EPA 904/9-76-021
FINAL
ENVIRONMENTAL IMPACT STATEMENT
City of Jacksonville, Florida
Wastewater Management Facilities
Arlington-East Service District
EPA PROJECT Cl20541
UNITED STATES
ENVIRONMENTAL PROTECTION AGENCY
REGION IV
1421 PEACHTREE ST., N. E.
ATLANTA, GEORGIA 30309
*— AUGUST 1976
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FINAL •
ENVIRONMENTAL IMPACT STATEMENT
ARLINGTON-EAST SERVICE DISTRICT
WASTEWATER MANAGEMENT FACILITIES
JACKSONVILLE, FLORIDA
PROJECT NO. C120541
Prepared by:
U. S^ ENVIRONMENTAL PROTECTION AGENCY
REGION IV
1421 PEACHTREE STREET, N.E.
ATLANTA, GEORGIA 30309
Approved by:
August 6, 1976
^Regional Administrator Date
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SUMMARY SHEET
Arlington-East Service District
Wastewater Management Facilities
City of Jacksonville, Florida
EPA Project No, C12Q541
( ) Draft
(X) Final
U, S. Environmental Protection Agency
Region IV
10-21 Peachtree Street, N.S*
Atlanta, Georgia 30309
1. Name ofAction
(X) Administrative Action
{ ) Legislative Action
2. Brief Description of Action
The subject action of this Final Environmental Impact
Statement (HIS) is the awarding of grant funds to the City
of Jacksonville, Florida for the preparation of plans and
specifications for regional wastewater treatment facilities
to service the Arlington-East District. The project
consists of a 10.0 million gallon per day (MGD) wastewater
treatment plant located at Millcoe Road, 13,900 feet of
outfall line terminating at the edge of the maintained
shipping channel in the St. Johns River, and approximately
38,000 feet of force main -which will be used to pump sludge
across the St. Johns River to the Buctanan Street
incinerator. This plan, with the exception of the sludge
force main, appears as alternative 1q in the Draft EIS.
3* Summary of Environmental Impact
The project will provide for:
(1) The removal of inadequately treated waste^aters
from tributary streams.
(2) Treatment facilities to adequately service existing
and future sources of wastewater.
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(3) Alleviation of existing adverse conditions
resulting from the operation of septic systems and small
package plants,
Allowance of orderly growth according to the
Comprehensive Development Plan for 1990.
(5) Provision of adequate noise and odor controls*
Since publication of the Draft EIS, the decision to forego
heat treatment and incineration facilities at the plant site
has eliminated major sources of unmitigated noise and odor.
<6) Construction only on the part of the site farthest
from the nearby residential community and provision of a
buffer zone of 114 acres adjacent to the site.
Adverse environmental effects are summarized as follows:
a. Construction Impacts
The construction of treatment facilities and interceptor
lines represent a long-term commitment of 46.98 acres of
land for the treatment plant site with subsequent loss of
approximately half of this acreage as wildlife habitat.
Short-term impacts due to construction will be minor but
will include dust, noise, odor, vehicle emissions, traffic,
and soil erosion. Construction activity in Mill Cove will
cause the temporary disturbance of two acres of salt marsh
and temporary impact on the aquatic animal community from
sedimentation and turbidity. A short-term period of panic
selling in the residential neighborhoods surrounding the
plant site may also occur before the plant goes into
operation. This impact will be of short duration since the
demonstrated compatibility of the plant in its proposed
location will not cause any long-term degradation of
surrounding neighborhoods.
b. Operaticnal Impacts
The operation of the waste treatment facility will cause
the discharge of initially 10 MGD and ultimately 20 MGD of
secondary treated wastewater to the St. Johns River and will
have minor impacts related to resource use, operational
noise and odor, and the movement of vehicles.
11
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-. c.. Secondary Impacts
Construction of the project will increase the potential
for development of areas set aside for preservation and
conservation and other sparsely populated sections of the
service district with concomitant impact to terrestrial
biota and wetland areas, Associated with this increased
growth potential is the need for water supply,
transportation, parkiands, recreational areas, and other
commonity services and facilities,
ft. List of Alternatives Considered
The following system alternatives were considered in the
Draft EIS and reconsidered primarily from a cost-effective
standpoint in the final project recommendation appearing in
this document;
(lq) Millcoe Road site and transmission system with
Quarantine Island outfall^ -
(Ib) Millcoe Road site and transmission system with
Blount Island outfall.
(2gj Danes Area site and transmission system with
Quarantine Island outfall,
(2b) Dunes Area site and transmission system with Blount
Island outfall.
(3) Dame Point-Fort Carolina Freeway Interchange site
and transmission system,
Site north of Craig Field and transmission system.
(5) Site east of Craig Field and transmission system
"A" .
(6) Site east of Craig Field and transmission system
(7) Site inside eastern boundary of Craig Field and
transmission system MBn.
(8) Site inside eastern boundary of Craig Field and
transmission system "B".
(9) Beacon Hills site and transmission system,
(10) Spanish Point site and transmission system.
111
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(11) Quarantine Island site and transmission system.
(12) Site inside southern boundary of Craig Field and
transmission system.
Non-structural systems, process subsystems, odor
control, noise control, and effluent and sludge disposal
alternatives were also analyzed in the Draft. The selected
alternative for final sludge disposal appears herein as do
some attendant modifications to noise and odor controls. In
addition, the "no action" alternative was also given full
consideration in the Draft,
5. Comments Received
Written comments on the Draft EIS were received from the
following Federal, State, and local agencies and interested
groups and individuals:
Federal
Department of Agriculture, Forest Service
Department of Agriculture, Soil Conservation Service
Department of Commerce, National Oceanographic and Atmospheric
Administration
Environmental Protection Agency, Office of Water Program
Operations
Department of Health, Education, and Welfare
Department of the Interior, Office of the Secretary
State
Florida State Clearinghouse
Department of Agriculture and Consumer Services
Department of Community Affairs
Department of Environmental Regulation
Department of Health and Rehabilitative Services
Department of Natural Resources
Department of State
Department of Transportation
Game and Fresh Water Fish Commission
St. Johns River Water Management District:
IV
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Local
City of Jacksonville, Departirsent of Public Works
Private Organizations
Florida Engineering Society, Jacksonville Chapter
Florida Wildlife Federation
Individuals
Mrs. R. E. Bowditch Mrs* Patricia J. Pillmore
Mr. Thomas F. Brewer Mrs* Charles Platt, III
Ms, Gwendolyn H. Brown ' Dr. Setts J. Soldwedel
Mr, William Colville Mr, John M. Stevens
Mr. Charles T, Morgan Mrs. Nadine Stevens
Mr, Sam E. Newey Mr, Melvin M. Summers
Mrs. Helen O'Quinn .Mr. F. J. Thibaultr Jr.
Mrs. Helen R. Werder
In addition, four comment letters signed by a total of 77
people were submitted to the Agency in the form of
petitions,
6. This final environmental Impact statement was made
available to the Council on Environmental Quality (CEQ) and
the public on August 20, 1976.
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TABLE OF CONTENTS
CHAPTER PAGE NO,
Preface lx
I. Additions, Revisions, and Verifications to
Information Contained in the Draft EIS 3.
A. Archaeological and Historical Survey — 2
B. Vegetative Survey 2
C. Arboristic Cover Types 2
D. Revised Population Projections- 3
E. Review of Sludge Disposal Alternatives 3
F. Noise, Odor, and Aesthetics 5
G. Cost-Effective Verification 6
II. Public Hearing on Draft EIS 23
EPA Response to Questions and Comments 97
1. Chlorination 9S
2. Incineration 53
3. Deep Well Injection 99
4. No Action Alternative 3.01
5. Noise and Odor 3.01
6. Aesthetics 3.04
7. Further Consideration of Alternative 11 3.05
8. Further Consideration of Alternative 12 3.05
9. Exact Construction Site 3.05
10. Buffer Zone 106
11. Access Road Safety 106
12. Effects on Mill Cove 106
13* Transmission System Funding 3.07
14. Public Disclosure 107
15. Public Water Supply 108
16. Jacksonville Area Planning Board
Policies and Standards 3.08
17. Impact on Major Landowners 3.08
18. Pressure from Major Landowners 3.09
19. Assistance Committee
20. EPA Contact with Other Agencies—
21» 1990 Water Quality Management Plan
22. Projected Population
23. Compatability of Plant Site with
Residential Area
24. Legal Requirements 3.10
25. Outfall Construction Permit 3.10
26. Decentralization of Treatment
Facilities 3.11
27. Blount Island Outfall 3.11
23. Cost-Effective Verification 3.12
Associated Exhibits 3.-3
VI
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III. Written Comments on Draft EIS with EPA Response- 133
A. Comments received from Federal, State, and
local agencies and private organizations 134
B. Individual comments sent directly to EPA. 184
C. Individual comments sent to other parties and
forwarded to EPA for reply- -— — 221
IV. Agency Decision—— .—.—-.- —.--. 234
Vll
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EXHIBITS
NO. TITLE PAGE
1-1 Archaeological and Historical Survey
of Plant Site and Outfall Corridor — H
1-2 (a) Plant Site and Interceptor Corridor
Vegetative Survey ------------------- 15
1-2 (b) Interceptor Corridor Vegetative Survey 16
1-2 (c) Interceptor Corridor Vegetative Survey 17
1-3 Arboristic Cover Types in the
Arlington-East Service District ----- IS
1-4 Sludge Handling and Disposal
Alternatives --- -
1-5 Sludge Force Main Route- ------------ 22
II-l Alternative 12 (Plant Site and
Transmission System) ----- - ----------
II-6 Consistency of Site 1 with the
Policies and Standards Handbook
of the Jacksonville Area Planning
Board (letter from JAPE)
II-7 Major Landowners in the Arlington-
East Service District
II-2 Buffer Zone ------------------------- 114
II-3 Safety of Plant Access Road (letter
from Jacksonville Traffic Engineering
Division) ---------------------------
II-4 Effects of the Project on the Water
Quality of Mill Cove (letter from
Jacksonville District, D. S. Corps
of Engineers) — - ------ - ------------- H7
II-5 Effects of the Project on Future
Navigation Projects (letter from
Jacksonville District, U. S. Corps
of Engineers) -----------------------
II-8 Application for a Department of the
Army Construction Permit by the City
of Jacksonville --------------------- 124
viii
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PREFACE
On December 26, 1975 the Environmental Protection
Agency, Region IV, issued a draft Environmental Impact
Statement (EIS) on the administrative action of awarding
grant funds to the City of Jacksonville, Florida for the
preparation of plans and specifications for regional
wastewater treatment facilities to service the Arlington-
East District, The EXS was filed with the Council on
Environmental Quality (No. 51825} and circulated for review
among various Federal and State agencies with expertise in
the matters therein and made available to the public*
Contained herein are revisions and, in some cases,
additions to the draft SIS, These revisions and additions
are based upon comments from Interested parties or further
EPA information, Basically,,howeverr the project has not
changed from the alternative recommended by the Draft EIS,
Plans and specifications will be prepared for a 10,0 million
gallon per day wastewater treatment plant to be located at
Millcoe Road and 13,900 feet of outfall line terminating at
the edge of the maintained shipping channel in the St. Johns
River, Since publication of the Draft, several changes to
the project having to do with final disposal of sludge have
been incorporated into the first phase design. These
changes consist of foregoing construction of heat treatment
and incineration facilities at Arlington-East and
constructing an 8-inch sludge force main from the plant site
to the Buc.kman street treatment plant in order to utilize
the existing capacity of the Buckman Street incinerator.
Rather than reprinting the text, figures, and tables of
the Draft SIS, the Final EIS should be read in conjunction
with the Draft. This document, when appended or Inserted
into the Draft ETS shall constitute the final environmental
impact statement in accordance with the Guidelines of the
Council on Environmental Quality, 40 CFR 1500, and with
EPAfs Final Regulations governing preparation of
environmental impact statements, 40 CFR 6,
Chapter I contains additions, revisions, and, in the
case of the comprehensive cost-effective analysis,
verifications to the content of the Draft EIS.
A Public Hearing on the Draft was held in Jacksonville
on January 26, 1976. Chapter II contains a transcript of
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that hearing as well as an Agency response to all comments
and questions raised.
Chapter III reproduces all written comments on the Draft
EIS with appropriate response on all comments and questions.
It is composed of three sections: Part A deals with
correspondence received from Federal, State, and local
agencies as well as private organizations; Part B with
individual comments sent directly to EPA; and Part C with
individual comments which were sent to other parties and
forwarded to EPA for reply.
Finally, Chapter IV presents EPA's conclusions and
administrative decisions concerning the City of
Jacksonville's grant application.
Publication of this Final SIS on the awarding of grant
funds for the preparation of plans and specifications for
regional wastewater treatment facilities to service the
Arlington-East District fulfills EPA's responsibilities
under the National Environmental Policy Act and EPA's
regulations for environmental review of construction grant
applications. In accordance with these regulations, a Step
2 grant offer will be made to the City of Jacksonville
thirty days after this Final SIS is filed with the Council
on Environmental Quality and made available to the public.
Anyone receiving this document who has not received a copy
of the Draft may request a copy from:
John E» Hagan III, Chief
Environmental Impact Statement Branch
Environmental Protection Agency
li*21 Peachtree Street, N. E,
Atlanta, Georgia 30309
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CHAPTER I
ADDITIONS, REVISIONS, AND VERIFICATIONS
• TO INFORMATION CONTAINED IU THE
DRAFT £IS
A) Archaeological and Historical Survey
B) Vegetative Survey
C) Arboristic Cover Types
D) Revised Population Projections
E) Review of Sludge Disposal Alternatives
P) Noise, Odor, and Aesthetics
G) Cost-Effective Verification
1.
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A) Archaeological and Historical Surveys
An archaeological and historical survey of the Millcoe
Road treatment plant site and the outfall corridor was
conducted by the Florida Department of State, Division of
Archives, History and Records Management, No archaeological
or historical sites eligible for listing in the National
Register of Historic Places or other-wise of national, State,
or local significance were found* A letter from the Florida
State Historic Preservation Officer describing the survey
along with a map showing areas surveyed is included as
Exhibit 1 of this chapter.
An archaeological and historical survey of the proposed
sludge force main route was conducted during the week of
August 2, 1976. Results of this survey were not available
at the time of printing of this document. However, a
condition shall be placed on.the grant to require mitigation
satisfactory to the State Historic Preservation Officer of
any adverse impacts to significant sites identified by the
survey, In addition, any interceptor lines funded by EPA
arants in the Arlington-East Service District must also have
survey work and appropriate mitigative measures as
recommended by the State Historic Preservation Officer.
B) Vegetative Survey
A vegetative survey of the interceptor and outfall
corridors has been conducted by the Florida Department of
Agriculture and Consumer Services, Division of Forestry.
Only naturally vegetated portions were surveyed and mapped;
Exhibits 2 (a) , (b) , and (c) of this chapter show the
dominant cover types. All corridor portions along presently
maintained roadway easements were excluded from the on-site
survey.
No rare or unusually large trees or trees with special
historical value were found, Mr, James A. Ehlers, Urban
Forester, has indicated that the interceptor corridors will
disturb a minimum of naturally vegetated systems.
C) Arboristic Cover Types
The map showing arboristic cover types in the Arlington-
East Service District (see Figure 2-11 of the Draft SIS), is
reprinted for clarity as Exhibit 3 of this chapter.
2.
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D) Revised Population Projections
The population projections presented in the Draft IIS
for the Arlington-East service District were based upon
projections presented in the Water Quality Management Plan.
These projections were agreed to at that time by the
Jacksonville Area Planning Board (JAP3) and SPA.
Within the past year, the JAPB has undertaken an in-
depth re-evaluation of their 'population projections
throughout the county. The total county projection for the
year 2000 has been lowered to 817,100 as a result of this
study. Major causes for this decrease are a lowering of the
birth rate and a lessening of the expected rate of in-
migration.
The current population of the Arlington-East area is
about 104,000. This figure is nearly identical to that
projected by the Water Quality Management Plan for 1975.
There is, therefore, no reason to alter the 10.0 MGD design
capacity of the first phase construction of the treatment
plant. It does seem likely, however, that the year 2000
population of the service area will be significantly less
than originally forecast. A twenty percent share of the
total county population would mean about 167,000 people in
the service area in the year 2000 instead of the
approximately 219,000 projected by the Draft SIS. This
would mean a decrease in the ultimate design capacity of the
treatment facility from the 25.0 iMGD shown in the Draft EIS
to 20-0 MGD* Further evaluations of the population
projections should be made when planning the expansion of
the 10.0 MGD facility.
E) Review of Sludge Disposal Alternatives
The Draft EIS described the final method of sludge
disposal for the Arlington-East facility as incineration
followed by landfilling of the ash, A re-evaluaticn cf the
feasibility and cost-effectiveness of various alternatives
to incineration has since been carried out by EPA and Flood
5 Associates, Inc. This investigation has shown that some
alternatives are not implementable or desireable for use at
the planned facility at this time*
The most desireable and cost-effective method of sludge
disposal for the first phase of the Arlington-East plant is
to forego construction of the heat treatment and
3.
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ALTERNATIVE
A. Heat treatment, vacuum filtration,
and incineration at Arlington;
landfill ash
B. Heat treatment and vacuum
filtration at Arlington; landfill
cake
C. Same as (A) except sized for present
design only. Expansion to ultimate
capacity accomplished by additional
facilities
0. Same as (B) except sized for present
design only. Expansion to ultimate
capacity accomplished by additional
facilities
£. Pelletization at Arlington
F. Heat treatment and vacuum filtration
at Arlington; use sludge as soil
conditioner
SLUDGE HANDLING AND DISPOSAL ALTERNATIVES
Ammmi,
Nonr
Saves cost of Incineration at
Arlington
Full utilization of sludge handling
and disposal facilities during
first phase of operation
Lower capital costs; full
utilization of sludge handling
equipment during first phase of
operation
Provides resource recovery
Provides resource recovery
High capital and annual costs;
incineration capacity not fully
utilized until plant reaches
ultimate design flow; does not
provide resource recovery
Relatively high capit3l and
annual costs; does not provide
resource recovery
Relatively high capital and
annual costs; does not provide
resource recovery
High annual costs; does riot
provide resource recovery
Not cost-effective unless part
of county-wide system; requires
railway and truck loading
facilities; depends upon demand
from outside market
Requires commitment of suitable
and adequate acreage
£L£XiaiUIY_
Heat treated and
dewatered sludge could be
used for soil conditioning;
commitment to incineration
not compatible with
eventual regional resource
recovery system
Heat treatment and de-
watered sludge could be
used for soil condition-
ing; option of incineration
at Arlington left open
tot treated and de-
watered sludge could be
used for soil condition-
ing; incineration In-
compatible with regional
resource recovery but less
expensive than In (A)
Same as (B) above
Compatible with eventual
resource recovery system
Same as (E) above
G. Heat treatment at Arlington;
truck to Buckman Street; vacuum
t filtration and Incineration at
Buckman Street; landfill ash
H. Heat treatment and vacuum filtration
at Arlington; truck to Buckman Street;
incineration at Buckman Street; landfill
ash
Heat treatment and vacuum filtration
at Arlington; truck sludge to Buckman
Street for Incineration or use as soil
conditioner. Use same trucks for either
option
J. Pump Arlington sludge to Buckman
Street via force main; heat treatment,
vacuum filtration, and incineration at
Buckman Street; landfill ash
*Chosen alternative
Uses existing capacity of
Buckman Street Incinerator; saves
cost of vacuum filtration and
Incineration at Arlington
Lower cost of hauling vacuum
filtered sludge to Buckman Street
(smaller vo1ume);uses existing
capacity of Buckman Street
incinerator; saves cost of
Incineration at Arlington
lower costs of hauling vacuum
filtered sludge to Buckman Street
or to soil conditioning site; could
provide resource recovery; could
use existing capacity of Buckman
Street incinerator; saves costs of
Incineration at Arlington
Host cost-effective alternative
for Arlington plant; uses existing
capacity of Buckman Street
incinerator
4.
Higher cost of hauling vacuum
filtered sludge to Buckman
Street (greater volume);
does not provide resource
recovery
Relatively high capital and
annual costs; does not provide
resource recovery
Relatively high capital and
annual costs; incineration option
does not provide resource recovery
Heat treated sludge could
be used for soil cond-
itioning; option of
incineration at
Arlington left open
Same as (G) above
Does not provide resource
recovery
Provides option of using
same trucks for inciner-
ation or soil condition-
Ing; does not require
firm commitment of
acreage since incineration
at Buckman Street serves
as backup option
Provides option of using
sludge force main In
regional resouces recovery
system; does not expend
capital costs for
facilities not compatible
with regional resource
recovery
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incineration facilities and to utilise the existing reserve
capacity of the incinerator at the Buckman Street treatment
plant. Transportation of sludge to Buckman Street could be
accomplished either by pumping via a force main or hauling
by truck.. Twenty-six trucks with a capacity of 6,000
gallons each would be required daily to haul heat-treated
sludge from a 10.0 MGD facility* To haul heat-treated and
dewatered sludge from a plant of that size would require
eleven trucks per day with a capacity of five cubic yards
each. In addition,, the truck hauling option would
necessitate unloading facilities at Buckinan Street. Cn the
other hand, construction of a sludge force main from
Arlington-East to Buckman Street at a cost of approximately
SI million, including a pump station, is more cost-effective
for the first phase of the project. Cost-effectiveness is
still maintained with the required added heat treatment and
dewatering facilities at Buckinan Street since this equipment
will not be required at Arlinerton. Additionally, the force
main option would also provide time to develop the most
cost-effective and environmentally sound sludge disposal
method for the entire Jacksonville regional system. The
Buckman Street incinerator was originally designed to
process sludge from the Buckman Street plant, the North
District plant and the first, phase of the southwest District
plant. The 201 Facilities Plan presently underway will
develop the optimum sludge disposal method for the
subsequent phases of all five regional treatment plants.
A letter from Flood and Associates, Inc, to EPA
summarizing their sludge handling analysis including the
cost-effectiveness of alternatives considered appears as
Exhibit 4 of this chapter. Exhibit 5 shows the routing of
the proposed sludge force main* The following table surronarizes
the alternatives considered by Flood as well as several others
developed by EPA.
F) Noise, Odor, and Aesthetics
The previously described changes in sludge handling and
disposal will eliminate some previously planned facilities
a-t Arlington-East. Planned noise and odor controls for
these processes were described in Chapter III of the Draft
EIS. Now, however, the decision to pump Arlington sludge to
Buckman Street for incineration has eliminated several
sources of unmitigated noise and odor and, consequently, the
need for associated structural noise and odor controls. The
new design will eliminate the heat treatment and
incineration building. This three-story structure was the
5.
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major potential noise source on the plant site (refer to
Table 3-8 of the Draft EIS) due to the large equipment
access doors and the high noise levels generated by sludge
handling equipment located inside. Significant noise
sources within the building which are now eliminated include
boilers, centrifuges, sludge conditioning equipment, the
multiple hearth incinerator, vacuum filters, ash conveyors,
sludge blending tanks and pumps, and heating and ventilation
equipment.
The potential for odor from sewage treatment facilities
is due -to the possible occurrence of malodorous inorganic
fsulfides and ammonia) and organic (mercaptans) chemical
compounds in reduced states. Such compounds occur during
periods of septicity when dissolved oxygen concentrations in
sewage are depressed to the point that oxygen is absent.
The points within the sewage treatment plant's process
sequence where septicity and consequent odor problems are
most likely to occur are the raw influent and sludge
handling processes. Measures to control odor from these
processes have been described in Chapter in of the Draft
EIS. Now, however, the decision to pump sludge to Buckman
Street has eliminated the need for most sludge handling
equipment at Arlington (centrifuaes, vacuum pomps, vacuum
filters, and sludge blending tanks). All structural odor
control measures described in the Draft EIS not having to do
with these particular components will remain. Specifically,
these include enclosing the bar screen, preaeration tank,
primary clarifiers, and sludge holding tank in a building
and treating vapors from these sources with a chemical
scrubbing system.
In addressing aesthetic impacts of the treatment plant
at Millcoe Road, the Draft EIS stated that the 74-foot
incinerator stack would, for practical purposes, not be
visible by residents in the area- The decision to forego
incineration at Arlington now eliminates any possible
aesthetic impact of the incineration building and
incinerator stack.
G) Cost-Effective Verification
Since publication of the Draft EIS, an independent
investigation of the most cost-effective plant site and
interceptor configuration has been completed by the Water
Division of SPA, Region IV. The purpose of the study was to
verily the least cost alternative for the proposed
6.
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wastewater regionalization system in the Arlington-East
Service District, A cost optimum algorithm was employed.
Capital cost data were obtained from carves developed from
actual bid prices in the southeast. The majority of the
treatment plant cost data were based on plants within the
State of Florida. Operation and maintenance costs were
derived from the EPA publication Guide to the Selection of
Cost Effective Wastewater Treatment Systems. Treatment
plant capital, costs included site preparation. Other needed
cost data were derived from the consultant's curves since no
independent data sources were available. These included the
capital costs of pump stations as well as the operation and
maintenance of transmission lines and pump stations. All
cost data were of necessity converted to forms usable by the
algorithm. Following is a summary of the algorithm1s
history and user the studied system, and the results of the
study.
History and Use of the Algorithm. The cost optimum
algorithm is a computer planning program that determines the
present worth of the least cost wastewater regionalization
system.
The computer executed methodology for optimization was
developed in 1971-1972 by Dr. Martin P.. Wanielista, Florida
Technological University, and was published in the Journal
of the Water Pollution Control Federation in December, 1973.
The algorithm has been used to determine the least cost
regional wastewater treatment systems for three 3-C studies:
Jacksonville, Orlando and Palm Beach,
The program has its utility in planning in that it is
able to analyze a multitude of alternatives. Because many
different configurations reflecting various treatment,
disposal, and transmission schemes are required to
accurately represent all possible alternatives, the model
input data must be displayed in a graphical nodal diagram.
Each node represents a treatment site or a collecting point
such as a pump station. If there are wn'» nodes representing
possible plant site locations, and "m" transmission lines,
then there are n! x m! (factorial) theoretical solutions to
the problem with the optimum solution being the least cost
alternative scheme.
The program determines the least cost alternative by
evoking an operation research technique called the "simplex
algorithm." The simplex algorithm procedure is an iterative
{repetition) method for solving linear programming problems
7.
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by finding successive basic-feasible solutions and testing
them for optimality. Simply, the simplex algorithm can be
regarded as a systematic and efficient procedure for
optimizing problems that are not limited by large nimbers of
variables and restrictions.
1 The important input data into the simplex algorithm
consists of the following items:
(!) Development of an accurate and detailed nodal
network which represents all possible transmission
lines, pump stations and plant site locations;
(2) Definitive and current cost curve data for the
various components {treatment, transmission and
disposal) needed to represent the indicated
networks. The cost curves should reflect economies
of scales for larger treatment facilities and
lines, i.e., the curve profile should be concave.
The Studied System. The wastewater treatment
regionalization network studied consists of 47 nodes, 124
pipes, and 12 proposed wastewater treatment plants located
at 10 different nodes, or locations, with 2 plants each
located at 2 nodes. This network represents all
configurations addressed in the Draft SIS {refer to Figures
3-1 through 3-11 of that document and Chapter II, Exhibit 1
herein) for an ultimate design capacity of 20 MGD.
Results. The least cost system shown by the algorithm
accounts for the present worth and the operation and
maintenance of both a wastewater treatment plant and its
associated collection system, Present worth calculations
were based on an interest rate of 5 1/8 percent and a
planning period of 20 years. Following are the rankings of
the first four most cost-effective configurations for the
project, as described in the Draft EIS:
20 MGO with Quarantine Outfall
Ranking Alternative P.M. x 10*
1 1 70.6950
2 3 70.6985
3 2 73.1556
4 4 73.6687
8.
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Ranking
1
2
3
4
20 MGD with Blount Island Outfall
Alternative
1
3
4
2
P.W. x 10
72.0650
72.6850
73.1556
74.4023
For the project as now planned (elimination of
incineration, heat treatment, and sludge handling at
Arlington and consturction of a sludge force nain to Buckman
Street) the cost rankings are as follows:
Ranking
1
2
3
4
20 MGD with Quarantine Outfall
Alternative
3
1
2
4
P.W. x 10
62.7955
62.9820
65.4426
66.0557
Ranking
1
2
3
20 MGD with Blount Island Outfall
Alternative
1
3
4
2
P.W.
10
64,6220
65.1734
66.0557
66.9350
As may be seen, Alternative 1 is the most cost-effective
for the project as described in the Draft EIS. For the
project as presently planned, however, Alternative 3 is
slightly less expensive. This is due to the shorter sludge
force main to Buckman Street which would be associated with
site 3. Notwithstanding this slight edge in cost-
effectiveness, site 3 has not been chosen due to overriding
environmental considerations (refer to rankings appearing in
Chapters III and VIII of the Draft EIS).
9.
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A detailed description of all configurations considered
including interceptor lengths, flows, slopes, capital costs,
and operation and maintenance is given in the EPA, Region IV
report Results of the Cost Optimum Algorithm for the
Jacksonville-ArTTngton East Environmental Impact Statement.
This report is available for review in the EPA, Region IV
office in Atlanta and in the office of the Deputy Director
of Public Works for the City of Jacksonville^
The capital cost for in-plant odor control for the first
phase of the planned facility has been estimated by Flood
and Associates, Inc. at $.2 million. This will cover the
chemical scrubber system and brick and masonry building to
house the remaining potential sources of odor. Piping and
electrical requirements are included.
10.
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I
Exhibit 1
STATE OF FLORIDA
of Stat?
THE CAPITOL
TALLAHASSEE 32304
BRUCE A. SMATHERS ' ROBERT WILLIAMS, DIRECTOR
SECRETARY OF STATS *•»».-.•« ? 1 Q 7 £ DIVISION OF ARCHIVES, HISTORY, AND
3 t •*"•* l ° RECORDS MANAGEMENT
(904) 4WM480
IN REPLY REFER TO:
Deputy Director of Public Works
City of Jacksonville
220 East Bay Street
Room 1207
City Hall
Jacksonville, Florida
Attn: Joe Hyatt
Re: Archaeological survey of Arlington Wastewater Management
Facility, Alternate #1, Duval County, Florida.
Dear Sir:
The Florida Department of State, Division of Archives,
History and Records Management conducted an archaeological and
historical survey of the proposed Arlington Wastewater Manage-
ment Facility, Alternate #1, in Duval County, Florida in ful-
fillment of an agreement between the Division of Archives,
History and Records Management and the City of Jacksonville.
The purpose of this survey was to locate and inventory any sites
eligible for inclusion in the National Register of Historic
Places which might be adversely affected by the proposed
treatment facility.
The survey was divided into two parts: the treatment plant
site itself, consisting of 46.98 acres, and the 13^900 linear
feet of outfall. The sewage treatment plant site is rectangular
in shape (running N/S) and contains two marsh areas, one near
the center of the property and one in the northeastern corner.
It also contained three elevated areas, one in the area centrally
north of the marsh; another in the area northwest of the first
elevated area; and the entire area at the southern end of the
property (see attached figure 2). The southern area was
covered predominantly with scrub oak while the areas near the
marsh and to the north contained pine and palmetto. It might
be noted that the entire southern area of the treatment plant
site contained trash deposits including such things as junked
cars, stoves, refrigerators, bottles, cans and other debris
which indicated that the area had been used extensively as a
dump in recent times.
11.
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Deputy Director of Public Works
April 5, 1976
page 2.
The survey methodology consisted of a physical walk-over
with the use of compass lines by James Chafin of this office.
The compass lines involved walking lines separated by approximately
fifteen feet, parallel to the eastern and western boundaries of
the property in a north-south direction until the entire area
south of the central marsh area had been covered thoroughly.
The two areas of higher elevation to the north of the marsh
area were also covered by the use of compass lines walked at
intervals of fifteen feet. However, these were covered by east-
west lines perpendicular to the eastern and western boundaries
of the property. Intermittent test holes were also excavated
with the use of a shovel. This involved random test pitting in
areas of higher probability of site location, such as areas of
higher elevation, and especially those near the marsh and in
the southern area of the acreage. These test pits were usually
dug to a depth of 18 inches and were approximately 8 inches
in diameter. Approximately fifty test pittings were done,
one-half in the area south of the marsh and one-quarter each in
the two elevated areas in the north of the property.
Also surveyed was the 13,900 linear'feet of outfall area
extending north-northwest from the north west comer of the
sewage treatment plant site area to the Merrill Road and on into
the Mill Cove area of the St. John's River (see attached figure 1).
Areas of higher elevation were surveyed more intensively than
marsh areas because of the higher probability of locating a site.
It has been found that due to human preferences for settling on
dry, well-drained surfaces, archaeological sites are most often
located on higher ground. The marsh areas, however, were covered,
though not with compass lines, with a simple physical walk-over.
Research on property title deeds was done in the office of
the Clerk of the Duval County Court to determine if any mention
was made of historical sites of significance possibly located
in the area. The research revealed that early property ownership
records burned in the Jacksonville fire of 1901, and recordings
prior to this date were only to be obtained through a private
firm (Title & Trust Co., Jacksonville, Fla.). The cost of
obtaining these records was not authorized in the survey budget.
Thus, the title deed research revealed nothing of interest.
However, during the actual walk-over, notice was made of any
architectural remains in the area. One collapsed wooden structure,
elevated on concrete blocks, was located. The building was
nailed with steel nails, roofed with tin, and was estimated
to date between 1930 and 1960. This structure was located
12.
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Deputy Director of Ptiblic Works
April 5, 1976
page 3.
approximately 760 feet north and 50 feet west of the SB corner
of the sewage treatment plant tract. It is of no particular
historic importance, though it was reported to the Historic
Preservation Section of this office.
No archaeological or historical sites eligible for listing
in the National Register of Historic Places or otherwise of
national/ State, or local significance were found in the course
of the survey. Thus the Arlington Wastewater Management Facility,
Alternate II, may proceed without further involvement of this
office.
This letter will serve as our final report on the Arlington
project and, as per the agreement, our office will shortly be
sending an invoice for this project in'the amount of $560.90.
Thank you for your interest in Florida's historical resources
If we can be of further service in answering questions about
the Arlington survey, please do not hesitate to write or call.
Sincerely,
Robert Williams
State Historic Preservation Officer
RW/Csh
13.
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V)
ATLANTIC ..
BOULEVARD ESTATES")! V*-
«tt ' "11 ft J^
TREATMENT PLANT SITE
ARLINGWOOD
^j—»_SJ1UB
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1
Exhibit 2(a)
Arlington-East District
Interceptor Corridor Vegetative Survey
Mixed stages
Mixed pine/hardwood
Species: Slash pine
loblolly pine
live oak
laurel oak
red bay
loblolly bay
wax myrtle
palmetto
MILL COVE
Cutover scrub 6-8"dbh
Mixed pine/hardwood
Species: slash pine
red bay
laurel oak
wax myrtle
loblolly bay
Proposed
Millcoe Rd STP site
Longleaf pine/Turkey oak ridge
Species: Turkey Oak
Longleaf pine
8-12" dbh
Interceptor shown by dotted line
Scale 1" = 2000'
15.
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1
Exhibit 2(b)
Arlington-East District
Interceptor Corridor Vegetative Survey
cypress stand
Sandlewood
(Developed)
Pine flatwoods
Species: slash pine
Mixed stages
Pine flatwoods
species: slash pine
cutover
Sandlewood STP
Interceptor shown by dotted line
Scale 1" = 2000'
16.
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exhibit 2 (c)
In
Survey
Grove
Park (developed)
pond pine
Low hardwood
Species: loblolly bay
wax myrtle
2-6" dbh
cr>
£
Beach Blvd.
0)
T5
O
to
Scale V-2000'
17.
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1- Uve Oak Hammock
2. Long-leaf Pine
Turkey Oak
3. STash Pfne
4. Hardwood Swamp
5. Cypress Stand
6. Water
7. Ruderal
8. Development
9. Marsh
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Exhibit 4
FLOOD & ASSOCIATES, INC.
Consulting Engineers
May 21, 1976
Mr. Diaz Callahan
Environmental Protection Agency
1421 Peachtree Street, NE
Atlanta, Georgia 30309
OFFICERS
JOHN H. FLOOD. JR.. P.E.
BILL L. BRYANT, P.E.
ROBERT L. BATES. JR.. P.E.
JAMES S. ENGLISH. P.E.
ROBERT V. TSUMPES
ASSOCIATES
BRUCE A. BELL. Ph.D., P.E.
ROBERT E. DE LOACH, JR., P.E.
U THOMAS HUBBARO. P.E.
TED B. MALINKA, P.E.
OFFICES
JACKSONVILLE
ATLANTA
PENSACOLA
Re: City of Jacksonville, Florida
Arlington-East Sewage Treatment Plant
EPA Project No. C12054010
City No. JS-40.1
Engineers' Project No. 7316
Dear Mr. Callahan:
This letter will provide a discussion of sludge handling for the subject
project.
We have generally reviewed the sludge pelletizing process developed by
Ecological Services Products, Inc. While the basic process is similar to that
used in Milwaukee and Chicago, resulting in a disinfected, dried sludge, the
relatively dust free nature of the Ecological Services Products process offers
significant market advantages. However, analysis and evaluation of the subject
project indicates that sludge drying operations are not implementable at Arling-
ton-East at this time.
The dried sludge product, of any type, must be delivered to fertilizer
manufacturers by rail. There are no rail facilities available in the Arlington
East area. Thus, a truck loading facility would be required on the plant site
and a remote rail loading facility would need to be constructed. Preliminary
investigations of this operation as part of an overall sludge study for the
City of Jacksonville, presently underway, indicate the most cost effective method
sludge drying would be a central drying and rail loading facilities located
at the proposed Mandarin-San Jose plant site. The City does not presently own
the proposed plant site and Mandarin-San Jose plant will not be built until the
mid-1980fs at the earliest.
Sludge drying operations are being considered in the Jacksonville sludge
study but in addition to the impracticability of implementing sludge drying on
the Arlington-East site, there are significant technical questions that remain:
1. Ecological Services Products are unable and/or unwilling to offer
fuel, power and polymer guarantees.
19.
904/724-3990 P.O. BOX 8868 S501 ARLINGTON EXPRESSWAY JACKSONVILLE, FLORIDA 32211
-------
Mr. Diaz Callahan
May 21, 1976
Page Two
2. Since the supplier refuses to provide anything but a turn-key
package there is no opportunity to utilize optimum equipment
selection.
3. There is some question as to whether the Belt press is superior
to Vacuum filters for this application.
4. There is very limited operational data on which to base operating
cost and performance.
5. The present situation, with a patent pending on the process, makes
it impossible to ascertain the nature and extent of the patent
protection and whether or not similar processes by other manu-
facturers may become available in the near future providing a
choice of equipment and a competitive situation.
•For the reasons delineated above, the sludge drying alternative has been
eliminated from consideration for Arlington-East. The remaining alternatives
are delineated below.
Alternate A-l - Heat Treatment of sludge followed by vacuum filtration and
incineration with waste heat recovery. This alternate is sized as to require
a minimum of later and total expense for expansion to ultimate capacity.
Alternate A-2 - Heat Treatment of sludge followed by vacuum filtration and cake
hauled to landfill. This alternate is sized in a similar manner to A-l.
Alternate A-3 - Flowsheet identical to alternate A-l except that sizing is
based on present design only. Expansion to ultimate capacity would be by
additional, duplicate facilities.
Alternate A-4 - Flowsheet identical to alternate A-2, sizing identical to
alternate A-3.
Alternate B - Pump sludge to Buckman Street for heat treatment and incineration.
This alternate is an interim solution which "borrows" against future capacity
at Buckman Street.
Presented in the Table on the following page are the capital and operating
costs of the significant items for each alternative. Capital cost has been
assumed to be amortized at 6% for 20 years. Operating cost has been estimated
for 10 MGD plant exclusive of labor.
20.
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Mr. Diaz Callahan
May 21, 1976
Page Three
SLUDGE HANDLING ALTEBNATIVES
Alternate
A-l
A-2
A-3
A-4
B
Capital
Cost $
8,713,000
5,913,000
7, 153,000
5,038,000
4,450,000
Amortization.
$/?r.
759,599
515,495
623,599
439,213
387,951
Operating
Cost :$/yr.
69,802
262,211
69,969
275,689
69,053
Annual
Costc$/yr.
829,401
777,705
693,568
714,902
457,004
Cost to
expand to
ultimate c
600,000
N/A
6,140,000
N/A
N/A
As may be seen from the Table, Alternate B, pumping of sludge to Buckman
Street is highly attractive from a cost standpoint. Additional savings will be
realized if Alternate B is chosen:-due to savings in labor costs which are not
included in the Table.
We recommend the adoption of Alternate B. Based on our discussions of
May 17, 1976 we are proceeding with finalization of plans and specifications
for the plant including Alternate B. Should you have any questions or desire
any additional information, please advise.
Sincerely,
FLOOD & ASSOCIATES, INC.
Consulting Engineers
Bruce A. Bell, Ph.D., P.E.
Vice President
BAB/cr
cc: Mr. J. H. Hyatt, P.E.
Mr. Troy Mullis
Mr. James C. Jones, Jr. , P.E.
21.
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ainou NIVIAI
3oams
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CHAPTER II
-Public Hearing on Draft EIS
-EPA Response to Questions and comments
•Associated Exhibits
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3
4
5
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7
8
?
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24-
25
ENVIRONMENTAL PROTECTION AGENCY
DRAFT ENVIRONMENTAL IMPACT STATEMENT FOR
THE ARLINGTON-EAST SERVICE DISTRICT
WASTEWATER MANAGEMENT FACILITY
PUBLIC HEARING
City Hall
Jacksonville, Florida
January 26, 1976
FRAN PHILLIPS, Chairman
DEBORAH H. BISHOP, Official Reporter
L. LEE LAWSON & ASSOCIATES, INC.
24.
(Court Reporters)
87 Walton St., N.W., Suite 400
Atlanta, Georgia 30303
Phone (404) 522-4600
-------
CONTENTS
2 OPENING REMARKS:
3 Ms. Phillips
4 STATEMENTS :
By Mr* Howard 5
By Mr. Johansen 12
By Mr* Adams 13
8 By Mr. Wilson 20
9 By Mr. Thomas Brewer 21
•
o
10 By Ms. Pillmore 24
By Mr. Hammack 28
12 By Ms. O'Quinn 29
13 _____ __________ By Mr. Buck 31
§
at
cB
z
14 By Mr. McGauley 33 8
15 By Mr. Spohrer 35 -1
in
16 By Mr. Poggie 39 •_
J
17 By Mr. Revels 39
18 By Mr. Don Brewer 43
19 By Mrs. Lockerman 47
20 By Mr. Cruce 48
21 By Mrs. Black 43
22 By Mr. Werder 49
23 By Ms. Webb 49
24 By Dr. Soldwedel 50
25 By Mr. Evans 62
25i
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24
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PROCEEDINGS
MS. PHILLIPS:
May I call the meeting to order, please? Good
evening, and welcome to this public hearing on the Draft
Environmental Impact Statement for the Arlington-East
Service District Wastewater Management Facility.
The National Environmental Policy Act of 1969 re-
quires an agency of the federal government to prepare an
Environmental Impact Statement whenever that agency pro-
poses to take a federal action significantly affecting z
the quality of the human environment. The City of £
Jacksonville, Florida applied for a grant from the £
Environmental Protection Agency to construct the pro-
cfl
2
posed Arlington-East Sewage Treatment Plant. EPA, £
3
responding to the mandate of the National Environmental -
Ui
Policy Act, 'determined that the issuance of funds for
the design of proposed Arlington-East Wastewater Managemq:
Facility was a major federal action significantly affecti
the quality of the human environment. Accordingly, on
October 8, 1974, EPA issued a notice of intent to prepare!
an Environmental Impact Statement. This public hearing
is being held purusant to the guidelines of the Council
of Environmental Quality and the regulations of the
Environmental Protection Agency with regard to the pre-
paration of Environmental Impact Statements.
26.
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V)
VI
i The purpose of the public hearing is to receive
2 comments from the public on the Draft Environmental
3 Impact Statement. This. Draft is being discussed in a
4 public forum to encourage full participation of the
public in the SPA decision making process, to develop
greater responsiveness of governmental action to the
public's concerns and priorities, and to develop improvec.
3 public understanding of federally funded projects. An
9 official report of these proceedings will be made and
*
o
10 become a part of the record. 5
«T
Notice of the public hearing was published in the £
<
Jacksonville Times-Union and Jacksonville Journal on
..... ....... .
13 January 5 and January 23. On December 26, 1975, Draft
2
14 Environmental Impact Statement was submitted to the °>
<
15 Council of Environmental Quality and made available to -1
in
16 the public.
17 I would now like to introduce the hearing panel.
13 To my right and your left, Joe Franzmathes, director of
19 the Division of Water Programs of Region IV; and seated
20 next to him, on your right and my left, is John Hagen,
21 chief of the Environmental Statement Branch for Region iy;
22 and I am Fran Phillips, Regional Council.
23 People that I would also like to introduce that are
24 not part of the hearing panel are Cal Callaway, chief of
25 the Florida Products Council, Mr. Hay with the EPA, down
27.
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with the Florida section, and Mr. Harold Rhodes, with the
State. Where is Mr. Rhodes?
MR. RHODES:
[Standing.]
MS. PHILLIPS:
Before we begin citizen testimony, Bob Howard,
chief of the Environmental Statement Preparation section,
will give us a brief summary of the project.
MR. HOWARD:
The Draft Environmental Impact Statement for the 2
u
Arlington-East project addresses alternatives for treaties
and disposing of municipal wastewater generated in the £
u
u
Arlington-East District of Jacksonville, Florida. The e
objectives of constructing these facilities are: (1) The£
c
attainment and preservation of high quality waters for
u
u
recreational, fish, and wildlife, and aesthetic uses,
and (2) The provision of treatment facilities to adequat^
service existing and future sources of wastewater.
The proposed treatment plant site is a forty-seven
acre tract located between Merrill and Monument Roads on
the east side of the proposed Milicoe Road. The plant is
designed for an initial capacity of ten million gallons
per day and an ultimate capacity of 25 million gallons
per day. The wastewater will be treated at the plant by
screening, preaeration, grit removal, primary
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4
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9
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settling, activated sludge aeration, secondary settling,
and effluent chlorination. Treated effluent is to be
transported through 13,900 feet of 48-inch force main,
including 7,500 feet of subaqueous line across Mill Cove,
and discharged in the main channel of 'the St. Johns River
off Quarantine Island.
The estimated total cost of the project, including
the wastewater collection system, is $48,559,307. The
EPA is proposing to contribute $25,031,-367 of this cost.
The objectives of the Environmental Impact Statements
are to evaluate all reasonable alternatives for meeting £
<
project objective, to inform the public of the environ- g
to
in
mental consequences of these alternatives, and to form a**
z
basis for future decisions on federal funding. °
s
Considerable effort was placed on community involve-^
m
ment in the preparation of this EIS. On November 14, -^
J
1974, the EPA held a public hearing in this room, which
many of you attended, to solicit comments on the proposed
project. In addition, a citizens' committee provided
input into the alternative analysis. Three meetings were;
held with that committee, and the input obtained was used
to weight environmental categories and to identify and
evaluate potential impacts.
In this evaluation, ten cites were considered. They
are: alternative one, which is the Millcoe Road site -—
29.
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r
2
3
4
5
6
7
a
9
10
u
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16
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18
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20
21
22
23
24
25
you can't see them back here, but it's the Millcoe Road
site; site two was the Dunes Area site; site three, the
Dames Point/Port Caroline Road site; site four the site
north of Craig Field; sites five and six, or alternative
five and six, the sites east of Craig Field; sites seven
and eight are sites on the eastern edge of Craig Field?
site nine is the Beacon Hills site; site ten, the Spanis^
Point site; site eleven, Quarantine Island; and site
twelve, a site south of Craig Field.
The analysis of alternatives found that the site z
south of Craig Field, the Millcoe Road site, the Dunes
site, and the site east of Craig Field, and the site
north of Craig Field were all relatively close in envirol
mental desirability. Construction costs at the Millcoe <•
3
4
Road, Dunes area, and Dames-Point sites were found to
u,
u
be within five percent of each other. For these reasons 7
the site at Millcoe Road which was proposed by the City
was considered to be an environmentally reasonable, cost
effective solution to providing wastewater treatment and
disposal facilities for the Arlington-East area.
Various measures have been proposed to be taken to
mitigate potential adverse impacts associated with the
i
project. Comprehensive odor and noise controls are to i
i
i
be utilized. The provision of the odor controls is ex-
i
pected to result in ail major sources of odor being broug
30.
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8
i under control. Minor sources will be effectively con-
2 trolled by good operational and maintenance practices,
3 and no adverse odors are anticipated to be noticeable
4 outside the plant boundaries. Modelling has shown that
5 with the use of the proposed noise controls, expected
noise levels will be below 45 decibels at all residences,
This level is approximately equal to existing minimum
background levels.
9 A two-hundred foot wide buffer zone and vegetative
*
10 screen on the east side and a one-hundred foot buffer z
zone on the north, west, and south sides will be jfj
<
12 retained. Additionally, a 114-acre wooded area north o
V)
V)
13 and east of the plant site will be purchased by the City*
z
14 and dedicated as a recreational area. °,
<
15 The adverse environmental effects of the proposed -1
u
16 project may be summarized as follows: (1) The commitment?
J
17 of 47 acres and loss of about one-half of this land as a
18 natural wildlife habitat; (2) Minor short-term dust, noisje,
19 vehicle emissions, traffic, and soil erosion impacts
20 during construction; (3) Temporary distrubance of two
2i acres of salt marsh during construction of the effluent
22 outfall; (4) Disposal of initially ten million gallons
23 per day and ultimately 25 million gallons per day of
24 secondarily treated wastewater to the St. Johns River;
25 and (5) Secondary effects of development pressure on areas
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set aside for preservation and conservation.
The major beneficial impacts of the project are:
removal of inadequately treated wastewater from tribu-
tary streams in the Arlington-East area; attainment and
preservation of high quality waters in the Arlington-Eas-f:
area; provision of treatment facilities for existing and
future sources of wastewater; alleviation of adverse
conditions resulting from the operation of septic systems!
and small package plants; and allowance of orderly growth
according to the Comprehensive Development Plan for
1990, Thank you, Fran.
MS, PHILLIPS:
Thank you, Bob. I understand there are some coun- "
cilmen in the audience that I didn't have an opportunity 5
3
to meet before the hearing, and I would like to intro-
u
u
duce them at this time, if they would please stand and
state their name. I'd like for the City councilmen to
please stand and state their names. Don Pruitt just
stepped out the door.
Also. I would like to express sincere apologies from
|
Jack E. Ravan because he's not able to attend the hearing
tonight.. He was called to jury duty, and he is on a
federal jury, and is in a motel room somewhere in Atlanta
held over with the jury, and that is why he could not
attend.
32.
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10
i Procedures for receiving public comment will be as
2 follows: everyone who is registered to speak will be
given an opportunity to be heard. We will hear from
speakers in the order of registration. If you wish to
speak and have not registered, please do so at this timej,
We will ask you to limit your remarks to ten minutes.
You may have additional time after everyone desiring to
8 speak has had an opportunity to be heard. I will ask
9 Gal to stand, signalling that you have used eight minutes
*
10 of your time, and then you can be seated, Cal. You're z
welcome to submit any written statements of any length, jjf
12 and the record will remain open for fifteen days for Q
this purpose. There will be no questions to the panel ^
z
14 from the speaker. You may submit questions in writing, °,
15 which will be answered in the final Environmental Impact-3
16 Statement. We reserve the ability to ask you to limit -j
J
17 your remarks to relevant issues, and I will ask you to
18 submit your statements in writing if those remarks are
19 not so limited. Formal rules of evidence will not apply
20 here. There will be no oath of witnesses. There will be
no cross-examination or direct questions to the speakers*
22 however, if there is a point that needs clarifying or
93 data is submitted that needs further documentation, I
94 will ask one of the members of the panel to address a
25 question to the speaker for purposes of clarification only
33.
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There will be no questions by the audience of any person:}
who make statements here. If you wish to rebut any remarJ
made, either register to speak again or submit rebuttal
in writing. When you're called on to speak, please preses
a copy of your written statement if you have one to the
court reporter and another copy to us. Stand at the
speaker's podium, give your name and address, the title
or group of which you are associated, if any.
We are now ready to begin. Our first speaker is
Mr. David K. Evans.
MR. EVANS:
o
z
tu
Good evening. My name is David K. Evans. I live o
V)
V)
at 10832 High Ridge Road, Jacksonville^ Florida. I "*
represent myself and the Holly Oaks Community Club and
Civic Association. Before going any further, I'd like -1
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to ask one question. We were not advised of a ten-minuts1
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time limitation. Dr. Soldwedel and I have spent a great
many hours over the past two years in going through this
material, and I don't think it is humanly possible for
anyone to make a reasonable explanation and ask the qtiesti:
necessary for us to come up with any opinion tonight; anc,
it's just impossible to do it in the ten-minute time lima
May we have a ruling?
IMS. PHILLIPS:
Yes, sir, Mr. Evans, you may have a ruling. If youx:
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statements are in a written form, you may submit written
statements of any length, which will become part of the
Environmental Impact Statement's official record. Because
of the great number of people who have registered tonight,
eighteen people, in fact, we are going to have to initially
limit our presentations to ten minutes. If you would
like to speak again and for a second time, you can feel
free to do so. If you would like to take some additional
time now to cut down your presentation to the relevant
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points, I would be glad to defer your presentation to z
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the last one on the list. jjf
MR. EVANS
I choose to defer my entire presentation until the *f
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last one on the list. I do want the people to be heard. °>
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Thank you .
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MS. PHILLIPS:
Mr. Johansen.
MR. JOHANSEN
I'm Councilman Johansen of District I, which is the
Millcoe Road area we're talking about. Approximately two
years ago, I was a member of the Affairs Committee of thils
council; however, before the rezoning of that tract of
land for the sewer land, I did that on the basis of the
professional, expert statements that were given us in the
many, many hours of testimony. There would be no odor;
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there would be no spillage; there would be no noise; and
they had the Urban Affairs Committee completely convinced
Approximately a year later, we had a meeting with
the people from the EPA, and they just reversed the
statement. Now, there could be odors; there could be raw
spillage; there could be noise. I think that the Urban
Affairs Committee two years ago was just necked down the
pants, and I certainly object to having a sewer plant of
that type that we could have odors and we could have
spillage in any way, shape, and form. Thank you.
[Applause.]
MS. PHILLIPS:
Thank you, Mr. Johansen. Dr. Betty Soldwedel.
DR. SOLDWEDEL:
I do not choose to speak now. I defer to Mr. Evans^
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and I'll be last. "^
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MS. PHILLIPS:
Mr. R. H. Adams.
MR. ADAMS:
Ladies and gentlemen, thank you for the opportunity
of addressing all of you tonight. I'm not going to try
to recap all the names of those who are here. I will
render a copy to the court reporter and to you at the emi
of my presentation.
Ladies and gentlemen, my name is Robert Hall Adams.
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, My residence address is 10585 Lakeview Road, East-Holly
2 Oaks, Jacksonville, Florida.
2 I have carefully reviewed both the Environmental
Assessment Statement, dated September, 1974, and the
Environmental Impact Statement, dated December, 1976, anc.
received by special delivery four days ago.
These two documents are, of course, but the tip of
the iceberg. The engineering drafts, blueprints, cor-
respondence, charts, et cetera, would fill a small room
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10 indeed; and it all started, publicly, at least, with a z
very, very small four-line ad on November 5, 1973, which jjf
12 was the notice of public hearing in the Jacksonville Q
13 Times-Union. This, then, was the birth of Project
14 number C120541.
Since all the prenatal work had already been ac-
15 complished without the public's general knowledge, I tiling
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17 it is fair to consider this new arrival as a candid an-
13 nouncement of the project, born out of wedlock and certainl
19 without the benefit of clergy. At that point in time,
20 the impact of this proposed plant and its environmental
2i effects, specifically those pronounced in Section 102(2}(c)
22 of the National Environmental Policy, became public.
23 As the record will reveal, nearly everything regarding
24 this proposed plant has changed. Thank you, Mr. Johansenj.
05 Costs, number of plants to be phased out, mitigating
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conditions, evaluation criteria, et cetera. The distinct;
purpose for its being, that is wastewater improvement, to
which any reasonable person would agree, sounds like a
distant bugler playing taps.
Following my review of these documents, participation
at several meetings and hearings, I finally, on Sunday,
January 19, of this year, did what I should have done a
long time ago. I visited the site, walked most of its
boundaries, rented a small airplane, flew over the area
affected, and the following Monday, visited with Mr. Joe z
Hyatt, department director for the Jacksonville Depart- jjj
ment of Public Works, at his offices for a period of £
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over two hours. He was extremely helpful and furnished **
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me a large scale map of the proposed plant (indicating). £
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i elevation number 31, and the southwest corner of the
2 plant property, which incidentally is within talking dis-
q tance of several mobile homes, whose owners were equally
4 baffled as to the exact plant location.
5 Some of the ground and aerial photos I took depict
6 the borrow pit to the east of the site which many of my
j neighbors mistook to be preliminary construction of the
g site. While this is in effor, it, of course, does point
9 out that insufficient information and improper delineatidn
10 of the site caused a degree of panic. Unless those z
II affected can readily locate the actual plant site, most £
12 of the documentation furnished, which is voluminous,
13 becomes completely secondary.
14 t1 (2) Of concern to me, also, is the proposed design °
is location of the main entrance road to the plant. It is -1
10 in
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15 not shown on the plans; it is, however, shown on this
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17 over here (indicating). As drawn, it merges with Monument
13 Road at a most hazardous point, where slope and turn change
19 require prudence under current conditions. The addition
20 of heavy truck traffic at this point is not consistent
2i with sound road design. When I asked the reason for this
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22 layout, the answer was even more frightening. It is being
93 located where it is for the sole convenience of a large
24 land developer who prefers not to lose the valuable road
25 frontage.
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(3) Under current federal public law restrictions,
public laws — I'm sorry, I do not have the number — I
am advised that no project is eligible for funding if
actual construction has begun on that particular phase
without prior granting of the funds. Specifically, in
the case of the Millcoe plant, none of the proposed tran^-
mission lines are eligible at present for 75 percent
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granting because of lack of funds at the federal level.
I asked Mr. Hyatt where, then, these funds would come
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from. I was advised that in the interim between be- z
ginning of plant construction and its completion, that £
if federal funds were not available, local monies would %
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have to be used — another unknown quantity. *
(4) On page four of the EIS, I note the proposed
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acquisition cost of the plant at $63.00 per acre and the-i
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buffer zone at $63.22 per acre. The two decimal point J
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typographical error is moot. I'm not trying to render
anyone culpable for that. The actual costs as reported
are $6,300.00 per acre and $6,322.00 per acre, respective,J
I have no expertise in real estate values, but I
was knowledgeably advised that less desirable land to
the southwest and south are realistically valued at
$15,000.00 per acre plus and up. Quick mathematics need
not be computed here except that the bottom-line cost of
the buffer zone could be one million, five — I
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, beg your pardon — $1,154,292.00. I'll repeat that figu::e
2 $1,154,292.00 more than anticipated by the City government
o if, indeed, 125 acres are valued at more realistic values
. than those shown on page four. This variance in actual
28 P2-ant cost could shift the fiscal advantages of Millcoe
to another plant alternate.
If, on the other hand, the City will arbitrarily
through the process of condemnation by virtue of eminent
9 domain confiscate beautiful wooded lands at lower than
10
apogee and become further proof of preferential, blatantjf
12 inequities and irresponsive action on the part of our
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elected officials; and at least I, who voted for consoli-
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14 dation, will be asking himself, "Whose real fault is
15 The "book1*, if you will, on the Millcoe plant will then
real values, then this whole mess will have reached its z
16 -^become required reading by all political aspirants, in- -J
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17 cumbent officials, real estate brokers, and junior law
18 clerks.
19 |0 How many here tonight know that a large home, facing
20 a beautiful, stocked pond, is being constructed within
2i the proposed buffer zone — the house, a probably $95,OOC
22 value?
23 She. way things look now — I missed a paragraph,
24 excuse me. In summary, no public official, at any level
25 of government, should be permitted to cast a vote or
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profess an opinion on this matter until he has reviewed
both documents, visited the site, and listened to his
constituents.
The way things look now, if this plant is approved,
the groundbreaking ceremonies will coincide nearly to the
day, I'm advised, with the two hundredth anniversary of
this democracy. Although I fail to find that in any
document, I rather envision the affair as being held at
3 a.m. without press coverage or benediction, attended bj
only one council member whose name will be drawn by
secret ballot the day before, the junior VP from the
land developer to the south, the general contractor,
representatives from the consulting firms, a freshman
draftsman from Public Works, and the mail clerk from
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the regional SPA offices, who will swing a two-gallon
bottle of Nutri-Gro against base line marker number 31
2
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I just couldn't resist that after finding base line mark®;
number 31.
I hope common sense will prevail, and that we may
regain some confidence in those we have selected, all of j
you, to protect us from ourselves because, quite frankly,'
I don't think I can stand any more protection of my j
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environment. Thank you very much. j
[Applause.]
•!S. PHILLIPS:
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2 Mr. Frank Wilson.
3 MR. WILSON:
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Thank you, Mr. Adams. Our next speaker will be
My name is Frank Wilson. I reside at 7272 San Jose
Boulevard. I am here tonight speaking on behalf of the
Florida Engineering Society, the Jacksonville chapter,
of which I am vice-president, and there are approximately
240 members in the Jacksonville area.
As we will all controversial projects, we have
<* *
presented this project to a. sub-committee for study and z
for reporting back to the executive committee. Their w
report, passed on to the general membership, and the §
V)
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13 implementation was passed out to the members in general "*
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14 of the chapter, and at our last meeting, this resolution°
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15 was overwhelmingly approved. I wish to read this -i
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resolution now. J
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January 20, 1976 — Whereas, the Jacksonville Chapter,
Florida Engineering Society, is an organization of profes
sional engineers with a vital interest in community
activities; and whereas, the proposed Arlington Sewage
Treatment Plant of the City of Jacksonville is a major
engineering project affecting the environment, economy,
and quality of life in Jacksonville? and whereas, the
construction of this plant will phase out a significant
number of smaller plants and systems presently discharging
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waste to tributary streams in the Arlington area; and
whereas, the design of this facility has incorporated:
a buffer zone of 118 acres to be used as a passive re-
creation area, and provisions of noise and odor controls?
and whereas, detailed environmental assessments and irapad
studies of the proposed site and fourteen alternate systeD
and sites have determined the original site would cause
no significant and environmental damage; and whereas,
this site would save the citizens of Jacksonville ap-
proximately $4,000,000.00 and be an operative facility
year sooner than any other site. {2
H
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Now, therefore, it is resolved that the Jacksonville
Chapter of the Florida Engineering Society endorses the <
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proposed Environmental Impact Statement Draft as pre- §
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pared by the Environmental Protection Agency which
approved locating the Arlington Sewage Treatment Plant
at the Millcoe Road site with Quarantine Island outfall.
Thank you.
MS. PHILLIPS:
Thank you, Mr. Wilson. I would ask the audience to
please be quiet. Our next speaker will be Mr. Thomas
Brewer .
MR. BREWER;
My name is Thomas F. Brewer. I reside at 4807 Water
Oak Lane in Jacksonville. I represent the Jacksonville
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Area Chamber of Commerce, and in that capacity served on
. the Citizens' Advisory Committee to the EPA for the stud}
„ of the Arlington-East Wastewater Treatment Plant.
21 First of all, I would like to make a comment to the
engineers in that they approved the original site and
the original site was not, in fact, the site that the
Environmental Protection Agency has rendered its approval
On this committee to review the proposed site and
various alternatives, we had five people from City z
government, five people from the "unaffected area," and w
12 five interested citizens. That committee reviewed each
13 site, each alternative, both environmentally and cost- <
wise. We used a formula that may be questioned, but at o
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15 the end of the committee meeting, we decided that perhaps-i
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we should ask the environmental protection agency to J
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17 select a particular site rather than throw all of our
12 figures into a hat and let them review them.
19 The committee chose to recommend to the Environmentail
20 Protection Agency that they select Dunes site two.
21 28 Now' there's a question of dollars involved. We're
22 talking about ~ I heard a figure a moment ago of four or
23 five million dollars — we're talking about a four percent
24 differential between the selection of Dunes site two and
05 the Millcoe site. That's not a great deal of money.
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The Chamber of Commerce does not feel that we should
construct a commercial plant within a residential area.
[Applause.]
We also would like to point out that once the biased
members of the committee, meaning those people who repre-
sent the Holly Oaks area and those people who represent
the City of Jacksonville and that one person on the com-
mittee who represents the landholder at the Dunes site,
once those people are eliminated, the vote of the quote,
end-of-quote, "impartial citizens" on the committee was 2
three to one in favor of choosing the Dunes site as n
d
opposed to the Millcoe site. £
V
The Draft EIS mentions the fact that the committee *"
voted in the way it did, mentions the fact that there was;
no citizen on that committee from a residential area that
would be affected by the treatment plant in the Dunes
area. That's not true. There was a member of the commit1
from the Arlington area who lives just a few blocks from
Dunes site two. He voted in favor of Dunes site two as
opposed to the Millcoe site.
In summary, the City of Jacksonville, in my opinion,
has not been concerned with the feelings of the citizens
of the area in which the plant is to be built. The
Chamber of Commerce feels that citizens have the right to
choose their own environmental destiny, and we ask that
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3 MS. PHILLIPS:
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5 MS. PILLMORE:
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they be given that right.
[Applause.]
Our next speaker will be Pat Pillmore.
My name is Pat Pillmore. I live on 3826 Tara Hall
Drive. It's near Holly Oaks; it's not in Holly Oaks.
I'm not representing anyone but myself.
It is my opinion and the expressed opinion of others
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in this room that EPA has not followed through with this z
impact study in a completely impartial manner. The £
EPA's responsibility is to environmentally sound, long- Q
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range planning, not only to flora/ fauna, endangered
. .. - - - z
species, et cetera, but also to mankind. The EPA is a 8
3
relatively: new agency and should be concerned with proving
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it can provide environmental protection. The SPA's strengt
and continued success lies in its integrity, not in its
ability to appease or compromise local politics.
Instead of choosing the most environmentally sound
area, by their own admission, a site has been chosen that
the Department of Natural Resources and the Corps of
Engineers has determined to be unacceptable because of itis
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influence with Mill Cove. Instead of concentrating on
more environmentally favorable site, they have tried to
engineer themselves around what was environmentally
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where they told me it was. It was in the O. S. Geologic^
Study done for the area planning board, and there were
no waterflow charts or tidal information in this study.
There was only topographical information which doesn't
make any difference in this particular study. This is
just one example of convenient oversight by the SPA Impacjst
Study, an oversight that could affect property owners on
the cove, a three-hundred member family-branch YMCA,
people who use the cove for recreation, and could perman--
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ently affect the environmental life of the cove ^
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outflow pipe into the channel and the tidal effects on o
Mill Cove.
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Also, in a telephone conversation with the Corps o
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pipe, quote, "We~suggest that alternates four through
ten would have a more likelihood of obtaining a permit
without objection since those plans involve a minimum
amount of underwater distrubance." Alternates four
through ten do not include the Mill Cove site, obviously
Without a permit to construct the outflow pipe, there
cannot be construction done on the regional plant. What
guarantee is there at this point that there will be con-
struction done on the proposed site considering the fact
25 that there has been no request made for the permit,
which is not outlined, and the Corps does not at this
point recognize the merits of the Mill Cove site?
It seems the conclusion of this Impact Statement
has been determined by cost rather than environmental
26 factors. If the Environmental Protection Agency is so
concerned about money, why can't low-interest loans be
given to the small sewage plant owners to facilitate
upgrading plants rather than giving the money to the Cit
to build a regional plant? It's a known fact that
private enterprise is more efficient than government
bureaucracy.
[Applause.]
The most obvious injustice is to the residents in
the Holly Oaks area. The ability of private citizens to
maintain or even control the quality of life in their
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5 MS. PHILLIPS:
28
own neighborhood does not exist. This situation proves
that government exists for the few/ but the question is:
which few? Thank you.
[Applause.]
Our next speaker will be Al Hammack.
MB. HAMMACK:
I'm Al Hammack. I live at 422 Osbrick Point. I'm
chairman of the Jacksonville Environmental Protection
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Board, but I'm speaking only for myself tonight. This z
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matter has not been brought before our full board. Jjj
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There are only three points that I'd like to make. Q
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money. Unless we continue to raise our water and sewage^
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rates in Jacksonville, for the sake of the environment
as well as the taxpayer/ the site you selected is the
best choice.
5 Number two/ all reasonable noise and odor abatement
systems have been designed into this plant. It provides
good protection for its neighbors.
Number three/ we need to get on with the job of
cleaning up our streams in Jacksonville. Any other site
selection will cause unnecessary delays.
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I believe you've done a thorough job, and1 I support
your decision. Thank you.
MS. PHILLIPS:
Helen O'Quinn.
MS. O'QUINN:
Hi, I'm Helen O'Quinn. I live at 10605 Lakeview,
Northeast. I recently read in the January 16 Washington
Post that the EPA in Washington, D. C. had asked that the
contractors of the regional sewage treatment plant known
as Blue Plane to modify the design from secondary treat- \
raent to alternative methods because of the high energy
2 use of the incineration process, and yet you are recom- <
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mending an incineration process for Jacksonville. '
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I know you are aware of the dangers of chlorination (
in the process because it was brought up at a citizens'
committee meeting at which I attended, and yet you are
proposing this chlorination process for this plant.
The printed media and the mayor have done an excel-
lent job in trying to convince the citizens of consolidat
Jacksonville that a small group of selfish Holly Oak
residents are continually costing them more money by de-
laying the building of this plant; however, if the truth
were told, the citizens of Jacksonville would realize tha
it is the alert, aware, and informed Holly Oaks' resident
who are trying to save them untold millions of dollars.
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, The people of Jacksonville need to know what is really
2 being imposed upon them.
3 According to the City's own economic feasibility
4 study, this plant will cost not just fifty million dollars
to build, but at least eleven million dollars every year
for twenty years just to get it paid for, and then, five
million dollars per year for maintenance operation, and
heaven knows what repair bills after twenty years.
For you to recommend to impose on the people of
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10 Jacksonville an annual cost of eleven million dollars z
for a plant — only one of a proposed five, by the way —{Jj
12 that is outdated before it is even built, since all of
13 the latest plants are against large, regional plants
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14 . that employ treatment processes that may be dangerous °,
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15 and that uses the most costly form of sludge treatment,
16 incineration, which contributes only to wasteful use of •]
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17 energy, leads me to believe that in responding to the
18 pressures on you to select this site, you have abdicated
19 your agency's basic responsibility to protect the quality
20 of the human environment and have, in fact, exploited
2i the residents of Holly Oaks in an effort to appease the
22 - local administration.
23 I submit that this proposed plant is an imposition
94 on the citizens of Jacksonville and that the entire project
95 4 should be withdrawn. The residents of Holly Oak don't
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MS.
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want you, and the citizens of Jacksonville can't afford
you.
[Applause . ]
PHILLIPS:
Thank you, Ms. O'Quinn. Our next speaker is
Mr. James Buck.
MR. BUCK:
Madame Chairman, ray name is James O. Buck. I reside:
at 1922 Holly Oaks Ravine Drive. I'm the president of
Buck and Buck, Incorporated. That's the developer of -5
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Holly Oaks Forest. £
I received also my big volume of mail last Thursday^
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and I have looked at it somewhat since then, and I no- *
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tice that the report says that there are five companies
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, Now, I — so this is wrong in the report. I have
2 no other lands over on that part of the property at all,
and after all, this is a collection point for sewage
plants, and we have the Jacksonville Suburban Facilities
had the franchise for that area, and has a plant over at
the foot of St. Johns Bluff Road and Fort Caroline that
has a million gallon capacity now. So we are in many
respects taken care of, and I just wanted this to be
9 right on the record.
•
10 I also wanted to say that of the sites that are z
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in the book, the number of sites that have been investi-£
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12 gated by the committee and considered, there's one site £
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13 that was never really considered in the past because it *
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14 - was said that the smokestack was such that it would have®
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15 some bearing on the use of — I mean, of the location of-i
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16 the plant there, and that was on the south end of Craig -^
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17 Airport, which is your item number twelve* your site
18 number twelve. Now, I notice in your report, your envircjn
19 mental people place that as number one environmentally as
20 the place to put the.plant, but I want to say to you that
2i the lands bordering Craig Field on the south are presently
22 either commercial now or will be commercial, and that you
23 will not have a problem from a residential standpoint,
24 S an<^ * want to urge that this committee go back and review
25 this thing/ and select site number twelve.
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[Applause.]
MS. PHILLIPS:
The next speaker will be Robert McGauiey.
MR. MCGAULEY:
My name is Robert McGauiey. I'm the vice-president
of the Alderman Park Civic Association. I live at
7711 Valley View Drive.
It had been my intention to endorse the remarks of
Mr. Dave Evans, who was supposed to be the first speaker,
but inasmuch as he is now going to be toward the end, 2
I'll have to endorse his remarks in advance. {j
We appreciate the fact that a regional sewage
treatment plant is planned to relieve the difficult
sewage problems in the area east of the St. Johns River.
We compliment the parties involved in the design and
the funding of this plant; however, we find it difficult-
to understand how or why a facility of this nature, with
this potential for malodorous air pollution, and I'm
reminded of Mr. Howard's remarks earlier that all is beii
5 done to alleviate this problem, but in my opinion the
potential still lies there, that a plant with this poten-
tial must be located so close to a residential area where
home values run as high as $75,000.00 to $100,000.00.
Actually, I should say, for that matter, where it ahouldz
be located near any residential area regardless of the
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1 values .
2 After reviewing maps of the proposed installation,
3 it appears that several of the alternate sites would be
equally as effective. Two that come to mind: the
Quarantine Island and the site east of Craig Field.
Granted that both of these sites may be more expensive to
build, but it seems to us that the one thing that's being
3 overlooked in this present formula for locating the plant
9 is the voice of the people. I will not believe that it
•
10 is the intent of EPA or any other agency, whether it be z
11 federal, state, or local, to ignore the mandate of the
12 people affected in locating projects of this type.
13 I am reminded of what happened in the City of Boston*
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14 some 22 years ago. They had a tremendous sewage problem^
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15 right in Boston, the towns right in Boston Harbor. To -J
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16 solve that problem, they took an island out in the har- -1
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17 bor — it couldn't have been more than half a mile or a
18 mile outside of Boston proper — and they built a huge
sewage treatment plant there. They collected sewage fron
20 shore and- pumped it from the mainland and pumped it out
2i onto the island where it was treated and then shipped out
22 by outfall out into the harbor. I would think that
23 7 Quarantine Island would deserve another look on this
24 basis, that that be the location of the site.
25 Therefore, speaking for the Alderman Park Civic
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Association, although we're not directly involved, I fee.
we must give vocal and moral support to our residential
neighbors. We heartily endorse the petition of the
people of Holly Oaks community, and recommend to you tha:
the facility not be located at the intersection of Millco
Road and Fort Caroline Road.
[Applause.]
MS. PHILLIPS:
Thank you. Our next speaker will be Mr. George
Spohrer. Did I.pronounce that correctly?
MR. SPOHRSR:
Madame Chairman, my name is George Spohrer. I
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all of the cost data from their consulting engineers. As
28 nearly as I can ascertain from the Draft study, they've
pretty well taken the City's figures right down the line,
and I'm wondering if the integrity of your programs can
be maintained by accepting those figures; particularly
since I understand that the decision to approve the
Millcoe Road site is based largely on cost/ and I say thit
because I believe Mr. Hammock earlier said the recommended
site, and as I understand the study, it's not the recom-
mended site. I believe the wording is that it's an
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acceptable alternative; however, environmentally, I be- ui
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lieve it was second or fifth, if I understand. g
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I also appreciate the remarks of this man from the **
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between the City of Jacksonville and any other interests
in the City of Jacksonville regarding this plan. I woul<
like to have the opportunity of reviewing that correspon-
dence if you decide that this would be appropriate.
Mr. Howard made a statement that was quoted in the
Times-Union that I'm not attesting to the accuracy of it,
but it was a quote, that the concern of the Holly Oaks
residents was based on fear, and that fear was that the
plant would emit an odor, and that it would be noisy, ami
so forth, whereas he states that the Environmental
Protection Agency's staff recommendation is based on thet-
jj
knowledge that it will not be. That's an interesting c
assurance, particularly since my understanding of the «
3
consultants for the EPA's review of the plants in Canton g
Ohio, and X believe Fort Lauderdale didn't really ~
u,
indicate this. In those plants, there are problems. I ""
understand this is going to be a model plant* There wil]
be none other like it, and this one will not have any of
these problems, but I've yet to find one that, you know,
operates like that. I'd like to know if there is one
somewhere in the world.
The other thing I would like to do for your record,
Madame Chairman, is ask if I might have a show of hands
of those in the audience who are from the so called affec
area? Let's call it the Holly Oaks community. Could we
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have a show of hands?
[Show of hands.]
This is the group that the City refers to as a
but vocal, minority.
MS. PHILLIPS:
Sir, I'm going to ask you for the record — could
we have a ~ we will have a count from those who registered
at the door of those people who are from the Holly Oaks
community because I think this is important for the
*
record. z
MR» SPOHSER: £
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Yes, I think so. I'm particularly interested in g
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the fact that it's important to determine — this is *
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two years, you know, down on the road on this thing. °,
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Many of these people have been to at least fifteen ->
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different hearings, which is interesting to see their -1
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tenacity and how strongly they are opposed, in fact, to
the Holly Oaks site.
[Applause.]
I'm not going to review all of this with you. I'm
particularly interested in hearing Dr. Soldwedel's
remarks and Mr. Evans' . YOU mentioned in your opening
remarks about the wishes of the people on it. This is
part of your charter and your charge as the Environmental
Protection Agency. We're particularly concerned about
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that, also, I think by virtue of the turnout at this
hearing and at all of the other hearings by virtue of
recommendations of the City Advisory Panel, which was
impaneled by the EPA. I think it's clear that the wishe^
of the people are that you not permit the City of
Jacksonville to construct a plant of this magnitude in a
residential community. Thank you.
[Applause.]
MS. PHILLIPS:
Our next speaker is Mr. Victor poggie. 2
V
MR. POGGIE: £
4
I pass at this time. £
MS. PHILLIPS:
V
Our next: speaker is Mr. Del Revels. 5
3
15 MR. REVELS:
u
For the record, I am Del Revels. I live at 4411
Charter Point Boulevard in Jacksonville. I am president
of the Greater Arlington Civic Council, comprised of all
known organized civic groups in Arlington.
I would like to approach — first, I would like to
say that I was privileged to have the opportunity to sit
on the* committee that studied all of the problems in re-
lation to the Arlington-East Sewage Treatment Plant, and
as Bob talked with me before I consented to serve, I
said, "Bob, do you think there's any idea of the citizens
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, here, those who do serve/ will have a chance to give
2 some meaningful input?1* and upon being reassured that we
would be, I agreed to accept, and it was quite an
experience.
I would like to, tonight as I speak to you from the
Greater Arlington City Council, address it basically in
two areas: one is odor, another is land use; and quote
8 to you very briefly from some of your documents. The
9 that I will read, page 35, of the Sewage Report for EPA
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10 203, dated October 20 of '75, and it said — it says z
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5 that when the incinerator is in operation, speaking of jjf
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12 the sewage treatment plant, this is an excellent means g
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10 of odor control. However, normal operating procedures <
10 *
14 will inevitably result in the incinerator being out of o
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15 operation while the rest of the sludge-handling equip- -i
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15 ment is still in use. During these periods, no odor J
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17 control would be utilized.
18 Continuing on to page 41 of that same document, it
19 says that an estimated 90 percent of the potential odor
20 emissions should be removed by these treatment techniques
2i *) ^at'3 great for the 90 percent, but what about the re-
22 maining 10 percent? It goes on to say that a very low,
93 yet detectable odor will probably be noticeable on the
24 plant site for short periods of time under certain atmos1
25 pheric and plant operating conditions. This type of odor
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episode would be generally due to operator error, equip-
ment failure, or oversight and should be correctable ono
detected. It is not possible to completely eliminate
this type of minor odor episodes; however, going on to
page 42 of the same report, it says that a well-operated
and maintained sewage treatment plant will generate a
minimum amount of odors at a low frequency of occurrence
*> However, the proximity to nearby residents, the inherent
variability, and uncontrolled error based entirely on
human operator control, and the potential for odor
episodes due to wastewater effluent searchlightings
and vast experience of three similar sewage treatment
plants indicate that this controlled strategy will not
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substantially — I repeat ~ will not substantially <•
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reduce potential odor emissions at the source, and
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consequently, will not substantially mitigate the poten-
tial impact of the Arlington-East Regional Sewage Treatm*
Plant.
Going back to 36, it reviews what you all did as yoi
looked at a controlled area where they do have one of
these plants in Canton, Ohio, and although that one was
not perfect and this one is going to be perfect, this is
what your record says on page 36. Of this group that
was questioned, it said 18.4 percent seriously considers*
moving because of odor pollution from the sewage treatme
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plant, and 36.8 percent felt that the value of their
homes had been reduced. If you were to take that and
, apply that to Holly Oaks, it would be quite an impact.
Some say, you know, it's one plant. Well, according to
your report on page 37, it says — it further indicates
, that people will identify the plant as the major source
o
_ of odor up to a distance of 4,750 feet.
o Leaving odor and going on to land use, on page 87 oi'
that same report, you said the comparability of a sewage
treatment plant located on each of the alternate sites z
with the surrounding land use lists must also be u
12 23 considered. As can be seen on the tables that you had g
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wasteater treatment as a constraint to development and
allow it to proceed as it otherwise would. The major
landholders in the service area are as follows: SWD,
Intriknik [sicj, Buck and Buck, the Brent Hodges family,
the Coppage family; and it went on, summing up by saying
:*•
these landowners will realize significant economic
benefit. Well, one of those landowners has told you what
he thinks about your statement* Maybe if you were to
consult the others, they might feel the same way.
[Applause.]
In summary, I would just like to say that the
Greater Arlington Civic Council opposes placing this
regional plant of 46 acres with a 79-foot high stag in *
or near any residential neighborhood. Thank you.
[Applause.}
MS. PHILLIPS:
Thank you. Our next speaker will be Mr. Don Brewer
MR. BREWER:
Thank you. I'm Don Brewer, city councilman for
District II, which comprises most of Arlington and abuts
the District I testimony that Mr. Johansen just spoke fa:
earlier this evening. I won't try to be political becausi
I can't top what I've heard. People who represent the
people directly and live out there have spoken fairly
clearly, I think, to this point, and I think that what I
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1 might try to do is bring some common sense to what's
2 happening here.
3 I think we're missing two problems. First of all,
4 the problem of developing regional sewage systems, I thi^ik
5 that's something that we've needed to do in Jacksonville
probably in this country, for some time. We're trying to
meet that problem head-on, however, with the placement o :
8 a sewage treatment plant of a regional nature in a resi-
9 dential neighborhood, and I don't think that's compatible,
10 and I think that history shows, and the current history z
shows, that it just doesn't work.
12 We have an experimental plant. They tell you it's
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13 new, and it's never been done. It's different and <
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14 better. That means it's experimental to me and I think °,
3
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15 to most of the community, and I think to our council. -1
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16 Now, Mr. Johansen, by the way, who spoke for this -\
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17 plan at the time the council passed it is now against it
13 and I think you'll find some similar changes elsewhere in
19 the City Council today.
20 The end doesn't justify the means. I'm for reason-
2i able sewage treatment, too, just as the mayor is, just a;s
22 the Water Sewer Department is. I'm for it. I've supported
23 it in ray five years on the City Council, but I won't
24 support it to the extreme that it does degradation to a
25 residential community, and that's not what the environment
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is all about. That's not what sewage treatment is all
about, particularly when there's a way in this area to
get the result we want without creating environmental
damage, and the human — there's a lot of effort spent iiji
this environmental report to talk about the amphibians,
the aammals, the reptiles, and the plants, but the singl^
greatest element of the environment, as far as I'm con-
cerned, these people behind of me and in front of you
concerned, are human beings; and it's one thing to tell
these people — now, as you see, they're very articulate^
as a group. You don't often see this kind of group at u
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a public hearing. It's one thing to tell them that a c
V
sewage treatment plant has to go in their neighborhood, «
but it's something else to tell them it's not going to c
3
stink. _
u
u
[Applause.] • -
You know, that's — they're just not going to be-
lieve that, and if you look at your maps when this thing
first came about, I wondered why we were going to put a
plant so far east and yet not serve the beaches. If you
look at your map, this plant location is fairly close to
the Jacksonville beaches area, and you see no line, no
transmission line, out there or you see transmission lin<
coming there back to this plant, all of those areas to t!
east, all of it to the east. The plant should be built
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as far to the east as we can build it to accommodate
twenty years down the road. It's not being built for
1976 only, but 1977. This plank is" going to last a hell
of a long time. We hope forty years. We can't afford i£
2 2 We ought to build it to accept the growth. Twenty years
ago there was nothing at Arlington. There may have been
3,000 people east of the St. Johns area, in what we call
the St. Johns area. Now, in 1950 — today, there are
some 130,000 people in that general area, and the beaches
•
IQ area, the area east of where this plant is located is z
still basically highly unpopulated, desolate land that £
12 will be developed. It will be developed during the £
en
13 lifetime of this plant, and it doesn't make any sense to*
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14 me to go through this same question, through these °
15 same problems, ten years down the road because we didn't-J
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15 have the foresight to see where the growth was coming J
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17 in the year 2000 when it was so obvious to all of us.
18 So, let me say in our —• I think in our effort, in
19 our sincere effort to meet current environmental problemsi
20 to phase out a number of inefficient, polluting water
sewage treatment plants. We've made a major mistake in
22 seeing one part of the problem, the need to go regional,
23 and being totally blind to the humanistic problems, to
24 the fact that the people just ain1t ready to have sewage
25 treatment plants in their neighborhood areas. I've never
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seen one successful. We've done it in Jacksonville. We
5 have an Anheuser Busch plant out here. We have a plant
that* s serving Anheuser Busch that was supposed to be
the most wonderful thing going, create tremendous probl
with people. We have the Buckner Street plant now, whi
is under construction now, the latest thing available.
We keep upgrading that plant, still we have recurring
problems with it.
Sewage treatment plants aren't to the extent, now
where they are trouble-free, and the ones we have now 2
are currently in industrial areas. Put in a middle of jj
a residential area, and we'll never hear the end of it, £
and I would hope that it's not going to be my fault.
c
I've supported the concept involved in this site locatiof
3
in this Impact Statement pretty much because that support
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the concept, and I think bends a little to support this -
site as an acceptable site, and I would hope that in the
long run, in the end, we'll be wise enough not to try t
make the end justify a fairly unpopular and impractical
and irrational means. Thank you.
[Applause.]
MS. PHILLIPS:
Thank you, Mr.. Brewer. Our next speaker will be
Mrs. Frances Lockerman.
MRS. LOCKERMAN:
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I'd like to give some of my time to Mrs. Soldwedel
or some of the other people who haven't spoken.
MS. PHILLIPS:
Thank you — yes, ma'am. Our next speaker will be
Reese Cruce.
MR. CRUCEs
I'm Reese Cruce. I live at 2215 Holly Oaks Drive.
I represent myself and my family, and practically every-
thing I touch on I was thinking about saying has been
said by those who are much more at ease with words than z
I am. I do want to thank them and particularly those
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MRS,
MS.
MR.
MS.
MS.
MS.
MR.
MS.
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BLACK:
Madame Chairman, this is just a humorous remark tha
I'd like to ask. Would it be possible to construct this
plant in Bay Meadows under you-know-whose doorstep?
[Applause.3
PHILLIPS:
Our next speaker will be Mr. Robert Werdar.
HERDER:
I wish to give my allotted time to Dr. Soldwedel
when she speaks.
PHILLIPS:
Our next speaker will be Alice Webb.
WEBB:
I'd like to relinquish my time to Dr. Soldwedalr
please.
PHILLIPS:
Thank you. That is the end of the official regis
tion list. We will return to Mr. David Evans, who has
ten minutes of his time, in addition to which he has 1
minutes of Mrs. Soldwedel's time. Mr. Evans, you haw
thirty minutes time given to you by the citizens.
EVANS;
Madame Chairman, I accede to Dr. Soldwedel first
and I will follow her.
PHILLIPS:
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Thank you.
DR. SOLDWEDEL:
My name is Ethel Merman, and I'm here for Act Two.
I'm Betty Soldwedel. I live at 1716 Ormond Road/ and I
represent myself and some of my neighbors. I will attempt
to be as brief as possible. I have several major points
to make, and I wanted to develop these rather fully/ so
I will not dwell at this time on other enormously inade-
quate procedures and statements in this Environmental
*
Impact study. Each should be developed, however, and z
vT
for that reason I enter them into the record now for £
your response in the final document. g
in
5 These are as follows: (1) Your agent, Mr. Howard, <
«B
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told me before this Environmental Impact study was °,
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begun that he would find the best sewage treatment plant-"
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in the country and show us how people there felt about -1
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odor and noise. Well, apparently the best plant he could
come up with was a twenty-year-old model in Canton, Ohio
where people did indicate odor and noise problems.
5 (2) What treatment was given to the data from Can toil,
Ohio/ by the EPA? A generalized writeoff that some per-
centage of people will always smell odors or think they
hear noises, whether they do or not.
Q (3) We are now told not to worry about visual
aesthetics because your people launched a balloon from
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the Mill Cove site and couldn't see it from our neighbor-
hood. A balloon — there is very little resemblance to
a plant of the magnitude you intend to build, and I wish
our Jacksonville residents and the City Council would go
down to see the new plant on Buckner Street to see exact;,
what this is all about.
(4) You formed a citizens' committee, which eventual
voted nine to four to move — depending on whether you
count the absentees or not -- to move the plant away fron
Mill Cove, and then, in this Environmental Impact study, \
make the shockingly absurd statement that the committee j;
is really not representative because there were no raembe^
from the Dunes or any other site. What kind of logic is*
this? Do you set the committee up so that any recommen-j
dation would be nullified unless it supported the Millcoc
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Road location?
5 (5) You have the nerve to state in this Environment*
Impact study that the citizens' vote to move was based 01
fear, principally of odor and noise, and that your concli
is based on knowledge. You never once acknowledged that
what the citizens may have been voting on was lack of
confidence and the unconvincing nature of the materials
which your people had developed and presented to us. I
think, for example, of the discussion of modern technolo*
in those committee meetings, which was illustrated among
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1 more adequate slides with the picture of one lone worker
2 standing with a bucket of Odor-kill over a chlorine trap
3 (6) We were asked, in committee, to review the
4 evaluative criteria on your list and to bring the suggestion
5 at the second meeting for others. When at that second
meeting attention was called to the fact that the human
element had been ignored in the criteria, we were told I
the EPA, and you will find this to be true if you review
9 the tape of that meeting, that the human element was im-
10 plicit in all criteria. We were also coached that it z
would be necessary to make trade-offs in our evaluation jjf
12 of science. Yet when we evaluated the sites in relation^
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13 to criteria and then assumed that all other factors *
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14 being equal — the desirability of water quality, for °
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15 example —- that the ratings should be — the ratings of -»
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the sites should then be based on proximity of the plant-1
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17 site to people, which is what we did. Mr. Howard shamed
18 us that we had not taken our task seriously, never once
19 asking anyone for our rationale in those evaluations.
20 (7) And where in your study do you give any specifi<:
2i attention to people affected? Nowhere, except to speculate
22 about real estate depressions in the event of panic
23 selling. You are required by the National Environmental
24 Policy Act to use methods which will insure that un-
25 quantified environmental amenities are given appropriate
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consideration. Yet nowhere in this study do you address
the desirability of one site over another in terms of
impact on people who are living there/ except you referezji
population tables/ and to persist in insisting that the
plant won't smell. We. note with interest/ parenthetical:.
that when you talk about smell/ you are always careful to
repeat that that does depend on maximum efficiency of
operation. When you talk about people/ you insist there
will be some noise/ but will only affect those who are
sensitive to noise/ and nowhere do you give serious dis-j
cussion to land use/ which will inevitably have a j;
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deteriorating effect on existing residential communities^
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, u
2 3 Tlie only thing compatible with the huge regional sewage *
treatment plant is heavy industry and warehouses. You <
know it, and we know it/ and we think you have chosen
to minimize this factor in this Environmental Impact
study.
[Applause.]
Let me comment just briefly on your correspondence.
20 °° vou mean to ceally suggest to us in this study that i
a year and a half you have corresponded with only four
interested agencies and even then/ only on their prelimi
assessments? Have you had no contact with a court
authority, for example, which would be involved in any
evaluation of at least six of the twelve sites? If you
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have, where is that correspondence, and if you have not
made contact, can you make us believe that you seriously
"J4 evaluated the alternate sites? We would like to see all
of your related correspondence.
Now, let's take a look at your conclusion that site
1Q is a reasonable alternative. I find it interesting
but not surprising that after a year of study, you came £
such a weak conclusion, a reasonable alternative. It is
not the best site, you say by your own evaluation. You
say that site 12 on Craig Field is the best site z
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environmentally. Well, we'll buy that. We are not be- w
12 holden to the Dunes site, unlike City officials who g
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appear to have a death grip on the Millcoe Road propertyf
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required to support site 12. Nowhere in this document
I do we find evidence that you even asked the Corps of
Engineers or the State of Florida, Department of Natural
Resources, or the Department of Interior to even specula:
on the adequacy of site 12. From reading their correspon
dence, it is apparent that they were not even asked to
comment on site 12, and why weren't they? This is your
best site environmentally. We would like answers to
those questions.
Let us look further at your treatment of site 12. 3
" - ' " U
The only thing in the world you hang your hat on is a t
statement that site 12 will cost more than the Millcoe \
Road location. We are not buying that. The cost figure!
28 ^at you present in this document are the identical cost<
figures supplied by the City's own paid consultants. It-
i
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is obvious that the City seems to have a total and un- •
compromising stranglehold on that Mill Cove real estate.
So, what if the City's consultants say that a plant at
site 12 would cost $3,000,000.00 more to build? We don*
know that to be true because neither are there cost
figures in your study to document that fact in detail no:
do we have any evidence that the Environmental Protectio
Agency made a serious attempt to do a detailed and inde-
pendent cost analysis at the City's consultants' figures
If Winn-Dixie were trying to sell me a ten-pound bag of
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potatoes, I wouldn't rely solely on Winn-Dixie to tell
how much that ten-pound bag of potatoes was going to
at Publix.
[Applause.3
We do not suggest that the figures are in error be-
0
, cause we do not have the technical expertise to make suclji
6
an analysis nor do we impugn the veracity of these
0 consultants; but we do find it inconceivable to believe
o
that any federal agency would spend one year studying
•
10 flora, the fauna, the swamps, and terrestrial vegetationz
«
only to base its decision on presumed cost differentials}^
between science and then to know that those cost dif- g
in
ferentials supplied by the City's paid consultants **
•to i.ej.enu-La,j.» au^i^jjL^evi wjf uiic ^j. ujf .a £/«.*. u WWJUA uo. M*** \-~*
Z
T , reappear, dollar for dollar, in what is purported to be °
14 &
an EPA study, with no indication that those cost figures-J
UJ
16 28 have been rigorously audited by qualified cost analysts.-J
Let me give you just one example of the crying need
lg for an audit. Let's take site 1Q and IB and 2Q and 2B.
The difference between the plant cost between 1Q and IB
is $2,659,778.00. The difference between the plant cost
for 2Q and 2B is $2,659,848.00, virtually the same,
virtually no difference. If you subtract the differences!
of site 1 and site 2, that's a difference of $70.00. Now,
if you look at the supporting narrative about sites 1Q
and IB and 2Q and 2B, you find that the differences in
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number of feet of pipe required ~ site 2 requires 5/000
more feet of pipe than site 1. Page 186 to 138, 5,000
more feet of pipe/ the difference in cost is $70.00. Do
you really believe that you are going to get nearly one
mile of pipe for $70.00?
[Applause.]
If so/ you had better snatch up that Dunes site/
because that is some kind of bargain. We think/ rather/
it is some kind of error. We think that you are obliged
28 to peirfQrm. a thorough cost analysis on all sites. •
While X am on cost/ let me also note, something t
«
about the cost differences between Millcoe Road and the '
Dunes site. By the City's consultants own figures, '
<
there is only a difference of $9/400.00 to the taxpayers]
at the City of Jacksonville between Mill Cove and the !
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Dunes location — $9/400.00. Furthermore/ the figures •
supplied by the City's consultants show that the annual
operating expense for this plant is cheaper at the Dunes
location by some $12,530.00 a year. This is over a
quarter of a million dollars for the life of this plant,
and those annual operating expenses will have to be born
specifically by the taxpayers of the City of Jacksonvill
No one will ever convince me that if the people of
Jacksonville had the true costs about these costs/ that
there is any reasonable — the true facts about these
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l cost's that there is any reasonable taxpayer who would
2 say they preferred the Millcoe Road location to the Dunes
3 location because of this $9,400.00 cheaper to build,
4 especially when that initial difference is going to be
5 returned in less than one year by savings to the taxpayers
5 of Jacksonville in annual operating costs to which the
7 federal government contributes nothing. As for the dif-
3 ference in whether you are going to contribute federally
9 and that is only to the construction of the plant itself
*
10 I'll leave that to you to determine, but as a contribute!
«/T
11 to that vast pot of federal tax dollars, I surely think jjf
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12 that a careful federal audit is essential. g
!3- 25 Now, let me conclude with a scenario. 1 have <
z
14 wondered for some time why the City has not applied for °
3
<
15 a Department of Army permit to cross Mill Cove. -»
til
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16 Particularly since it is obvious from the letters in -j
J
17 this book that you are going to have trouble getting
18 such a permit. It has finally dawned on me what you may
19 be doing, and I think that this may come as a shock to
20 the City Council, the Urban Affairs Committee, the peopljs
21 east on Fort Caroline Road, the people in the harbor,
22 and the people in Beacon Hills. This is not a hearing
23 only on site 1Q, crossing Mill Cove to Quarantine Island
24 This is a hearing tantamount to endorsing both 1Q and IB
25 alternatives. This is a hearing to grant approval to the
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City to draw up plans and specifications that lock us
into a site location. In other words, if this grant is
made, the location becomes fixed.
This leads me to my scenario, and I suggest it
merely as a hypothesis. I suggest that perhaps you now
know you are going to have trouble getting a permit to
cross Mill Cove and that possibly, that is why Mr. Howard
casually asked us to rate the B alternatives when the
advisory committee met, never once giving us detailed
specifications. The City people undoubtedly think that z
there is going to be trouble getting site 1Q approved
because if you look at the way they voted, page 376, youg
so
en
tn
will see that they did not vote for the plan that they *
2
have been advocating around here for two or three years,°
s
<
the 1Q methodology. They voted first for IB. By that J
u
u
very vote, they admit that the plan they sold the Urban -^
Affairs Committee and the City Council was not such a
red-hot idea after all.
Now, what is plan IB? It is a plan to run thousand
of feet of pipe up Fort Caroline Road, past the harbor,
out Pulton Road, through Beacon Hills, to eventually
dump in the St. Johns River at a point east of Blount
Island. You people have very carefully rated this metho<
second-best environmentally.
What I see happening down the road is this. You wi
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have the 1Q method denied by those related agencies that
are involved in the decision, but in the meantime, by the
fact of this grant, you will have approved the location,
so you will come back perhaps, and say, "Well, method IB
is a reasonable fall-back position,1* and so, we are not.
really talking about the cheapest plant here tonight.
We may be talking about a plant scheme that is very likely
to cost something on the order of $37,000,000.00. I see
this as a piecemeal attempt to push through a project to
get this site locked up first, and no matter what
happens with the Corps of Engineers and other agencies
later on, you step in with you fall-back strategy to
construct twenty thousand, twenty-five thousand, or
u
z
o
o
V)
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plant should really be located if you are not allowed to
cross Mill Cove, and with that we come right back to you}:
best site, site 12, which does not propose to cross Mill
Cove in the first place, and which is virtually the same
cost as 13, and less costly than 23 to begin with. Nor
does it propose to rip up the streets that people use an
impose on them the debilitating consequences of construe
We would like to see the 3 alternatives removed from the
study on the grounds that there is no detailed documental-
tion in your study to support a conclusion that they
are satisfactory environmental alternatives, and that
these 3 alternatives were never considered by the Urban £
V
u
Affairs Committee and the City Council when they voted *
2
on this project. Nor have the people on Port Caroline g
Road, the harbor, or Beacon Hills been adequately ac-
quainted with these 3 alternatives. In other words,
the City proposed originally site 1Q, and that is what
the City Council bought, so let the City administration
live with it, and if 1Q turns out to be not such a good
idea, as far as we are concerned, it is back to the
drawing boards r unless you are willing to recommend site
12 or one of the original site alternatives.
Although you may not be required to do so by
bureaucratic procedures, we think it would be prudent, ti
say the least, to obtain a specific determination of the
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appropriateness of your plan to cross Mill Cove before
you spend one dime on planning.
Those are my comments on your study, and yet, if
you persist in using only cost figures and possibly
cunning maneuvering to make a major determination that
affects our lives directly, I can only pity us all. Wha^
is this city, after all? It is people more than it is
politicians. It is our homes more than it is sewer plants.
It is a binding sense of community and not political
*
puffery. We may well ask ourselves and you, "What good z
is your pseudo-cost effectiveness if in the process you £
ignore the will, and you break the spirit, of the
people?"
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Facility. We have, in fact, participated in committees
and discussions and learned a great deal about such
facilities. In fact, at times we and even I tended to
agree that this was a good plan and would not have an
adverse effect upon our community, only to investigate
and read further that what was presented to us was incor^r
or distorted.
To clarify some of these points, we have prepared
some questions, many of which are still unresolved.
Was it not the responsibility of the citizens 2
committee appointed by the EPA to review the environment!*
criteria and to analyze the alternatives? Was it within^
v,
»,
their scope to make recommendations? Didn't the EPA "
themselves appoint this committee? Didn't you state in c
s
your report that this committee was "not representative1*,
u
a
since none of the committee lived near the Dunes site or-
any of the other sites? Do you by chance know where
Mr. Wilkens and myself live? I live closer to another
alternative. Don't you state in'this report that you,
the EPA, knows more than the people? And if not, how
would you interpret this statement: "The ratings given
by committee members were fully considered prior to
giving the impact ratings for each alternative. The
scores given by the citizens group indicate a fear that
there will be adverse effects on the Holly Oaks communit
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due to construction and operation of the proposed sewage
treatment plant. The ratings prepared by EPA indicate
5 the knowledge that the plant will not produce offensive
6 odors, noise, or be visually offensive to the surrounding
community"? *
6 21 Does the EPA require that we follow^the guidelines
7 of the 1990 Water Quality Management Plan? What are
these guidelines? Who ruled they were feasible? Why
aren't our local leaders familiar with these dictates?
*
10 What is the 1990 Water Quality Management Plan going to z
11 16 cost? Are you aware of the policies and standards £
<
12 handbook of the Jacksonville Area Planning Board? §
" WJ
13 5 Isn't it true that there will be occasion — isn't *
14 it true that there will occasionally be odor from this °
3
15 facility? Isn't it true that a solid majority of the -J
u
u
16 respondents in the Canton, Ohio, test area identified -J
J
17 their plant as a source of odor? Isn't it true that in
18 excess of 35 percent of the respondents felt that the
19 value of their homes had been reduced by their plant?
20 Isn't it true that 18 percent of the people who responded
2i seriously considered moving because of odor pollution
22 from their sewage treatment plant? Isn't it true that
23 your test cities, namely, Canton, Ohio, and Port Lauderd4le,
24 do not compare with Holly Oaks? Aren't you asking us
25 to accept a plant that all admit will smell from time
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to time? Can you flatly state that all potential odor
problems can be anticipated and prevented? How do you
propose to control unknown causes of odor? How do you
propose to control the septic odors that will occur when
they store raw sewage within the manifold system when
breakdowns occur? Isn't this what Mr. Hyatt said they
would do in such a situation?
Didn't. Frederick R. Harris, Inc., consulting engine^
originally site this plant in the Dunes as the most cost
effective? Wasn't it also more environmentally suitablea
V
|g than Millcoe? Has there been any pressure from large £
4
landowners to site this plant in Millcoe rather than: the£
a
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Dunes? Have the landowners in the Dunes taken any *
2
position on the Dunes site? Isn't it true that there is£
3
<
a planned urban development that the Dunes siting would -
it
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interfere with? Why does it always come back to Millcoei
|5 Isn't the Millcoe site's closest neighbor the suburban
utilities water supply well for this area? Hasn't there
been problems with that well developing cracks in the
casing? This is their closest neighbor. Why doesn't
the Environmental Impact study say anything about this?
Would you classify Holly Oaks as a residential
area? What would you classify a regional sewage treat-
i
ment plant as? Is it not the purpose of any comprehensi'
23: land plan to avoid spot zoning? Is this plant not a cas«
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of spot zoning? Didn't Mr. Kenneth Black, Regional
Director of the Department of Interior Fish and Wildlife
Service, state that, quote, "Treatment plant siting on
Quarantine Island would detract from a quality recreatioiji
experience1*? Would you call this a good neighbor?
D
it true that of all the localities that the City and the
6
EPA have cited as comparable treatment plants, that all
of these other facilities were located in an industrial
o
9 area or alongside an interstate expressway, or in fact
10 the plant was there and the community developed around SjJ
11 it?
12
28 Is ifc not the duty of the E3?A and their
V)
13 bility to check the criteria, the alternatives, and the <
fiscal effectiveness of any plan such as the Arlington- o
3
15 East Sewage Treatment Plant to be presented to it for _j
16 27 an Environmental Impact study? Is it not within your -i
J
17 responsibility to determine if there might be other
lg feasible alternatives? Would ray assumption be correct
that if there is cause to question the cost figures, thajb
you confirm the project figures with the appropriate
authorities, namely, in this case, the City and its
22 consultants? Did you do this in the case of the Arlington-
23 East Sewage Treatment Plant? Would it in the case of
94 28 large cost differentials be within your responsibility
25 to seek outside opinions to justify these differentials
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y
and determine why such differentials exist? Who was the
authority with whom you discussed this? Would you agree
a §26,000,000.00 increase on a project originally estima
at less than $23,000,000.00 is excessive? Is inflation
the real culprit for this increase in cost? What is the
total cost of this project, and does that include the
second phase of the project, and does that include the
debt service? I don't find these figures. How much is
the total cost including debt service? How much is it
i
really going to cost each household? Would you agree
any plan that reduced the cost and still produced the
end result could be more cost effective? Define cost
effective, please.
Was any consideration given to the capacity of the !
4
private utilities in the area? Wouldn't this be con-
i
sidered a viable alternative if they could relieve the '
26 problem? Why wasn't it considered a viable alternative?
Did you discuss the feasibility of expansion of any of
these utilities? Isn't it true that some of these
utilities have additional capacity available at this tims
Isn't it true that some of these are now meeting the EPA
requirements of the future; and if not, then why did the
Public Service Commission imply this with their recent
rate increases? In fact, aren't some of these private
utilities considering using their effluent for productiv
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i purposes?
2 Gentlemen, ladies, when these questions are answered
and discussed with the public, the creditability of this
project will then be ascertained. However, public projects
with little or no- input from the citizenry will never
scale these heights. I might add that the citizenry is
what we have long called the human element.
Of all the agencies and organizations that have pro-
vided input and mandated portions of this plan, the
Jacksonville Area Planning Board's policies and standards
in
handbook is the only one that has recognized the value £
12 of the human element and accepted the advises of
13 citizens' advisory committees. In fact, the siting of *
z
14 16 this heavy industrial complex in a residential area is °
&
15 in violation of this manual's guidelines. I submit that-J
UJ
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16 the above-mentioned manual become a part and parcel of
_i
17 this and any other plan for a regional sewage treatment
18 plant in this city.
19 26 In fact, when speaking of plans, nowhere in the
20 volumes that have been printed on this plant do the plans
2i take advantage of the assets of the private enterprise
22 system. We have been told some of the private utilities
23 in the area are now meeting the standards of the EPA and
24 could alleviate the emergency nature of this project if
25 an orderly plan were followed with an eye to the future.
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Such a plan would include a joint effort of both
private and public utilities. Our crying need is not
the private utilities but the City owned and operated
utilities, most of which are not located in the Arlingto^i
area, even, but are located for the most part south of
the expressway and Atlantic Boulevard.
You are asking the people of Holly Oaks to shoulder
a burden that is not even their *s and then have not made
a sincere attempt to listen to us,
Obviously, time would not permit me to explain suchi
-. «
a plan tonight when other alternatives have been met wit|
«
•
total disdain and discrimination. The City has shown <
«
2S any alternatives to be more costly, but in fact, had the]
primary plan been one of the alternate sites, they would!
have been able to show it as the most cost effective.
i
The administration has continually told the people that
the residents of Holly Oaks are responsible for the
increases in cost.
We were told that the cost figures as presented in
the Environmental Assessment Statement and to City
Council and its committees were derived from the Bnginee:
News and Records Periodical. Isn't it true thai: these
cost figures did not include all the sophisticated equip
ment that heat treatment and incineration require?
2 If it did, explain to us why the heat treatment
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units are projected to cost 7.6 million dollars and the
solids-handling units 8.2 million. I would like to point
out that the cost of either one of these units is greater
than the entire projected cost of the whole plant itself
as recently as October of 1974.
We don't believe that the 1974 Environmental Assessiiient
7 Statement included cost estimates for the facility as
3 they described it. So far, they have been unwilling to
9 show us detailed cost estimates. Perhaps City Council
y
10 should take a look at the figures that were presented z
to them and ask the administration what happened. JU
The plan as submitted discounts deep well injection^
in
13 because of a lack of available knowledge.
z
14 The statement, "The solution to pollution is
15 dilution," we all agree is obsolete, yet the plan we
u
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15 are discussing still professes such a concept. Secondary1
J
17 treatment by anyone's standards is solution by dilution
18 when it is returned directly to our fresh water tributaries.
19 The City, its consultants, and the EPA have consistently
20 ignored any alternative to dilution as too costly, yet
2i 3 recent developments in other areas show that deep well
22 injection is not only more cost effective, but less
93 hazardous to our environment. Why don't we have cost
24 figures for deep well injection?
25 It is our contention that the cost figures presentee,
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for the alternate sites were merely modifications of the
Millcoe plan and were not produced as a primary alternat
system.
28 We challenge these alternate cost figures. We can
find no creditability to this plan. We know the real
answer to siting this plant in Millcoe. We know the rea
answer to the cost figures. We know the real answer to
all the questions that have been asked. The answer is
politics.
[Applause.I
Not cost effectiveness, not the environmental
aspects and impacts, not land use planning, and not evej
the human element, but politics. We challenge this
26 attempt at the takeover of the private enterprise systei
i 9 We challenge the EPA's statement that their own conaaitt
was not representative; but in reality, the people were
2.1 trying to be heard. We challenge the 1990 Water Qualit
Management Plan and its dictates. We challenge the
23 selection of the Millcoe site. We challenge the siting
16 an industrial complex in a residential area. We
2S challenge their cost figures. We think the City owes
the Holly Oaks community an apology. Thank you.
[Applause.]
MS. PHILLIPS:
Mr. Evans, thank you for your comments, and as
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chairman, may I say that I appreciate your patience in
complying with the hearing procedures.
Let the record reflect that we have received testi-
mony from all citizens wishing to speak on the Draft
Environmental Impact Statement for the Arlington-East
service district. It is my opinion that the concerned
citizenry have raised significant questions which EPA
must review, consider, and respond to prior to awarding
9 grant funds on this project.
10 [Applause. 3
Therefore, although only a thirty-day interval is jlf
to
12 required from this date until publication of the final o
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13 EISf I am requesting, as chairman of this public hearing ^
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14 and as a member of the hearing panel, that EPA take at 8
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15 least an additional fifteen days as a minimum and ||j
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thereafter whatever time is necessary to respond to these!
17 public comments. Mr. Howard, do you understand?
\
13 The U. S. Environmental Protection Agency wishes
19 to thank you for attending this public hearing and your
20 comments .
2i [Applause.]
22 [Whereupon, the above-entitled hearing was conclude
23
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Responses to the questions and comments raised at the
previously presented Public Hearing on the Draft
Environmental Impact statement are presented in this
section* To facilitate reply, these questions and comments
have been grouped into major subject headings (e.g. noise
and odor, costsr etc.). The questions and comments made at
the hearing have been assigned numbers which correspond to
the major subject heading discussion containing the reply to
that question. These numbers appear in the left margin of
the Public Hearing text next to the pertinent question or
comment* Major subject headings are as follows:
1. Chlorination
2. Incineration
3. Deep well Injection
*. NO Action Alternative
5* Noise and Odor
6. Aesthetics
7. Further Consideration of Alternative 11
8, Further Consideration of Alternative 12
9. Exact Construction Site
10. Buffer Zone
11» Access Scad Safety
12. Effects on Mill Cove
13. Transmission System Funding
14. Public Disclosure
15. Public Water Supply
15. . Jacksonville Area Planning Board Policies and Standards
17. Impact on Major Landowners
18. Pressure from Major Landowners
19. Assistance Committee
20. EPA Contact with Other Agencies
21. 1990 Water Quality Management Plan
22. Projected Population
23. Corapatability of Plant Site with Residential area
24. Legal Requirements
25. Outfall Construction Permit
26. Decentralization of Treatment: Facilities
27. Biount Island Outfall
28. Cost-Effective Verification
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1* Chlorinatioa
Chlorine is a common element best known as a heavy,
greenish-yellowr irritating and,, under certain conditions,
toxic gas of disagreeable odor. It is widely used as a
disinfecting agent in water purification and,, when used in
municipal waste treatment,, also reduces odor production* In
the Arlington-East Plant it will be employed in the
pretreatment and final disinfection processes- In
pretreatment^ chlorinatioa serves as one of the processes
necessary to render the wastewater more amenable to primary
treatment. In the final disinfection stage it is necessary
to kill or render harmless the bacterial organisms and
viruses in the effluent. Ozonation and chlorination are the
two methods of disinfection commonly used. Chlorination has
been chosen for use in the Arlington-East plant since it is
significantly cheaper than ozonation and uses less power..
2. Incineration
Alternative methods of final sludge disposal have been
addressed in Chapter III of the Draft EIS. Previous studies
save rejected these alternatives for use in Duval County on
the basis of prohibitive environmental and/or cost
considerations. One method of final disposal to which the
Draft EIS gave particular attention was the use of the
thickened, dewatered,. and heat-treated sludge for a
combination land spreading and land reclamation operation
involving the extensive and barren strip-mined areas which
exist in the Arlington—East Service District, such a plan
would eliminate the costs of constructing and operating a
multiple-hearth incinerator. Major obstacles to this
operation, however,, are the costs of transport to the site,
the cost of tilling the sludgef and, most significantly, the
unavailability of a commitment of lands for this purpose.
A new analysis covering the feasibility and cost-
effectiveness of various alternatives to the formerly
proposed incineration of sludge at Arlington-East has been
conducted by EPA and Flood and Associates, Inc, Results of
this study along with a description of the sludge disposal
method now planned are given in Chapter I.
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3. Deep Well Injection
Chapter III of the Draft EIS discussed structural
subsystems available for treated effluent disposal. Among
these subsystems were shallow and deep well injection.
Shallow well injection has been eliminated from
consideration primarily by geologic limitations and the need
for protection of the shallow aquifer as a potable water
supply. On the other hand, the EIS is clear in stating that
deep well injection has not been discounted and is
considered a "potential viable disposal alternative in
Jacksonville." The EIS goes on to discuss areas of concern
which must be adequately addressed before deep well
injection could be carried out and states only that this
disposal method is considered "non-viable for immediate and
large-scale applications in Duval County."
In June, 1970 the Federal Mater Quality Administration
(now the EPA) published a policy statement limiting the
disposal or storage of wastewaters or other wastes by
injection. Since that time,'the Florida Department of
Natural Resources has adopted this statement as Department
policy. The policy states, in part, that "subsurface
disposal or storage should, at no time, be authorized simply
because it may appear to be the easiest and least expensive
alternative for the waste producer. It could well result in
serious pollution damage and require a more complex and more
costly solution on a long-term basis."
For certain municipalities and in certain locations, the
underground injection of wastes may well be the most
environmentally acceptable practice available. In many
areas where water resource management problems are forecast,
the EPA. has recognized the need to begin conserving
wastewater having a potential for reuse by future
generations whenever practical to do so. This method of
subsurface "storage" is particularly adoptable and
acceptable when the planned reuse is for agricultural or
other non-potable demands. In Jacksonville, however, any
such potential reuse would most surely be for potable
purposes. The Administrator's Decision Statement Number 5
(Subsurface Emplacement of Fluids; April 9, 197ft) states
that "SPA will oppose emplacement of materials by subsurface
injection without strict controls and a. clear demonstration
that such emplacement will not interfere with present or
potential use of the subsurface environment, contaminate
groundwater resources, or otherwise damage the environment."
It is true that deep well injection is beina used in
some parts of the country to Combine effluent disposal and
99.
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water reuse- In both California and New Yorkr wastewater is
used to recharge the potable ground-water supply and to
create a hydraulic barrier against salt water intrusion.
However, this effluent is of very high quality and, in the
case of California,, meets- virtually all of the O« S. Public
Health Service standards for drinking water. Furtherr in
both of these cases, travel through a fine-grained aquifer
ensures against the survival and transmission of any
bacteria and viruses remaining in the tertiary treated
effluent. The Floridan aquifer^ however, generally consists
of cavernous limestone and dolomite. The lateral passage of
injected water through this media does not provide any
positive filtration for microorganism removal. Therefore,
any residual viruses or bacteria in treated effluent would
not be subject to removal by passage through the aquifer
media. It would likely be possible for the injected
effluent to be carried via a subterranean cavern or open
fissure directly to a nearby water well. Of course,, if the
effluent were treated to a higher degree than is now
planned,, injection into the Floridan aquifer might
eventually be given consideration. Such treatment, howeverr
is generally prohibited by cost except in those cases where
there is no other alternative.
The recently enacted Safe Drinking Water Act (Public-Law
93-523) has,, for the first time, established a detailed
technical approach to protection of groundwater by the
federal government. The Act provides for the placement of
primary enforcement responsibility for protection of public
water systems on the individual states and is specific with
respect to actions that must be taken to protect groundwater
from unrestricted injection of wastes. One of these
requirements (regarding the issuance of a temporary permit
for underground injection) is that the State must show "that
injection of the fluid would be less harmful to health than
the use of other available means of disposing of wastes or
producing the desired product." Disposal of secondary
treated and disinfected waste to the St. Johns River will
not pose a health hazard nor will it carry with it the
potential for aquifer contamination. It does not embody the
concept of "solution to pollution by dilution1* since it
entails the discharge of treated and disinfected waste in
compliance with applicable state and federal laws and
regulations concerning discharge to surface waters.
100.
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4. No Action Alternative
The "no action" alternative was considered throughout
the alternative analysis process of the Draft SIS. This
alternative was rejected primarily because it dees not:
a) Provide for the removal of inadequately treated
wastewaters from tributary streams;
b) Provide treatment facilities to adequately service
existing and future sources of wastes;
c) Provide for alleviation of existing adverse
conditions resulting from the operation of septic systems
and small pacXage plants; and
d) Provide for allowance of orderly growth according
to the Comprehensive Development Plan for 1990.
5* Noise_ and_
As originally designed, the Arlington-East facility had
a higher potential for emission of nuisance odors. Had this
original design been retained, EPA would undoubtedly have
given greater consideration to the possible effects of odor
on surrounding residents in its analysis of site
suitability. However, the odor production from operation of
the controlled plant as presented in the Draft SIS was
expected to result in no detectable nuisance odors off the
plant site, structural, as well as non-structural, measures
to achieve this objective have been detailed in Chapter III
of the Draft BIS, Changes in the selected method of sludge
disposal since publication of the Draft have, however,
eliminated several sources of unmitigated noise and odor.
These changes, along with modifications to structural noise
and odor controls, are discussed in Chapter I.
The probability of a very low, yet detectable odor on
the plant site for short periods of time under certain
atmospheric and plant operating conditions has been
acknowledged in the Draft SIS for the controlled facility as
proposed in that document* However, the provision of
several backup systems, also so described, would have
prevented noticeable odors from leaving the plant site.
The effect of a worst case condition odor episode on
surrounding residents from the controlled plant with sludge
'^han-diiner-"--and--=in<:-iaeEation>,h.as,,,-te€!en-;,addr,ess,e.d^ i,^ the_ Draf.t,
FIS. Such an occurrence would likely have involved low
101.
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intensity odor being detected off the plant site with
possible identification as a nuisance by residents. Once
again, however, planned odor control measures and backup
systems made this situation highly unlikely* Further, the-
removal of incineration and virtually all sludge handling •
facilities at the plant makes this possibility even more
remote.
At present there is no "model1* plant in existence
comparable to the facility which was proposed in Arlington
with noise and odor controls. There are, howeverr plants in
existence similar to the Arlington-East facility as
previously proposed without noise and odor controls. Two of
these (the Canton and the Ft. Lauderdale facilities) were
selected by EPA's contractor for use in his analytical
reports on noise and odor. The plants were never intended
to represent the *bestw sewage treatment plants in the
country. They were selected as being similar in size and
operation to the Arlington-East facility with incineration
and sludge handling and without, once again,, the noise and
odor controls which are now incorporated into the design of
that plant. While it is true that the Canton facility is
twenty years oldr it has been upgraded and is similar to the
Arlington plant as proposed in the Draft EIS in wastewater
characteristics* treatment processesr and sludge handling..
Residents in the vicinity of the Canton and Ft.
Lauderdale plants were surveyed as a ''test* group to enable
a comparison with the survey of the "control* group in Holly
Oaks. Thus, the responses of the people in Canton and Ft.
Lauderdale reflect exposure to treatment facilities without
the noise and odor controls planned for the Arlington-East
plant. These responses demonstrated the need for the
subsequent development and costing of a control strategy to
be applied to the Arlington plant. The noise and odor
production of these uncontrolled plants bears little
resemblance to that which would have been emitted by the
controlled plant as described, in the Draft SIS and even less
resemblance to the noise and odor production from the plant
without incineration and sludge handling. Similarly, the
EPA*s staff recommendation for the Millcoe Road site is
based on the knowledge that noise and odor from the plant
will be controlled to the levels described earlier in this
section.
Further confusion in the understanding of the Odor
Control section of Chapter III is apparent from several of
the comments made at the Public Hearing. Concern was
10Z.
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expressed over the following statement quoted here from the
Draft BISr
"In summary,, the combined vapor from, the
centrifugesr vacuum pumps and filters and
sludge-blending tanks are proposed to be
routed to the inlet air fan of the multiple
health incinerator* When the incinerator is
in operation,, this is an excellent means of
odor control* However, normal operating
procedures will inevitably result in the
incinerator being out of operation while the
rest of the sludge handling equipment is still
in use. During these periods* no odqr control
would, be utilized,'*
This statement represents a description of odcr control
as originally proposed for the Arlington facility. The
section of the SIS entitled "Additional Odor Controls"
describes the measures planned for inclusion into the plant
design air the time the Draft EI& was written*
The portion of the Odor Control section of Chapter III
of the Draft stating that "this control strategy will not
substantially reduce potential odor emissions- at the source
and consequently wiH not substantially mitigate the
potential impact of the Arlington-East Regional sewage
Treatment Plant1* clearly refers to "a control strategy based
solely on operator dependent: measures". It does not refer
to the control strategy involving structural design
modification*
The section of Chapter II describing additional odor
controls does state *an estimated 90 percent of potential
odor emissions should be removed by these treatment
techniques.* This represents *all major potential odor
sources being brought under control.1* The remaining 10
percent consists of "minor sources of potential odor
emissions (which) should be effectively controlled by good
operational and maintenance practices.* The additional odor
controls proposed for the plant in the Draft SIS were a
combination of structural and non-structural measures. The
EIS is very clear in stating that non-structural measures
alone for the plant as described in that document "will not
control potential odors from the Arlington-East Regional
^t^e.«fefer®ahoJja1,dayfs^^»nc^a.:ncje..,,in3=Ji,,-
the surrounding Community*1*
103.
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Regarding plant breakdowns and the necessity for storage
of raw sewage within the press-are manifold system, the
resulting odors would depend in large part upon the length
of time of storage* Under these conditions, odors escaping
the manifold system would most, certainly have similar impact
under each alternative since all alternatives are very
similar in terms of numbers of pump stations and feet of
force main. Should the breakdown be exceedingly long, the
option of temporarily bypassing the plant might be
considered rather than risk backujp of raw sewage beyond the
manifold system-
Existing point sources of annoying odor in the area have
been described in Chapter II of the Draft EIS. These
sources are largely industrial- While it is true that odor
emissions from the Sewer District: No. 2 and Euckman Street
regional sewage treatment plants have caused sporadic
citizen complaints,, it must be recognized that these odor
problems are largely caused by the industrial wastes which
these plants treat {see page 32 of Draft EIS)» The proposed
Arlington-East facility will not be required to treat any
such problem industrial wastes. Furtherr the Arlington
facility is now being designed with odor controls lacking in
the otheir two plants and without incineration and sludge
handling facilities.
6. Aesthetics
Chapter III of the Draft EIS contains an assessment of
plant visibility at Site 1 using a weather balloon which was
raised to the height of the highest structure (the
incinerator stack) of the plant as originally designed.
Admittedly, there is little resemblance between a sewage
treatment plant and a balloon. The purpose of the weather
balloon study was,, however, to determine the visibility of
the highest portion of the plant—the part which might be
visible to surrounding residents over the treetops. Results
indicated that the vegetative buffer zone would, for
practical purposes, screen the plant.and the incineration
facilities from the view of even the closest residents, In
addition, any possible aesthetic impact is now even further
mitigated with the decision to forego construction of the
heat treatment and incineration facilities at Arlington-
East-
104.
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7* Further Consideration of Alternative 11
The Quarantine Island plant site is located on the east
end of the island, Reasons for not choosing this
alternative are implicit in Chapter III of the Draft EIS.
Briefly, however, the plant site requires dewatering, piling
support, and a considerable amount of sand fill to raise
the plant site and the perimeter road to elevations not
subject to flooding. Other necessary measures unique to
this alternative include the construction of an 800 foot
access bridge and raw sewacre force main across the narrow
channel between Reed and Quarantine Islands, the ultimate
construction of two parallel force mains across Mill Cove,
the construction of an additional master pumping station at
the intersection of Millcoe Road right-of-way and Fort
Caroline Road, and the construction of some 9,000 feet of
new roadway providing access to the site through Beacon
Hills.
8. Further Consideration of Alternative 12
Regrettably, the draft impact statement was printed
without benefit of a map showing the total transmission
system associated with Alternative 12, The screens and
negatives necessary for such a map were unavailable at that
time since the transmission system was not specifically laid
out for this alternative. These have since been produced
and a map showing the entire Alternative 12 system is
included as Exhibit 1 of this chapter. Lack of a system map
notwithstanding, it was known that the number of pumping
stations as well as overall force main lengths and
configurations were similar to Alternatives 7 and 8. This
enabled Alternative 12 to be considered throughout the
alternative analysis process in the impact statement from
both a monetary and environmental standpoint, Consideration
of the feasibility of Alternative 12 was thus implicit in
the alternative analysis process.
9» Exact Construction Site
The exact location of the proposed plant site as well as
the location of the facilities on that site appears in the
Draft EIS as Figure *-l.
105.
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10. Buffer Zone
The cost of the 46*98 acre plant site was set in court
condemnation proceedings at $6,300 per acre. Since the
buffer zone is immediately adjacent to the plant site, it is
reasonable to assume that a similar value will be placed
upotr that land.. The appraiser hired by the City has,, in
fact, recommended a price slightly lower than the $6,300 per
acre figure used in the cost analysis, condemnation
proceedings are expected to begin as soon as the grant offer
is made to the City by EPA. The owner of the dwelling now
under construction within the proposed buffer zone will be
permitted to occupy the house if he so desires*
A map showing the plant site location as well as the
land to be included in the buffer zone appears as Exhibit 2
of this chapter.
11. Access Road Sa fety
The Jacksonville Traffic Engineering Division has been
contacted to review the safety of the proposed location for
the plant access road. Their findings, as documented by
Exhibit 3 of this chapter, indicate no traffic safety
problems are foreseen in the location of the proposed
facility access road.
12. Effects on Mill Cove
Effects on Mill Cove from both outfall construction and
plant operation were considered throughout the alternative
analysis portion of the Draft EIS. While it is true that
the Mill Cove Model Study presently being carried out by the
0. S. Army Corps of Engineers is not complete, preliminary
data indicates that effluent from the proposed treatment
plant will not significantly affect Mill Cove (refer to
Corps of Engineers letter dated March 2r 1976 which appears
as Exhibit * of this chapter) .
Engineering necessary to restore navigation to Mill Cove
has not been completely finalized. The Corps has commented
specifically on the relationship of the outfall across the
cove to any future navigation projects. These comments
appear as Exhibit 5.
106.
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13. Transmission System Funding
The Environmental Protection Agency finances 75 percent
of eligible project costs. Certain appurtenant costs, not
related to the treatment plant itself, are presently
ineligible for Federal funding. Among these costs are those
associated with force mains and pumping stations. It is not
known at this time if a portion of these costs will be
eligible for federal funding during the period of treatment
plant construction. This determination will depend on the
amounts of money appropriated to the EPA's construction
grant program for fiscal year 1977. The construction of the
actual treatment facilities is presently the first priority
of available federal funds. Similarly, the state of
Florida's priority system presently precludes most
interceptor funding. However, interceptors appurtenant to
the treatment works may be funded in part under the State
priority system. The recently completed cost analysis
conducted by EPA shows the present worth of Alternative lq
to be $34C521,500. of this, $8,630,375 will be financed by
local monies. The analysis also shows the present worth of
the total system associated with Alternative lq as
$62,982,000. Of this, 528,460,500 represents costs of the
transmission system. Portions of this cost may be included
in the project for Federal grant funding.
14. Pub1ic Disclosure
It is the policy of EPA to make the fullest possible
disclosure of records to the public consistent with the
rights of individuals to privacyr the rights of persons in
trade secrets and other information entitled to confidential
treatment, and the need for EPA to promote frank internal
policy deliberations and to pursue its official activities
without undue disruption. Any written request to EPA for
existing records shall be deemed to be a request for records
pursuant to the Freedom cf Information Act, 5 U.S.C. 552.
Treatment of snch requests by EPA will be in accordance with
the regulations governing them as they appear in Part 2 of
Chapter I of Title 40 of the Code of Federal Regulations
published ia the Federal Register, vol. 40, No. 45, Part I,
dated Thursday, March 6, 1975.
107.
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15. Public Water Supply
No land disposal of effluent or sludge will occur at the
Millcoe Road site* Also, standard precautions will be taken
concerning raw sewage overflow (spills). Plant capacity
will be designed to accommodate surge flows* Facilities
will be provided for the chlorination of plant effluent,, and
emergency power facilities- will be provided at key locations
in the event of an external power failure. The plant will
be manned twenty-four hours a day and with the aid of
computerized monitoring of operational features* as well as
telemetric input from tributary pumping stationsf
reliability of operation should be maintained at a maximum.
In any case* the suburban utilities water supply well
for the area must* by lawr have a sealed casing to ensure
against contamination from all sources. Any known defects
in the casing of this well should be reported to the local
health department and appropriate measures taken.
16. Jacksonville_Area Planning Board Policies and Standards
The Jacksonville Area Planning Board does not feel that
the selected site contradicts its Policies and Standards
Handbook for the* following reason sr
1} There is presently no development on the south,
westr and north sides of the proposed plant location.
2) By ensuring retention of existing vegetation and by
providing for additional tree planting* the proposed 11*
acre buffer zone included in the project will provide
adequate visual as well as environmental protection to
surrounding areas,.
The position of the Planning Board in this matter is
documented by Exhibit 6 of this chapter.
17. Impact on Manor landowners
If a regional system is not implemented, the development
which could be supported would be limited in some parts of
the service area because of septic tank restrictions (pages
343 and 344 of Draft EIS). The land most affected is
located south and east of Craig Airport. Extensive
development would also be more difficult to achieve in those
areas now discharging into the tributaries because of the
present virtual moratorium on new discharges into these
108.
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streams (page 157 in Draft EIS). Therefore, the project
will benefit major land developers who own land in these
areas. Major landowners as they existed in 1971 in the
areas in question are shown in Exhibit 7 of this chapter.
Development could potentially proceed without the
project in the northern portion of the service area with
small plants discharging directly into the St. Johns River.
18. Pressure from Malor landowners
The Stockton, Whatley, and Davin Company does plan
extensive development in the dunes area and is opposed to
the choice of site 2 for construction of the waste treatment
facility. EPA's selection of site 1, however, has been
based strictly upon the environmental and cost effective
analyses presented in Chapter 3 of the Draft SIS and
verified in Chapter 1 of this document.
19. Assistance Committee
The Assistance Committee was established to provide
citizen input into the decision making process by
identifying areas of citizen concern and evaluating project
alternatives based upon these concerns. The alternative
selected by the committee (No. 2) was strongly considered by
EPA along with Alternatives 1 and 12. In addition, the
relative weighting of environmental criteria (identified
concerns) developed by the committee was used by EPA in its
own evaluation.
20. EPA Contact with Other Agencies
In preparation of the Draft SISr contact was made with
every local, state, and federal agency concerned with the
project (see references cited in that document beginning on
page 377). In addition, EPA has met all requirements for
the review of the Draft Sis by other agencies.
21. 1990 Water Quality Management Plan
EPA has approved the 1990 Water Quality Management Plan
(WQMP) for the City of Jacksonville. Exact giant site
recommendations, however, were not required to be made at
109.
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the time of this approval- The sites shown in the WQMP are
generalized locations based upon projected centers of flow*
Extensive consideration in areas such as cost effectiveness
and environmental impact are not made in the WQMP bat in the
201 Facilities Plan
• Sxact site recommendations are thus
made in the 201 Plan and finalized,, if necessary, in the
EAS/EIS procedarev
22. Projected Population
The projected future population throughout the project
service area was considered in the site selection process
(see Figures 2-25 and 2-27 and page 364 of the Craft EIS) .
Population projections for the service district have been
changed since publication of the Draft. These changes are
explained in Chapter I. Although they represent a revision
in projections for Duval County and Arlington, these changes
do not affect the future population center of the service
area.
23. Compatability of Plant Site with Residential Area
Noise and odor- controls,, elimination of incineration and
sludge handling facilities, and distance between the site
and the surrounding community will mitigate adverse impacts*
Locating the treatment plant on the Millcoe Road site is not
considered "spot1* Boning because of the extensive vacant
surrounding land* The Jacksonville Area Planning Board
concurs with EPA in1 that the Millcoe site is suitable for
the proposed facility*
2*» Legal Requirements
EPA has fulfilled all legal requirements in the
preparation and review of both the Draft and Final EIS»s*
25* Outfall Con
strugti
on Permit
The Army Corps of Engineers is the federal agency
responsible for issuance of the outfall construction permit*
Since publication of the Draft EISr application has been
made for this permit by the City of Jacksonville, The Corps
has been asked to Comment- specifically on the liklihood of
permit issuance* Their reply appears as Exhibit 5 of this
110.
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chapter. A copy of the Cityfs construction permit
application appears as Exhibit 8,
26. Decentralization of Treatment Facilities
Under present regulations, it is not possible to give
low interest federal loans or construction grants of any
type to agencies either public or private who are planning
construction or improvement of a wastewater treatment
facility which is not a part of an appro-wed wastewater
facilities plan. The "no action" alternative was considered
throughout the alternative analysis of the Draft EIS. This
alternative would require expansion and upgrading cf the
many small and privately owned treatment facilities
discharging to the tributaries. Associated costs would have
to be borne by the private parties involved. Further, the
advantages of centralized versus decentralized wastewater
treatment was considered throughout the alternative
analysis. Briefly, these advantages are:
1) lower cost
2) increased efficiency and dependability
3) removal of discharges from the tributaries
4) greater ease in meeting possible higher water
quality standards in the future.
27. Blount Island Outfall
The Blount Island outfall was considered as an integral
part of several alternatives in the Environmental Assessment
Statement prepared by the general and design consultants of
the City of Jacksonville. This EAS was completed and
submitted to the City long before the preparation of EPA*s
Draft EIS and was a major source—but by no means the only
source—of information used in the preparation of that
document.
The Rational Environmental Policy Act of 1969
-------
-the environmental impact of the proposed action
-alternatives to the proposed action
In this case, the action proposed by the City cf
Jacksonville in their application for federal funds was
Alternative 1 with a Quarantine Island Outfall. As
required, the Draft EIS evaluated the environmental impact
of that alternative as well as others. During preparation
of the Draft it became apparent that consideration should
also be given to the Blount Island outfall in combination
with sites 1 and 2, notwithstanding the fact that this had
not been previously considered. This was not an attempt to
split the project into segments in order to avoid
foreclosing on possible future options regarding final plant
site selection. It was, rather, an opportunity for EPA to
comply to the best of its ability with the letter and spirit
of the National Environmental Policy Act in considering all
feasible alternatives.
28• Cost-Effective Verification
An independent investigation of the most cost-effective
plant site and interceptor configuration has been completed
by the Water Division of EPA, Region IV. Methodology and
results are presented in Chapter I.
112.
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113.
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Sewage Treatment Plant Site
Plant Outfall, Diameter and Length as Noted
Transmission System for Existing City
Owned Systems
Pumping Station, Identification and Capacity |
as Noted
Force Main, Diameter and Length as Noted
Transmission System for Existing Private
Systems
Pumping Station, Identification and Capacity
as Noted
^^"^™ Force Main, Diameter and Length as Noted
• • • Service District Boundary
EXHIBIT 4-13
ALTERNATIVE NO. 12
SITE INSIDE SOUTHERN BOUNDARY OF CRAIG FIELD
AND TRANSMISSION SYSTEM
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II
Exhibit 2
114.
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II
Exhibit 3
DEPARTMENT OP PUBLIC WORKS
Engineering
Streets and Highways
Water and Sewer
Sanitation
Public Buildings
Traffic Engineering
February 18, 1976
Mr. Robert Cooper
Environmental Protection Specialist
Environmental Protection Agency
1421 Peachtree Street, N.E*
Atlanta, GA 30309
Bear Mr. Cooper:
Concerning the City of Jacksonville's Arlington-East Wastewater Management
Facility (EPA Project C 120 541), Mr. Joe ^ratt requested that I review
the vehicular access and the intersection of the proposed facility access
road and Monument Road.
plant staffing will be:
Three Shifts:
7:30. A.M.
3:00 P.M.
11:00 P.M.
4:00 P.M.
11:00 P.M.
7:30 A.M.
TOTAL
35 Persons
5 Persons
5 Persons
MHHMWWwwr
45 Persons
Vehicles in and out will be:
Staff personnel cars and pickups
10 Service Trucks - leave at 8 AM and return at 4 PM
Materials Delivery - four trucks per day
Ash Haul-out - two trucks per day
Sludge Dumping - two trucks per hour
TOTAL
IN
45
10
4
2
18
MB*««M
79
QOT
45
10
4
2
18
••«•••••
79
Monument Road in the vicinity of the proposed facility access road is a two-
lane road built to state highway standards and is posted with a 55 MPH speed
limit at the present time. The terrain is rolling and there is no develop-
ment along the roadway. A motorist entering Monument Road from the proposed
facility access road has a, 1,500 foot sight distance in each direction, which
''III'
115.
AREA CODE 904/S33-5510/1007 SUPERIOR STREET/JACKSONVILLE, FLORIDA 32205
-------
Mr. Robert Cooper
February 18, 1976
Page 2
is more than adequate for the various types of vehicles that will travel
to and from the proposed facility. Sludge disposal trucks are dumping
off of Monument Road about 2,500 feet to the south of the proposed inter-
section at the present time. We can foresee no traffic safety problems
in the location of the proposed facility access road.
Very truly yours,
George S. Adams, P.E., Chief
Traffic Engineering Division
GSA/cds
cc: He. Joe Hyatt
Public Works
116.
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II
Exhibit 4
DEPARTMENT OF THE ARMY """
JACKSONVILLE DISTRICT, CORPS* C$F ENGINEERS
P. O. BOX 407O
JACKSONVtLLE. FLORIDA 322OI
SAJE»-EE \r,\, 1-0'— 7 l&rch 1976
Mr. F. Theodore Bistarfield
Ecologist
U. S. Environmental Protection Agency
Region IV
1421 Peachtree Street, N. E.
Atlanta, 6A 30309
Dear Mr. Bisterfield:
This is in reply to your letter of 18 February 1976 relative to EPA*s
Jacksonville, Arlington-East District Draft Environmental Impact Statement.
The Hill Cove Model Study, which is expected to contribute greatly to our
knowledge of the circulation patterns in the area, is not complete. How-
ever, preliminary data gathered in connection with the study indicates
that the proposed sewage plant effluent probably would not significantly
affect Mill Cove.
Based on available velocity and cross-section data, approximately 10
percent of the total river flow on flood and ebb tides moves through Mill
Cove. Assuming uniform effluent discharge from the outfall divided evenly
between ebb and flood tides, Mill Cove would receive a certain amount of
effluent. Rough estimates taking into account distance to the ocean,
travel time of the ebb current, and mixing action indicate that about
9 percent of the total effluent discharged would move through the cove.
Due to the location of the proposed outfall line, no newly discharged
effluent would move directly through Mill Cove but only that portion already
mixed in the river system.
In view of the fact that this effluent is to receive secondary sewage
treatment, the effect on water quality in Mill Cove would appear to be
minimal.
We hope this information will be of assistance to you. If we can be of
further help, please let us know.
yours,
Gjnw&SR&Zt
JAMES L. GARLAND
Chief, Engineering Division
117.
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II
Exhibit 5
DEPARTMENT OF THE ARMY
JACKSONVILLE DISTRICT. CORPS OF ENGINEERS
P. O. BOX 497O
JACKSONVILLE. FLORIDA 322O1
SAOEN-DL 17 March 1976
Mr. John A. Little
Deputy Regional Administrator
United States Environmental Protection Agency
Region IV
1421 Peachtree St., N.E.
Atlanta, Georgia 30309
Dear Mr. Little:
This is in reply to your 8 March 1976 letter which requested
information concerning your Wastewater Treatment Project, Arlington-
East District (Department of the Army permit, Application No.
76M0112) in Jacksonville, Florida.
Information requested is presented in the same order as in your letter.
1. The Mill Cove model study is presently in the earlyj testing1
phase. Therefore, we are unable to state, at this time, ,whetherjor -;
not modifications to Quarantine Island will be required which would be-
interfered with by your proposed outfall line. If the outfall line
is installed and the model study shows that the line interferes, .with £
necessary modifications to the island, the outfall line would have to _•
be relocated by the owner. Based on the present model study schedule,^
detailed information would be available in mid-calendar year-19ZT whtch
would provide data to answersyour question. ~"
2. Based on the permit application which indicates that the outfall
line would be placed across our upland disposal area on Quarantine Island
to a top elevation of approximately -2.0' m.l.w., we do not foresee
interference with our continued use of the area. However, our continued
future use of the area could cause some subsidence of the existing under-
lying material. The type of installation used for the outfall line
across the island should take this into consideration in order to avoid
possible failure of the line which could cause serious damage to future
dikes constructed around the area.
118.
-------
SAJEN-DL 17 March 1976
Mr, John A. Little
3. The outfall Tine crossing of Mill Cove as presented In the
permit application, would place the top of the pipe a minimum of
9.0 feet below mean low water for a distance of 800 feet. This is
acceptable to us since these clearances will allow reasonable
tolerance 1n establishing the proposed Mill Cove navigation channel
location in the future. It should be noted that the Mill Cove model
study is to determine means to promote increased circulation of water
through the cove. By increasing the circulation of water, depths may
be reestablished along the previously existing natural channel in
Mill Cove and this could leave the outfall line suspended in the water.
4. Based on the permit application the proposed outfall line
termination point provides 160 feet of clearance from the edge of the
existing 38-foot channel bottom* It would also provide about 110 feet
of clearance from the channel bottom for a 45-foot project. The above
clearances from the existing 38-foot project channel and proposed
4&-foot project channel are acceptable. The outfall Tine shouTd remain
at least TOO feet frour the proposed 45-foot project channeT bottom.
This should prevent damage during any blasting or dredging operations.
5~ See comment 4 above? for acceptable clearance of outfall Tine
from the proposed 45-foot project channeT bottom.
6. The location and dimensions of the proposed turning basin have
not been established to date and it may be several years before the
exact location and dimensions are finalized. We therefore cannot state
at this time whether or not the Tocation of the outfall line as presented
in the permit application would interfere with the proposed turning basin.
If, after finaTization of the turning basin location and dimensions, the
outfaTT Tine interferes with the construction or safe use of the basin,
the outfall line will have to be modified by the owner.
7. Based on engineering data furnished with the permit application
and that the end of the outfall line would not be closer than 100 feet
to the proposed 45-foot project channel bottom, the effluent velocities
would be dispersed and would not create cross currents that would be
hazardous to navigation. Therefore the plan shown in the permit
application or the use of a "T" at the pipe end would both be acceptable.
It should be noted that the use of a surface discharge, via a^spillway,
as an alternative method of discharge as presented in our 15 July 1975
Tetter to you, was merely a suggestion for your consideration due to
.119.
-------
SAJEN-DL 17 March 1976
Mr.- John A. Little
the possible conflicts with the use of a submerged outfall. Since that
time the engineering data furnished with the permit application shows
that the conflicts have been resolved, except as discussed in comments
1 and 6 above. In our opinion, if the effluent has received secondary
treatment, there should be no greater adverse impact to water quality,
littoral biota and aesthetics, by use of a spillway than by use of a
submerged outfall.
We foresee no further technical problems which would delay your issuance
of a permit to the city of Jacksonville.
We trust that our response has provided the information that you need.
If we can be of any further help please let us know.
Sineerely yours,
GARLAND
ngineering Division
120.
-------
II
Exhibit 6
JACKSONVILLE AREA PLANNING BOARD
February 25, 1976
EIS Branch
Environmental Protection Agency
1421 Peachtree Street
Atlanta., Georgia 30309
ATTN: Bob Cooper
Dear Bob:
This has reference to your phone call on February 18, 1976.
The Policfes and Standards Handbook, prepared by this agency
in 1973 and adopted by the Jacksonville City Council on 2/10/76,
includes the following policies re the location of sewage
disposal facilities:
Section 2.420 b page 38. General Policies
(INSTITUTIONAL AND GOVERNMENT USE)
b. Facilities such as warehouses, refuse disposal
facilities, sewage treatment plants, city asphalt
plants, etc., should be located in industrial or
remote areas. Some, such as water ar sewer pumping
stations, must be located in residential areas, and
in these cases landscaping should be provided.
Section 6.131 c page 77 - Sewage Disposal Policies
(WATER AND SEWER UTILITIES)
c. Location of treatment plant facilities should be
reviewed by JAPB for conformity with the comprehensive
plan, projected impact on surrounding areas, and suit-
ability of site plan.
The proposed location of the Arlington East Treatment Plant
(Site #1 - Mill Coe Road) was reviewed by this agency for Metropolis
Clearinghouse and for re-zoning reviews. Finding that the plant and
its location were in accord with area-wide plans and policies, the
staff gave favorable reviews in each case (RPCBP-3 date 8/31/73)
and Ord. 73-1548 datedl/15/74. The staff also participated in
the citizens committee meetings organized by EPA.
121.
AREA CODE 904 / 633-2690 / ROOM 401 -COURTHOUSE / JACKSONVILLE, FLORIDA 32202
-------
Mr. Bob Cooper
February 25, 1976
Page Two
The factors that led to the determination that the site (#1)
fulfills the intent of the above mentioned policies are listed
b e 1 ow:
1. Presently, there is no development on the south, west,
and north sides of the proposed location.
2. The residential development on the east is separated
by an existing lake.
3. The proposed 114 acre buffer included in the project,
for ensuing retention of existing trees and for additional
tree planting and landscaping provides adequate visual
as well as environmental protection to surrounding
areas.
I hope this clarifies our stand on this program. If you need
any further information, give me a call.
Sincerely,
:dward D. Baker, AIP
Executive Director
EDB:BKM:fj
122.
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123
-------
APPLICATION FOR A DEPARTMENT OF THE ARMY PERMIT
One set of original drawings and two copies which show the location and character of the proposed activity must be
attached to this application (see sample drawings and checklist).
1. Application number (To be assigned by Corps).
2. Date.
Feb. 1976
Day
Mo.
Yr.
3. For official use only.
4. Name and address of applicant.
City of Jacksonville
Department of Public Works
220 East Bay Street
.Jacksonville, Florida 32202
Telephone —*- 90^/633-2920
Social Security No.
N/A
5. Name, address, and title of applicant's authorized agent for permit application coordination.
Sverdrup & Parcel and Associates, Inc.
11 East Porsyth Street
Jacksonville, Florida 32202
Telephone Number __.„
90V356-5503
6. Describe the proposed activity, its purpose and intended use. including a desct-ption of the type of structures, if any
to be erected on fills, or pile or float-wjported platforms, and the type, composition and quantity of materials to be
discharged or dumped and means of conveyance.
Construct sewage treatment plant subaqueous outfall force main extending.
across Mi3.1 Cove, Marion Island and Quarantine Island into the St. Johns
River for discharge of secondary treated effluent. Disturbed area to
be returned to natural elevation.
7. Proposed use.
Private O
Public0
Commercial O
Other O (Explain in remarks)
8. Name and addresses of adjoining property owners whose property also adjoins the waterway. ^Cont'd - Item 15)
City of Jacksonville ' Herbert B. Holler, Jr.
220 East Bay Street Post Office Box Ul •
Jacksonville, -Florida 32202 Atlantic Beach, Florida 32233
James 0. Buck
•1709 St. Johns Bluff Road
Jacksonville, Florida 32211
Lois P. Tindell
Post Office Box 8787
Jacksonville, Florida 322H
9. Location where-proposed activity exists or will occur.
From Sec. 1 Twp 2 South
Sec. In • Twp_J-..South
27
_27.
27 East, to
East*
{Where applicable)
Florida
Duval
Jacksonville
Sun
County
in • City or Town
Nww - Ci'» of Town
10. .Name of waterway at location of the activity. Mill .COVe and St. Johns River
«:».,-
ENG
FORM
1 APR 74
REPLACES ENG FORMS 434S AND 434S-1 (PART A). MAY 71
AND 4345-1 (PAHT B». JUN 71. WHICH ARE OBSOLETE.
{EP 1145-2-1)
W..-4.-1 O . IS - I
II
Exhibit 8
124.
-------
ti. Date activity is proposed to commence.
Unknown
Oats activity is expected to be completed..
Unknown
12. Is any portion of the activity for which authorization is sought now complete? Yes O
If answer is "Yes" give reasons in the remarks section. Month and year the activity
was completed . Indicate the existing viotte. on the drawings.
No 03
13. List all approvals or certifications required by other Fetter*!, interstate, state or local agencies for any structures.
. construction, discharges, deposits or other activities described in this application.
Issuing Agency Type Approval Identification No. Date of Application Date of Approval
D.E.R. Water Quality & Utility Application being prepared
E.P.A.
Water Quality & Utility
Installation Perait
Application to construct
. pollution source
3 Feb. ?6
Pending
14. Has any agency denied approval for the activity described herein or for any activity directly related"to the activity
described herein? Yes D N» S3 (If Yes" explain in remarks) ' • ..'
15. Remarks {see paragraph 3 of Permits Pamphlet for additional information required for certain activities).
Item No. 8 (Cont'd) .
Thomas C» Mundy, Sr.
9133 Fort Carolina Road
Jacksonville, Florida 32211
16. Application is hereby made for a permit or psrroiu to authorize the activities described'herein. I certify that I am
familiar with the information contained in this application, and that to the best of my knswleuge and.belief such_
information is true, complete, and accurate. Ifurther certify that I pssvss the authority to undartajp-eirpfoposed
activities. 0^" °^ Jacksonville
NJi
Director "
orics
18 U.S.C. Section 1001 provides that: Whoever, in any manner within the jurisdiction of any department or .
agency of the United States knowlingly and willfully falsifies, conceals, or covers up by any trick, scheme, or device
a material fact or makes any false, fictitious or fraudulent statements or reoresentations or makes or uses any false
writing or document knowing ssme to contain any fs'se fictitious or fraudulent statement cr entry, shall b* finsd not
more than $10.000 or imprisicnad not more than five years, or both.
The application must be si^cd by the person who dssires to undertake the proposed activity; however, the application
may be signed by a duly authorized agent if accompanied by a statement by that person designating the agent and'
agreeing to furnish upon request supplemental information in support of the application. .
If the activity Includes the discharge of dredged or fill material in navigate wafers o» the transportation-of dredged
material lor the purpose of dumping it in ocean waters, the application must be accompanied by a fee of Si00 for
quantities exceeding 2500 cubic yards and S10 for quantities of 2500 cubic yards or less. Federal. Slate and local
governments are excluded from fhis requiremant
125.
-------
JAliltC / '" / '. - - jr ^ >>>««1^-O • ' ' ' _J - - .•
SFH /"• ^^^yr^; .- '^A-—"CUT" ! --°^x;
-^ ..J-^p^^*^^ '"" i29 '"""/"
:
QUARANTINE
ISLAND-
31, - :-.
Reed Island
T-PROJECT LQCATION---
.-.J^^<: ••• .;/>S-(7S
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A-siite- £» -^M^%
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.iQ-Ar»o &ot I?J/;TOM r,^e^
LOCATION MAP
FROM
EASTPORT QUADRANGLE
AND
ARLINGTON QUADRANGLE
7.5 MINUTE SERIES
U.S.. GEOLOGICAL SURVEY MAP
scale in fset
2000 1000 0 200O
JS- 40.2, ARLINGTON EAST DISTRICT
'
126.
C'JTPAUL FOSCS MAIN
SVERDRUP a PARCEL AND ASSOC-.INC.
GENERAL CONSUITANT
CITY OF- JACKSONVILLE
DEPARTMENT OF PUBLIC WORKS
PROPOSED SUBAQUEOUS OUTFALL
FORCE MAIN CROSSING MILL COVE
a EXTENDING INTO ST. JOHNS RIVER
JACKSONVILLE* FLORIDA
DATE:
5,
SHEST i OF s
-------
JS-40.2, ARLINGTON EAST DISTRK
OUTFALL FORCE MAIN
SVERDRUP a PARCEL AND ASSOCv
GENERAL CONSULTANT
CITY OF JACKSONVILLE
DEPARTMENT OF PUBLIC WORK
•PROPOSED SUBAQUEOUS OUTFAL!
FORCE MAIN CROSSING MILL C0\
a EXTENDING INTO ST. JOHNS RIVE
JACKSONVILLE, FLORIDA
DATE* FEBRUARY 5,1978
SHEET 2<
-------
m
yj
JS-40.2, ARLINGTON EAST DISTRICT
OUTFALL FOHCg MAIN
SVERDRUP a PARCEL AND ASSOCvIN
GENERAL CONSULTANT
CITY OF
DEPARTMENT
JACKSONVILLE
OF PUBLIC WORKS
PROPOSED SUBAQUEOUS OUTFALL
FORCE MAIN CROSSING MILL COVE
a EXTENDING INTO ST. JOHNS RIVER
JACKSONVILLE, FLORIDA
OATEi FEBRUARY 5,1375
SHEET 3 OF
-------
££/>
o
EAST DISTRICT
OUTFALL FORCE MAIN
£
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12
9.
SVERDRUP a RARCEL AND ASSOCvlN
GENERAL CONSULTANT
CITY OF JACKSONVILLE
DEPARTMENT OF PUBLIC WORKS
PROPOSED SUBAQUEOUS OUTFALL
FORCE MAIN CROSSING MILL COVE
& EXTENDING INTO ST. JOHNS RIVER
JACKSONVILLE, FLORIDA
OATE« FEBRUARY S, I9T6 SHEET 4 OF
-------
"D
130.
SVERDRUP a PARCEL AND ASSOC-,!N(
GENERAL CONSULTANT
CITY OF JACKSONVILLE
DEARTHENT OF PUBLIC WORKS
PROPOSED SUBAQUEOUS OUTFALL
FORCE MAIN CROSSING MILL COVE
EXTENDING INTO ST. JOHNS RIVER
. JACKSONVILLE, FLORIDA
-------
NATURAL
pRAOE
50'
LIMITS OF CONST
M.L.W.
m
' . ' *
CANA» BOTTOM X^.
.
id
PIPE TRENCH BOTTOM
.
!
1
>
?
2
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I
. '
V.
<
•V"
It
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3
'RUCTION CANAL
EL. -f.O
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it
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NATURAL
GRADE
r ' r
PROPOSED 42ir POLYETHYLENE
f OUTFALL FORCE MAIN
TYPICAL SECTION •-
HORZ.
VERT.
EXCAVATE PIPE TRENCH V/HERE REQUIRED.
PROVIDE 3l MiN. COVER OVER PIPE.
CANAL TO BE FILLED WITH MATERIAL
REMOVED, RETURNING DISTURBED, AREA
TO NATURAL. ELEVATION.
131.
JS-40.2, ARLINGTON EAST DISTRICT
OUTFALL FORCE MAIM
SVERDRUP a PARCEL AND ASSOCvlNC.
GENERAL CONSULTANT
CITY OF
DEPARTMENT
JACKSONVILLE
OF PUBLIC WORKS
PROPOSED SUBAQUEOUS OUTFALL
FORCE MAIN CROSSING MILL COVE
a EXTENDING INTO ST. JOHNS RIVER
JACKSONVILLE, FLORIDA
DATE' FSSaUART 5, r»76
SHEET S OF 8
-------
30-. SHF.ZTIMG, STEEL OR WOOD '
30.1 It is to be understood that ths cost for a.ll sheeting, that has been
driven and pulled by cha Contractor, as specified in Section 2B, shall bo include
in the unit price for pipe work. Steal sheeting driven and left in place for all
depths when authorized by ths Er.ginaar or called for ou the Contract: Drawings, -w:
be paid for at the unit price bid in the Proposal.
30.2 All sheeting used for trenches ten ft. in depth or less, is for the Coi
tractor's benefit only, whether steal or wood and will not be a payable item. ~L:
vood sheeting is used for excavations 10 feet or less in depth, it shall be left:
in place and cut off, a niniirun of 30 inches below grade and will not be a payab!
item-. If the Contract Drawings and Documents call for steel -sheetins to ka left
in place for depths 10 feat or less or as authorized by- the Engineer, than it vil
ue paid, for a£ fclife uuic price uiu iu Lhe
31. SIIaATION AHD EROSION " . - •
• *
31.1 .The Contractor shall take steps and make suitable provisions to mini-
mize siltation and erosion of -waterways which may result fron,, or.as a result of.
operation during the course of construction of. this project.
V
31.2 The Contractor is ccutiqnad that during the excavation and/or main-
tenance of the subject project, creation of turbidity in the excess of -fifty" (5CT
Jackson Units (measured in accordance vith the State of Florida's Department of
Pollution Control Technical KsEorandurz 4-4) above the background level and/or
directly or indirectly affecting the water quality in any waterway in such a mam
as to exceed ths limitation on the concentration of various constituents for sucl
waters as prescribed in Chapter 17-3, Florida Administrative Code., is a violatioi
of the Water Quality Standards of the State of- Florida.
31.3 Turbidity shall not exceed, fifty (50) Jackson Units as related to stan-
dard caitdle turbidineter above background within one hundred (100)- feet of the Ci
struction activity. • _
31.4 The Contractor is hereby advised rhat silt barriers ara to be used at-
all waterway crossings or at any time during construction that "Siltatian or Ero
may occur.
31.5" The Contractor shall submit to the Engineer for written approval, prio
•to construction, the method to bs used to 'control the turbidity as stated in par
graph 31.3. "The Engineer's approval of the method to be used in no -way relieves
Contractor of liability in case of a citation by the Department of Enrirooiaental
Regulation. . •
End of Section 1A
132,
-------
CHAPTER III
WRITTEN COMMENTS ON DRAFT EIS WITH
EPA RESPONSE
Part A; Comments received from Federal, State, and local
agencies, and private organizations,
Part S; Individual comments sent directly to SPA,
Part C; Individual comments sent to other parties and
forwarded to EPA for reply.
133.
-------
PART A
AGENCY COMMENTS ON THE DRAFT EIS
Presented herein are all letters of comment received by
EPA on the Draft SIS from Fed-eral, state, and local agencies
as well as private organizations. The letters are presented
in the order in which they were received. Responses have
been made individually.
134.
-------
A.I.
JACKSONVILLE CHAPTER
FLORIDA ENGINEERING SOCIETY
affiliated with
NATIONAL SOCIETY OF PROFESSIONAL ENGINEERS
January 20, 1976
A,La.
Environmental Protection Agency
Region IV
lU21 Peachtree St. N. E.
Atlanta, Georgia 30309
RESOLUTION
WHEREAS, The Jacksonville Chapter, Florida Engineering Society, is
an organization of professional engineers with a vital
interest in community activities; and.
WHEREAS, The proposed Arlington Sewage Treatment Plant of the City
of Jacksonville is a major engineering project affecting
the environment, economy and quality of life in Jacksonville;
and
WHEREAS, The construction of this plant will phase out a significant
number of smaller plants and systems presently discharging
waste to tributary streams in the Arlington area; and
WHEREAS, The design of this facility has incorporated: a buffer zone
of one hundred eighteen acres to be used as a passive re-
creation area, and provisions of noise and odor controls; and
WHEREAS, Detailed environmental assessments and impact studies of the
proposed site and fourteen alternate systems and sites have
determined the original site would cause no significant and
environmental damage; and
WHEREAS, This site would save the citizens of Jacksonville approximately
$•^,000,000 and be an operative facility one year sooner than
any other site.
NOW, THEREFORE, it is resolved that the Jacksonville Chapter of the Florida
Engineering Society endorses the proposed Environmental Impact Statement
Draft as prepared by the Environmental Protection Agency which approves
locating the Arlington Sewage Treatment Plant atr the Millcoe RoacTsite
with quarantine Island Outfall,
Respectfully submitted,
arl~W. Crist, President
R. 'J-oyce-; Jr., Secretary
135.
-------
A.I. Response to comments by the Jacksonville Chapter of the
Florida Engineering Society
Response A-l.a,
None required
136.
-------
A-.2,
UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE
State Office, P. 0. Box 1208, Gainesville, FL 32602
Mr. John E. Hagan, III
Chief, SIS Branch
Environmental Protection Agency
1421 Peachtree Street, N. E.
Atlanta, C-A 30309
February 6, 1976
Dear Mr. Hagan:
RE: Draft Environmental Impact Statement on Arlington-East Service
District, Wastewater Management Facilities, Jacksonville, Florida
EPA Project No. C120541
Our staff has reviewed the subject statement and we offer the follow-
ing comments:
A. 2. a. Tb-e corresponding mitigation numbers, beginning with impact number 14,
page 355, should be corrected for clarity.
The statement is well done and we have no further comments to offer,
We appreciate the opportunity to review and comment.
Sincerely,
S. Austin
State Conservationist
cc: R. M. Davis
F. G. Maxwell
LJ SJ
a. 'i i ni i_-'t i .n,
-j^
137.
-------
A. 2. Response to comment by U. s. Department of Agriculture,
Soil Conservation Service
Response A. 2, a.
Chapter VI of the Dra£t SIS summarized unavoidable
adverse impacts and available mitigative measures. Impacts 1
though 13 correspond to mitigative measures T though 13.
However, the mitigative explanation for adverse impact No,
1* was inadvertently omitted,, hence confusion in correlating
the remaining impacts and mitigative measures, when the
mitigative explanation for adverse impact No. 14 (slight
water quality degradation in a small mixing zone at the
point of discharge in the St. Johns River) is insertedr the
remaining mitigative measures (14-28) should each be
advanced one number. There will then be a total of 29
unavoidable adverse impacts and corresponding mitigative
measures.
Mitigative measure No. 14- should read:
"Large dilution factors, thorough mixing afforded by
strong tidal currents, and the ability of pollutants to exit
the estuary on ebb tidal cycles, will ensure minimal effect
on water quality and maintenance of accepted water quality
standards. *»
138.
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A.3
FLORIDA WILDLIFE FEDERATION
AFFILIATED WITH NATIONAL WILDLIFE FEDERATION
4080 NORTH HAVERHILL ROAD, WEST PALM 8SACH, FLORIDA 33407
' ^>S. PHONE: (305) 633-2328
Executive Director
JOHN C.JONES
President
C. RICHARD T1LL1S
2812 Rosco-mjrion Drive
TaitariasseeVF'L 32303
1st Vice President
WILLIAM M. BLAKE
P. O. Sox 9066
Tampa, FL 33604
2nd Vice President
WALTER BRANDON
2321 Fairway Dnva
West Palm Beach, FL 33401
Secretary
HERBERT R. PRUETT
1 408 3.E. Bayshore Drive
Apt. 1201
Miami, FL 33131
Treasurer
FRANK COLLINS
1 48 Abaca Orivs
Palm Springs, ?L 33460
Region 1 Directors
HERS ALLEN
1301 Pasadsna Dr>ve
Dunedin, FL 33S28
DOROTHY SAMPLE
200 Sunset Drive
St. Petersburg, FL 33707
Region 2 Directors
SEN. LEW 8RANTLEY
422 Copaland Street
Jacksonville, FL 32204
DR. FRANK PHILPOTT
420 N.W. 25th Street
Gainesville, FL 32601
Region 3 Directors
W. CARROLL HIXSON
206 West Lloyd Street
Psnsacola, Florida 32S01
DAVID E. LA HART
Rt. #12, Box 978
Talianassee, FL 32304
Reaion 4 Directors
WILLIAM F. COLEMAN
7237 Pioneer Road
West Palm Beach, FL 33406
RALPH E. JOHNSON
295 N. W. ISStft Street
Miami, Florida 33169
Region 5 Directors
.. CHARLES E, FORD
4109 Merryweather Drive
Orlando, FL 32309
ROBERT W. HOfWOOO
275 Gray Road
Melbourne, FL 32901
Directors-at-Large:
T. N. ANDERSON
JAMES WINQHAM
JEANNE NISWONGER
MURRAY OVERSTREET, JR.
O.L. "Sonny" PEACOCK
February 18, 1976
Mr. Jack E. Ravan
Regional Administrator
Environmental Protection Agency
1421 Peachtree Street N. E.
Atlanta, Georgia 30309
Dear Mr. Ravan,
The Florida Wildlife Federation has reviewed the Environmental
Impact Statement on the Arlington-East Waste Treatment Facilities
in Jacksonville, Florida.
We recommend that you prohibit any use of these facilities to
serve developments —present or future— in any coastal wetland A. 3. a
areas. The service area for the proposed facility which is being
considered for a federal grant includes coastal wetlands, parti-
cularly in its eastern portion.
The Environmental Protection Agency has frequently stressed the
need to protect wetlands, both tidal and fresh, in many actions.
It also has specific responsibilities to do so under Section 404
of the NEPA. It is a concordant step for EPA to require in its
grants for waste, water treatment facilities equal protection of
those vital areas.
We have not: been able to attend the local hearings on this matter
and therefore ask that you include this letter of recommendation
in your hearing record on the Arlington-East Waste Treatment Faci-
lities.
Sincerely,
A.3.b
(/
John C. Jones
Executive Director
139.
Printed on 100% reclaimed waste
-------
A, 3, Response to comments by the Florida "Wildlife Federation
"Response A. 3. a.
SPA most strongly agrees that the coastal wetland areas
located,,- for the most part, in the eastern portion of the
Arlington-East Service District should not be developed*
However, it must be recognized, that EPA has no control over
local zoning. Most of the area in question is currently not
zoned for any type of development (refer to figure 2-30 in
Draft EIS). This means that any future development in these
areas must be approved and zoned appropriately. The
Development Plan for 1990 developed by the Jacksonville Area
Planning Board (refer to figure 2-29 in Draft EIS) has
designated the wetland areas in the service district, as
well as other extensive wetland areas throughout the county,
as preservation or conservation zones* This Development
Plan, as well as the Short Range Development Plan, provide
direction for efficient land use development and for
protection of these environmentally sensitive areas as well
as for proper phasing of required community facilities.
Throughout its analysis of alternatives, the EPA gave
strong consideration to effects on environmentally sensitive
areas. These areas are shown on figure 2-37 of the Draft
EIS. By referring to figure 3-1 of that document,- it may be
seen that such consideration is not in conflict with the
ultimate interceptor system associated with the planned
facilities.
Response A.3.b.
Although the need to protect wetlands is implicit in the
letter and spirit of the National "Environmental Policy Act
of 1969, the Act does not contain a Section 40U nor any
section dealing with wetlands in particular, section 404- of
the Federal Water Pollution Control Act as amended, however,
does address shellfish beds, fishery, wildlife, and
recreational areas but only as they might be affected by
dredging and spoil disposal. No such activities are
associated with the planned Arlington-East project. In any
case, any such future activities planned for navigable
waters would require a permit from the 0. S. Army Corps of
Engineers,
140.
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A.4.
DEPARTMENT OF HEALTH, EDUCATION. AND WELFARE
REGION IV
50 7TH STREET N.E.
ATLANTA, GEORGIA 30323
February 19, 1976 OFFICE OF THE
REGIONAL DIRECTOR
HEW-627-1-76
John E, Hagan, III
Chief, EIS Branch
Environmental Protection Agency
1421 Peachtree Street, N.E.
Atlanta, Georgia 30309
Subject: Arlington-East Service District
Wastewater Management Facilities
City of Jacksonville, Florida
Project No. C120541
Dear Mr. Hagan:
We have reviewed the subject draft Environmental Impact Statement,
Based upon the data contained in the draft, it is our opinion
that the proposed action will have only a minor impact upon the
human environment within the scope of this Department's review.
A. 4. a. The impact statement has been adequately addressed for our
comments .
Sincerely yours,
Philip P Sayre
Regional Environmental Office
DHEW - Region IV
141.
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A.O- Response to comments by the 0. S. Department of Health,
Education and welfare
Response A.4.a.
None required
142.
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A.5.
DEPARTMENT OF PUBLIC WORKS
C.C. Holbrook, P.E., Director
Engineering
Streets and Highways
Water Services
Sanitation -
Traffic Engineering February 25, 1976
Mr. John E. Hagan III, Chief
Environmental Impact Statement Branch
U. S. Environmental Protection Agency
1421 Peachtree Street, N.E.
Atlanta, Georgia 30309
Dear Mr. Hagan:
Draft Environmental Impact Statement on the Arlington-
East Service District, Wastewater Management Facilities
Jacksonville, Florida, EPA Project No. C 120 541 010
I refer to your letter of December 26, 1975, enclosing
a copy of the Draft Environmental Impact Statement for
the subject project and requesting comments on the
Impact Statement.
The Department of Public Works has reviewed the Draft
Environmental Impact Statement in its entirety and
attended the January 26, 1976, public hearing held
on the draft statement at 7:00 p.m. in the Council
Chambers, 15th floor, City Hall, Jacksonville, Florida.
The statement thoroughly evaluates the environmental
effects of the proposed action and if no action is
taken. The statement provided a complete disclosure
of potential impacts of all the alternatives. The
draft statement revealed that Alternative 12 (South
edge of Craig Field), Alternative 1 (Millcoe Road),
Alternative 2 (Dunes area), Alternatives 4 and 5
(East of Craig Field), Alternative 3 (Daines Point--
Ft. Caroline Freeway), Alternative 11 (Quarantine
Island) and Alternative 4 (North of Craig Field) ,
were all reasonably close with regard to environ-
mental effects and that Alternative 1 was shown <
to be the least costly. In the final analysis,
there were no appreciable adverse environmental
effects on any of the sites evaluated. However,
there were considerable differences in the costs
ranging from $2 million, difference between Millcoe
site and the Dunes area (the second most costly
site) and $16.4 million, difference between the
Millcoe site and the Beacon Hills site (the most
costly).
143.
AREA CODE 904 / 333-2920 / 220 S. SAY STREET / JACKSONVILLE, FLORIDA 32202
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John E. Hagan III
February 25, 1976
Page Two
B.S.a. We concur with the administrative action of awarding
grant funds to the City of Jacksonville, Florida, for
the preparation of plans and specifications for a 10 MGD
Wastewater Treatment Plant to serve the Arlington-East
District to be located at Millcoe Road, Alternate la,
and 13,900 feet of outfall line terminating at the
edge of the maintained shipping channel in the St.
Johns River.
Sincerely, _*L
rtJ-tfP
oe H. Hyatt/P.E.
Deputy Director of Public Works
JHH/ns
144. - 145
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A.5. Response to comments by the City of Jacksonville,
Department of Public Works
Pesoonse A.5.a.
None required
146.
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A.6. ;
UNITED STATES DEPARTMENT OF AGRICULTURE!
FOREST SERVICE
1720 Peachtree Road, N, W.
Atlanta, Georgia 30309
8400
February 27, 1976
Mrv John E. Hagan,. Ill
Chief, EIS Branch
Environmental Protection Agency
Atlanta, Georgia 30309
A.6.a.
A.S.b.
Dear Mr. Hagan:
Here are United States Forest Service, State and Private
Forestry comments on the draft environmental statement
entitled, "City of Jacksonville,. Florida,. Wastewater
Management Facilities, Arlington - East Service District'*.
Generally, project impacts on forest lands and resources
are adequately described and evaluated. We especially
commend project use of a professional forester to check
proposed interceptor corridors for rare and/or large tree
specimen. We assume, also, that the statement on page 333
relative to the absence of any unusually large or rare
trees on the proposed plant site is based on a professional
forester's examination.
Since the Service Area is already deficient in recreational
lands and project induced growth is expected to double the
present demand by Year 2002, the 144 acres of woodland
proposed for buffer zone should be considered for more than
passive recreational use. We recommend consultation with
the local representative of the Florida Division of Forestry
relative to management of the tree cover on the 200 feet
wide buffer strip and the 114 acre buffer zone for aesthetic
and recreational purposes.
Thank- you for the opportunity to review and. comment on this
excellent draft EIS.
EPA-IMPACT STATEMENTS
Area Environmental Coordinator
cc: Florida Division of Forestry
147
i-* •" * f "*, ^ /
nN Kl*R ,':
REGION 17, ATWNTA, GA,
S200.I1 (1/69
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A,6. Response to comments by the U. S, Department of Agri-
culture, Forest Service
Response A.6.a.
The Millcoe Road plant site as r*2ell as all other
alternative sites were visited and evaluated by an SPA
terrestrial biologist. His findings show no unusually large
or rare species of trees existing in the area to be cleared.
Re s po n s e A. 6 . b.
The bufter zone will initially be maintained as a
passive recreation area by the City of Jacksonville
Department of Recreation. Eventually, the Department will
evaluate recreational needs in the area and, if warranted,
propose a plan for recreational development of the buffer
zone to the City Council.
148.
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J. ' A;7
v UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
Review of Draft EIS for the City of Jacksonville,
SUBJECT: Florida Wastewater Management Facilities- DATE: Mflo
Arlington-East Service District
FROM: Kenneth E. Biglane, Director
Division of Oil and Special Materials Control (WH-548)
TO: Jack Ravan, Regional Administrator
Region IV
Attn: John E. Hagan, lit
Chief, EIS Branch
The comments of the Office of Water Program'Operations on the
subject EIS are enclosed. Should any of the issues raised in these
comments require clarification, please contact Geraldine Werdig,
Chief, Environmental Evaluation Branch (202) 245-3054.
Project Description
Location: Jacksonville, Florida on the ocean side of the St. Johns
River
Proposed Action: A 10 MGD wastewater treatment plant and 13, 900
feet of outfall line terminating at the edge of the maintained
ship channel in the St... Johns River. The project includes
interceptor lines, a sludge incinerator, and provisions
for land spreading of sludge.
Fourteen alternatives were evaluated, including different
sites, transmission systems,, and outfalls. A citizens
committee was assembled to provide input into the analysis
and assist in the ranking of the alternatives*
Major Issues: Potential noise and odor impacts from a wastewater
treatment plant were the main areas of concern. Extensive
discussion was provided on these two areas.
OWPO Project Reviewer: David A. Eberly
Enclosure
149.
EPA Bsrm 1320-6 (R.v. 6-72)
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Office of Water Program Operations
Comments on
Draft EIS for the
Wastewater Treatment Facilities,
Arlington-East Service District
This is a very good example of an issue-oriented EIS, with the primary
emphasis being on the noise and odor factors. These are the areas that have
apparently been of the greatest concern to the citizenry. Considerable effort
has gone into an in-depth examination and evaluation of the potential effects
of the alternatives as regards noise and odor. We commend the region on
preparing such a good issue-oriented statement and encourage you to continue
and expand the use of this approach in future EIS's. We have only a few
minor comments to offer.
A.7.a-. 1. The discussion on wastes from water craft (p. 87) should reference the
proposed EPA regulations for a Marine Sanitation Device Standard
(Federal Register, Vol. 40, No. 198; Friday, October 10, 1970).
A.7.b. 2. The population increases attributed to the Westinghouse Company's
Offshore Power Systems project do not quite agree with the figures
in the U.S. Nuclear Regulatory Commission final EIS for Floating
Nuclear Power Plants. This document should also be included in
the references.
A.7.C. 3. The second paragraph on page 321 should refer to alternatives 5 and
6 rather 4 and 5.
A.7.d. 4. The project cost on page 326 should be $48, 559, 307, not $48, 449, 307.
A.7.a. 5- The chlorinated effluent will cause a localized kill of the animal segment
of the plankton (p. 337). Although this is expected to be negligible,
provisions should be made for dechlorination should the effects be
greater than anticipated.
150.
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A*7 Response to comments by U. S, Environmental Protection
Agency, Division of Oil and Special Materials Control
Response
In the Federal Register, Vol. 40, No, 198 of Friday,
October 10, 1975, the EPA published proposed standards of
performance for marine sanitation devices. These standards
do not req-uire the installation of a toilet facility on any
vessel not so equipped but apply only to vessels en which a
marine toilet facility has been installed. The U. S. Coast
Guard has the statutory responsibility to implement the EPA
vessel sewage standard,- promulgated certification
procedures, and design and construction requirements for
marine sanitation devices,
Response A.7.b.
The Draft EIS states that the Westinghoxise company's
Offshore Power Systems (OPS) project will employ ap to
10-,000 people directly and 20,000 indirectly, for a total of
approximately 34,000. The U. S» Nuclear Regulatory
Commission's Final EIS relating to the manufacture of .
floating nuclear power plants by OPS {October, 1975) agrees
with this direct employment figure and goes on tc assume
that an in-migration of some 90,000 persons "may occur due
to operation of the (floating nuclear power plant) facility
and related service operations'* at a rate consistent with
the direct employment figure. The effects of operation of
the facility on population growth in the Jacksonville area
are difficult to assess. Some of the complex factors
bearing upon such an assessment are discussed in the NRC
impact statement. It is, however, feasible that the
creation of 34rOOO new jobs could bring about a total in-
migration of some 90,000 persons.
Response A.7.c.
Correct; reference should have been made to alternatives
5 and 6 rather than 4 and 5.
Response A.7.d.
Correct;_the_project cost should read $48,559,307 rather
than $_48,449,307.
151.
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Response A.7.e.
Only as much chlorine as is needed for effective final
disinfection will be used. The Jacksonville Department of
Public Works expects no adverse impacts (i.e., localized
plankton kill) as the result of residual chlorine in the
effluent. The large dilution factors which will be present
in the outfall line "will ensure a zero concentration of
residual chlorine at the point of discharge.
152.
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AV8
United States Department of the Interior
OFFICE OF THE SECRETARY
WASHINGTON, D.C. 20240
PEP ER-76/56
MAR 12 1976
AuS.a.
A. 8 A.
Dear Mr. Hagan:
Thank you for the letter of December 26, 1975, requesting
our views and comments on the draft environmental impact
statement for Wastewater Management Facilities, City of
Jacksonville, Arlington-East Service District, Duval County,
Florida. Our review indicates that the proposal is adequate
as it relates to mineral and cultural resources. However,
several additional areas of concern are discussed below.
From the information provided, it appears that there will be
no adverse impacts to existing public recreation areas from
the plant and its interceptor line, outfall lines, and sludge
disposal sites. Of the 12 alternative plant sites evaluated,
only Site 10 has a recreational area within 3,000 feet.
However, there is a well-recognized secondary impact of in-
creased growth potential in the area from the completion of
this facility (see page ii, c., Secondary Impacts). The
prospect of accelerated development would place a heavier
strain on the existing recreational areas, which are already
deficient by 700 acres (pages 131-133), to fulfill resident
needs- With this in mind, we are pleased to note that the City
plans to purchase and dedicate a 114--acre wooded area for
recreation purposes as part "of the total project (page 2 and
page 303), but we would like the statement to elaborate on
proposed plans for this area* Similarly, the statement should
include plans for the 200-foot-wide buffer zone with vegetative
screen (page 2), as this tract could also help meet some of
the recreation needs mentioned on pages 131-133. In addition
to the passive use anticipated in the buffer zone and the 11M—
acre area (page 303), the statement should address the potential
for some active recreation development.
There ^may also be some potential for trail development or im-
proved public access along rights-of-way associated with the
sewer lines. The final statement should address this in the
same section.
153.
!J <--,--- t '. V^fO i
H I*. KOAXTAi
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"A 98-acre wooded area" proposed for purchase and use as a
recreational area has been referred to (page 187, paragraph 1),
while elsewhere it h?s been stated that "a 114— acre wooded area
will be purchased by the City and dedicated as a recreational
area" (page 2, paragraph 5). A reference has been made to a
"buffer"" zone of"118 acres adjacent to the site" (page ii,
paragraph 3), while elsewhere a reference,is made to "a 114-
acre buffer between the plant site and the surrounding com-
munity" (page 339, last paragraph). As far as we are able to
determine", the 93-acre, 114-acre, and 118-acre areas referred
A.S.c. to are identical. It would be advisable either to make the
figures consistent or to clarify what areas are referred to.
Figure 2-11, page 4-8, Arboristic Cover Types, is not helpful
A.S.d. because the symbols for several tree types are indistinguishable
from one another,
The Flood Prone Areas map (page 58, Figure 2-13) should indicate
A.S.e. the location of the wastewarer treatment facilities to facili-
tate evaluation of effects of flooding. Also, potential effects
of tidal flooding of the St. Johns -River resulting from hurri-
canes and extratropical storms should be discussed.
« g £ The statement should evaluate impacts on the shallow aquifers,
although we anticipate that the net impacts would be beneficial.
We also do not find any conclusions as to the effects of exportir
A.S.g. from the area as sewage effluent much of the groundwater pumped
from the Floridan aquifer; presumably this will be a necessary
environmental cost; but the amounts involved should be put into
perspective with the total amount available from, the aquifer and
A.S.h with other related considerations. We find no information on
sewer infiltration, inflow or exfiltration; presumably modern
materials and specifications will make such losses and their1
effects negligible, but a proper appraisal of the project should
include these aspects. The incineration method of sludge proces-
sing seems adequately described and should greatly reduce poten-
tial impacts on groundwater, if implemented (page 2, 200). we
note, however, that disposal by land spreading is also under
consideration to avoid costs of construction and operation of the
A 8 i incinerator (page 203). The statement mentions potential impacts
of this less expensive method but should more specifically evalu-
ate them. The document should also indicate mitigating measures
for impacts from sludge disposal, including methods for collector
isolating, and/or beneficiation of leachates and plans for moni-
toring.
154.
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Correspondence in Appendix III discusses possible conflicts
between the proposed outfall and navigation channels in St.
Johns River (page 396, paragraph 3-8). The environmental state-
ment mentions that the effluent would be disposed of in approxi-
mately 38 feet of water at a point approximately 500 feet off
Quarantine Island (page 328, paragraph 3). Although potential
conflicts between the outfall pipeline and the' diked dredge
spoil disposal area on Quarantine Island have been discussed
(page 337, paragraph 1), we have found no discussion of poten-
tial conflicts with navigation channels, including the possi-
bility of a future enlarged M-5-foot-deep channel that has been
referred to on page 396.
We appreciate your acceptance of our previous suggestions (letter
of July 15, 1975) pertaining to acceptable plant sites and out-
fall locations. Furthermore, we believe that construction
methods as outlined on page 358 will minimize biological damage..
We hope these comments and suggestions will be of assistance
to you.
Sincerely yours,
\3si3tont secretary of the Interior
Mr. John E. Hagan, III
Chief, EIS Branch
Environmental Protection Agency
14-21 Peachtree Street, M.E.
Atlanta, Georgia 30309
155.
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A.8 Response to comments by U. S. Department of the Interioi
Office of the Secretary
Pestxmse a,8,a.
Refer to response 3,S.b.
Response A. 8. b .
The largest portion of the rights-of-way associated with
the sewer lines are located along city streets, EPA agrees
with and encourages the concept of trail development and
improved public access along sewer line rights-of-way where
feasible. It is, however, the responsibility of the City of
Jacksonville tc take such action where appropriate,
Response A. 3vc.
The three buffer zone areas referred tc are identical.
The correct acreage is 114; refer to Exhibit 2 of Chapter II
for the exact location.
RestxDnse A. 3. d.
Figure 2-11 (Arboristic Cover Types) of the Draft EIS is
reprinted for clarity as Exhibit 3 of Chapter I.
Resoonse A.3.e.
The 0. S. Army Corps of Engineers has conducted flood
frequency studies of the St. Johns River estuary and has
determined that tidal stages of approximately ten feet
M.S.L, can be anticipated in the vicinity of Quarantine
Island at a frequency of once in fifty years. Reaulatory
agency requirements and the dictates of good design practice
necessitate construction of the proposed treatment facility
at elevations not subject to floodings. The very sirall
scale of figure 2-13 ("Flood Prone Areas) of the Craft EIS
would make it extremely difficult to accurately pinpoint the
construction site. However, the U. S. Geological Surrey in
Jacksonville has indicated that the proposed construction
site, with an elevation of approximately forty feet M.S.L.,
would be safe from not only the fifty year but the 100 year
frequency flood as well.
156.
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Response A.8.f.
The shallow aquifer system supplies a much smaller
amount of the total water used in Cuval County than does the
Ploridan aquifer. Some 10 to 25 MGD are withdrawn from the
former while the latter supplies 150 to 200 MGD plus an
additional 50 to 70 MGD at Fernandina Beach {pages 72 to 73
of the Draft EIS). Ten to sixteen inches of rainfall
annually is estinated as necessary to recharge the shallow
aquifer system in Duval County, Rainfall in the area
averages 53.1 inches per year. Impact of the prcpcsed
project on water quality of the shallow aquifer system is
not expected to be adverse,. Indeed, the shallow aquifer is
becoming increasingly attractive as a source of water supply
as the potentiometrie surface of the Floridan aquifer
declines. It is to be noted that withdrawal through wells
is not the only source of discharae from the shallow
aquifer. Springs and seeps,. evapotranspiration, and
downward percolation to the Floridan aquifer also act to
deplete water quantity. Nevertheless, the shallow aquifer
retains a more than adequate supply of water for current and
projected uses.
Regarding quality of the shallow aquifer, the project is
expected to have a beneficial impact since it will minimize
the need for future installation of septic tank systems in
areas not entirely suitable for their proper operation*
This would decrease the possibility of seepage to, and
subsequent contamination of,, the shallow water aquifer (see
pages 290-291 of Draft STS) ~
Reseponse A.. 8. a.
Amounts of water being withdrawn from the Floridan
aquifer in Duval County, as well as the effects of this
withdrawal, have been documented in Chapter II of the Draft
EIS (refer to pages 72 through 75). The deepening cone of
depression in the potentiometric surface of the aquifer
centers around downtown Jacksonville (refer to figure 2-17
of the Draft EIS), In fact, throughout most of the
Arlington area, the aquifer maintains a potentiometric head
between 35 and 40 feet M.S.L, The growth supported by the
proposed regional system will increase the present water
supply demand by the year 2002 by approximately seventy-five
percent as the population of the service area increases to a
projected 167,000. However, it is to be remembered that
even without the regional system, the population of the
service district could increase to perhaps 185,000 (see page
157.
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343 of the Draft SIS). Thus, the year 2002 copulation
project of 167,900 with the regional system represents no
induced growth in Arlington, Further, if not allowed to
take place in Arlington, this growth would undoubtedly not
be eliminated but vsould only be dispersed to ether areas of
Jacksonville.
Response A.8.h.
An infiltration and inflow analysis for the Arlington-
East District was completed by Sverdrup 5 Parcel and
Associates, Inc., general consultants on the project, in
December, 1973, The study investigates the extraneous water
flow entering existing collection system elements which will
be tributary to the proposed treatment plant. Excessive
infiltration/inflow is defined as being present in a sewer
system if the cost estimate for its treatment would be
crreater than the cost estimate for its correction. Based on
this economic analysis, infiltration/inflow is nor excessive
in any of the areas tributary to the proposed Arlinaton-East
treatment facility,
Response A.3.1.
The greatest environmental drawbacks to the use of
sewage sludge in land spreading operations are odor and
possible effects on crroundwater. Methods of mitigating
disagreeable sludge odors both at the treatment plant and at
the land spreading site are discussed on pages 202 and 203
of the Draft SIS. As discussed in Chapter I of this
document, a review of sludge disposal alternatives has been
conducted to evaluate alternatives to incineration. These
alternatives include land spreading, land filling, and
pelletization,
?estx>nse A. 3.1.
Refer to U, S. Army Corps of Engineers letter dated
March 17, 1976 which appears as Exhibit 5 ,of Chapter II of
this document.
158.
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A.y.
UNITED STATES DEPARTMENT OF COMMERCE
The Assistant Secretary for Science and Technology
Washington, D.C. 20230
March 19, 1976
Mr* John E. Hagan, III ^
Chief, EIS Branch
Environmental Protection Agency-
1421 Peachtree Street, N.E.
Atlanta, Georgia 30309
Dear Mr. Hagan:
This is in reference to your draft environmental impact
statement entitled, "City of Jacksonville, Florida Waste-
water Management Facilities, Arlington-East Service
District." The enclosed comments from the National
Oceanic and Atmospheric Administration, National Marine
Fisheries Service, are forwarded for your consideration.
Thank you for giving us an opportunity to provide these
comments, which we hope will be of assistance to you.
We would appreciate receiving six (6) copies of the final
statement*
Sincerely,
'Sidney's.. Gaier
Deputy Assistant Secretary
for Environmental Affairs
Enclosure - Memo from: NOAA, National Marine Fisheries Service
(2-17-76)
159.
.IMPACT STATEMENTS
••••,
D
^rPf^udQfl-Uii-ii
K--^ —
I MAR 2 S 1376
i-H IT, «iiANTA. GA.
"75-191*
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February 17, 1976
U.S. DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
NATIONAL MAfllNE FISHERIES SERVICE
Duval Building
9450 Gandy Boulevard
St. Petersburg, FL 33702
FEB27
1976
FSE21/JRH
TO :
TERU:
FROM:
Director
Ofc of Ecology & Environmental Conservation, EE
.^ Associate Director for
J -Resource Management, F3
/
TV William H. Stevenson '""
Regional Director
'/V
SUBJECT: Comments on Draft Environmental Impact Statement — City
of Jacksonville, Florida, Wastewater Management Facilit-
ies Arlington-East Service District (EPA) (DEIS #7601.33
The draft environmental impact statement for City of Jacksonville,
Florida, Wastewater Management Facilities Arlington-East Service
District that accompanied your memorandum of January 27, 1976, has
been received by the National Marine Fisheries Service for review
and comment.
The statement has been reviewed and the following comments are
offered for your consideration,
GENERAL COMMENTS; -
The statement would be much improved if assertion, conclusion,
conjecture, or judgmental decision were identified as such.
Modifying terms such as "significant, insignificant, healthy,
marginally, and poorly" used throughout the narrative should be
defined.
SPECIFIC COMMENTS:
II. The Environment Without the Proposed Action
A. The Natural Environment
3. Wetlands and Water/Land Interface
b. Biota
\
160.
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-. Q Page 60, paragraph 1 - Inasmuch as the intertidal survey results
by Tone in 1972 are cited and qualified fay terms "marginally pro-
ductive" or "unproductive," the statement should make an effort to
"A.9.b. denote by what comparison such conclusions are formed. Inclusion
of sampling methods, the degree of taxonomical efforts used by
Tone and a citation of this work in the reference section would
help to clarify this viewpoint..
\ n Tone's findings show inordinately low benthic invertebrate popu-
lations, however, later in the statement, (Table 2-25 , pages 109-
111) sampling in Mill Cove reported by the Corps of Engineers
(intertidal station 3D) showed at least 13-16 taxa and 14,758-
21,910 organisms per square meter.. That Tone reported 2-3 species
and 128-3 44 Q organisms /m2 and used the term "marginally productive"
seems incongruous to later observations that numerous species and
organisms have been found in the area.
Page SO', paragraph 2 - Since the term "insignificant" is used to
A.9.d. describe benthic populations in the beach zone, the statement
should point out the basis by which insignificance is concluded.
A.9,e. Similarly, does a catch of 23 species truly indicate good diversity
of fish and the great importance of shallow near-shore areas?
A 9 f Psge SO, paragraph 4, Marsh Flora - Advanced waste treatment
* * * capabilities should be added to the benefits attributed to salt
marshes. In a study of the work done and value accruable to salt
marshes, potential waste assimilation work valued up to $2500 per
acre per year has been calculated. i/
4 , Water
b, -Biota
% g _ Page 99', paragraph 1 - The statement is unclear- in reference to
rough and game fish production in the St. Johns River. The source
of the data, its application to the proposed facility, and how it
relates to the commercial fishery and its purported reduction in
catch per unit of effort or time should be given.
Ill . Alternatives
C» Development of. Viable System Alternatives
I/ Gosselink, J.G., Odum, E.P., and R.M. Pope. 1974^ The value
of the tidal marsh. Center for wetland res., Louisiana St.
Univ. / Baton Rouge, LSU-SG-74-03. 30p~
161.
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-A'.Q.h.. Page 257, paragraph 3 - If the routing of the outfall along Fort
' Caroline Road up to a disposal point opposite Bbunt Island is
worthy of consideration, the route line should be depicted on one
of the figures. We find this alternative particularly attractive,
since it would avoid entrenching the outfall line across Mill
Cove. It is stated (page 337, paragraph 1) that a 14-foot deep
trench of unknown width would be dug some 7,000 feet across Mill
Cove with implementation of proposed Alternative 1Q. The state-
ment further relates that a "huge quantity" of spoil would be
placed alongside the trench, but does not describe the method-
^A.9.1- ology. We suggest, therefore, that the statement include:
(a) the amount of material to be excavated;
(b) a description of the excavation methods ; and
(c) the fate of excess spoil materials once the pipeline
is emplaced.
In regard to point (c), it should be considered that a 7,000 by
4-foot outfall pipe across Mill Cove will replace a volume of
material at least equal its own. This would be at least 88,000
cubic feet (3.1416 x 4' x 7,000') or about 3,259 cubic yards of
A.9.J. spoil. The EIS should consider placement of this material to a
location where it would not impair circulation, navigation, or
biota in Mill Cove or adjacent waters.
The DEIS should, therefore, completely discuss the alternative of
routing the outfall pipe along Fort Caroline Road to a disposal
point opposite Blount Island (Alternative 13). This alternative
would forego construction difficulties in Mill Cove, concomitant
losses of estuarine resources, and possibly allow easier repair of
the line if needed in the future. We further note that Alternativ
IB had the second highest EIS rating (Table 3-20, page 317) and
was the third least expensive for project costs (Table 3-23, page
325) .
9. Aquatic Flora and Fauna
A Page 292, paragraph 2 - Documentation should be provided for the
"•"•^•contention that the chlorinated effluent will cause a very localiz
planktonic kill, that significant biostimulation is unlikely, and
that contact by fishes with the outfall plume will not be detri-
mental .
VI. Adverse Impacts which Cannot be Avoided and Available Mitiga-
tive Measures
A. Adverse Impacts
162.
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JV.9..K Page 355, number 15 - The DEIS should include more specific des-
criptions of the impact on the aquatic animal community during and
after construction* The trench across Mill Cove will run about
• 7,000 feet, will be about 14 feet deep, and will possibly require
digging a ^ork channel. Also, once the pipe is emplaced, a loca-
tion for an estimated 3,200 cubic yards of spoil must be found.
B. Mitigative Measures to Adverse Impacts
A.9./R. Page 358', number 13 - In the event that the proposed Mill Save plant
is built, plans should seriously consider rerouting the proposed
outfall line away from Marian Island, not placing spoil on adjacent
marsh, and progressive backfilling of the cut. In our opinion,
however, the best mitigative effort would be to reroute the outfall
line along Fort Caroline Road to an exit point opposite Blount
Island (Alternative IB) .,
It is requested that one copy of the Final EIS be sent our Area
Supervisor, Environmental Assessment Division, NMFS r P.O.. Box
4218, Panama City, FL 32401.
cct
F34, NMFS, Washington, D.C. (3)
FSE213, Panama City,- FL
163.
-------
A,9. Response to comments by U. S. Department of Commerce,
National Oceanic and Atmospheric Administration,
National Marine Fisheries Service
Re spon se A . 9 ..a
Reference is made to Table 2-10 of the Draft SIS, One
specie was collected at Clapboard and Brown's Creeks and
none at Back River. These results were interpretei as an
indication of a lack of biologic productivity. Six species
were collected in Mill Cove leading to an interpretation of
the area as marginally productive.
Re snon se A . 9 . b .
Reference is made to the final report entitled (1An
Ecological Survey of Blount Island with Particular Reference
to Back Rivern prepared by Frederick C. Tone of Battelle,
Inc. for the Jacksonville Port Authority. The report covers
the period January 6, 1972 through March 31, 1972 and was
completed April 28, 1972. Tone's report was appended to the
Final SIS for 31cunt. Island Development completed by the a,
S. Army Corps of Engineers, Jacksonville, in August 1973.
This SIS was cited as a reference in the Arlington-East
Craft but the Tone report was not cited separately.
Response A.9.c,
Refer to the last paragraph of oage 109 of the Drafi
EIS.
Response A.9.d.
Refer to the last paragraph of page 57 of the Draft EIS.
Response A.9.e.
The Tone survey which yielded 23 species of fish did
indicate a good diversity per se; that is, at the time of
the survey. Admittedly, however, neither one nor several
catches is sufficient to assess the population and
utilization of the near shore area. A comprehensive .._._ _.. _
samplincr effort of 1 to 2 years would be needed for this
purpose. Available information was used "By EPA in the Draft
EIS (i.e., the Tone survey); more extensive efforts were,
unfortunately, not available.
164.
-------
"Response A. 9. f.
The value of the marsh-estuarine aquatic system in
providing" advanced waste treatment has been discussed in the
Draft EXS (refer to page 54}, Further, the reference cited
by NOAA in their letter of February 17, 1976 was used and
cited by EPA as a reference (see page 380 of Draft EIS),
Response A.9.q.
The source of the data is shown on page 99 of the Craft
EIS as the Water Quality Management Plan for the City of
Jacksonville. The application of the data to the proposed
facility is to show one aspect (i.e., declining
productivity) of an estuary long siibjected to excessive
waste loadings. Finally, the Draft EIS is clear in stating
that the fisheries catch realized by each fisherman is
decreasing for equal time spent.
Response A.9.h.
The Blount Island outfall would be installed parallel to
Fort Caroline Road thence northward across the Beacon Hills
subdivision entering the St. Johns River near the southeast
corner of Blount Island as shown on maps for alternatives 4
through 3 in the Draft 513 and alternative 12 in this
document.
Response a.9.i..
Refer to Exhibit 8 of Chapter II for outfall line
construction details and conditions,
Response A..9.1.
All excess spoil will be placed on Quarantine Island at
a site approved by the Corps of Engineers.
Response &. 9. k»_
Refer to response &.7.e, for discussion of the effects
of residual chlorine in the effluent, Significant
biostinvulation (i.e., plankton blooms) as well as adverse
effects to fishes are unlikely due to the level cf treatment
the effluent will have received and due to the large
dilution factors available at the point of discharge.
165.
-------
Response A.9.1.
Impact on the aquatic animal community durinq and after
construction of the outfall across Mill Cove has been
addressed in the Draft SIS, Refer to pages 291, 293, and
337 of that document.
Restxsnse A.9.rn.
Cros'sing Marian Island with the outfall line will result
in temporary disturbance of approximately two acres salt
marsh*. From the outfall location nap included in Exhibit 8
of Chapter IT, it may be seen that routing the outfall
around the island would result in considerably areater
disturbance (i.e., trenching) of the bottom of Mill Cove.
Further, Marian Island is subrneraed at mean high tide {refer
to engineering drawings included in Exhibit 3 of Chapter II)
and should thus be very responsive to natural restoration
after completion of mechanical restoration by the
contractor.
*(about one-half acre on Marian Island itself).
166.
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ff. 10'
STATE OF FLORIDA
I*jrartm*itt nf A&mitttjsiratum
Division of State Planning
Reubin O'D. Askew
860 Apalachee Parkway • IBM Building SOVSRNO*
TAJLLAHASSEE
RG Whittle. Jr. . 32304- Lt. Gov. J. H. "Jim" wiun
SWTC PUWN.NC OiWCTOR * «"""ST"T"»
C90
-------
Mr. Jack E. Ravan
March 23, 1976
Page Two
after evaluating the overall economic and environmental factors relating
to the twelve proposed alternatives, Alternative One is generally acceptable
and, if immediately implemented, may abate a critical pollution problem.
However, we recommend that the effluent discharge at the outfall line on
Quarantine Island be re-evaluated after the Corps of Engineers has completed
their river modeling study to determine its affect on Mill Cove..
In accordance with the Council on Environmental Quality guidelines
concerning statement on proposed federal actions affecting the environment,
as required by the National Environmental Policy Act of 1969, and U.S.
Office of Management and Budget Circular A-95, this letter, with attachments,
should be appended to the final environmental impact statement on this project.
Comments regarding this statement and project contained herein or attached
hereto should be addressed in the statement.
We request that you forward us copies of the final environmental
impact statement prepared on this project.
Sincerely,
R. G. Whittle, Jr., Director
RGW:k:em
Enclosures
cc: Mr. John Bethea
Mr. Charles Blair
Mr. Robert Williams
Mr. J. Landers
Mr. Joe Hyatt
Mr. Harmon Shields
Mr. William Ravenell
Mr, Wayne Voigt
Mr. Jack Merriam
Mr. W. N. Lofroos
Mr. H. E. Wallace
Mr. Walter 0. Kolb
168.
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State of Florida
DEPARTMENT OF NATURAL RESOURCES
HARMON W. SHIELDS
Executive Director
A.10.a.
CROWN BUILDING / 202 BLOUNT STREET / TALLAHASSEE 32304
February 20, 1976
Mr. Wayne C. Voigt, Chief
Bureau of Intergovernmental Relations
Division of State Planning
660 Apalachee Parkway, IBM Building
Tallahassee, Florida 32301
Dear Mr.. Voigt:
Reference is made to your memorandum dated February 4
requesting review and comments on SAI 76-1373E — Draft
Environmental Impact Statement, City of Jacksonville,
Wastewater Management Facilities, Arlington-East Service
District.
Pursuant to your request the Department staff has
reviewed the Draft Environmental Impact Statement and
provides the following comments for your consideration:
"The staffs of the Bureau of Coastal Zone Planning
. and the Bureau of Marine Science and Technology
have reviewed the environmental impact statement.
The following comments represent the composite
views of both bureaus:
I* Alternatives 1, 2 and 3 do not appear to
be the most preferable for a project of
this magnitude. The necessity of crossing
Mill Cove, a water body currently suffering
sedimentation problems as well as water
quality problems, with a 13,800 foot outfall
line does not appear to be consistent with
the goals and objectives of either bureau.
It is our concern that the amount of con-
struction within the water body and the
subsequent environmental destruction could
seriously affect an area whose health is
already marginal. Moreover, the end of the
REUB1N O'D. ASKEW
Governor
BRUCEA.SMATHERS
Secretary of State
ROBERT L.SHEV1N
Attorney General
GERALD A. LEWIS
Comptroller
PHILIP F. ASHLER
Treasurer
DOYLE CONNER
Commissioner of Agriculture
RALPH D. TURLINGTON
Commissioner of Education
169.
V ADMINISTRATIVE SERVICES • LAW ENFORCEMENT « MARINE RESOURCES
DIVISIONS /
-------
Mr. Wayne Voigt
Page Two
February 20, 1976
pipe itself will jut into the St. Johns River
at one of the narrowest strictures of the commer-
cial ship channel. While this may be a minimal
safety concern it would be sounder planning to
locate any outfall pipe at a wider portion of
the river.
.A.lO.b. 2. Alternatives 6, 7 and 8 also appear to be
inappropriate for a project such as the one
at hand. These alternatives would necessitate
modification of a large freshwater swamp immedi-
ately east of Craig Airfield. Because of the
water retention, filtration, recharge and
wildlife habitat functions of large swamps,
it appears that the environmental trade-offs
involved in destroying the integrity of this
habitat could override the benefits of an
integrated sewage system for the Arlington area.
, IQ.c. " 3. Staff recommends against Alternatives 9 and 11.
The Florida Coastal Zone Management Atlas^ indi-
cates that both sjtes are located within the
statistical 100 year hurricane flood zone. The
amount of investment necessary to protect such
a large public work does not seem to be warranted
and would not be sound coastal zone management.
.10.d. ^e Bureau staffs would, therefore, recommend consideration
of Alternatives 4, 5 and 10 as the most feasible. We do
note that Alternative 4 contains some swamp area. It
appears, however, that the swamp comprises no more than
1/4 to 1/5 of the area to be utilized. Further, the
swamp is not part of a major system such as the swamp
.east of Craig Field, but appears to be a remnant area,
modified by past development and contributing little environ-
mental value to the area. Alternative 4 would also offer
the advantage of utilizing lands adjacent to a moderately
busy airfield (more than 100,000 flights annually) in a com-
patible land use design. The environmental trade-offs not-
withstanding, it appears that Alternative 4 should definitely
receive serious consideration.
Alternative 5 appears to be quite suitable for this activity
and should be considered seriously as well. Since the area
in question has extremely sparse development presently,
170.
-------
Mr. Wayne Voigt
Page Three
February 20, 1976
planning should insure that compatible land uses
develop in and around this site as the area grows.
Finally, Alternative 10 offers most of the advan-
tages of either Alternative 4 or 5. Additionally,
it offers the benefit, in case of an accident or
spill, of location close by a large relatively
natural marsh system should it be necessary to
dispose of untreated or semi-treated effluent in
cases of peak overloadt the assimilative capacity
of the marsh itself could be used to take up this
overload without affecting the St. Johns River itself.
While it is recognized that the St. Johns River along
this reach is Class III waters and would never be
used for commercial shellfishing, etc*, it is our
opinion that the maintenance and improvement of
St. Johns River water quality could conceivably be
aided by building in this safety feature*
The combined staffs of the bureaus would, therefore,
recommend consideration of the three afore-mentioned
alternatives as most feasible for the project at hand.
Sincerely,
James G. Smith
Administrative Assistant
JGStrt
170a.
-------
"DEPARTMENT OF™'COMMUNITY. AFFAIRS .
Division of Technical Assistance
A-95 COMMENTS
U.St Environmental
r-iginator Protection Agency
Subject
Reviewer
Wastewater Management
Facilities for Jacksonvi]
Date 3/2/76
Staff review has 'been made of the Environmental Impact
Statement. The project would meet the goals and objectives
of this Department. Therefore, we would have no adverse comments
,« We would note that the facilities are planned for or will
-"• 'pass through areas prons to the 100 year flood. We will assume
that the facilities will be flood proofed as recuired. .
171.
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STATE OF FLORIDA
DEPARTMENT OF ENVIRONMENTAL REGULATION
2562 EXECUTIVE CENTER CIRCLE, EAST
MONTGOMERY BUILDING
TALLAHASSEE, FLORIDA 32301
REU8IM O'O. ASKEW
GOVERNOR
JOSEPH W. LANDERS, JR.
SECRETARY
March 18,
Mr. Wayne Voigt
660 Apalachee Parkway
Division of State Planning
Department of Administration
Tallahassee, Florida 32304
Env*ar3:onmental Impact Statement
Wastewater Management Facilities
Arlington East District/
Jacksonville
S.A.I, Project. No* 7 6-137 3E
Dear Mr. Voigt:
Our Department has reviewed the subject environmental impact
statement and is generally in agreement with the final conclu-
sions. Planning- for this particular project started about 1970
and as a result of this planning effort/ our Department certified
to the Environmental Protection Agency, a Step 2 grant application
(for development of project plans & specifications) on April 9,1974.
Since our Step 2 certification, some controversy arose from resi-
dents in the area concerning the proposed plant location on Mill-
coe Road. This site location controversy prompted the Environ-
mental Protection Agency (EPA) to declare and produce the subject
environmental impact statement.
The project consists of a 10 MGD activated sludge treatment facility
(25 MGD ultimate year 2002) located on a 46,98 acre site. The
plant will discharge effluent through a 13,900 ft.-48 inch outfall
including 7,500 ft., of subaqueous line across Mill Cove and Quaran-
tine Island to a 35 ft- depth on the near slope of the shipping
channel on the St. Johns River. This particular discharge point
was choseri by city coordination with the U.S. Corp of Engineers.
In an attempt to further isolate the plant, the city of Jacksonville
will purchase 114 acres adjacent to the plant site to be used by
area residents as a passive recreation area. The proposed site on
172.
-------
Mr* Wayne Voigt
Page Two
March.18, 1976
Millcoe Road has the advantage of being near the centroid of the
service area, which translates into the shortest possible lengths
of transmission lines in order to get sewage flow to the plant,
This particular fact is why alternative Ho, 1 '(Millcoe Road site)
is nearly 2.0 million dollars less than the next nearest alternative.
Since almost any project such as buildings, roads, bridges, treat-
ment systems, etc,, causes environmental damage to some degree, it
is an advantage to the environment to keep sewage line lengths as
short and direct as possible,
The proposed sewage treatment outfall line construction will cause
some short term stream erosion and sedimentation, however, no long
term impacts are anticipated from those now existing. It will
improve the tributary streams however .
This project will immediately, upon completion, phase out four of
six city owned treatment systems in this service area presently
discharging to tributaries and eventually will phase out other
systems in the service area.
The estimated project cost for this project in 1974 was about
26 million dollars, The current estimate of the project cost
is 48.5 million. The project cost has almost doubled in about
two years. Any further delay in the project (for example change
in treatment plant site and/or outfall location) will not only
prolong below-standard pollution discharges in the area, but will
also mean escalation in project costs with the necessity or
higher sewer service charges for area customers,
In summary, it is our concern to:
1} Abate pollution in the area by removal of below-standard
discharges to tributaries of the St. Johns River,
2) Preservation of high quality waters and other environ-
mental factors.
3} Alleviation or prevention of groundwater contamination.
It is our opinion based on voluminous data presented in the envi-
ronmental impact statement, that the proposed Millcoe Road pro-
ject will meet these goals with a minimum of environmental dam-
age, and, further, it is the most cost effective alternative of
those presented,
Sincerely yours,
Howard L. Rhodes, P.E.
Chief, Wastewater Management
HLR/tmh and Grants
cc: Robin Fletcher
\ 173.
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• FLORIDA GAME AND FRESH WATER FISH COMMISSION
RANDOLPH R. THOMAS. Chairman
Jacksonville
£ P. "SONNY" BURNETT. Vica Chairman HOWARD OOOM
Tampa Marianna
DR. O. E FRYE. JR., Director
H. E WALLACE Deputy Director
ft M. 8RANTLY, Deputy Director
DONALD G. RHODES D.D.S.
Satellite Beacn
GEORGE G. MATTHEV
Palm Beach
FARRIS BRYANT BUILDING
620 South Meridian Street
Tallahassee. Florida 32304
March 19, 1976
Mr. Wayne C. Voigt
Bureau of Intergovernmental Relations
Department of Administration
620 South Meridian Street
Tallahassee, Florida 32304
Ret SAI 76-1373, City of Jacksonville
Arlington-East Service District
Wastewater Management Facilities
Dear Mr. Voigt:
We have reviewed the draft environmental impact statement for the proposed
Arlington-East Service District Wastewater Management Facilities and offer the
following assessment. Our comments are provided relative to our responsibilities
of protecting the state's fish and wildlife resources.
The City of Jacksonville, in conjunction with Flood and Associates consulting
firm and Sverdrup and Parcel engineering firm, proposes to construct regional
wastewater treatment facilities to service the Arlington-East District. The pro-
ject will provide for (1) the removal of inadequately treated wastewater that
presently flows into tributary streams and the St. Johns River, and (.2) reduction
of adverse conditions resulting from the operation of septic tank systems.
. The operation of the waste treatment facility will discharge 10 million gal-
lons per day and ultimately 25 million gallons per day of secondary treated waste-
water into the St. Johns River and will have other minor impacts such as opera-
tional noise and odor. The construction of the project will probably increase the
potential for development of areas that do not have this potential presently.
The primary concerns of this agency are related to the potential impact of the
project on water quality in Mill Cove and problems with plant site placement. This
assessment is not intended to restrict the progress of the project, since imple-
mentation will be a significant factor in reducing the problems 'of the St. Johns
River. Rather, the purpose for our concerns and recommendations is to reduce, as
much as possible, the potential problems associated with the construction of the
plant and the discharge into the river.
174.
-------
Mr. Wayne C. Voigt
Page two
The City or Jacksonville has recommended alternative #1 (Millcoe Road System)
as the most viable site for construction of the proposed plant. This site is
located bet-ween Merrill Road and Monument Road, about 2.5 miles due south of Mill
Cove. It is about 47 acres in size and_has an average elevation of 40 feet mean
sea level, i-he southern portion being well above the highest flood stage of the
extreme lower St. Johns River.
The treated plant effluent would be discharged through 13,900 feet of 48
inch outfall line, including 7,500 feet of subaqueous line, north across Mill
Cove and Quarantine Island to the aain channel of the St. Johns River.
The portion of the tract to be affected is a sand ridge, vegetated by long
leaf pine and turkey oak. Wire grass is the primary ground cover. The upper sand
ridge slopes to a marshy area through which a small creek runs. Several hydric
species of plants occur here including pickerel weed, bulrush and cinnamon fern.
Maples, gums and scattered cypress occur in this area. The applicant has indi-
cated this zone will not be affected.
Inasmuch as the area proposed for the plant is within a fairly populated and
developed area, and trends show the population increasing in this vicinity, it is
our opinion that the low to moderate wildlife habitat that exists now will soon
be lost to community expansion. We have no objections to the plant being built
at this sice. We do, however, have several concerns regarding the outfall pipe
that traverses Mill Cove and Quarantine Island. After discussing the matter with
representatives from the City of Jacksonville, it is our opinion that several
extremely pertinent factors have not been adequately examined. First, there have
been no studies involving the fate of the effluent after discharge into the river
10.f,(DEIS, page 363, paragraph 2), and it is our opinion that the possibility of back-
flow into Mill Cove is considerable. This possibility is heightened by two factors:
(1) There will be a barrier placed riverward of the outfall which is designed to
disperse the effluent. It appears to us that this will keep the treated water
close to shore and thus will accentuate movement into Mill Cove as the tide fluc-
tuates, and (2) the effluent can enter Mill Cove at two points, one at the east
end of Quarantine Island and the other at the west end of Quarantine Island. In
fact, this point of discharge is probably the site location with the highest po-
tential of allowing faackflow into Mill Cove»
The Corps of Engineers has constructed a model of the lower St. Johns River
basin and is studying the hydrographies of this area. These results are due in
the next few months and this may aid the concerned agencies in the answer to
questions relative to the water movements into Mill Cove, We feel it is impor-
tant to consider this point since the pipe will discharge 2,500 pounds (and ul-
timately about 6,300 pounds) of BOD per day into the river. Since Mill Cove
has incurred considerable silting in the past few years it is recognized that-
the system has problems with adequate circulation, and if backflow of the effluent
would occur, these problems would only be compounded by further water quality
degradation.
175.
-------
Mr. Wayne C. Vbigt
Page three
• Regarding plant siting, we feel that the City of Jacksonville and the con-
sultants should have considered the possibility of utilizing available natural
systems for points of discharge for the outfall pipe. For instance, site #5 is
located on a xeric pine ridge that slopes quickly to a series of tidal creeks and
\. 10.g.marshes that ultimately dissipate into the St. Johns River. While we are uncer-
tain of the effects of this volume of water being discharged into this marsh, area,
there remains the possibility that this system could accomodate this flow and
could provide a free filtration system for the effluent before it reaches the
river. If this is a viable option, the potential problems of damaging the St.
Johns River system with the effluent BOD and suspended solid loads would be con-
siderably reduced*
In conclusion, the aims and goals of this agency would not be served by
delaying this project for another year. On the other hand, we want the best pos-
sible solutions to the problems of the St. Johns River. If feasible, we feel
that the applicants should attempt to'relocate the outfall pipe away from the
openings into Mill Cove and possibly to a site where natural filtration systems
could be utilized to further cleanse the effluent* If further assistance is
required, please contact us.
Sincerely,
H, E. Wallace
Deputy Director
HEW/GAH/dg
176:.
-------
\ JOHNS RIVER WATER MANAGEMENT BISTRIC
ROUTE 2 BOX 695
PALATKA, FLORIDA 32077
TELEPHONE 9C-4 • 235 - 53S3
March 23, 1976
MEMO TO: Mr. Walter Kolb
FROM: Jack Merriam
SUBJECT: Arlington East Sewage Treatment Plant
As an outcome, of the information provided in the March 12 meeting
which you held in Tallahassee, I would like to modify my original
comments to you on this project. The environmental impacts of
sites number 1 and 2 are not different enough to warrant addit-
ional time delays and costs. However, the two disposal sites may
have significantly different environmental impacts. My analysis
favored the Bloun.t Island site over the Quarantine Island site.
A.lO.h. There are still some unanswered questions concerning the impact
of the Quarantine Island disposal alternative upon Mill Cove.
It seems imperative that the impact of the Quarantine Island
outfall upon Mill Cove be adequately assessed before construction
is begun. If it can be demonstrated that the outfall will not
cause new problems in Mill Cove or exacerbate existing problems,
I would be better able to support the Quarantine Island site
over the Blount Island site.
JM/jba
-------
A.10. Response to state agency comments forwarded by
the State Planning and Development Clearinghouse (A-95)
Response A.10,a.
Refer to Exhibit 4- of Chapter II for comments relative
to the project*^ impact on water quality of Mill Cove.
Refer to Exhibit 5 of Chapter II for comments relative to
the relationship bet-ween the outfall line and the commercial
ship channel in the St. Johns River.
Response A.lO.b.
Choice of site 7-3 would eliminate approximately 15
acres of wetland habitat while site 5-6 is covered
predominantly with longleaf pine and turkey oak.. Site 7-8
is ranked lower than site 5-6 primarily due to its effects
on freshwater wetlands. In any case, both sites are not
among the highest rated alternatives from an environmental
standpoint (refer to impact ratings shown in Chapter 3 of
the Draft SIS) .
Response A.10..C.
Sites 9 and 11 are both less than 10 feet above mean sea
level and measures which would be necessary to prepare them
for construction are described in the Draft EIS (pages 193
and 19U). Once again, both sites are not among the higher
rated alternatives from an environmental standpoint.
Restxmse A.lO.d.
The alternative analysis appearing in Chapter III of the
Draft EIS gave serious consideration to all alternatives.
It is noted that the choice of site 4- would eliminate 31
acres of cypress swamp (page 279 of Draft) while the choice
of site 10 would eliminate approximately 46 acres of mature
hammock, the cover type least abundant within the service
district (page 280 of Draft). As seen in the environmental
impact ratings, site 5-6 was rated relatively high
environmentally; choice of either of these alternatives,
however, would also incur relatively high costs.
Response A.lO.e.
Refer to response A.8.e.
178.
-------
Response.^.. 10_._ :f.__
Refer to Exhibit U of Chapter II.
Re spon se A.iQ.j.
As stated on page i of the Craft ETS, and discussed a-
length throughout that document, the project will provide
for the removal of inadequately treated wastewaters from
tributary streams.
Hesconse A.lO.h.
Refer to Exhibit u of Chaoter II.
179.
-------
R Q Whittle, Jr.
STATE PLANNING CXRKTOB
AMI.
STATE OF FLORIDA
of Abtttitustratum
Division of State Planning
660 Apalachee Parkway • IBM Building
TALLAHASSEE
3230*
C90'O
Reubin O'D. Askew
Lt. Gov. J. H. -Jim* Will!
SCCXCTMT at AOMINISttATION
March 29, 1976
Mr. Jack E. Ravan, Regional Administrator
U.S. Environmental Protection Agency - Region.IV
1421 Peachtree Street, N.E. <
Atlanta, Georgia 30309
Dear Mr. Ravan:
In a letter dated March 23, 1976, we reviewed and com-
mented on the following draft environmental impact statement:
City of Jacksonville, Florida, Wastewater Management
Facilities Arlington-East Service District SAI # 76-1373E
Since that time we have received amended comments from the
Department of Natural Resources which we are forwarding to you.
We request that you consider these comments along with those pre-
viously sent.
Sincerely,
R. G. Whittle, Jr
Director
RGW:K:ga
Enclosure
cc: Mr. John Bethea
Mr. Charles Blair
Mr. Robert Williams
Mr. J. Landers
Mr. Joe Hyatt
Mr. Harmon Shields
Mr. Wayne Voigt
Mr. Jack Merriam
Mr. W. N. Lofroos
Mr. William Ravenell
Mr. H. E. Wallace
Mr. Walt Kolb
180.
-------
State of Florida
DEPARTMENT OF NATURAL RESOURCE
HARMON W. SHIELDS
Executive Director
CROWN BUILDING / 202 BLOUNT STREET /TALLAHASSEE 32304
REUBINO'D. ASKEW
Governor
BRUCE A. S.MATHERS
Secretary of State
ROBERT L. SHE VIN
Attorney General
GERALD A. LEWIS
Comptroller
O PHILIP F. ASHLER
>O Treasurer
DOYLE CONNER
Commissioner of Agricultu
RALPH 0. TURLINGTON
Commissioner of FMucatto
March 19, 1976
\
Mr. Wayne C. Voigt, Chief
Bureau of Intergovernmental Relations
Division of State Plannincr ^
660 Apalachee Parkway, IBM Building"
Tallahassee, Florida"32301
Dear Mr. Voigt:
«
\
Reference is made to our February 20 letter providing
comments on SAI 76-1373E — Draft Environmental Impact
Statement, City of Jacksonville, Wastewater Management
Facilities, Arlington-East Service District.
The attached modified comments by our Bureau of Coastal
Zone Planning are provided for your consideration,
Sincerely,
j James G. Smith
P Administrative Assistant
JGS:rt
Enc.
181.
DIVISIONS /
ADMINISTRATIVE SERVICES • LAW ENFORCEMENT • MARINE RESO URGES
\: Pi U i _D V
P_P.5 O 1.' ^.£ R
-------
State of Florida
DEPARTMENT OF NATURAL RESOURCES
TO:
FROM:
RE:
FiCE MEMORANDUM
Charles M. Sanders, Director
Division of" Resource Management
Bruce Johnson, Chief
Bureau of Coastal Zone Planning'
March 15,
MAR
Div. of Rsswra Mgmt.
jjPt of fotursi Resources
March 12, Clearinghouse, Subject: SAI 76-13 7 3E, Arlington
East Wastewatar Treatment Facility
As a result of additional information provided by the Jacksonville
Public Works Department and • their, consultants on the Arlington
East Was tewater. Treatment Facility, the Bureau of Coastal Zone
Planning and the Bureau of Marine Science and Technology wish to
offer the following modified comments as their recommendation
to the Clearinghouse on this project:
A..LT.3. 1_ It does appear that alternate 1 is a feasible site
particularly in light of the total cost as compared
with that of the other sites considered. If this
site is chosen, however, we would prefer that all
possible consideration be given to rerouting the outfall
pipe through the Beacon Hills section rather than through
Mill Cove and across Quarantine Island.
^ ^_ k 2. It is also apparent that sites 5 and 6 are suitable as
well as site 10. In case of the impossibility of utilizing
site 1 these alternatives would be more preferable than
any of the others herein presented.
It is, therefore, our opinion that there is little difference
between alternates 1, 5f 6, and 10 with the exception of the
potential detriment associated with the proposed outfall line
of alternate 1 now crossing Mill Cove. We would, then, recommend
realignment of the outfall if at all possible.
Thank you for the opportunity to comment.
BJrtls
182.
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A. 11. Response to amended comrrents from the State of Florida
Department of Natural Resources forwarded by the State
Planning and Development Clearinghouse (A-95)
Response A.11.a.
Chapter III of the Draft HIS gave extensive
consideration to the Blount Island outfall. For further
information relative to the project's impact on Mill Cove
refer to Exhibits '-* and 8 of Chapter II,
Resconse A.ll.b.
Refer to response A.lO.d.
183.
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PART B
INDIVIDUAL COMMENTS ON THE DRAFT EIS
Presented in this section are those letters sent
directly to SPA by private individuals commenting on the
Draft EIS, The issues raised by these people have been
addressed elsewhere in this document and/or in the Draft*
In addition, most of these letters have been answered
directly under separate cover. Those that have not are
answered herein.- Presentation is made in the order in which
the letters were received by the Agency.
184.
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1056 OAK STREET
January 5, 1975 JACKSONVILLE. FLORIDA 32204
(904) 358-3372
Mr* JackE, Ravan, Regional Administrator
United States
Environmental Protection Agency
Region IV
1^21 Peachtree Street N.E.
Atlanta, Georgia 30309
Re; EPA Project C 1205^1
Arlington East Service District
Waste Water Management Facilities
Jacksonville, Florida
Gentlemen;
As a member of the citizens advisory committee appointed
"by your agency to review alternative sites for the above
referenced facility I am extremely disappointed with your
approval of the Mill Coe site. As your records indicate,
I do not live within the affected area. I represented the
Jacksonville Area Chamber of Commerce and was one of five
committee members representing the community at large.
After numerous hours of reviewing environmental and cost
data for the proposed Arlington East facility the committee
recommended a site in the Dunes area north of Regency Square,
The only committee members not agreeing with this site
selection were City of Jacksonville officials. Four of the
five city representatives voted against the committee site
recommendation. The fifth official, a councilman representing
the Arlington area voted in favor of the committee recommendation.
While I understand the manner in which the data was weighed in
order to arrive at your final decision to approve the Mill
Coe site, I do not feel that the Environmental Protection
Agency gave sufficient weight to the input of the community.
Since the citizens on the committee (other than city officials)
all agreed that the Dunes area was most favorable and the
cost differential was negligible, it would seem that that
site would have been the logical choice. It is certainly
the best site environmentally according to your survey,
Have we arrived at the point in time where people are not
served by government but mandated by it ? I certainly hope
not. I personally feel that the intent of the advisory
committee was good and that if the Mill Coe site be finally
185,
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Page 2
Mr* Jack E. Ravan
Environmental Protection Agency
January 5, 1976
selected that not only have we as committee members wasted
a great deal of time, but that your Agency and the City
of Jacksonville would be making a sham of the process intended-
to aid citizens in the selection of their community environmental
destiny.
Obviously I intend to be present at the public hearing on
January 26, 1976 and make my feelings known, I'm not sure
that the outcome of this hearing will be given much credence
since the committee recommendation certainly was not*
I urge that you reconsider the approval of the Mill Coe site
and that the original site selected by the City of Jacksonville
and later selected by the advisory committee, Dunes Area I , be^
approved as the final site for this most important facility.
Thank you for your consideration.
Thomas F. Brewer
TPB/ft
CG: Hon. Hans Tanzler, Mayor
City of Jacksonville
Hon. Charles E. Bennett
Congressman
b
Assistance Committee Members
186.
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1924 Holly Oaks lake Road West
Jacksonville, Florida
January 9, 1976
President Gerald Ford
1600 Pennsylvania Avenue NW
Washington, D. C.
Dear Mr. President:
As a citizen of a small carraunity, Holly Oaks Forest, a subdivision in Jacksonville,
Florida, I, along with I'm sure all of our residents, wonder if we any longer have
any voice in our Government.
The City of Jacksonville purchased 46 acres adjoining our community to build a major
Sewage Treatment Plant. If we were to overlook all of the obvious reasons for not
wanting this plant, the size alone irakes it totally incompatible with our residential
area.
We requested an Environmental Impact study, and the EPA finally selected a 15-man
Citizens Committee to study the 12 sites under consideration: 5 city members, 5
interested parties, and 5 disinterested. After much study on their part, the site
chosen was not our Millcce site but a sand dune area devoid of hates and wildlife
and ideal for heavy industry. Among those voting for this sand dune was a Chamber
of Conmerce member and a representative frcm the League of Women Voters, both
among the five disinterested citizens. Cnly 4 of the 5 city members voted for our
site. The final citizens vote taken at its last official meeting recommended the
dunes site by a vote of 9 to 4.
In spite of the Citizens Committee study and recairrendation, the EPA has new issued
its study which supports the city's preselected sits: our adjoining property.
We have requested help thru all channels including our Congressman who was quoted
in our Tings-Union newspaper as saying "it was a political decision and he could not
see why a Federal Agency was getting involved in it; and he though such decisions
should be left to local officials." This makes us wonder why we have an EPA.
It is impossible to relate our two years of frustration. We believe this site will
set a precedent by putting this plant in a residential neighborhood.
Where do people go to be heard if we've tried everyone but our President?
Sincerely yours,
jUL^> #t (J
Helen R. Werder
187.
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Patricia Jean Pill more
3826 Tara Hall Drive
Jacksonville, FL 32211
January 13, 1976
Mr» John R. Quarles, Jr.
Deputy Administrator
Environmental Protection Agency
kOl M. Street N.W.
Washington, O.C, 20460
Dear Mr. Quarles:
In reference to the Waste Water Management Facilities, Arlington East
Sewer Distric, Jacksonville, Florida, ! am questioning the E.P.A. approval
of the plant sight at Mill Cove Road.
The citizen committee chosen by the E.P.A. of 5 city representatives,
5 partial and 5 impartial members did not even consider the proposed
sight on Mill Cove Road in the first 6 chosen sights.
Also the Mill Cove sight and one other vri 11 affect Mill Cove on the
St. Johns River. A study quoted on page 398, Oept. of Natural
Resources, and page ^01, Flood and Associates, Inc., "These alternate
sights have in camion a proposed fall out in or quite close to Mill
Cove. At present Mill Cove is suffering serious sedimentation problems
dae to -Construction at either end caused by continuous maintenance
spoilage associated with adjacent ship channel. Navigational charts less
than 10 yeaes old indicate less than 15 feet throughout the cove while
existing depth probably does not exceed 6 feet except in isolated spots.
The staff is therefore concerned about additional sediment build up in the
cove as well as possible pollution problems associated with the extreamly
poor circulation of the cove if these alternates were implemented."
Mill Cove is a protected marshland, many private homes are built along the
Cove and a plus 300 member, family branch YMCA utilizes the cove for
recreational sports. These factors seem to have been ignored and I feel
further studies should be carried out before the city begins construction
on the Arlington East Sewer Plant at Mill Cove Road. At present construc-
tion will probably begin after January 26 the date of the last public
hearing on the proposed sight, As Mayor Hans Tanzler has already publicly
announced that the Mill Cove Sight is the final decision.
Sincerely yours,
Pat Pillmore
188.
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•* ?*! S? f -» "'"'•"ST*
-
January 13, 1.976
1056 OAK STREET
JACKSONVILLE, FLORIDA 32204
(904) 358-3372
Jack E. Ravan, Regional Administrator
United States Environmental Protection Agency
Region IV
1^21 Peachtree Street
Atlanta, Georgia 30309
Res Draft Environmental Impact Statement
SPA Project C 1205^1
Waste Water Management Facilities
Jacksonville, Florida
Dear Mr, Ravan:
It has been brought to my attention that there will be
considerable citizen input at the public hearing pertaining
to the above referenced draft EIS "(January 26, 1976).
The draft denotes preliminary approval of the Mill Coe site -
as requested by the City of Jacksonville. Since public
sentiment seems to favor the Dunes site (as did the citizens
advisory committee) the following questions arise:
1) Should, after the public hearing, the City
of Jacksonville request approval of the
Dunes site, would it'"be necessary to have
additional studies made by EPA?
2) Should the City of Jacksonville request approval
of the Dunes site, would SPA approval be imminent?
If not, could you approximate the time frame
for approval?
3) How is the inputof the public hearing to
be weighed?
I would appreciate any assistance which your Agency
could offer in answering these questions for me, Thank
you for your assistance
Thomas F. Brewer
STATEMENTS
TFB/ft
189,
REGION IV, ATLANTA, GA.
-------
January 15,'1976
Mr. Russell Train
Administrator
Environmental Protection Agency
401 M Street, N. W.
Washington, DC 2046Q
He: Sewer Plant in Arlington East
Jacksonville, Florida
Dear Mr. Train:
I object to the E.P.A. 's support and approval of the site selected fay
the City of Jacksonville, Florida, for the location of a large sewerage
disposal plant. The plant's site is adjacent to the Holly Oaks Forest
residential area and is very much opposed by the local residents. This
opposition brought about an investigation by the E.P.A. from Atlanta,
Georgia. The E.P.A. created a cormittee of 15 members, five from the
city, five from Holly Oaks Forest and five from Duval County to determine
possible alternatives. Using the criteria selected by the E.P.A*, the
cortnittee, by a vote of 11 to 4, found that the site selected by the City
was harmful to the environment and selected another one. Your Department
then over-ruled the findings of your committee on the basis of economics.
Economics was one of the criteria your men selected for the conmittee to
consider in making their choice. It seems that the committee has a higher
regard for the impact on the environment of the local area than dees your
DeDartment.
filliam Colville
WC:bs
William Colville EPA • IMPACT STATEMENTS
10238 Lakeview Road Wesi
Jacksonville, FL 32211
10238 Lakeview Road West Fnin^fr'DrPnn HI"?
U< JAN 2 6 1976
K3IOK IV -WUNTA. GA,
190.
-------
January 20, 19?6
Mr. Hussall Train, Administrator
Svironmental Protection Agency
*K31 >! St., N. W.
Washington, D. C, 20460
Bear Sir :
In 1969 we purchased our present home which is located in the Holly Caks
section of Jacksonville within sight of the present location being con-
sidered as the first choice of the Arlington £ast Sewage Treatment Plant.
We have heard various promises, claims and counterclaims that the proposed
sewage plant would XCT endanger the environment, would NOT create a health
crcblem or be a public nuisance. I DC NOT believe any of these promises
and cite as an example a study made by the EPA. A review of this lengthy
study discloses that had this plant been constructed as originally proposed
it would have resulted in noise and air pollution, However, supposedly
these hazzards will be reduced except during short periods of time (accor-
ding to EPA).
The people of Holly Oaks are at a loss to explain or understand WHY such
a plant has to be placed in a populated area of upper to middle income
homes (or an3/ residential area) when there are vast stretches of unpopu-
lated land to the East or 1 mile south which seem more suitable except
for economic reasons. We do not feel it is fair to place such a burden
on our families by its construction at the proposed location.
If the plant is constructed in our neighborhood what guarantee do we have
against the possible noise and air oolluticn not to mention the economic
impact on cur residences . If these faars nrove to be true we feel we
would get the deaf ear treatment and that our only recourse would be to
move at a considerable financial less.
We appeal to you by all that is right and decent not to approve the city
of Jacksonville's recommendation for the site of the Arlington Plant
but to relocate it AWAY from populated areas. Let those who live near it
do so by choice and not by force,
Sincerely
1703 Cellar Circle
Jacksonville, Fla. 32211
191.
-------
January 23» 1976
Mr* Russell Train, Administrator Re: Arlington-East Regional
Environmental Protection Agency Sewage Treatment Plant
U01 M Street N¥
Washington, D. C. 20460
Dear Sir:
The Environmental Impact Statement prepared by the people from your
Atlanta office gives the weakest kind of approval to the Mill Coe Road site,
calling it "a reasonable alternative*"
Many people in Holly Oaks have fought for two years to establish their
position that a regional sewage treatment plant does not belong within 1000
feet of an established residential community* However, it appears that the
B.P.A. is yielding to intense pressures coming from—where?—the city ad-
ministration? the land developers?
We are writing to ask you. for a full review of the whole affair before
you approve the Atlanta Environmental Impact statement. The people are not
getting fair consideration of their wish to live undisturbed by encroach-
ment of a heavy industrial-type plant*
Very truly yours,
^/£u^~*) - /nr &LM^.& 3*
s - o/
-------
Jacksonville, Florida
January 23, 197c
Mr» Russell Train, Administrator
U. S. Environmental Protection. Agency
It01 M Street N. 1-u
Washington, D. C. 2Gii.60
Dear Mr. Train.:
I aiu writing in regard to the East Arlington Regional Sewage Treatment Plant
in Jacksonville, Florida, which is now purported to be located in the resi-
dential area of Holly Oaks Forest,
Gould you tell me why the 3.?.A, would send representatives from Atlanta to
hold public and semi-public meetings; would hire experts to study and report
on the environmental factors of twelve alternate sites; would compile, at
great expense, an immense impact study, containing many factual errors; would
ask a committee of selected Jacksonville citizens, Holly Oaks residents3 and
city government representatives to spend hours studying this voluminous report
in order to rank a group of environmental factors on a scale of one to ten;
would compare these rankings on all twelve alternate sites - to find that the
committee had ranked the Holly Oaks site as sixth and then would turn around
and say that they haddecided that the plant should be put in Holly Oaks because
that was the cheapest site?
For heavenfs sake, we all knew that from, the beginningI 3»?*A» was requested
to make its own study because we thought that your function was protecting the
environment and quality of life of people - not saving money.
It is a sad commentary on our government when the citizens must go to Washington
for protection from their local officials, but it is even sadder when they can't
get it.
Has all this been an expensive game, played with federal funds (which seem so
important, all of a sudden)? Has all this activity been merely a ploy to hide
the fact that the residents of Holly Oaks are being exploited by the 3.?.A. in
order to appease our local administration, with which it has had so many other
disagreements 1
If so, I have more respect for armed robber, who at least is honest enough to
put the gun in your face and say, "This is a stick-up,"
If you are truly interested in protecting the environment for now - and the
future - you will do a little digging for facts and will find out why certain
factions want the plant on that site. Is it because they want our waterfront
along Fort Caroline Road for future industrial expansion, and they know that
193.
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January 23, 1976
Page 2
this plant is the first step in eventually changing the character of the
neighborhood from residential to industrial, gradually forcing the residents
out and industry in - something they could never otherwise accomplish?
At the risk of repeating myself, let me once again remind yojz that Holly Oaks
Forest is a relatively small, secluded community of naturally wooded, small
estate sized lots, many of which surround our peaceful and serene lake* Its
residents are a closely knit group - almost like a. large family - who, with
their own hanas, built their own Community Club building and fire house,
chipping in money to buy their own fire engine and pumper. They have never
asked the government for anything. The greater part of them are the original
home owners, who felt twenty-five years ago, as they do now, that the privacy,
the peace, the serenity of this beautiful wooded area with its pretty little
lake was well worth the added mileage to and from work* They are not rich,
but hai?e done without other things in order to have the kind of home and
community they could relax in and enjoy.
If the main, reason for protecting the environment is the benefit and protection
of people, then you cannot, in good conscience, approve this site and still
justify your agency's existence* It all boils down to this - Is the develop—
ment o£ large industrial complexes, pouring more pollution into the rivers and
air really more important than the peace of mind and the tranquility of the
spirit of people1 Do only murderers, rapists, traitors, and welfare recipients
have civil rights, any more? High-handed activities such as this are respons-
ible for the growing frustration and resentment of the average citizen toward
his government.
In other words - Is this government, with its many agencies, responsive to the
will of its citizens; do we, in fact, have a government by consent of the
governed?
The government spends all sorts of money to support wasteful programs here and
abroad; now, when we, the very people who work to support these programs, and
oftentimes sacrifice, say to our government, "Please, let us preserve this
peaceful and serene community for our children and grandchildren to come,"
surely our government will not reply, "Sorry, we don't have the money.."
Sincerely*
Mailing Address -
106C5 Lakeview Road Bast
Jacksonville, Fla. 32211
CC: President Gerald R. Ford
Governor Reuben Askew
Senator Richard Stone
Secretary of State Bruce Smathers
State Senator Dan Scarborough
(Mrs.) Helen Fender O'Quinn
• IMPACT STATEMENTS
2 0 1976
194.
- , REGION IV, ATLANTA, GA.
.*.'
-------
January 25, 1976
foii:^ reference to: Arlington-East
Sewage Treatment Plant, Jacksonville, Fla.
Mr. Russell Train
Administrator
Environmental Protection Agency
Washington, D. C.
Sirs
It is inconceivable to us to learn that a federal agency - yours - could
spend one year studying the flora, fauna, swamps, and terrestrial vegeta-
tion of our area, only to base its final conclusion with regard to plant
location on presumed cost differentials between sites.*
We now know that the cost figures, supplied by the city's consultants,
reappear dollar for dollar in the SPA Environmental Impact Study, Are we
to believe that the Atlanta office rigorously audited these figures and
that the auditing was done by qualified cost analysts?
When your own Atlanta office rated another site (South of Craig Field) as
more environmentally desirable but then relented in its decision in favor
of costs* we think a full scale cost audit is called for.
We shall appreciate a response from you on this matter.
Sincerely yours,
195.
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January 25, 19?6
Mr. Russell Train, Administrator Re: Arlington-East Regional
Environmental Protection Agency Sewage Treatment Plant,
U01 M Street N'W Jacksonville, Fla,
Washington, D, C. 2QkoO
Dear Sir:
If you read the letters in the ippendix of the Environmental Impact
Study prepared by the Atlanta E.P.A. office, you will discover that not
only the people out several governmental agencies have questions about the
propriety of crossing Mill Cove and extending discharge pipes through
Quarantine Island. These include the Corps of Engineers, the Department
of Natural Resources for the State of Florida, and the Department of In-
terior.
We believe that you are -obligated to insure that all necessary per-
mits and approvals have been obtained before you plunge ahead with approval
of the construction and Design plan, To do less would be to support piece-
meal approvals which are not in the public interest and which often can have
a coercive affect on other agencies to "go along."
Can you advise us whether or not the permits and approvals will be ob-
tained before the site supported by the 2.?.A, is approved?
Very truly yours,
<^v FJL't, 3:--
y -1
£\££&- ^
^
-------
c?.a.S£XS-
;?/?,'t>^//
-/C^ TIL * J*J-^ f^K
-------
949 ARLINGTON ROAD
JACKSONVILLE, FLORIDA 32211
PHONE AC 904/724-1683
724-2191
January 27,1976
Mr. Fran Phillips
U.S. E.P.A.
1421 Peachtree Street, N. E.
Atlanta, Ga. , 30309
Dear Mr. Phillips ;
Having read the newspaper this morning I am extremely disappointed that we are once
again having a stall by your agency to make the final decision to go ahead with the sewer
plant on Merrell Road. It is obvious that a small vocal group from the Holly Oaks area
dominates the thinking of your agency.
We have had continued postponements at great sacrifice of the developernent of south-
side Jacksonville and a tremendous increase in the cost because of the delay.
I am a property owner within a thousand feet of this plant and again wish to go on record
that we are for this site and against any further delays.
Trusting to hear from you with a go ahead after this delay .
Sincerely,
Sam E. Newey
SEN/kb
FPA - IMMCT STATEMENTS
< JAN -
o 1376
_
REGION IV, ATLANTA, GA."^
SALES
INVESTMENTS
-19 8._
APPRAISALS
PUBLIC RELATIONS
DEVELOPER
-------
Melvin M, Summers
1727 Ormond Road
Jacksonville, Florida
February 12, 1976
Mr. Russell Train, Administrator
Environmental Protection Agency
401 H Streett N. W*
Washington, D.C.. 20460
Dear Mr* Train:
I am a resident of and property owner in the community of
Holly Oaks which is just easterly of the site of the proposed Arlington
East Sewage Treatment Plant*. This is a beautiful area of over 300 homes
valued from $40,000 to $100,000..
To my astonishment, your Atlanta Office has recently approved
this site for the Sewage Treatment Plant* This approval was given despite
your agency appointed 15 member advisory committee's recommendation of a
site further removed from our area* The reason the recommended site was
not approved was that the corporation, which owns this land is politically
powerful in Jacksonville* Therefore, they only had to say, "No, not on
our land",; and their wishes were obeyed* We are not that powerful politic-
ally but we do have a vote and we intend to use it. The Atlanta Agency
has recommended Site 12 which is at the Southeast corner of Craig Air Field.
The sewage treatment plant at this location would harm no one. This is
where it should be built..
We are aware of the need for this facility in Jacksonville, but
we do not feel that it is necessary or right that it should be built so
close to this fine residential area and thereby destroy it. We were of the
opinion that the function of your Agency is to prevent this sort of thing
from happening* If you become a part of this plot to destroy us, then I
would say most emphatically that your Agency's name is a misnomer and that
it should be rightfully known as the "Environmental Pollution Agency".
We are still hoping that justice will prevail here.
Very truly yours,
Melvin M. Summers
cc: Mr. Robert L.. Sansom
t
199.
•'/L
I I r -
* s-u.
-------
Jacksonville, Florida
February 25, 1976
Mr. Russell Train, Administrator
Environmental Protection Agency
401 M Street, N. W.
Washington, D. C. 20460
Dear Mr. Train:
As residents of Holly Oaks, we appreciate your completing the environmental study
of the Arlington East Sewage Treatment Plant. Frankly, we are puzzled, are not
people and their homes part of the environment? There are several factors in your
study that do not make sense and which x^e cannot understand.
Your agency formed a Citizens Committee that voted nine to four to move the plant
from the Millcoe Site, as it was not environmentally suitable. Apparently this
fact was completely ignored in your study. In a newspaper article, your Atlanta
agency stated that people are more important than money; that is why you initiated
the environmental study. However, in your final decision you moved back to the
Millcoe Site because of the cost factor, which is highly inaccurace, using the
City's own figures.
We feel your agency made the correct selection in Site #12 as the most environ-
mentally suitable, but ma.de a complete reversal of all your findings and your basic
commitment to the environment by bowing to che cost factor, which appears to be
erroneous.
It is inconceivable to believe that your agency would allow the city to build this
plant so close to a. residential neighborhood, thereby destroying a beautifully
wooded area and the homes of hundreds of people -- gentlemen*._ you are not protect-
ing the human element in your decision!
We do not deny the need for sewage disposal, bur we do deny the City's choice of
3. site for a hugh regional plant neighboring on a residential area, when by present
day thinking, this type of plant is obsolete before it is built. We do not suggest
that any residential area should be subjected to this down-grading when there are
many desirable sites that would not be offensive to any human element.
We, who live in this area, can only stake our future in the credibility of your
agency doing a proper study and our dependence on the very basics of the Environ-
mental Protection Act.
Sincerely yours,
Residence Address -
10626 Fort Caroline Road
Jacksonville, Fla. 32211
F. J'. Thibault, Jr.
200.
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February 24, 1976 : Page 2
Copies to: <
Mr. Robert Zener, General Counsel
Environmental Protection Agency
Mr. David R. Hopkins, Chief, EIS Branch
EPA - Atlanta, Ga.
Senator Richard Stone
Senate Office Building
Washington, D. C.
Senator Dan Scarborough
State Capitol
Tallahassee, Fla.
201.
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B.I
February 27, 1976
John E. Hagan III
Chief, Environmental Impact Statement Branch
1421 Peachtree Street NE
Atlanta, Georgia 30309
Dear Mr. Hagan:
The enclosed series of articles by Mike Clark, Jacksonville^ Journal
QDveminental Affairs Staff, ar£ enclosed for your examination. These
articles raise questions pertinent to the Environmental Inroad: Statement
prepared by the EPA in relation to the Arlington-East Sewage Treatment Plant.
We submit the following articles and questions, therefore, for your attention
and response in the rebuttal to criticisms which your office is preparing to
submit to the Council on Environmental Quality.
B.I. a. (1) What justification-is there for the excessive cost differentials,
on a per gallon basis, between the Arlington-East plant and the
plants at Tanpa, Tallahassee, Miami?
B.l.b. (2) The City of Jacksonville cost figures are suspect, to say the
least. Has the EPA made a complete cost analysis of the City
of Jacksonville estimates, anywhere as detailed as that rre.de
by this newspaper reporter.
i
B.l.c. (3) Is there tacit agreement to expand the Arlington-East plant to
a 50 to 60 million gallons per day plant, thus eliminating the
necessity for other proposed Jacksonville regional plants not
! yet under construction?
B.l.d. (4) Would your agency approve expansion of the Arlington-East plant to
a capacity exceeding the planned 25,000,000 gallons per day capacity?
,8. I.e. (5) W^ald_your agency have aujhority^g^ pTOvent^^e^ City of^ Jacksonville
rrcm~exparding"tHe_ Arlj^^^ESt^pTanT^^^^l±e~25 , OOP , OOP capacity
_
once the inj^a^
B.l.f. (6) What is the meaning of Mr. Hyatt's statement (February 9 article)
that "The southwest plant cost so little because the EPA would not
fund much construction there?"
B.l.g (7) Why are you people supporting an incineration process which is
known to be a source of air pollution?
B.l.h. (8) Your team objected to sites east of Craig Field because of existing
cypress swamps. What merit is there in Professor Cdum's research
1A n
202.
K-'
r
-------
page two
(University of Florida) which suggests cypress swamps
can actually be enhanced and sewage adequately disposed of,
without resorting to expensive regional, heat treatment?
What specific attention are you people giving to less
costly, although unconventional methods of sewage treatment?
. B,l-.i. (9) Please comment on the article of February 10 in its entireity.
You may want to demure that you have not had an opportunity
to review bidding specifications because your grant under
consideration is "to develop plans and specifications.1
Yet these specifications apparently do exist already and have
been, reviewed by a newspaper reporter. Inasmuch as the cost
escalations are a key issue in this plant location debate,
and since the cost estimates are available which seem to have
gold-plated, the plant at other locations, we want to insist
that a preconstruction audit be performed before you make a
final determination, on the site.
B.l.j- (10) As a matter of information to this community, please advise
how many other sewage projects have you on record as
approved by your office that use equipment or construction
services or contracts from the following companies:
ELF Instruments
The Taulman Company
EEMCO
Envirotech
or any subsidiaries or affiliated groups
of any of the above
B.l.k. (11) Ttoo articles indicate that Mr. Robert Howard is analyzing the
costs. If this information is correct, can you provide us
with information as to Mr. Howard's qualifications as a cost
analyst? We would like to know:
(a) What is Mr. Howard's major field of study?
(b) Where did he complete his collegiate study?
(c) What previous experience has he had in directing
environmental impact studies?
(d) Who provided supervision of his work in Jacksonville?
(e) Please describe the nature of that supervision.
B.l.T (12) Please describe the qualifications of others in EPA in the
area of cost analysis and the nature of their reports on
cost figures for the twelve alternate sites.
B.l.m. (13) Please provide us with information as to the number of days
Mr. Howard or other Atlanta EPA staff or consultants to EPA
have been on assignment in Jacksonville on per diem, the
purposes of their trips, and copies of their trip reports
for the period covering November 1, 1974 through February 15, 1976.
203.
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page three
B.l.n. (14) Can you state without qualification of any nature
that Site 12 IS more costly than either Sites 1 or 2?
Please give us your rationale.
B.l.o. (15) What attention dees your agency pay to "cost benefit"
as opposed to "cost effectiveness"? Your study appears
to be concerned only with the cheapest possible costs.
Can you tall us what regard you have given to cost-
benefit ratios for the 12 sites with the "human element"
calculated in that analysis?
B.I.p. (16) In view of the fact that the Riles Conmittee of the
Jacksonville City Council has new seen fit to approve
introduction of legislation to revoke authorization
for the Millcce Site and to return the Council to a
neutral posture to review all sites again, what is
your justification to press ahead with a grant
authorization on this maximally controversial site?
(Reference the above as a follow-up to the February 17
article.)
We expect that these questions merit a full response in the final Environmental
Impact Study.
Sincerely yours,
Mr. and Mrs, Fbbert Iferder
1924 Holly Oaks Lake Poad Was
Mr. and Mrs. William
10233 Lakevisw Foad South
Ji
Mr. and Mrs. John'Stevens
1724 Orrrond Road
Mr. and Mrs. Reward Hall
1647 Cellar Circle
/> *•
Mr.' and Mrs. Raynor E. CBowditch
1700 Holly Caks lake Road West
Mr. and Mrs. Bobert Hulsey
1715 Ormond Rsad
cc: Fran Phillips.
Jack Savan
204. - 205.
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B.I. Response to comments by Mr, and Mrs. Robert herder,
Mr. and Mrs. John Stevens, Mr, and Mrs. Say nor
Bowditch, Mr. and Mrs. William Colville, Jr., Mr. and
Mrs. Howard Hall, and Mr. and Mrs, Robert Hulsey.
Response 3.1. a.
There are,. in this case, three primary reasons for cost
differentials on a per gallon basis. First, the other
plants mentioned were upgraded or expanded from existing
facilities whereas the Arlington- East plant will be
completely new* Second, two of the other plants have much
larger design capacities than does the Arlington plant.
Sewage treatment generally becomes cheaper on a per gallon
basis as the volume to be treated increases,- Third,/ sludge
handling and disposal facilities at the Arlington plant
originally accounted for about one third of planned capital
costs. These facilities (heat treatment and incineration)
have now been eliminated from the design.
Response B.l.b
Refer to the cost-effective verification section in
Chapter I.
Response B.l.c.
The Water Quality Management Plan for Cuval County
approved by the Jacksonville Area Planning Board, the
Florida Department of Environmental Re-gulation, and EPA
recommended five regional treatment plants for the
Jacksonville area. Based on current population projections,
the design capacity of the Arlington- East plant is expected
to be 20 MGD in the year 2000. Any deviation from the Plan
or any other plan for periods beyond the year 2000 would
require approval by all parties concerned.
Response B.l.d.
Refer to previous response.
Response B . 1 . e .
Any plant expansion using EPA funds must be based on an
approved Facilities Plan. The City of Jacksonville could,
however, expand the plant at its own expense if it obtained
the necessary discharge permits.
206.
-------
Resoog.se _ J3 ,JL ._f _..
The Southwest plant has a much smaller design capacity
than Arlington-Sas-t, has no sludge handling and disposal
facilities as did the original Arlington desiqn, and «as
funded before inflation rates escalated capital costs to
their current levels,
Pesponse B.I.a.
Refer to the section of Chapter I dealing with review of
sludge disposal alternatives,
Response B.l.h,
Some research has been done concerning the ability of
wetlands to assimilate domestic wastes. In Jacksonville,
however, cypress swamps do not exist in. sufficient quantity
to be considered as a means of regional sewage treatment and
disposal (refer to Figure 2-37 of the Draft SIS). Further,
the swamps that do exist are very close to developed areas
and will become even closer as development proceeds eastward
in Arlington, Finally, the ability of these areas to
function as water retention and groundwater recharge areas
must be protected,
SPA regulations require the consideration of
alternatives to meet the requirements of best practicable
waste treatment technology, Refer to Chapter m of the
Draft EI3 for a discussion of non-structural and structural
alternatives considered.
se 3.1.1.
EPA regulations prohibit specifications that contain
proprietary, exclusionary, or discriminatory requirements
other than those based upon performance unless such
requirements are necessary to test or demonstrate a specific
operation, or provide for necessary interchangeability of
parts and equipment, or at least two brand or trade names of
comparable quality or utility are listed and are followed by
the words "or equal," While companies and specific
manufacturers can be listed as a part of the specifications,
the term I1or equal" allows any other companies or suppliers
of like equipment to be utilized,
The plans and specifications referred to have not been
reviewed and certified to EPA bv the Florida Department of
207.
-------
Environmental Regulation. Upon receipt, EPA will take the
necessary steps to ensure maintenance of competitive bidding
opportunities.
Regarding the requested preconstruction auditf refer to
the cost-effective verification section in Chapter I.
Response B.1.1.
The companies referred to are among those listed in
specifications in accordance with the previously described
regulations. For further information regarding these firms
in connection with federally funded wastewater treatment
projects, refer to the procedures outlined in the section of
Chapter II dealing with public disclosure^
Response 3.l.k.
All costs were analyzed by the Water Division of EPA,
Region IV, The cost study and results were then supplied to
the EIS staff.
Resoonse B,1.1.
Sources of costs used in the cost optimum algorithm are
described in Chapter I- These costs were compiled by civil
and sanitary engineers in the Florida Section of EPA Region
IV*s Water Division. All costs were then supplied to the
Technical Support Branch of the Water Division where the
algorithm was carried out by graduate sanitary engineers,
Further information concerning the qualifications of all
personnel involved in the cost analysis is available by
following the procedures outlined in the section of Chapter
II dealing with public disclosure.
Resnonse B.l.m,
EPA, Region IV staff members have been in Jacksonville
on seven occasions for public hearings, consultation with
local agencies, and meetings with the Citizens Assistance
Committee* Approximately 28 man-days have been expended in
Jacksonville by six members of the EIS Branch. The only
consultants to EPA who have been in Jacksonville are
personnel of the firm of Environmental Science and
Engineering, Inc. of Gainesville, Florida who carried out
the noise and odor analytical report described in the Draft
EIS, For more detailed information concerning EFA personnel
208.
-------
visits to Jacksonville, refer to tr.e procedures outlined in
the section of Chapter II dealing with public disclosure,
Fesconse B.l.n.
As may be seen in the summary of the cost effectiveness
verification presented in Chapter I, site 12 was not ranked
in the top four most cost-effective alternatives for any
flow or outfall configuration, as T*ere sites 1 and 2. While
the treatment plant and effluent pumping station costs are
virtually the same for sites 1, 2, and 12, major cost
differences are found in site preparation and outfall
construction. Total costs for site preparation and outfall
each of these sites are as follows:
Site 1 52.6 million
Site 2 S4.8 million
Site 12 56,U million
The major cost differential bet-ween site 12 and sites 1 and
2 is due to the length of the outfall required tc discharge
to the St. Johns River, The total length of the outfall for
site 12 would be 30,800 feet versus 17^700 feet for site 2
and 13,900 feet for site 1. Remaining differences in ccsts
between site 12 and sites 1 and 2 are due to differences in
transmission line lengths and number of pumping stations.
Hesoonse 3.1.o.
The EPA. does not determine cost-benefit ratios for
wastewater treatment projects which it funds. Rather, the
total cost of each alternative is developed and the primary
and secondary impacts of each are determined and evaluated.
Alternatives are then ranked according to cost and
environmental i.tipact with the final selection dependenc upon
the most cost-effective and environmentally sound project.
Resconse S. 1. c.
A. Step II application for clans and specifications was
certified to EPA by the Florida Department of Pollution
Control (now the Florida Department of Environmental
Regulation) in April, 1974. Shortly thereafter, a decision
was made by SPA to prepare an EIS due to the significant
controversy surrounding the proposed project. Both the
Draft and Final EIS recommend funding of the project at the
site originally proposed by the City of Jacksonville. EPA
209.
-------
has had no correspondence from an official representative of
the city requesting termination of review of the Step II
application as submitted.
210.
-------
B.2
February 27, 1976
10559 Lakevj.ew Rd. E
Jacksonville, Fla 32211
John E, Hagan III
Chief, Evinonmental Impact Statement Branch
1421 Peachtree Street NE
i Atlanta, Georgia 30309
Dear Mr. Hagan, RE: EPA Project CL20541
Arlington East Seweage-Treatment
Plant
i In regards to the above plant, I have some unanswered
questions.
(1) Is it not true, that the specifications as written
r on this plantcan be construed as closed specifications,
in that thej_r very nature eliminates competative
bidding?
Q 7 h (2) Page 327 of the Draft Impact Statement shows an
Electric Sub-Station. Is this designed so that only
i one supplier can bid competatively?
S.2.C. (3) Is Mr. Howard of your officeby coinceden.ce, the same
Mr. Howard, who was once employed by the design-
consultants of th-L.3 project?
1.2.d. (4) How do you justify, the hign cost of this secondary
- treatment plant, when more sophisticated AWT plants
in ot.-ier cities cost less on a per gallon basis?
I would anticipate that these questions and their answers
will appear in your final Impact study.
Very truly yours,
Charles' T. Morgan
U
211.
-------
B.2. Response to comments from Charles T, Morgan*
Response B.2.a.
Refer to the first paragraph of response B*l.i.
Response B.2.b.
No? refer to the first paragraph of response B,l,i.
Response 3.2.c.
No,
Response 3«2.d.
Cost curves have been developed "by EPA, Region IV from
actual bid prices on similar projects in the southeast and
in Florida, Each facility, however, has irregularities or
features which can act to raise or lower the capital cost of
the total project* Such variables include outfall length,
site preparation, sludge disposal facilities, and, in the
case of upgraded or expanded plants, reusable equipment. It
is conceivable that an advanced waste treatment plant in
another area could cost less on a per gallon basis than
Arlington-East, However, without examples it is impossible
to comment specifically..
212.
-------
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218.
-------
S.3. Response to comments from Patricia Pillmore,
P.espon se B. 3 .a .
The Water Quality Management Plan for Cuval County
recommended, five regional plants for the Jacksonville area.
Included in the Plan was the treatment and incineration of
District II plant sludge at the Buckman Street plant. There
are no plans to tie in any future regional plants to
Arlington-East, The City of Jacksonville is presently
enaaaed in a Section 201 Facilities Planning study.
Acceptance of the 201 Plan and/or any deviation from the
present Water Quality Management Plan must be preceded by a
public hearing and approval of the Jacksonville
Planning Board, the Florida Department of
Regulation, SPA, and the public.
Response 3.3. b.
As described In Chapter I, it is new planned to
Incinerate Arlington-East sludge at the Buckman Street
plant, Ash from this incinerator will be disposed of in the
proposed 516 acre North Sanitary Landfill to be located on
the east side of Mew Berlin Road and just south of Cedar
Point. Road, Approximately 2.5 tons of ash per -day would be
produced by the incineration of sludge from 10 million
gallons per day of domestic waste.
P.e soon s e ..3 . c
The Water Quality Management Plan for Cuval County
•determined that the discharge of secondary treated
from recommended, facilities would not have a detrimental
effect on the water quality of the St. Johns r?iver. The
assimilative capacity of the river is such that the
projected discharge of treated wastewater from the entire
Jacksonville area throughout the planning period T«ill net
cause a violation of water quality standards nor preclude
intended uses of the river. Further, the lower St. Johns
River is a tidal estuary. The City of Jacksonville obtains
its entire water supply from the Floridan aquifer system
(see page 73 of the Draft 5IS) and has no plans tc use
another source,
219.
-------
Response 3. 3. d.
Changes in the sludge handling equipment at Arlington-
East have been described in Chapter I. Among these changes
are the elimination of centrifuges and incineration
facilities. The proposed level of treatment will remove
ninety percent of BOD and ninety percent of suspended
solids on a monthly average,
Response S.3«e.
The secondary treatment process has a history of hiah
reliability. The Arlington-East facility is not
experimental. Moreover, controls for remaining noise and.
odor sources will effectively prevent any annoyance to
residents in the area. The referenced plant in San Diego
County, California is an advanced waste treatment facility
providing reusable water. Such a plant would be
considerably more expensive in terms of capital costs and
operation and maintenance than the proposed Arlington-East
facility.
220.
-------
PART C
ICrjAL COMMENTS ON THE CRAFT
RECEIVED INDIRECTLY 3Y EPA
This section reproduces those Individual letters of
comment, which were sent to other offices and forwarded to
EPA for reply, The Issues raised have been addressed
elsewhere in the Final ETS and/or in the Draft. Each of
these letters has, however, been individually answered under
separate cover. Presentation is made in the order of
receint.
221.
-------
January 13, 1976
_<=^ •: .zx u
Mr. Laurance Rockefellow, Chairman
Citizens Advisory Committee on
Environmental Quality
1700 Pennsylvania Avenue N.W.
Washington, D.C. 20006
RE:
EPA Project Cl 20541 010
Waste Water Management Facility
Arlington-East Service District
Jacksonville, Florida
Dear Sir:
Following two years of controversy over the site selection for the
above project, the Atlanta EPA office concluded that the Milcoe Road sita,
originally selected by the city of Jacksonville, was the most desirable.
In reaching this decision the EPA made a.mockery of a Local Citizens Advisory
Committee selected by their own Atlanta EPA office.
This committee of citizens was made up of five representatives frcta the
affected area, five city officials and five impartial citizens. The five
impartial citizens represented such groups as the Chambers of Commerce asd the
League of Women Voters. After lengthly study of cost and environmental -actors,
the committee voted (by majority) to support an alternate site- The Dunes.
The Atlanta EPA office in reaching their decision in favor of the Hilcoe
Road site, based on cost factors, issued a statement that the recornrjerxjazions
by the Citizens Advisory Committee was not a valid representation of persons
affected. Their explanation for this was no one living at the Dunes was
represented. I submit to you that the integrity of the EPA is on the line.
Let me explain that the owners of the Dunes property had a representative on the
committee, and secondly no one lives closer to the Dunes area than the ccnnunity
of citizens objecting to the Milcoe Road site. The Dunes site is less zhan a
mile down the road from the Milcoe Road site, but by moving the proposed project
to the Dunes there would be no established residence affected. I might idd
there is no wildlife and little vegetation there as it is nothing but sand that
is dead from mineral mineing. It is interesting to note that one of the renters
represented a community far removed from the Milcoe Road site, but as close as
a mile and one half to the Dunes site. This person voted for the Dunes site.
222.
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- Page 2 -
May I concluda by saying that although the Atlanta EPA office based
their selection of the site on cost factors alone, I can find no place in
their Environmental Impact Study where they have provided cost findings other
than cost factors identical to those submitted by the City of Jacksonville
from their consulting firm, Flood and Associates.
If this matter is within the area of your concern I would appreciate
your committee investigating the mockery of the Citizens Advisory Committee,
especially those disinterested members who spent several months in an
impartial study of this undertaking.
Thank you for your time and concern.
Yours truly,
Ms.Gwendolyn H. Brown
1841 Holly Oaks Lake Road West
Jacksonville, Florida 32211
cc: Mr. Robert Zener
General Council of EPA
401 "N" Street, N.W.
Washington, O.C. 20464
Enclosure
223.
-------
1716 Ormond Boad
Jacksonville, Florida
January 20, 1976
Congressman Charles Bennett
2113 Kayburn Office Building
Washington, D. C.. 20515
Latter in reference to'the Arlington-East Sewage Treatment""
Plant, Jacksonville, Florida
*.
Dear Congressman Bennetts
After sane thought whether or not to bother you again about this subject, I
have decided to write you because I remain deeply disturbed. I wonder if we
have, really core to the point where government agencies - whether local or
federal - will be allowed to say that they know better than the people, what
is best for the people?
For two years,- as you know, the residents of Holly Oaks have protested every *
step of the way that a 10 to 25 million gallons per day sewage treatment plant
is sinply not compatible with our residential environment. Just briefly and •
as you know, the city's original assessment statement was evidently deemed
inadequate by the Atlanta E.P.A. office a year ago, and the Atlanta office
recently completed its Environmental Impact Statement. Four particular
areas of concern in that study, I believe, need your attention.
1. First, Atlanta E.P.A. formed a Citizen's Advisory Committee to review their
preliminary draft of the study. I was one of those individuals. The
committee consisted of 15 people: five from the city, five from the affected
area (so called by the Atlanta EPA although only three of us actually live
in Holly Oaks. The other two represented the Arlington Civic Club and the
Greater Arlington Civic Association and reside several miles from our area) ,
and five from impartial groups of greater Jacksonville, including, ironically,
ah Urban Planner front Stockton, Whately, and Davin, the company which heads the
list (reference page 343 in your copy of the Environmental Impact Study) of
those who will benefit most economically from the construction of the facility.
At any rate, after considerable hours of meetings and study, this Advisory
Committee voted 9 to 4 to move the site to a dunes area less than a mile
down the road but more than a mile from the Holly Oaks community. With
the exception of one city councilman who was included among the five "city
representatives", only the city representatives refused to vote for the
alternate dunes site, in spite of the fact that this dunes site was their
own second choice in their rankings, (reference page _in the study).
One can only wonder why in the world the city is so intransigent and
beholden to that Mill Cce property.
•
Voting .-with the affected area people to move the site were the impartial
representatives from the Chamber of Commerce of Jacksonville, the League
of Women Voters and the St. John's River Water Management Board. After
the meeting, and this is not represented in the Atlanta E.I.S. study, two
224.
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pa'ge
people who were absent ware polled and voted not bo move. They were the SWD
roan and a man from an architectural association. The final vote, in either
case, was to trove, 9 to 4 or 9 to 6, depending on hew you look at the vote
and how you feel about the fact that the absentees did not participate in or
benefit from the committee discussion prior to vote- taking.
in spite of the citizen's expressed wishes, Atlanta E.P.A. concludes
in its study that the Citizen's Advisory Committee acted based on f ear t and the
E.P.A. was making its decision based on knowledge. (Reference page 375) . I
personally think this is an affront to the intelligence of people and tliat such
a conclusion smacks of a totalitarian attitude on the part of government workers:
We have the knowledge; we know best. -
Fear is not the basis for ranking, but rather the rankings, I believe, are
based on our; knowledge that the S.P.A. study materials which they provided
did NOT convince the readers - affected area or iinpartials - that the Mill
Coe road site was the best alternative.
•
2. To add further insult, the E.P.A. Impact study states (Reference page 375)
that the Advisory Ccirrnittee was really not representative because there was
no one on the cormittee from the dunes area. What kind of logic is this to"
justify dismissing the Committee's vote? 'The E.P.A, itself forced the
Committee. Did they set it up so that any recommendation would be
nullified unless it supported the Mill Cce road location?
3. The third major area of concern deals with costs. The E.P.A. decision
to support the site- is based on costs, which the study implies would be
cheapest at the Mill Cce site. (You are probably aware of the fact that
the E.P.A. staff did NOT rate this site as most environmentally
suitable. They rated it 6th.) While I do not suggest that the cost
figures are wrong, I do think that the E.P.A. should be required to
perform a ccnprehensive audit by qualified cost analysts, inasmuch as
the cost figures which appear in the E.P.A, Impact Study are the identical
cost figures supplied by the City's consultants at the final meeting of the
Advisory Committee, I think we should know to what extent E.P.A. , as they
are required to do by requirements of the National Environmental Protection Act,
conducted a comprehensive review of the grant applicant's (the City)
consultants' cost figures. This is essential in view of the fact that the
E.P.A. 's decision to go along with Mill Cce seems to be based on cost
differentials.
4. Please be advised further that NO correspondence included in the
Environmental Impact Study appendicies supports the Mill Cce location:
not from the State of Florida Department of Natural Pesources; not from
the Corps of Engineers; not from the U. S. Department of Interior
Fish and Wildlife Service. The treatment of letters by E.P.A. (reference
pages 367-368) is completely inadequate and perfunctory, in my judgment.
With regard to the U. S. Department of Interior letter, the E.P.A.
response completely ignores Interior's first recommendation : "We believe
that the least biologically damaging alternative would involve con-
225.
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page three
*
struction of the plant at the unvegetated strip mine area " which, is the
dunes location.
*
With regard to the objections raised by the State of Florida Department of
Natural Resources, the Environmental Impact Study notes that the Department of
Natural Resources had insufficient maps and data to justify their celticisms.
This is an interesting response from the E.P.A. in view of the fact that the
E.P.A. apparently supplied the materials which the Department of Natural
Resources- used! (Reference pages 367 and 406).
With regard to the Corps of Engineers objections, the E.I.S. says in response:
"latest comtunication indicates no problems are foreseen." Oh, really? These
"latest comnunications" are not contained in the Environmental Impact Study. •
Further, I am told by an individual here in Jacksonville that no Department
of Army permit has been sought nor have detailed plans or the Environmental
Impact Study>:itself been forthcoming to the district Corns office. (As -late as
last Friday, 1/16/76..)
*' *
» *
I regret the length of this communication but I am appalled that in vie,'/ of the
foregoing this Environmental Impact Study has been forwardedcto the national
office of E.P.A- and to the Council on Environmental Quality for approval. We
have a public hearing next Monday, but, after reviewing the E.P.A. responses
to the public in the past, I have very little expectation that the report of
that hearing will be any more than superficial.
Can you, as our representative, communicate to the E.P.A. that when government
agencies ask for citizen participation in decision-making they are obligated
to pay attention to what the majority says; that in the interest of minimal
objectivity, an audit is required to determine if in fact there is any significant
cost difference among the sites; that all necessary permits, permissions,
approvals, and/or reviews by related governmental agencies MUST BE IN HAND
before construction plans are authorized and funded and the first spade is
turned. Otherwise fragmented approval of a piece of a total project too
frequently leads to irreversible consequences. .
* • *
I shall appreciate your consideration.
(Dr.)
226.
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jean
Hall
32211
3anwvig 20,1976
US SmatoA ChoAl&A Bemiett
Kaybu-tn Eiiiiding
.C. 20510
Rep. Bennett,
AS a private on I am faeeormotg .6tcA£iU.6tg ly i an
, feot/i diet n0t ap^iove tAe M^f. Cove &^ght becaaie o^ Attong znv<(Jvmvnto£.
T/ie Mt££ Cove Sight vAuzh, the. E.P.A. itgafi -U, a "x.2£U>onsMt i i^me -otitanced at Tot, and t/tfc Fzd&wl Gov^anmt CLan GlVc
ol( doLLaA^ to a iwuu£ja.paJLity that ca.n zn&hte. that minadipcititij to tafee
a Amatt aane44 one by one, -U t/vcA hov) wa aAe going to mcun&un faze.
Some o^ t££i£EPA gxa/e-aiajx/ -£4 m// tax money, t/ieA.e^2/te,, I am pairing
t'ruj, wni£a.ple. tak&iautJi?aM jias.-am^g to have, to pay again \QA the. ap
gAading o& the. &maLl$A ^e«€A ptanti one! I mi/i nave to pay again /SOA the tin-
in to tne Atgional plant. The, impti£&tion& o£ thi& pAogAam 4eem4 to me to
06 one 4tep c/o4€A to Scciali&m.
cJM. Jean
227.
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January 21, 1976
U.S. Representative Charles Bennett
2113 Rayburn Office Building
Washington, D.C. ' ?515
Reference
Wastewater Management Fac
Arlington-East Service Di
Dear Sir:
The Atlanta E.P.A. Office has recently concluded an Environmental Impact Study
following two years of- controversy over the site selection for a regional
sewage treatment plant. While the Atlanta Office of E.P.A. concluded that
the Millcoe Road site was not most environmentally desirable, cost factors
of the alternative sites were said to be over-riding determinants, and the
subsequent selection by Atlanta E.P.A. was the Millcoe site. This was
their conclusion, in spite of the fact that a Citizen's Advisory Committee,
formed by Atlanta E.P.A., voted by majority and after lengthy study of cost
and environmental factors, to support an alternate site.
If you have the opportunity to examine the Environmental Impact Study, you,
will note that the cost figures adopted by Atlanta E.P.A. as their own appear
.to be the identical costs developed by the grantee's consultant. While I
understand that the courts have ruled inconsistently in several suits dealing
with this practice, I am writing to ask your opinion of the integrity of this
procedure in this particular case since those costs were used to support the
site preselected by the grantee (the City of Jacksonville) over the strenuous
objections of those who live in the immediate vicinity and the majority of the
Citizen's Advisory Committee.
Finally, can you advise me whether or not the national office of the
Environmental Protection Agency will require a preconstruction audit- before
acting on the Atlanta E.P.A. Environmental Impact Study? Such an audit,
which is-consistent with recommendations in the E.P.A. -document"Review of
the Municipal Waste Water Treatment Works Program (Nov. 30, 1974) appears to
be appropriate to maintain the integrity of the construction grants program.
Thank you for your time and consideration of the above,
JMS:fs
cc: Lawton Chiles
Richard Stone
William Chappell
Reufain Askew
Robert Shevin
Harmon Shields
1724 Ormond
Jacksonville, Florida
32211
228.
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U. S. Representative William Chappell JAfi 2 2 F?C
1124 Longworth Building
Washington, D.1 C. 20515
Dear Congressman Chappell:
The Citizens Committee formed by E.P.A. to review the Arlington-East
Sewage Treatment Plant Sites and costs in Jacksonville voted 9 to 4 to move
the plant to the isolated area north of Regency Square, away from the site
adjacent to Holly Oaks property owners. The four voting against the nove
were all City representatives who apparently will support nothing but the
Holly Oaks site. Of the five designated as "affected area" representatives
on this committee, only three actually reside in Holly Oaks. The other two,
plus the impartial representatives of the Chamber of Commerce, the League of
Women Voters and the St. Johns River Water Management Board, joined with the
Holly Oaks residents in the judgment that the site should be moved.
The E.P.A. later polled two people who did not attend the meeting and
recorded their votes (as though they were there for the discussion of al-
ternatives) as negative.
7
In spite of the foregoing, the E.P.A. Atlanta office appears ready to
support the City's preselected site.
We now ask you to lend your support by affirming to the national E.P.A.
office that the will of the people, as evidenced by this vote, be honored in
its decision-making.
Very truly yours,
Address:
&*+•"•
229.
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United States Senator Lawton Chiles
2107 New Senate Office Building
Washington, D. C. 20510
Dear Senator Chiles:
b
The Citizens Committee formed by E.P.A. to review the Arlington-East
Sewage Treatment Plant Sites and costs in Jacksonville voted 9 to 4 to move
the plant to the isolated area north of Regency Square, away from the site.
adjacent to Holly Oaks property owners. The four voting against the move
were all City representatives who apparently will support nothing but the
Holly Oaks site. Of the five designated as "affected area" representatives
on this committee, only three actually reside in Holly Oaks. The other two,
plus the impartial representatives of the Chamber of Commerce, the League of
Women Voters, and the St. Johns River Water Management Board joined vith the
Holly Oaks residents in the judgment that the site should be moved.
The E.P.A. later pollad two people who did not attend the meeting and
recorded their votes (as though they were there for the discussion of al-
ternatives) as negative. ' •
In spite of the foregoing, the E.P.A. Atlanta office appears ready tc
support the City's preselected site.
We now ask you to lend your support by affirming to the national E.P
office that the will of the people, as evidenced by this vote, be honored i
its decision-making.
Very, truly yours,
Address
)7oo
230.
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US Senator Lawton Chiles
2107 New Serrate Building
Washington,DC
Patricia Jean Pillmore
3P26 Tara Hall Drive
Jacksonville, Florida 32211
The intention of this letter is to present some of the question-
able practices of the Enviornmental Protection Agency concerning
their dealings with the City of Jacksonville in their "environ-
mental impact study on a regional sev/er plant, and their flagrerJ
ignoring- of Environmental Agencies recommendations as 'well as
distasteful treatment of local citizens.
The Environmental Protection Agency's, Jacksonville, Florida,
Arlington East Sewer Systen Impact Study of December 15, 1975>
that will be submitted to the Washington. Office after the last
public hearing January 26, 19?6, states that the City of Jackson-
ville has purchased the land a.t the Mill Cove plant site, '."/hen
in fact the plant site is not owned by the City. As the citys
agreement for this proposed site deals almost exclusively with
cost, over-riding environmental consideration, is this not a
'srepresentation QJ
availabil
and Questionable practices of the
gross m
N-*-
factors, availability of land, as
acts
that could influence cost
sumption of approved permits
As recommended by ri.P.A. regulations 'a 15 member committee was
chosen by the E.P.A. composed of 5 city representatives, 5 dis-
interested members and 5 interested citizens, But the committee
v/as not chosen at the beginning of the impact study, only after
local citizens committees had expressed opposition to the Mill
After much
Time
and study the committee recommended
Cove Site.
sites other than Mill Cove sites, all for environmental reasons.
The citizens committee has been si:;:hted by the E.P.A. as invalid
because there v/as no committee representative from the Dune Site
area, their first choice of plant sites.
v/as allowed only 5 interested members and
to evaluate.
The Citizens Committee
there were 11 sites
Do private citizens have any voice in hov/ their Federal Tax
Monies are spent? When a Federal Agency can be swayed by local
government is there any integrety in the Federal Agency that is
handing -out millions of dollars of Federal Money ear marked for
Environmental Improvement?
231.
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, '. . -2-
With 11 sites to choose from that di.fi not have people in close
proxcimity to the site. The city and the E.P.A., while ad-
mitting: are not the best environmentally sound choices, recommend
that the said plant be built on the Mill Cove Site, in the
middle of a residential area, because of a 2 million dollar cost
factor. Isn't the E.P.A. designed to help communities overcome
the cost barrier to environmentally sound planning?
Before a final public hearing, required by law in an Environ-
mental Impact Study, both the Mayor of Jacksonville and the
E.P.A. announced publicly that the site selection has been final-
ized and the plant will be built on the Mill Cove Road site.
This final hearing is designed for community input and is the
last opportunity for the citizens to exnress support or objection
to the E.P.A. on this project. • •
*.
Have the citizens of Jacksonville rights been abridged, or violated
by virtue of the fact that the E.P.A. and the city government
announced the final site selection before they received all
community input required by lav/7
Both State of Florida Department of Natural Resources and the.
Corp of Engineers have expressed concern about the possible
pollution problems associated with using the Mill Cove Site. The
City of Jacksonville Department of Public Works proposes to. rim
a pipe containing treated sewerage out-fall across Mill Cove and
across Blount Island, and into the main channel of the St. Johns
River.
Mill Cove is slowly dying as"a result of silt and matter -infill-
tration,- Mill Cove is a tidal cove and as a result of this in-
filltration the tidal flow is becoming increasingly restricted.
Both of the above mentioned agencies are concerned about the
life of Mill Cove if increased matter, is allowed to be -ounroed
into the main channel itself which washes into the cove.
The primary source the E.P.A. used for the rebutal of the above
is a letter from the consulting firm of Flood and Associates
stating that the construction of the out-fall pipe for treated
sewerage will'not introduce solids directly into Mill Cove, but .
they do not show how it could indirectly introduce solids into
the cove. At this point we are unable to locate both the results
of the study made on water flow in Mill Cove by Flood and Associat
or any mention, in the E.P.A. Study of its use of Flood and
Associates findings. Flood and Associates said, refer to the E.P.
Arlington East Sewer Study, the E.P.A. said to refer to September
197^Sssesment Study, the Essesment Study referred to a water
quality Management Study and that study offered no explanation
of water flow in Mill Cove. . - -
A construction permit is required from the Corp of Engineers
before the out-fall structure can be built through the cove and
extended into the main channel of the St. Johns ""River. The Coro
has already informed the E.P.A. that they have an objection to
the 'use of Kill Cove since only the Mill Cove sites create the
most underwater disturbance,
- ' ' 232.
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JL
-3-
The Corn is currently v.'orlcin^ on a Model Study of the water
flov; to be completed "by 197?, vith specific interests in the
cove. If the Corp deems it necessary to alter [.''ill Cove due
to findings from this study, the city's nro-ooced out-fall
pipe v/ould have to be moved and re-routed at the city's ex-
Dense.
In view of the fact that the Corp of Engineers has already
stated that approval of the out-fall pipe rxLanned for the
Cove may not be issued, and the Corp's future plans canncrt "be
predicted on further engineering in the Cove, hov/ can the S.P.A.
and the City government go ahead v/ith the Mill Cove Site for
a regional sev/erage treatment plant facility?
Representations of your publication are most v;elcorne to come
and see for yourselves v/hether E.P.A. is really v;orking for
environmental quality or is it just another Federal give-av/ay
program. Is this the v/ay E.P.A. operates throughout the country?
RespecfuTly your
Patricia Jean Pillrnore
PJPirad
233,
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CHAPTER IV
AGENCY DECISION
234.
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Based on the information, analyses, and findings
presented herein and in the Craft EIS, the Environmental
Protection Agency will otter a Step II grant to the City of
Jacksonville, Florida for the preparation of plans and
specifications for remonal wastewater treatment facilities
to service the Arlington-East District. The project will
consist of a 10.0 MGD wastewater treatment plant located at
Millcoe Road, 13,900 feet of outfall line terminating at the
edge of the maintained shipping channel in the St. Johns
River, and approximately 36,000 feet of force .nai.n which
will be used to transport sludge across the St. Johns JRiver
for incineration at the Buckman Street ^astewater Treatment
plant incincerator. This plan, witn the exception of the
sludcre force main, appears as Alternative 1q in the Draft
FIS.
Special conditions of the arant will be that the City of
Jacksonville ccrrclete its 201 facilities plan of v,hich this
project has been determined to be a component part, that it
acrree to continue t.o pursue the rrost cost-effect ive and
environmentally sound method of sludge disposal Ecr all
facilities existing and planned, that it obtain cor use as a
passive recreation park and additional buffer zone tne 11".
acre tract shown herein as Exhibit 2 of Chapter II, and that
it carry out any mitigative rreasures recommended by the
archaeoloaical and historical survey of the sluJae force
main route.
This decision concerning the Step II grant constitutes
commitment for a Step III construction grant when sr.
acceptable Step III grant application is received cy
^
235.
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