natural hydroperiods from excessive groundwater withdrawals and mining. Therefore, our approach to evaluating the presumption that severe flooding and tree destruction was caused by Hurricane Irma also included an evaluation of historical USGS photographs of trees associated with the SFR and tributaries to the SFR. Figure 1. Santa Fe River Basin area of study, located in the north Florida portion of the regional Floridan aquifer system and including parts of Alachua, Baker, Bradford, Clay, Columbia, Gilchrist, Lafayette, Suwannee, and Union Counties, over World Topo Map and World Imagery basemaps.
study. More detailed examination revealed that the Chemours/DuPont Trail Ridge mining operations extended into contiguous Baker, Clay, and Duval Counties, which also could be contributing to the flooding in downstream areas of the SFR and were included in our study area. Some of the Chemours/DuPont Trail Ridge mining operations extend beyond the boundaries of the SFR Basin in Baker and Clay Counties.

Precipitation Data and Analyses
This investigation used 123 years of precipitation data (January 1895 to Decem- Total monthly precipitation was averaged for the SFR Basin using Google Earth Engine (https://earthengine.google.com/) and WBD files downloaded from the National Map Download Viewer (https://viewer.nationalmap.gov/basic/).
Monthly precipitation data for the SFR near Graham gage station were retrieved using the data explorer tool from PRISM (2018b). Time series analyses and the identification of climatological normals for the SFR area of study and the SFR Near Graham gage included the computation of 30-year averages of monthly precipitation for three periods (1928-1957, 1958-1987, and 1988-2017).

Shapefiles and Other Data Obtained from Agencies
The shapefiles for the SFR Basin used in this study were obtained from the USGS WBD. The sub-regions of the Floridan aquifer system included in Figure 1 were created using widely-accepted map vectorization procedures, including the control-point based georeferencing of the sub-regions map included in Krause & Randolph (1989) and the heads up digitizing of the resulting georeferenced map image (Xu et al., 2016). Shapefiles for USGS active and inactive gage locations for surfacewater monitoring were obtained from the USGS National Water Information System (NWIS) (USGS NWIS, 2018) for south and north Alligator Creeks in Bradford County; the New River in north central Florida; Olustee Creek; the Sampson River; and the SFR. Graphs of stream discharges and gage heights also were obtained from NWIS. Labels for peak stream discharges and gage heights occurring during the months and years when Hurricane Dora, the "No Name Storm," Hurricanes Frances and Ivan, Tropical Storms Beryl and Debby, Hurricane Hermine, and Hurricane Irma affected the SFR Basin were added to those NWIS graphs to facilitate comparisons of those storm events. The periods of record for the active USGS monitoring stations considered in our study are not consistent within or among those locations. The periods of record for the SFR near Graham began October 1, 1986 for stream discharges and October 1, 2009 for gage heights. The periods of record for the SFR at Worthington Springs (02321500) began October 1, 1986 for stream discharges and October 1, 2007 for gage heights. The periods of record for the SFR at O'Leno State Park (02321898) began January 10, 2011 for stream discharges and June 9, 2010 for gage heights. Those dates, for initiation of monitoring at the SFR at O'Leno State Park location, are approximately 47 years after Hurricane Dora and six years after Hurricanes Frances and Ivan. The periods of record for the SFR at River Rise (02321958) did not begin until October 1, 2015 for both stream discharges and gage heights and cannot be used for comparisons of dates for any of the hurricanes or tropical storms evaluations in our study except for Hurricanes Hermine (2016) and Irma (2017). The periods of record for the New River near Lake Butler (02321000), the only SFR tributary with an active monitoring site, began October 6, 1990 for stream discharges and October 1, 1990 for gage heights.
The latitudes and longitudes for the Chemours Company TT LLC (Chemours, formerly DuPont) Florida Trail Ridge Mine discharge locations and volumes for heavy mineral mining wastewater permitted in Baker County were obtained from the FDEP's major permit for industrial wastewater FL0435490 (file number FL0435490-007-IW3S), effective for May 15, 2016 through May 14, 2021. The most recent modification of that permit (009) was issued by FDEP on October 31, 2018. Considerable daily discharges of Chemours' heavy mineral mining wastewater will continue under that modification, without consideration of potential flooding downstream of those discharge locations. The latitudes and longitudes for discharge locations D-001 and D-002, and volumes for discharges of Trail Ridge heavy mineral mining wastewater permitted in Bradford County by the FDEP were obtained from the FDEP's revised major NPDES permit FL0000051 (file number FL0000051-012-IW3S), effective June 29, 2017 through June 28, 2022. The location of Outfall D-001 was reported to be "located approximately at latitude 29˚55'25"N, longitude 82˚03'43"W". The location of Outfall D-002 was reported to be "located approximately at latitude 29˚54'38"N, longitude 82˚02'12"W". Shapefiles of those heavy mineral mining wastewater discharge locations in Baker and Bradford Counties were created from those latitude and longitude coordinates. The boundaries of the proposed and existing Chemours/DuPont Trail Ridge mining operations and groundwater supply wells authorized by St. Johns River Water Management District (SJRWMD) consumptive use permits (CUPs) for the initial mining in Clay County were provided by the SJRWMD and were the same shapefiles used in the analysis by Bernardes et al. (2014). These are not the only CUP wells that may occur or have occurred during that mining operation. The acquisition and methods for the FDOT (1973) and Vernon (1951) mapped lineaments indicative of fractures in Florida were described in Bacchus et al. (2014), Bernardes et al. (2014), and Lines et al. (2012). The Digital Elevation Models (DEMs) used to illustrate the lateral extent and relative depths of flooding associated with Hurricane Irma in the lower SFR vicinity of O'Leno State Park and Buzzards Roost Prairie, were obtained from the SRWMD.

Spatial Extent and Relative Depths of Peak Flooding in the Lower Santa Fe River Associated with Hurricane Irma
A preliminary analysis of the spatial extent of the September 2017 flood event in the area of study was conducted using the DEMs from the SRWMD, a reference surface simulating water level, and the software ArcScene, version 10.6 (ESRI).
The DEM (terrain elevation) used by our study derived from high-accuracy Light Detection And Ranging (LiDAR) technology (RMSEz of checkpoints for non-vegetated areas not higher than 0.055 meters or 0.18 feet) and results from processing of LiDAR point clouds acquired by flights in 2011 (Northrop Grumman, 2011), 2013(Digital Aerial Solutions, 2013 and in January and February 2017 (Dewberry, 2017). The elevation data from the SRWMD were received as . This is the closest SFR gage upstream of Buzzard's Roost Prairie, in Columbia County, and the lower SFR (west of Interstate 75 and east of Highway 41), in Alachua County. This area of the lower SFR experienced extensive, severe, and prolonged flooding in September 2017, during and following Hurricane Irma. Gage height at this location has been collected since June 2010, including daily gage height data before, during, and after Hurricane Irma. Those data are provided at the USGS data portal (https://waterdata.usgs.gov/nwis/dv?referred_module=sw&site_no=02321898). Horizontal and vertical datum matched the reference DEM dataset and no datum transformation was required to analyze the datasets. Our modified bathtub approach used the peak gage height associated with Hurricane Irma to depict the extent and relative depth of that flooded area. The following methodology was applied to generate and analyze the extent and the depth of the continuous body of water during peak flooding:  Figure 2 illustrates the total monthly precipitation for the SFR Basin (WBDHU8) from January 1895 to December 2017. Total monthly precipitation for that period of record for the SFR headwaters in Bradford County is not shown because it was comparable to results for the SFR Basin in Figure 2. The vertical columns of alternating shading (background) in this figure separate each decade of monthly precipitation data. Alternating colors were used for even and odd months, to facilitate viewing of the data. The horizontal dashed line across the period of record is positioned at the peak total monthly precipitation for Hurricane Irma, during September 2017 (309.4 mm or 12.2 in). This horizontal line allows comparisons of total monthly precipitation for Hurricane Irma to total precipitation for preceding months dating back to January 1895. Figure 2 shows that total monthly precipitation for Hurricane Frances and Ivan in September 2004 (474.8 mm or 18.7 in) and for Tropical Storm Debby in June 2012 (520.1 mm or 20.5 in) both exceeded total monthly precipitation for the month of Hurricane Irma (September 2017). Figure 2 also shows four additional peaks of total monthly precipitation that exceeded total monthly precipitation for the month of Hurricane Irma, but were not described or named as flooding events by or in Bradford County. Those peaks (not labelled in Figure 2) occurred in August 1985 (329.6 mm or 13 in), February 1998 (320.6 mm or 12.6 in), August 2008 (312.1 mm or 12.3 in), and June 2017 (321.1 mm or 12.6 in). Following is the chronological order of storms and hurricanes, including month, year and total monthly precipitation, that have been identified by Bradford County, funding agencies, and other agencies and individuals as causing flood events in the SFR Basin and that were considered in our study: Hurricane Dora (9/64 -304.3 mm or 12 in); "No Name Storm" (3/93 -93.2 mm or 3.7 in); Hurricanes Frances + Ivan (9/04 -474.8 mm or 18.7 in); Tropical Storm Beryl (5/12 -211.3 mm or 8.3 in); Tropical Storm Debby (6/12 -520.1 mm or 20.5 in); Hurricane Hermine (9/16 -185.8 mm or 7.3 in); Hurricane Irma (9/17 -309.4 mm or 12.2 in). Figure 3(a) provides a more detailed comparison of the total monthly precipitation for the storms and hurricanes influencing the SFR Basin that are labelled in Figure 3. Total monthly precipitation for 1964, 1993, 2004, 2012, 2016, and 2017, with months identified for the storms and hurricanes labelled in Figure 2, for: (a) entire Santa Fe River Basin and (b) Santa Fe River headwaters at the USGS Santa Fe River Near Graham gage station.  Figure 3(b) also displays the total monthly precipitation for those storms and hurricanes labelled in Figure 2 based on total monthly precipitation for the SFR headwaters in Bradford County at the USGS SFR Near Graham gage station. This SFR gage station is the nearest active gage station to the Santa Fe Swamp, which is the headwaters of the SFR and located upstream of that gage station.

Historical Precipitation
Based on the total monthly precipitation for the SFR Basin, the total precipitation values for the months of the tropical storms and hurricanes considered in our study (Figure 2 and Figure 3) were, from least to greatest: "No Name Storm" (93.2 mm or 3.7 in) < Hermine (185.8 mm or 7.3 in) < Beryl (211.3 mm or 8.3 in) < Dora (304.3 mm or 12 in) < Irma (309.4 mm or 12.2 in) < Frances + Ivan (474.8 mm or 18.7 in) < Debby (520.1 mm or 20.5 in). Results of the analysis of average total monthly precipitation for the three 30-year periods of 1928-1957, 1958-1987, and 1988-2017 are provided in Figure 4(a) for the entire SFR Basin and in Figure 4 30-year periods (1928-1957, 1958-1987, and 1988-2017) for: (a) entire Santa Fe River Basin and (b) Santa Fe River Near Graham gage station.

Historical USGS Stream Discharges and Gage Heights
The locations of all of the USGS gage stations for the SFR and tributaries Alligator Creek, New River, Olustee Creek, and Sampson River are shown in Figure 5.  Vernon (1951) as diagonal yellow lines, and the CUP wells pumping ground water from the Floridan aquifer system as red circles. yellow circles in Figure 5 indicate the locations for Chemours' permitted wastewater discharges. The red circles in Figure 5 indicate the locations for the CUP wells identified in the analysis by Bernardes et al. (2014) for groundwater withdrawals from the Floridan aquifer system for Trail Ridge mining operations. The reason for the inactivity of the remaining gages was attributed to limited funding for the USGS, rather than irrelevance of those data (USGS, personal communication, R. Knapp 12/18), suggesting data from those gages could have provided valuable information regarding the source of flooding in the SFR Basin and should be re-activated. The single active USGS gage monitoring station in the New River is New River Near Lake Butler (02321000). As of September 2017, the four active USGS gage stations in the SFR, within the study area, were (from east to west): SFR Near Graham (02320700), SFR at Worthington Springs (02321500), SFR at O'Leno State Park (02321898), and SFR at River Rise Near High Springs (02321958). Those active USGS gage monitoring stations in the New River and SFR are identified by diamond symbols in Figure 5. Figure 5 also shows the boundaries for Chemours Trail Ridge mining operations, east of the Osceola National Forest in Baker, Bradford, Clay, and Duval Counties to the north and in Bradford and Clay Counties to the south. Also shown in Figure 5 are the discharge locations for the Chemours heavy mineral mining wastewater permitted by FDEP and the locations of the SJRWMD CUP groundwater supply wells (red circles) used for the Chemours Trail Ridge mining operations in the southern boundary area in Baker and Clay Counties, as identified in Bernardes et al. (2014). This figure also includes the fractures mapped by FDOT (1973, red diagonal lines) and by Vernon (1951, yellow diagonal lines). Vernon (1951) focused on mapping the fracture network of an area of north Florida, while the Remote Sensing facility of FDOT (1973) mapped a more extensive fracture network and covered the entire state. Both mapped fracture networks are relevant to our study area.        The shortest period of record for active USGS gages for the SFR is provided at the USGS gage for the SFR at River Rise Near High Springs. This gage station is located west (downstream) of the O'Leno State Park facilities and Buzzards Roost Prairie. The USGS graph for stream discharges and gage heights only extend from October 1, 2015 through 2018 ( Figure 10). Peak stream discharge and gage height at that location were 529.5 m 3 sec −1 (18,700 ft 3 sec −1 ) and 6.4 m (21.1 ft), respectively, in September 2017 during Hurricane Irma.

Historical USGS Photographs of the Santa Fe River and New River
The USGS NWIS website included historical USGS photographs of the SFR taken  with the SFR and New River shown in Figure 11 provide evidence of some other cause for tree deaths in the SFR Basin that pre-dated Hurricane Irma in 2017.
Additionally, the precipitation record (Figure 3(a)), as well as the dry stream channel and surrounding vegetation in the USGS photograph of the SFR at Worthington Springs on December 20, 2006 ( Figure 11(a)) suggest that lack of precipitation was not the cause of that dry stream channel. Therefore, those mining operations were considered as a contributing factor to the extensive flooding associated with Hurricane Irma in the SFR Basin.

Separate FDEP permits for Chemours mining wastewater ponds in adjacent
Baker County appear to authorize additional discharges of heavy mineral mining wastewater to the New River Swamp from at least the two southern Chemours discharge points identified in the FDEP permit for the Baker County Chemours Trail Ridge mine wastewater ponds. The New River Swamp wetlands are the headwaters of another SFR tributary, the New River, which is designated as critical habitat for the federally endangered oval pigtoe mussel (Pleurobema pyriforme). The historical precipitation data do not support the pattern of flooding associated with Hurricane Irma, or the reported increasing extent and magni-  County is within the Peace River Watershed of the regional Floridan aquifer system.
A study evaluating the magnitude and extent of groundwater alterations surrounding that mining operation in Hardee County (Peace River Watershed), using near-infrared (NIR) data from natural depressional wetlands, documented high mean NIR values consistent with hydroperiod-altered wetlands dominated by invasive plant species for 284 wetlands (50 and 60 percent total number and area, respectively), including some depressional wetlands more than 5 km (3.1 mi) from study-area mines (Bacchus et al., 2011). Ground assessments in that study also included recording the presence, in or surrounding the wetlands, of any of the following indicators commonly associated with areas of hydroperiod alterations in the U.S. southeastern coastal plain: 1) premature tree mortality or decline; 2) poor crown condition; 3) insect and disease damage; 4) degraded soil conditions such as subsidence; 5) fragmentation of habitat; 6) invasive species (insects and plants); and 7) significant fire damage in fire-adapted ecosystems (Bacchus et al., 2011). The premature tree mortality and decline observed and described from our study were comparable to the premature tree mortality and decline associated with that Hardee County mining operation, where groundwater withdrawals were approximately half the volume of groundwater discharges from FDEP's single NPDES permit issued to Chemours/Dupont for discharges in Bradford County (Bacchus et al., 2011). The comparable premature death and decline associated with both mining sites provide support for the conclusion that Hurricane Irma was not the only cause of tree fall in Bradford County.

Discharges of Heavy Mineral Mining Wastewater
The wastewater at Outfall D-001 was described as "an existing 40.0 MGD daily permitted maximum" to Alligator Creek (WBID 3606), which is described as "Class III fresh surface water." The point of that discharge is shown in Figure 12(a).
S. Bernardes et al. This heavy mineral mining wastewater treatment system provides acidification with ferric chloride, sulfuric acid, aluminum sulfate, or ferric sulfate to a pH between 3.0 and 3.5 standard units for flocculation of colloidal material followed by settling in a series of diked ponds, neutralization with hydrated lime to a pH between 6.0 to 8.5, and additional settling with final discharge to Alligator Creek. Upon Department approval, polymer addition may be provided after neutralization for aluminum reduction prior to final discharge to Alligator Creek, at D-001, which flows west in Bradford County. Storm water and rainfall from the mined areas are also collected and treated as described above. The treatment train consists of the addition of barium chloride to the wastewater at the location where ferric chloride, aluminum sulfate and or ferric sulfate is added (prior to the humate settling ponds). A portion of the effluent is directed to the Southwest Quadrant Pond. The existing recycle line from D-001 was tapped and a pipeline was constructed to route approximately 400 gallons per minute (gpm) of the treated wastewater to an existing ditch which then discharges into the Southwest Quadrant Pond (location D-002) with eventual discharge into Blue Pond, which is the portion of Alligator Creek that flows south in Clay County. This rerouting of final effluent is the result of an effort by The Keystone Stakeholders to help improve lake water levels in the Keystone Heights area. The second existing discharge of heavy mineral mining wastewater, Outfall D-002, is at the Southwest Quadrant Pond, which then discharges to Blue Pond (WBID 2501). Blue Pond also is described as a "Class III fresh surface water".
The point of discharge of heavy mineral mining wastewater for D-002 also is shown in Figure 12(a) and Figure 12(b).
Following the route of flow in Bradford County from the Chemours D-001 discharge point, ditches were evident east of Starke in the vicinity of Highways 230 and 16, and NE171st Street. Those ditches appeared to divert a portion of the D-001 discharge of heavy mineral mining wastewater from Alligator Creek, north into Water Oak Creek (Figure 13(a)). This discharge north to Alligator Creek, flowing behind homes on the west side of the Starke Golf and Country Club, should be investigated as the potential source of the severe flooding of those homes on more than one occasion. Additionally, because Water Oak Creek is a tributary of, and discharges to the New River, this discharge to the north should be investigated to determine the magnitude and extent of impacts to that designated critical habitat for the federally endangered oval pigtoe mussel.
Any of the Chemours Trail Ridge discharges of heavy mineral mining waste- with Chemours discharges to the New River Swamp headwaters of the New River in Baker County (Figure 13(b)), simply would by-pass tributaries to the SFR in Bradford County and divert those combined Chemours' discharges, increasing flooding to downstream sections of the SFR in other counties (e.g., Alachua, Columbia, and Union Counties).

Amendment to Fact Sheet for FDEP's Chemours NPDES Permit in Bradford County
The That amendment also claimed that: 1) stream "restoration" was not done because it has been cost-prohibitive and 2) dredging events destabilized the stream in many locations "causing continued erosion and water quality problems."

Indicators of Long-Term Anthropogenic Hydroperiod Alterations
The photographs in Figures 14(a)  Creek. Dewatering the surficial aquifer greatly decreases or completely eliminates baseflow of ground water required to maintain natural flow in the stream during periods of low rainfall.
In addition to providing information about the impacts to the surficial aquifer, Figure 14 (Bacchus, 2006), in addition to destructive wildfires (Bacchus, 2007). The root systems of these native trees also play an important role in preventing erosion of stream banks. Consequently, the premature decline and death of those trees contribute to increasing sediment load in streams, such as Alligator Creek, even in the absence of any sediment-laden discharges of heavy mineral mining wastewater from the Trail Ridge mining operations. Additionally, Figure 12   In order to improve hydrologic conditions within the floodplain and reduce some of the sediment load from going to Lake Rowell down Alligator Creek, Suwannee River Water Management District (SRWMD) in cooperation with the Florida Fish & Wildlife Conservation Commission (FWC) and the City of Starke, plan to conduct a floodplain restoration project which will re-establish the flow connection from the a portion [sic] of the altered creek to a 47-acre floodplain parcel known as the Edwards Bottomlands. The restoration project will improve water quality, fish and wildlife habitat and the hydrology within the altered wetlands. SRWMD is also evaluating the potential acquisition of a 14-acre tract of historic floodplain, adjacent to the 47 acre parcel, as part of this project.

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During the days of September 2 through September 4, 2016, Governor Scott issued a State of Emergency for Bradford county, Executive Order 16-205, signed August 31, 2016, requirements and effects of statutes and rules which conflict with the provisions of this Order are suspended to the extent necessary to implement this Order. In response to the order, a site inspection was conducted on September 7 to view the West Levee system at Trailridge. The system was stable with no discharge occurring at this location and no evidence of a breach in the berm. The pump system was operating as normal. For the days of September 1-September 5, the Alligator Creek stage level at US 301 stream gage was reviewed and the Trailridge discharge for those days are [sic] listed in Table 4. The maximum day of discharge was September 3 at 7.34 MGD which is less than 0.5% of the total basin flow to Alligator Creek.

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Paragrapgh [sic] 6 is copied here: 6. The Department finds that • The Chemours Company TT LLC needs permission to discharge wastewater into the waters within the state for a period of time necessary to complete research, planning, construction, installation, or operation of an approved and final control system; • There is [sic] no present, reasonable, alternative means of disposing of the wastewater other than by discharging it into waters of the state; • The granting of a discharge permit will be in the public interest; • The discharge will not be unreasonably destructive to the quality of the receiving waters.
To reduce the volume and iron loading into Alligator Creek the NPDES permit should require that the discharges be split equally between D001 and D002. The discharge limit for D001 should be set at 20 MGD to reduce the total iron discharged into Alligator Creek and the Sampson Basin.
(1973) and Vernon (1951). Figure 12(a) and Figure 12 The headwaters of the SFR, the Santa Fe Swamp, are located along the eastern boundary of Bradford County, but are not shown in Figure 12(a) or Figure   12(b). The western boundary of Figure 12 Table 1.

State of Emergency Declaration for Hurricane Hermine
The Amendment to Fact Sheet also addressed Hurricane Hermine. found to substantiate that pre-emptive releases of contaminated water were not made from Chemours' discharge locations prior to anticipated increases in precipitation from hurricanes and tropical storms, including those addressed in our study.

FDEP Sampling, Inspections, and Results
The Amendment also stated that the "discharge to D-002 is 'report' only, and the quantity of the discharge of heavy mineral mining wastewater is not limited unless it is restricted by requirements from other regulatory authorities." Because Chemours is allowed to divert unlimited Trail Ridge heavy mineral mining wastewater from D-001 to D-002 and because FDEP does not collect or analyze samples of heavy mineral mining wastewater from the D-002 location to Blue Pond, south through a series of lakes to dewatered Brooklyn Lake, those discharges from D-002 could be significantly more contaminated than Chemours discharges of heavy mineral mining wastewater at other discharge locations. The Amendment to FDEP's Chemours NPDES permit for Bradford County also included the statements on PDF page 51 (Table 3), confirming that FDEP was not able to analyze samples for Radium 228 and that the sampling protocol was compromised by blank sample containers that were contaminated. • The total ammonia concentration in the grab sample collected and preserved for chemical analysis was 0.04 mg N/L. Based on the pH, salinity, and temperature of the effluent as collected, the calculated unionized ammonia concentration was < 0.02 mg/L.
• The effluent's iron (1080 ug/L) exceeded Class III Fresh Water Criteria and the permitted limit. Turbidity and alkalinity were detected in the effluent at levels that comply with Class III Fresh Water Quality Criteria (62-302.530, F.A.C.) and/or permitted limits. Total suspended solids, fluoride, arsenic, total chromium and nickel were detected between the laboratory method detection limits (MDL) and practical quantitation limits (PQL).
• The overflow lab did not have enough sample volume to perform QC and analyze Radium 228, therefore, no Radium 228 results were reported.
• Nitrate + nitrite was detected in the field blank. Discharges over the spillway at the south end of the West Levy that bypass the water treatment facility need to be addressed. These discharges have occurred on several occasion [sic] and need to be addressed in the current permit renewal. These discharges are releasing untreated mine contact water with high humate content.

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The failure to control or address erosion from the mined areas that have not been reclaimed and the role the erosion plays as the source of humate in stormwater need to be addressed. Humate rich strata deposited during the dredge mining are eroding and causing very high humate levels in stormwater. The erosion problem needs to be addressed as a BMP to reduce or even eliminate the high levels of humate. The current conditions east of CR 225 in Bradford County on land owned by the SRWMD indicate that erosion BMPs have not been implemented on mined property. The impacts of the erosion east of CR 225 in Bradford County on land owned by the SRWMD needs to be addressed immediately and in the new NPDES permit.
The humate rich stormwater requires treatment with ferric solutions to remove the humate. Eliminating the waste product humate at its source is a waste reduction method. Reducing the amount of ferric solutions used should have a priority over doubling the permitted iron discharge levels that is [sic] proposed in the current permit application.
The apparent spill(s) of ferric solutions may require a review of the facility's BMPs and response procedures to spills of hazardous materials.
The water balance diagram included in the permit does not include watershed discharges. The water balance diagram shows an almost zero discharge operation. A revised water balance is needed.

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DEP staff appear to have failed to review the abnormal events files for the Chemours facility. These abnormal events reports [sic] detail periods when water has passed over the spillway. Google Earth images also show apparent repairs to the spillway area. DEP staff appear to have failed to look at the path water takes after it passes over the spillway as erosion and sediments should have been clearly visible. The failure to design for adequate stormwater storage at the West Levee could be corrected by fixing the erosion problem so rate of runoff is slowed or eliminated. This needs to be addressed in the permit. The inspection schedule for the West Levee is not acceptable. The current stormwater systems transfer water from the SJRWMD and from 3 or more WBIDS to Alligator Creek. It is this transfer that may be contributing to flooding downstream of D001. The end of pipe discharge from the two pumps at the West Levee would appear to be a point discharge that should be documented as to volume and water quality. It cannot be determined from the Google Earth images if the pipe discharges are contained conveyance system that would carry the mine contact water to the treatment facility or if the discharges can flow to other areas.
There is no indication that the settling ponds have had sludge removed. The holding capacity of the system may have been reduced to the point that it can no longer handle large rain events. An analysis of the current holding capacity of the setting ponds is needed.

Discussion of Changes to Permit Limitations
Changes to the FDEP Chemours' NPDES permit for Trail Ridge mining operations in Bradford County also were discussed in the Amendment, indicating that the "current wastewater permit for this facility FL0000051-012-IW3S expires on September 6, 2016". A relevant excerpt from pdf page 57 of that permit is included in  (Table 3).

No Supporting Documents
The Amendment to the Fact Sheet for FDEP's Chemours NPDES permit in Bradford County also stated that there "are no supporting documents for the finding of facts in 6.b), c) and d) in the ADMINISTRATIVE ORDER ESTABLISHING COMPLIANCE SCHEDULE UNDER SECTIONS 403.088 (2) and 403.067(7) F.S." The lack of supporting documents referenced in the Amendment to the Fact Sheet also included the statements from pdf pages 61-62 of Chemours' FDEP NPDES permit in Table 2.

Discharge Monitoring Reports
Pages 63-94 of the FDEP's Chemours NPDES permit in Bradford County include blank copies of forms and instructions for self-monitoring required by FDEP for that NPDES permit. The Discharge Monitoring Report (DMR) comprises Part A of the required monitoring reports and is included on pages 63-67 of FDEP's NPDES Final Permit Renewal for Chemours Trail Ridge mining in Bradford County. The instructions for the DMR-Part A of the self-monitoring reports are provided on page 77 of the permit. That form provides a box titled, "No Discharge from Site" that can be checked if the permittee claims that no discharge has occurred for that monitoring period. That form also includes a box titled, "Comment and Explanation of Any Violations" that can be checked if the permittee is self-reporting violations of permit conditions. These self-monitoring conditions in the FDEP permit make it extremely difficult, if not impossible for FDEP staff to document the accuracy of discharge-related violations that may contribute to or cause downstream flooding.

pH
Page 64 of the DMR appears to allow a daily range in pH that is more than two orders of magnitude, from 6.0 as the daily minimum to 8.5 as the daily maxi- Rich.) were rooted in an unaltered stand of cypress with free-flowing hydrology along the St. Johns River, Florida in St. Johns County, adjacent to Clay County (Bacchus, 1990;Miller, Bacchus, & Miller, 1993). Those pH values were consistent with other natural, unaltered stands of bald-cypress analyzed throughout Florida (S.T. Bacchus, unpublished data).
Conversely, the interstitial pH was 5.3 and 6.5 in the upper 15 cm (5.9 in) of soil surrounding the primary root mass of bald-cypress and lower soil horizon, respectively, in the eastern portion of the same bald-cypress stand where the hydrology had been altered by construction of a road that impounded the flow.
The bald-cypress trees in the impounded portion of the bald-cypress stand were exhibiting typical signs of premature decline, exhibited by cypress subjected to chronic hydroperiod alteration with only half an order of magnitude change in natural pH conditions (Bacchus, 1990;Miller, Bacchus, & Miller, 1993;T.

Bacchus, unpublished data).
Additional cause for concern over the apparent 2.5 orders of magnitude in pH range allowed for Chemours' discharges of heavy mineral mining wastewater is that native plant and animal species with limited distribution (e.g., the federally endangered oval pigtoe mussel found only in a tributary to the SFR) may have considerably different pH requirements than commonly occurring species that are found in a broad range of habitats. One example is pond-cypress (Taxodium ascendens Brongn.), which has an interstitial pH of 4.5 in unaltered sites within its natural range that coincides with the extent of the Floridan aquifer system, compared to the pH range for bald-cypress. The US Fish and Wildlife Service (USFWS) designation for Critical Habitat for the federally endangered oval pigtoe mussel on November 15, 2007(USFWS, 2007 states that ''Various contaminants in point and non-point source discharges can degrade water and substrate quality and adversely affect mussel populations.'' That designation also states, "High temperatures or decreasing pH may increase the toxicity of metals to unionids (Havlik & Marking, 1987, p. 14)." There was no indication that the impacts of such drastic changes in pH, natural iron concentration, or any other component of the Chemours' discharges of heavy mineral mining wastewater on the oval pigtoe mussel were considered prior to the permitting of those Chemours discharges.

Expenditures of Public Funds
The approximately $2.8 million funding from the USDA/NRDC, the SRWMD, 100-year flood elevations. The July media release also stated that SRWMD would install automated water level gages on Lake Sampson and Alligator Creek to provide real-time flood information to the public and that flooding along Alligator Creek appeared to be caused by the inability of the creek to handle the amount of runoff produced by the storm rather than the water level in Lake Sampson, which is controlled by a floodgate. That media release also stated that The Suwannee River Water Management District (District) is working cooperatively with the Florida Fish and Wildlife Conservation Commission (FWC) and the City of Starke to restore a portion of Alligator Creek in Bradford County. As part of the project, a sediment control structure will be constructed in the creek to capture and prevent sediment from entering Lake Rowell and to help restore the wetlands and floodplain by redirecting water into remnant creek channels on property owned by the City of Starke. The Alligator Creek Restoration project will restore and enhance the hydrology and aquatic habitat of 31 acres of remnant floodplain wetlands and prevent 169 tons of sediment per year-the equivalent of 10 dump truck loads-from entering Lake Rowell," said Brian Kauffman, District senior professional engineer. The City of Starke has agreed for the sediment control structure to be constructed on City property and to operate and maintain the structure after completion. The City has contributed $25,000 toward the project, the FWC is providing $250,000, and the District plans to contribute up to $325,000, pending approval of the proposed Fiscal Year 2012-13 budget. The Federal Emergency Management Agency will conduct a flood study on Alligator Creek that will be used in construction plans. The project supports the District's core mission goals to protect water quality, provide flood control, and protect natural systems. It is one of five major water quality improvement projects, in which the District has set aside $2.9 million to implement during Fiscal Year 2012-13. Journal of Geoscience and Environment Protection "storm water discharged from DuPont had minimal effect on the overall flooding as this water was retained onsite and released after the peak of the storm event," without providing records of those discharges. That statement is inconsistent with subsequent observations by local residents of high water levels at bridged crossings for the SFR and tributaries in the vicinity of Chemours discharge locations for heavy mineral mining wastewater. Those observations by local residents included unexplained high water levels preceding the onset of storms and hurricanes, as well as during periods of no rainfall, suggesting Chemours discharges of heavy mineral mining wastewater as the source of those unexplained high water levels.
The NPDES Final Permit Renewal for Chemours in Bradford County recognizes the Chemours Trail Ridge mine as a "system that was designed and operated for the transport and movement of waters from one basin to the next ba-    Counties, 210 and 200, respectively, and fracture intersections are potential locations of interlinked cavities where changes in ground water may be magnified (Lines et al., 2012).

Fractures throughout the SFR Basin and Trail Ridge Mining Operations
Another important consideration described in Bernardes et al. (2014) was that microfracture abundance was related directly to macrofracture abundance (Marrett, Ortega, & Kelsey, 1999;Ortega & Marrett, 2000) in many cases. Microfractures were not mapped by FDOT (1973) or by Vernon (1951). Microfractures also were not addressed by Faulkner (1973), which described additional related work by Vernon and personal communications with Vernon, as well as fractures described in Vernon's initial publication addressing fractures in the north Florida area of the Floridan aquifer system (Vernon, 1951).

Historical Precipitation
The horizontal line in Figure 2 illustrates total monthly precipitation peaks for previous storm events in the SFR Basin that were comparable to or exceeded the total monthly precipitation peak in September 2017, during Hurricane Irma. Those previous peaks comparable to or exceeding the monthly precipitation associated with Hurricane Irma were not addressed by Bradford County, federal agencies, or the SRWMD as resulting in comparable flooding in areas of record flooding attributed to Hurricane Irma (e.g., Bradford County, Worthington Springs, Buzzards Roost Prairie). Figure 2 also illustrates that total monthly precipitation associated with Hurricane Irma in 2017 was approximately half that of the total monthly precipitation associated with Debby in 2012, and with Frances + Ivan in 2004, but without the record stream discharges and gage heights in the SFR Basin during Hurricane Irma. The total monthly precipitation reported in the area of the SFR headwaters ( Figure 3(b)), for the storms and hurricanes considered in our study, and the total monthly precipitation reported for the entire SFR Basin (Figure 3(a)) for those same months and years were not identical. The small differences in Figure  3(b) would not influence the flooding in the area funded by the USDA/NRCS DSR emergency project grant for flood abatement, tree removal, and sediment removal, with non-federal funding from the SRWMD and Bradford County.
That is because the rainfall reported for the SFR headwaters location ( Figure  3(b)) discharges directly to the upper SFR, south of the USDA/NRCS project area in Bradford County, flowing west to the lower SFR. The area covered by the USDA/NRCS DSR emergency project grant for flood abatement, tree removal, and sediment removal, begins at the headwaters of Alligator Creek at the north end of the Chemours/DuPont mining operations in Bradford County ( Figure   17), shown as an open-water pit in Figure 12(b) and Figure 17. That area receives the Chemours/DuPont heavy mineral mining wastewater discharges from D-001 authorized by the FDEP NPDES permit, flowing north, the west through Starke (Figure 12(b)), then southwest into Lake Rowell (Figure 12(a)), then south into the Sampson River, before finally flowing south in the Sampson River, then into the SFR west (downstream) of the headwaters gage for the USGS SFR Near Graham gage station. Bradford County (Figure 13(b)). Those headwater wetlands would have retained precipitation from Hurricane Irma and future storms and hurricanes, as well as from previous storms and hurricanes dating back to when Chemours/ DuPont initiated mining in those headwater wetlands. In addition to permanently eliminating the amelioration of precipitation from hurricanes and other storms, the permanent loss of those headwater wetlands also eliminated the natural recharge of the regional Floridan aquifer system provided by those headwater wetlands. The town of Worthington Springs was named after that spring, which was a large tourist attraction during the early 1990s. Historic photographs of Worthington Springs during its prime days as a tourist attraction and during the period of time encompassing our study, and consistent with observations made during our study, are provided at the following link:
The Springs of Florida (Rosenau, Faulkner, Hendry & Hull, 1977) included the following information regarding the demise of that spring: On April 24, 1972, highly colored water from the river was backed up over the spring and into the swimming pool: no flow was evident. When the spring is flowing, the spring water may have appreciable color... Utilization-None.
The "highly colored water from the river" referenced in that publication is from natural levels of tannic acid characteristic of Florida's "Blackwater Stream" ecosystems (Florida Natural Areas Inventory & Florida Department of Natural Resources, 1990) The reference to "appreciable color" when the spring is flowing is indicative of the limited flow of ground water from the Floridan aquifer system from that spring, because that groundwater flow characteristically is crystal clear and without any significant tannins that would impart the "appreciable color" of surface water from the streams. The demise of the name-sake spring in the town of Worthington Springs, Florida is similar to the demise of Kissengen Springs from phosphate mining in the Peace River Basin (Lewelling et al., 1998) and the demise of the name-sake spring in the town of White Springs, Florida from phosphate mining of tributary wetlands to the Suwannee River.
An audio/video recording of the flooding associated with Hurricane Irma on September 11, 2017 at the State Road 121 bridge over the SFR in Worthington Springs was created by a Union County resident and is available online (https://youtu.be/ag-ZwZxXt9Y, personal communication, M. Burton 2/19). In that video, USGS staff monitoring the flooding confirm that discharge at that location was the "highest they ever recorded," at "almost 25,000 cubic feet per second" (ft 3 sec −1 ). That discharge is consistent with the record discharge spike shown in Figure 7(a) and was approximately 283.2 m 3 sec −1 (10,000 ft 3 sec −1 ) greater than previous peak discharges that occurred in October 5, 1992 and June Journal of Geoscience and Environment Protection 28, 2012 shown in Figure 7(a). Monthly precipitation for the SFR basin and those two previous peak discharges were 155.1 mm (6.1 in) and 520.1 mm (20.5 in), respectively. A similar record gage height of approximately 9 m (30 ft) at the Worthington Springs gage station for September 2017 is shown in Figure 7(b).
Previous peak gage heights at that location were approximately 6.4 m (20.9ft) in August 25, 2008 and 7.6 m (25 ft) on June 28, 2012 (Figure 7(b)). Monthly precipitation for those two previous peak gage heights was 312.1 mm (12.3 in) and 520.1 mm (20.5 in), respectively. That video of the downstream portion of the SFR includes evidence of premature decline in trees associated with the SFR that is consistent with long-term anthropogenic hydroperiod alterations, such as mining, described in Bacchus (2006), Bacchus et al. (2011), andBernardes et al. (2014).

Video Documentation of New River Flooding Associated with
Hurricane Irma on September 11, 2017 The location of SFR flooding associated with Hurricane Irma on September 11, 2017, shown in the video taken at USGS SFR at Worthington Springs gage station, is less than a kilometer (mile) downstream from the confluence of the New River tributary flowing into the SFR. The USGS gage at that New River location is not active, as indicated by the pink circle symbol at the confluence of the New River with SFR in Figure 5. An additional video of flooding associated with

Historical Stream Gage Data
The only active USGS gage station on the New River, upstream of the confluence of the New River with the SFR, is the USGS New River Near Lake Butler. That gage station is marked by the pink diamond symbol in Figure 5. That active gage station is located approximately one-third the distance northeast from the SFR at Worthington Springs gage station and the clusters of discharges of Chemours' heavy mineral mining wastewater permitted by FDEP in Baker County (yellow circles in Figure 5). The discharge and gage height data for SFR New River Near Lake Butler are included in Figure 8(a) and Figure 8( Figure 6(b)). That record discharge was more than 85 m 3 sec −1 (3000 ft 3 sec −1 ) greater than the previous two peak discharges in February, 1998 and June 2012, associated with an event not evaluated in our study, and Tropical Storm Debby, respectively. That record gage height was approximately 1 m (3.3 ft) greater than the previous peak gage height in June 2012, associated with Tropical Storm Debby. That record gage height also was more than 1.4 m (4.5 ft) greater than a previous peak gage height in January, 2010 (event not evaluated in our study) and more than 2.5 m (8.2 ft) greater than a peak gage height in September 2016 (Hurricane Hermine). The peak discharge and gage height associated with Hurricane Irma at that SFR gage station also are not consistent with the considerably lower precipitation records for the SFR headwaters near Graham during September 2017 for Hurricane Irma. That suggests discharges of Chemours' heavy mineral mining wastewater from D-001 to Alligator Creek, Lake Rowell, Lake Sampson, and the Sampson River, prior to discharging into the SFR, were a factor in the flooding in Bradford County. That also suggests that at least a portion of discharges of Chemours' heavy mineral mining wastewater were diverted to the D-002 location and possibly north to Water Oak Creek. Those discharges could contribute to the flooding associated with Hurri- The locations of those two gage stations are marked by the white diamond symbols in Figure 5. The peak discharges associated with Hurricane Irma at those two gage stations were 750.4 m 3 sec −1 (26,500 ft 3 sec −1 ) and 529.5 m 3 sec −1 (18,700 ft 3 sec −1 ), shown respectively in Figure 9(a) and Figure 10 Comparison of the historical precipitation data to the historical stream gage data displayed in Figure 6 through Figure 10 does not support the conclusion that precipitation from Hurricane Irma alone resulted in the extensive flood levels and durations associated with Hurricane Irma in Bradford County and in the lower SFR, including at Buzzard's Roost Prairie. That comparison also did not support the record stream discharges at the SFR at Worthington Springs gage station.
Specifically, those recorded stream discharges and gage heights for the SFR Near Graham suggest that Chemours discharges of heavy mineral mining wastewater from D-001 may be flowing into and through the Santa Fe Swamp to this USGS gage station and/or that the long-term groundwater withdrawals for the Chemours/DuPont Trail Ridge mining operations have resulted in such severe alteration of the natural hydroperiod of the Santa Fe Swamp that those SFR headwaters no longer are capable of functioning as headwater wetlands, retaining and storing water. The fact that the entire Santa Fe Swamp cypress stand ignited and burned, killing the fire-adapted pond-cypress, supports the conclusion that severe alteration of the natural hydroperiod, including dewatering of the organic cypress soils, has occurred. Catastrophic fires that destroy pond-cypress wetlands are characteristic of those types of anthropogenic hydroperiod alterations (Bacchus, 2006(Bacchus, , 2007.

Inactive USGS Monitoring Locations and Historical USGS
Photographs of the Santa Fe River and New River

Inactive USGS Monitoring Locations
The map in Figure 5 shows additional USGS monitoring locations that currently

Historical USGS Photographs of the Santa Fe River and New River
The presence of numerous dead and fallen trees associated with the SFR and New River gage stations in historical USGS photographs ( Figure 11) approximately ten years before Hurricane Irma crossed the SFR Basin in 2017, is relevant because funding from the USDA/NRCS and SRWMD for Bradford County was based in part on presumptions that Hurricane Irma had resulted in the death and downfall of trees in SFR tributaries in that vicinity (i.e., Alligator Creek and the Sampson River). That presumption also included the presump-

Conclusion
Comparisons of the historical precipitation data and historical USGS stream discharge and gage height data for the SFR Basin and headwaters do not support the conclusion that total precipitation (rainfall) during Hurricane Irma alone caused those increases in severity and duration of flooding in the SFR Basin. The fact that flooding downstream of the Chemours/DuPont discharge locations did not occur or was less severe during previous tropical storms and hurricanes with greater associated total precipitation than during Hurricane Irma supports the conclusion that severe flooding in Bradford County and downstream associated with Hurricane Irma was not the result only of total precipitation produced by that hurricane. Additionally, historical USGS photographs show tree death and downfall in both the SFR and New River that predate both Tropical Storm Debby (in 2012) and Hurricane Irma (in 2017). Those historical photographs, combined with the additional documentation of premature decline and death of trees in that vicinity  prior to Hurricane Irma, and extensive documentation in published literature of premature decline and death of trees, including tree fall, solely from groundwater alterations and in the absence of tropical storms and hurricanes support the conclusion that groundwater alterations rather than total rainfall and winds from Hurricane Irma were responsible for tree deaths and downfall in upstream tributaries of the SFR in Bradford Counties, and in proximity to the CUP wells for those mining operations, also can contribute to the irreversible alteration of natural hydroperiods, in addition to widespread induced recharge and dewatering of the surficial aquifer, and surface waters, including streams, natural lakes, and wetlands associated with those fractures. Those adverse impacts can occur for many kilometers (miles) from that mining area. The increasing magnitude of the severity and duration of flooding in the SFR Basin, combined with the irreversible adverse impacts to vegetation, surface waters, and the regional Floridan aquifer system, in addition to the potential adverse impacts to the federally endangered oval pigtoe mussel and designated critical habitat, should be sufficient for the US Army Corps of Engineers (USACOE), the USEPA, and the USFWS to initiate a comprehensive Area-wide Environmental Impact Statement, considering the regional cumulative impacts of this mining, combined with the proposed new phosphate mining in Bradford and Union Counties.