United State ;       Region 4        EPA 904/9-78-026C
          Environmen ,:i Protection   o45 Courtland Stteet. NE   November 1978
          Agency        Atlanta GA 30308
&EPA      Environmental       Final
           Impact Statement


           Central Florida
           Phosphate Industry


           Volume  III

           Responses to
           Comments on DEIS

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                                                    904/9-78-026(c)
           FINAL AREAWIDE ENVIRONMENTAL IMPACT STATEMENT
                CENTRAL FLORIDA PHOSPHATE INDUSTRY
                            VOLUME III
               U,S, ENVIRONMENTAL PROTECTION AGENCY
                             REGION IV
                     ATLANTA, GEORGIA  30308
                             APPROVED:
                                                NOVEMBER. 1978
:GIONAL ADMINISTRATOR                            DATE

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FINAL AREAWIDE ENVIRONMENTAL IMPACT STATEMENT




      CENTRAL FLORIDA PHOSPHATE INDUSTRY









                  VOLUME III




        RESPONSES TO COMMENTS ON DEIS

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                               VOLUME III

                                Contents
Section 1, Transcript of Public Hearings                           1-1
Section 2, Responses to Public Hearing Comments                    2-1
Section 3, Written Comments                                        3-1
Section 4, Responses to Written Comments                           4-1

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          SECTION 1





TRANSCRIPT OF PUBLIC HEARINGS

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                              SECTION 1

                              CONTENTS
                                                               Page
Transcript of Bradenton Public Hearing
   May 22, 1978, 7:00 p.m.                                      1-1


Transcript of Bartoy Public Hearing
   May 24, 1978, 7:00 p.m.                                      1-111


Transcript of Punta Gorda Public Hearing
   May 25, 1978, 7;30 pm                                       1-195

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                 UNITED STATES OF  AMERICA
              ENVIRONMENTAL PROTECTION AGENCY
                         REGION  IV
A Public Hearing:


  DRAFT AREAWIDE ENVIRONMENTAL IMPACT STATEMENT

  CENTRAL  FLORIDA PHOSPHATE INDUSTRY

  March 1978
                             Time:

                             Date:

                             Location:
7:00 p.m.

May 22,  1978

Bradenton,  Florida
                           -oOo-
                BAY PARK REPORTING COMPANY
                       COURT REPORTING
                     11 I-'OURTH STREET NORTH
                    ST. l>l'TriRSBIJR(i, FLORIDA  31701
                          (811) Ml-8388

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     APPEARANCES:

            THE CHAIRMAN:
10


11


12


13


14





16


17


18


19


20


21


22


23
            THE  PANEL:
                            PAUL TRAINA
                            Director  of the Enforcement  Division
                            Environmental  Protection Agency
                            Atlanta,  Georgia
DRU MARVIN COLLINS
Florida Department of
 Environmental Regulation
Tallahassee, Florida

BILL STOWASSER
Bureau of Mines
Department of Interior
Washington, D.C.

BILL PHILLIPS
Office of Regional Counsel
Environmental Protection Agency
Atlanta, Georgia
'.M

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 1     SPEAKER




 2     Ernie Estevez                            35




 3     Fred Duisberg                            42




 4     Gloria Rains                             45




 5     Jeff Lincer                              60




 6     Jonathan Miller                          72




 7     Ann McCrainie                            78




 8     Mary Greer                               82




 9     Archie Carr                              83




 10     David Rosen                              91




      Homer Greer                              93




 12     Jean Russell                           101




 13     Catherine Fernald                      102




 14




 15




 16




 17




 18




 19




 20




 21




 22




 23




 24




25
                              /-

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2                                (Whereupon, at 7:10 p.m. the




3          hearing was called to order)




                   MR. TRAINA:  The hearing is open.




           Good evening, ladies and gentlemen.  My name is Paul




     Traina, and I am Director of the Enforcement Division of the




     Environmental Protection Agency, Region IV, in Atlanta,




8    Georgia.




9          The Regional Administrator of Region IV, Mr. John White




10    has designated me to conduct this hearing tonight.




11          I'd like to introduce the panel members who are with me



12    this evening.  On my immediate left is Dr. Marvin Collins.




13    Dr. Collins is representing Mr. Jay Landers, Secretary of the




14    Florida Department of Environmental Regulation.




is          On my immediate right is Mr. Bill Stowasser.  Mr.




16    Stowasser is with the Bureau of Mines.  He's representing the




i/    Department of Interior in Washington.



is          On my extreme left is Mr. Bill Phillips, who's with the



19    office of counsel, with EPA in Atlanta.




20          And next to him is Mr. John Hagan, who is Director of



21    our Environmental Impact Statement unit in our office of EPA




22    in Atlanta.



23          Tonight's hearing is concerned with a two-year study on



24    environmental, social and economic effects of continued ex-




25    pansion of the central Florida phosphate industry.

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i           The purpose of the study is to comply with the National
2    Environmental Policy Act of 1969.
3          Issuance of national pollutant discharge elimination
4    system permits for new sources of phosphate mining and chem-
5    ical processing operations constitute a federal action., which
6    signficantly affects the human environment.
7          As such, the NEiPA requirements require development of ajn
a    Environmental Impact Statement prior to issuance of the NPDES
9    permits.
10          It was determined early in 1976 that the number of new
it    phosphate operations, which would request NPDES permits, woul|3
12    make individual site-specific Environmental Impact Statements
,3    ineffective in determining areawide and cumulative effects
14    of these operations.
15          Each individual study would determine effects of that
16    particular operation, and areawide or cumulative effects mighj:
]7    easily have been neglected.
18          For this reason, all new source permits were held in
]9    abeyance while the areawide Environmental Impact Statement
20    was developed.
2,          A draft of this statement has been prepared, and notice
22    of its availability was published in the Federal Register,
23    Volume 43, dated April 21, 1978.
24          This hearing is for the purpose of receiving comments
25    from the public on this draft Environmental Impact Statement.

                            /-.r

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           All substantive comments  on this  draft EIS will be



2    considered by EPA  and summarized  and  addressed  in  the final


3    Environmental Impact Statement.



           This is your meeting tonight; we're here  to  hear your


     comments, and we can assure you  those comments  will be con-


     sidered and addressed in the final EIS.



           As stated on the agenda, we will  start with  a brief


     presentation by EPA, primarily  the contractor for  the study,



     Texas Instruments.  They will summarize  the major  conclusions


10    of the draft EIS and how the conclusions were developed.


n          At that point then, we will turn  the meeting over  to


     you for any comments you care to  make on the EIS.


           Before we get into the statement,  or the  summary of the


     statement by the contractor and my own  people,, is  there  any-


     one representing any of the officials,  elected  officials,



)6    at the local level, Congressional level?  We'd  like you  to


17    stand and be recognized



]Q          (No response)


19          Okay.  At this point I'd  like to  introduce to you, I


     think a person who most of you know,  Mr. Gene McNeill with


     EPA in Atlanta, who is the Project Officer.



           Gene?
22


                   MR,  MC NEILL:  Thank you, Mr. Traina.
23


           Just a couple more introductions.  I saw  a couple of


     our Advisory Committee members here,  who have served on our
25

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i     Advisory Committee throughout this study.  I think I saw


2     Bucky McQueen; he's the representative from Charlotte County


3     Yeah, there's Bucky.  And Homer Hooks, the industry's rep-


4     resentative.  I saw him here somewhere.  There he is.


5           Were there any more of the Advisory Committee members


6     here?  I didn't get a chance to quite look through all the


7    registration cards to check it out.


8          (No response)


9          Other members of the Advisory Committee from, well,


10    from this area anyway, we had a Commissioner, John Saba,


n    from Sarasota County who served on the committee, is serving


12    on the committee, I should say; Glen Schaefer from DeSoto


)3    County.  Some of these others will probably come to some of


14    the other meetings.  And Gordon Bartle from Manatee County.


           We're going to, in our presentation tonight, we're goin


     to be extremely brief.  There's no way, as those of you who


     are familiar with this study, -that we could go into much


     detail, the findings and conclusions of this study tonight,


     and still allow time for presentations from you.


           As Mr. Traina said, the primary purpose of the main  pur


     pose of this hearing, is to give you, the citizens, a chance


     to comment, both comment on the study, offer suggestions,  or


     say what you think about it, both here orally, and, of course


     as we stated, the record will be open to receive written


     comments through June 23rd.
25

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19
21
           With that, I think for right now I'll Introduce Larry


2    Bowles, who was the Project Manager for our prime contractor,


3    Texas Instruments, Incorporated, and he'sll make a brief


     presentation on the findings of the study, aftd then, after


5    he finishes that, I'll summarize the proposed action, which


6    is what we've been calling the selected scenario of the


7    study.


 8          Larry?


 9                  MR, BOWLES:  Could we have the slide projector


10    on, please?


n          My name is Larry Bowles,  I'm with Texas Instruments,


12    Incorporated.  I'd like to introduce Dr. Audrey James, one of


13    my colleagues, the ecologist on the staff.


14          And with her is Dr. Arnold Stalder, and there were a


15    total of about a dozen of us who worked on the program who


     were considered the basic staff.  At the peak of the program,


     there were about twenty-two of us with some consultants,,


           I've decided that the beat approach for this presenta-
 18
     tion tonight would be, first of all, brief.  I want to make
     the statement that this (indicating) is my pointer^ in case
     you think it might be something else, and just cover with you
     some of the ground rules of the study.


           As Gene pointed out, it would be very difficult in a


     presentation, at least in a brief presentation, to cover all
24

     the major findings; and then present to you some of the
25

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,      philosophy  of the study, and then turn it back over to Gene

2      and Mr. Traina for reception of comments.
3           First of all, reminding most of you, it was a seven-
      county study area, which involve^ the counties between
5      Sarasota and Tampa, along the coast, and then a tier of
6      four  counties along the interior.
           What  we have* outlined here is the study area and what
      is considered the Bone Valley formation.
           This  gray area  is the majority of .minpd areas or active
      mines, and  the crosshatching areas are mines that have been
      applied for, at  least through the DRI process.
           Topographic relief shows you that here in PoLk County,
      you're on what's called the Polk County uplands and the mines
      extending down along  the ridge and the new mines along the
14
      DeSoto plain and the ridge lying right in this area.

           It also includes, the study area included the harbors
16
      of Charlotte and Tampa Bay.
17
           Pardon the busy slide here, but I did want to cover
18
      some  of the major ground rules under which we conducted the
19
      study for the Environmental Protection Agency.
20
           First of all, to rely as much as possible on existing
      data.
22
           We received help from many agencies, federal, state,
23
      regional planning councils and local agencies.
24
           EPA furnished a considerable amount of data, especially

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,     with respect to radiation.
2           USGS allowed us to use their recently-developed model
3     of the Floridan Aquifer and also furnished us with data to
4     model the ground water of the area,
5           The Fish and Wildlife Service contracted to do their
6     own inventory and distribution data of the fish and wildlife
7    in the area.
0          The Bureau of Mines furnished a considerable amount of
O
9    information, and we used the human population projections
10    based on University of Florida estimates.
           There was a steering committee representing the federal
     agencies and the Florida DER, as well as an advisory committe^
     representing SWFMD and representatives of the seven counties,
     the environmentalists and the phosphate industry.
           We performed an assessment of the environmental effects
     of five alternative scenarios proposed by the steering com-
16
     mittee in the plan of study, with the major interest being
     towards the decision indicators described by the steering
     committee, with priority direction from them, as we developed
     the information, and, of course, the funding limitations
     being a constraint.,
21
           Then we assisted the Environmental Protection Agency
     in preparing the Draft Environmental Impact Statement, and
fc O
     we will be assisting them in responding to the comments re-
24
     ceived at the hearings and also in the mail.
                                                                   10
                               1-10

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i           TI has supplemented their staff, because,of the very



2     complex issues and the short time frame in which we had to



3     pull the information together for the EPA, with people that



     had been involved in the issues for some time, representing



5     the local Florida scene.



6           Mr. James Nicholas of Florida Atlantic University



7    assisted Louise Young and Carl Hice of our staff in socio-



8    economics.  Dr. Paul Urone and one of his colleagues assisted



9    Arnold Stalder in air quality.



10          Dr. Eric Rifkin assisted Audrey and Mike McDaniel in



n    ecology and served in an advisory capacity on general effects



12          Mr. Peter Schroeder of Geraghty and Miller assisted



13    with hydrogeology with Bill Underwood and Bill Lancaster of



     our staff.
1 4


           And Mr. Sam Lockwood of Tomasino and Associates assiste



     me and other members of the staff in describing  the scenarios
16                                                            '


     in more operational terms, as well as the surface water.



           We did forecast the resources and the environmental
18


     demands as we could best project them through the year 2000.



     The baseline data and regulations were primarily as they



     existed on 1 August 1976.  You have to set a time frame in
21


     which you're operating on any planning study, such as this,



     so our time frame was 1 August '76 to the year 2000.



           We prepared preliminary findings in the form of working



    papers.. Which were distributed fairly widely, and we received



                                                                    11

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i     many comments on those, which assisted in the development of



2     the information to make sure it was valid and adequate.



3           The integrating theme that we used was that of per*



4     forming environmental land use planning, and some of you may



5     have been in attendance at a seminar that EPA and TI sponsored



6    on that that helped bring out many of the issues that were



7    very important in helping resolve some of the information



8    together.



9          We did have to make some adjustments to the data base



10    as it existed on 1 August '76.  One was that existing future



     land projections, land use projections, had to be set for the



12    year 2000.



13          In looking at future land use projections that existed



     on existing maps, we found that there was s,pme naivete in



15    development of a data base for the use of the land by the



16    phosphate industry, and with the assistance of the individual



17    phosphate companies in response to a land use questionnaire,



18    we developed a more refined approach to their future land



19    plans.



           And we did base our regulations for permitting in wet-



2]    lands and waters of the EIS based on full implementation of



22    the Corps of Engineers regulations, even though they didn't



     become fully implemented until 1 September '77.



           And again, for planning purposes, so we'd have a base-



     line to work with, those companies that were not permitted



                                                                    U

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 1    to operate, or the facilities that were not permitted to
 2    operate,  by August 1 '76, we, for our purposes, considered
 3    them new sources.
 4          We focused on two times; first of all, the year 200Q,
 5    which we thought was the most reasonable forward projection
 *    we could make.  The other one was the impacts associated with
 7    the year 1985, because of this peaking in production.
 8          And pulling together the cast of characters, as would
 9    be the operation of the phosphate industry under the alterna-
te    tive scenarios, we first of all developed a list of those
n    activities that were permitted as of 1 August '76, those
12    who had, in some way, mostly through the DRI process, had
13    acknowledged that they wanted to permit additional mining
u    facilities, and then from the land use questionnaire, we
15    made an additional list, one of which we put under the
16    scenario describing permitting existing and new sources,
17          Let me footnote here that from the information we
is    developed, the new sources or the new operations would be
w    all mining operations.
20          There was  one for some time period, there was one
21    company that was planning on a chemical plant, but they changed
22    their plans during the conduct of the study, so actually
23    we're talking about mines, so this third list of mines here
24    is what we call  in the Draft Environmental Impact Statement
25    the industry view, just to give a sort of pointed perspective
                                                                     13

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,     if the industry was to carry out their plans as revealed



2     by the land use questionnaires.



3           I want to acknowledge the help we got from several

                        i

4     agencies and individuals, and this is just a sampling of



5     them.



6          We obtained  information, air quality information,



7    through the use of one of our consultaata. from JOER..



8          This is more information here on vegetative fluoride,



9    which was a very important part of the study.



10          We obtained  some information with the assistance of



n    the various phosphate industries.



12          USGS, as I pointed out, did help us in developing a



)3    very good picture,,.,as it existed in the data, of the  ground



14    water, Floridan Aquifer.



15          Of course, chemical characteristics of the seven-



16    county study area were important, and we were assisted by



17    the Corps of Engineers and their reports on that.



18          We did focus on Tampa Bay, as I mentioned, and  we



)9    were assisted by the Tampa Bay Regional Planning Council.



           Also the Central Florida Regional Planning Council



21    assisted us out of Bartow, and again, we looked at Charlotte



22    County, and the Southwest Florida Regional Planning Council



     assisted us there.



           This long list is a list of phosphate effluence,
24


     phosphate industry effluence, besides describing, the  existing



                                                                   14
                                 1-14-

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i     environment, as most people would define it.   The phosphate


2    industry has already operated In the area,  so obviously they1;



3    part of the existing environment, ;and we needed  tb£s  informa-


4    tion to describe that part of the environment, and-we were


5    assisted by the Department of Environmental Regulation.


6          All the staff members of Texas Instruments conducted


7    a field reconnaissance photo and' visual observations  and some


8    sampling to assure that we were acquainted  with  the area,  and


9    we took several hundred pictures, and this  is just a  small


10    sampling of some of the scenes we did see.


n          Here, an aerial/reconnaissance; this  is an active strip


12    mine.  In the background you see a hardwood forest.


,3          Of course, some of the other scenes we  saw included  a


u    beneficiation plant, where the rock is pre-proces*fed, and


15    much of it is then made into chemical fertilizers dn  pjLaats


     in the seven-county study area.


           This is a mined pit that was abandoned, as best we can


     tell twenty-five to thirty years ago, and left pretty well


     without man's intervention, and this is what  resulted under


     natural system dynamics.


           Here's a slime pond.  You can see the water fowl in  the


     area.  Again, not a considerable amount of  man intervention;


     there's some natural restoration here.
23

           This Tenoroc wildlife refuge is a cooperative effort
24

     between the phosphate company and the Florida Audubon Society
25                                                                J
                                                                    15

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1





2





3





4





5





6





7





8





9





10





11





12





13





14





15





16





17





18





19





20





2





?2





2C





24
and this particular slime pit has undergone some natural



de-watering and re-vegetation, so this is part of your



landscaping in the seven-county study area.



      Additionally, an additional reclamation practice is to



fill and level the land to plant grass, and this particular



area, very near Bartow, is used as a recreation park.



      By far, the majority in percentage of the land re-



claimed by the phosphate industry is used for grazing.



      Some of the scenes where there has not been direct



involvement of the phosphate industry include,.this sand pine



scrub, a hammock, and of course the wildlife associated with



these, range land.  Here's a type of wetland, wet prairie,



and another type of wetland.



      Agriculture is another major industry in the seven-



county area, especially in the area bKe'phosphate industry



is proposing to mine.



      Besides cattle grazing, the course includes truck crops



as a major agricultural industry in the seven-county study



area, as well as citrus crops.



      Of course, we have your rivers.  This is the Peace



River, which is used for commerce, recreation —



      And, of course, the bay*  I believe this is confluent



with the Alafia into Tampa Bay, and you are familiar with,
of course, the resort communities, which represent another






                                                               16
     major land use of the study area.

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 ,          There have been approximately 1,700 pages of reports


 2     published, part as working papers and the Draft Environmenta'.


 3     Impact Statement, and we'd like to think us, along with EPA,,


 4     strive for excellence.


 5          We don't claim to be perfect, and as hard as we did


 6     work, we did discover that there was one table that probably


 7     would have clarified some of the text material in the Draft


 8     Environmental Impact Statement.


 9          I'll show this for just about thirty seconds here,


)0     and  this will be included in the final Environmental Impact


n     Statement, as well as the other comments Deceived.


12          And that's all I have, Gene.


           Thank you.


u                  MR. MCNEILL:  As Mr. Traina will point out in


      a  few minutes, when we get to the part about your comments,
I D

      we'll ask you to come up and use this podium.
16

           Just a couple of comments before I get into the preposejd


      action.
18

           I mentioned an advisory committee a few minutes ago,


      and  the advisory committee was made up of representatives
20

      from each county in the study area,and a representative from


      the  Southwest Florida Water Management District, and we asked
22

      the  Florida Phosphate Council to select a representative to


      represent industry, and we asked the Florida Audubon Society
24

      for  a representative to represent the Florida environmentalist
25

                                                                    17

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     groups, and Charles Lee was their representative,




2          We also had a steering, inter-agency steering committee




3    which I did not mention, and this initially was to fee made




     up of the federal agencies, which are involved in regulating,




     permitting, or at least in affecting the Florida phosphate




     industry, and of course these agencies would be several in-




7    terior agencies:  the US Army Cdrps of Engineers, because




8    they're involved in the 404 permitting, or, permitting dredge




     and fill operations affecting the waters of the US and wet-




10    lands, and of course EPA and CEQ also were involved.




11          At the first steering committee meeting, w.e decided we



12    should also ask the State of Florida, since the advisory




13    committee was set up with primarily local agencies and,




14    representatives.




           We decided to ask the State of Florida for a rep-




16    resentative on the steering committee, and we wrote the




17    governor, and the governor designated Jay Landers as the




18    steering committee representative.




19          And then, just a couple more introductions.  I see Bud



20    Randall is here; he's the Manatee County Pollution Control




21    Director.  I know I saw him earlier.   Bud?




           And Jeff Lincer from Sarasota County; he's the acting



23    director of Sarasota County's Pollution Control, and one guy




24    that helped us so much I've got to introduce him, Bill Wilson




25    with USGS out of the Tampa sub-district office.  Don't hide,
                                                                    18

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 i     Bill,  I  saw  you  earlier.  He's here.
 2           Is  there anyone here  from  the three regional  planning
 3     councils  that Larry mentioned?
 4           I'm sorry;  I can't see  for the  light in my glasses.
 5     Would  you holler  out your name?
 6                  MR, OCKUNZZI:   Bill Ocltunzzi with 'thfe Tampa 'Bay
 7     Regional  Planning Council.
 8                  MR. MCNEILL:  Tampa Bay Regional Planning Coun-
 9     cil.   Some of the regional  planning councils are conducting
10     their  hearings on their 208 plans now, last week, this week,
n     and next  week.   I'm sure they're involved in that.
12           But those  three agencies, as Larry said, provided a
13     lot of information and input  into this study.
u           Okay.  With that, I'll  go into,: real-brief. JLy, I'll go
15     through what we call now the  proposed action and briefly
16     explain  it.
17           We  put copies of the EIS out on the table.  I hope
18     anyone who has not received a copy through tfae mail was able
,9     to pick one up, and those who have one or have a copy here,
20     if you'll just open it to page 1.70 to the front, or middle,
2,     of the text part  of it.
22           These four  pages, 1.70  -- three pages -- 1.70, 1.71 and
_.     1.72 do outline the proposed action.
£. J
24           I'll quickly explain what we mean by that.  Many of you
25     have been involved throughout this process and are familiar
                                                                    19

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 1    with how we went about selecting this proposed action, but



 2    for those of you who aren't, I'll briefly explain it.



 3          Our original plan of study included six scenarios.



 4    We call it scenarios because we were talking about an area-



 s    wide study and not an individual plant-complex, so we were



 6    talking about scenarios of development of the industry, and



 7    these range from full development or permitting all new



 8    sources who made application under existing regulations,



 9    local, county, regional, state and federal regulations.



10          That was, you might say, the full action scenario.



n    It ranged from that, as required by the National Environments



12    Policy Act, which is the legal basis of development of the



13    Environmental Impact Statement.



14          We are required to have a no-action alternative, in



15    this case the no-action scenario, and that one was no further



16    issuance of any new source NPDES or water discharge permits.



17          As we mentioned in some of the public meetings we had,



is    throughout the study, we really didn't expect any o&e of the



19    six scenarios to be selected, but we said probably it would



20    be a combination, and it is a combination.



21          The proposed action constitutes a combination of what



22    we feel is the best of each of the scenarios that were in the



23    original plan of study.



24          Now, the basis of this selection,  what we were calling




25    the selected scenario and are now calling the proposed action
1
                                                                    20

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i|    in  the ElS, this  is based on all the information that was

2     developed during  the study, which, as each task, each major

3     task  in  the plan  of study, as each of those tasks were

4     completed, we made available what we call working papers, wha

5     you might say reports on the information developed in each

6     individual task as it was completed, so of course that was

7     the information we developed.

e          But what, in some cases, was even more valuable were

9     the comments we received on the working papers.  That's an

10     easy way to find  out whether you're doing it right or wrong,

n     is  to, as you do  your work, make it available to the public

12     and to the industry and environmentalists and let them look

13     at  it, and they'll let you know.

14          People will let you know if you're off track, and they'll

,5     point out what your errors are, and this has been a valuable

16     process  in the study, making these working papers available

,7     and receiving comments.

)8          Now, we have not yet been able to, as we received

,9     comments on the working papers, to revise and re-issue each

20    working paper.  We were using the comments, and they were

2,     used in the, as I said earlier, in selection of the scenario.

22          But right now,  once we got this draft EIS together,

     we were able to get around to using these comments and what

     we're doing right now is we are re-writing, with the con-

      tractor assisting, we're re-writing, revising, the working
                                                                   21

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i     papers, and they will be re-issued.



2           Like we said in the public 'notice, it would be re-issuejd



3     about the time as the final EIS.  We think now it'll be re-



4     issued prior to issuance of the final EIS, and these will



5     reflect, as I said, all the comments we got.



6          Okay.  Based on all that information that was developed



7    plus, as most of you are aware, several advisory committee



8    meetings, several public meetings and several steering com-



9    mittee meetings, we were able to come up with a combined



10    scenario, which was the selected scenario, which is the



n    proposed action and is outlined on pages 1.70 through 1.72.



12          So now, I111 quickly go through this and turn it back



)3    over to Mr. Traina so we can get to the important part of



14    this meeting.



15          First of all, and again, this is the scenario for



16    development of any new source mining and benef iciation opera-



)7    tions or new source chemical plants, as defined by EPA under



18    the NPDES permit system.



)9          First of all, .the requirements for mining and beneficia



20    tion operations.  One was to eliminate the rock drying proces



21    at the benef iciation plant and transport wet rock to the



?2    chemical plants.



23          In the interest of time, I won't go into any detail as



24    to what the benefits of each of these individual requirements



     are, but I111 just briefly go over the requirements.
25
                                                                   22

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,           I think some of these are obvious, such as that one;
2     eliminating the drying process would eliminate existing, or,
3     would eliminate air emissions of particulate or dust, which
4     would result from a new phosphate rock dryer.
5           Of course, in this case, we do, as you see just under
6     that, we have a possible exception.  It's been pointed out
7     to  us, the original selected scenario stated that period,
g     but it's been pointed out to us that when rock $8 shipped
9     on  the world market to Europe, Canada and Japan, that it may
     not be feasible to ship the wet rock.
           It may be more costly from an energy standpoint to
     ship additional, say, 6 to 15 percent moisture, which is
     in  the wet rock, than what energy would be saved from not
1 \3
     drying it in Florida.
14
           So we will allow, on the site-specific studies —•- I
     should mention right now, since I haven't yet, any new source
     mine or chemical plant will still have to do a fite-specific
     EIS.
18
           This areawide EIS will be the basis of the site-specifi
19                                                           r
     studies.  This will provide the areawide and cumulative
20
     effects, but any new source will have to do a site-specific
     EIS.
22
           So in this case, if this exception were to be applied
                                               i
     in  a specific case, the site-specific EIS would have to
     examine, first of all, if it would be more costly, from the
                                                                   -23

-------
,     energy standpoint, to ship the wet rock than to dry it in
2     Florida.
3           And then, second, since part of the basis for concluding
4     eliminating the drying process is the effects, the effects
5     of the air emissions of the dust, plus the emissions of radic
6     nuclides, then we would ask a close examination of the effects
7     of such a drying operation, if it met the other condition of
8    the exception.  In both particulate emissions': and radiation,
9    control would have to be assured prior to issuance of the
]0    permit.
n           Okay.  I went into more detail on that one than I
     intended to.  I won't go into that much detail on the others.
           The next one is to meet the --- In the case of the
I 0
     water discharges from the mining operations., the State of
     Florida's effluent limitation is more stringent thanEPA's.
     We're saying meet the State of Florida's effluent limitation
     on the mining operations.
           We find that that does adequately protect receiving
     water.
19
           The next one is eliminate conventional above-ground
20
     slime disposal areas.  I think the slime disposal problem
     is certainly one of the major problems in the mining and
22
     beneficiation operations.
           The next one is	We really are sort of repeating,
     since we're saying our basis is, first of all, meeting existing
                                                                    24

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3

4

5

6

7

8

9

10

11
20
21
22
requirements, but we're repeating here in the scenario meet

Southwest Florida Water Management District consumptive use

permit requirements.

      And closely following that, we say provide storage that

allows recirculation of water recovered from slimes.

      What it amounts to, under existing Southwest Florida

Water Management District requirements, the industry, the

mining and processing has about reached its limit on the

amount of water that can be feasibly recirculated.

      As they go to this technology that allows elimination

of the slime ponds, it releases water that is right now in

the conventional operations tied up in the slime settling

process and does allow for greater recirculation.

      But we're saying that in the site-specific study to

show that you will provide for adequate storage of that water

released from the slime, so it would be otherwise tied up in

slime fchan a conventional slime :sefctli,ng,operation to increase

the potential recirculation, actual and potential recirculation

of water.
of water from the Floridan Aquifer.

      This next one is something we  were asked to look at,
23   with some of the comments we received, several of the comment

     was to look at the use of connector wells, more of a concern

     of adverse effects, I think; plus a concern should it be
                                                                   25

-------
     continued as a water conservation measure, and we're listing


2    this in the proposed action.


3          We're saying continue to use connector wells but only


     with very careful, I should say, continued very careful


     monitoring by the industry, local government and the state


     and the Water Management District, careful monitoring pri-


     marily to assure that water quality, -which -7- I don't .know


8    how many of you are familiar with connector wells.


9          They drain water from the shallow water tables


     directly into the Floridan Aquifer, and generally the water


     quality in the shallow water table is sufficient to allow


     direct discharge into the Floridan Aquifer,- but it does


     take careful monitoring to assure the quality continuously


     meets drinking water standards, as one example, so it can


     be discharged directly into the Aquifer.


           So what this one, use connector wells, is saying is


     continue to do that but with careful monitoring.


           The next one, the EPA Office of Radiation Programs is
18

     continuing to work on guidelines, which we really expected


     to have been published by now, and these guidelines are


     regarding radiation levels allowable on reclaimed land, both


     for existing structures on reclaimed land and guidelines for


     allowable levels on undeveloped reclaimed land.
23

           I talked with the Office of Radiation Programs just
24

     last week, and they're assuring us now that these two sets

25                                                                  26

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      of guidelines will  be  out  in June and July, and these will



2     be in final form.   They have been out in draft form.  I'm



3     sorry;  they won't be  in final form, but they will be pub-



4     lished  in the Federal  Register .as proposed guidelines.



5           The draft  copies were distributed several months ago.



                   MR. TRAINA:  I might say, Mr. McNeill, it's



      refreshing to have  EPA criticize EPA in a report.  I think



      it's  about time  we  did something like that —



                   MR. MCNEILL:  Well, I think the only —



10                  MR. TRAINA:  -- admonishing EPA to come out



n     with  some radiation guidelines.



12                  MR. MCNEILL:  The only thing, as Larry pointed



)3     out,  and  as we said several times through the study, one



)4     thing we've really  found is that we're not perfect.  That's



      one thing we've  proven, I  think.  We already knew it.



            Okay. The next  one, meet county --- Again, we're



      repeating what had  been one of the bases, is meet existing



      requirements, but we're saying again meet county and state



      reclamation requirements, and we're saying and further, in-



      clude in  the DRI and,  if a site-specific EIS is developed,



      which it  will be for any new sources.
21


           An  inventory  of  types of wildlife habitat in the area



      to be mined  and  in  the area immediately surrounding it, and



      we're saying here,  and this is just going a little further



      than  is currently done in DRl's and will be dor$g in site-


                                                                    27

-------
!     specific EIS's anyway, we're saying just in the mining



2    reclamation plan, take into account the existing wildlife



3    habitat in the immediate area and surrounding area, and



4    come  up, as part of the mining and reclamation plan, a



5    plan  to adequately protect the wildlife resources along



6    with  other resources  in the area.



7          And then, the next one is protect or restore wetlands



8    under the jurisdiction of the Corps of Engineers, Section



9    404(b) of the Federal Water Pollution Control Act.



10          And within that one, we have categorized wetlands,



n    and we're saying that these will be further defined in the



     site-specific studies, but I won't repeat what we have



     written here.  You can see what it is.
I *j


           But what we're  saying is Category 1 wetlands are the



     ones  that are so important they must be protected, and must



     be protected to the extent that they shouldn't be mined.



           We're saying even a temporary loss of these^ wetlands,



     even  if they could be restored over a twenty-year period,
1 8


     say,  the temporary loss is too important to these wetland



     systems to allow them to be destroyed, even if the destructicjn



     is temporary.



           Category 2 wetlands are those which are less important



     than  Category 1 and could be restored to perform useful

-------
 i     in  the  individual site-specific studies, and then again,
 2     Category 2 might be an isolated pocket-type wetland, which
 3     the site -specific study would determine la not important to
 4     perform wetlands functions, either on a -- certainly not on
 5     a regional basis, but even on a local basis, and would
 6     therefore not have to be protected or restored.
 7          Okay.  That's briefly the scenario for further de-
 g     velopment of the mining industry*
 9          For our chemical processing, as Larry stated, under
)0     our proposed action, by canvassing industry, and Bureau of
n     Mines and others, we understand that there aren't any
12     proposed new source chemical plants and, of course, we have
13     no way  of knowing.  A new company may come in tomorrow and
14     plan to construct a new chemical plant, but everything we
15     hear from the industry and the Bureau of Mines tells us that
      the chemical processing capacity from now until the central
I O
17     Florida area is mined out — - The chemical processing
      capacity is already here; no new chemical plants are needed.
1 8
           But we did examine the effects of existing chemical
      plants  and included in the proposed action any requirements
      that would have to be met if a new chemical plant were
22     proposed.
           This first one is, again, sort of repetitive, because
23
24    we're saying — We have already said that we would meet any
25     existing requirements, but we're saying that, as far as air
                                                                    29

-------
     pollution, air quality, to meet the existing new source


     performance standards or meet the new source performance


     standards; and also? on the water part of It, we're also


     saying meet the design surge capacity In the recirculated


     water system that are Included In the EPA standards of


     performance for new sources for water


           The next one is not an existing requirement.  We're


     saying that because of the potential of any of these new


     source chemical plants .contaminating .ground water.and the


     Floridan Aquifer from the highly-contaminated water in the


     gyp ponds or the recirculated contaminated water systems,


     because of that potential, we would say to line these gyp


     ponds with an impervious material, unless, in the site


     specific study it could be or can be demonstrated that lining


     is not necessary to protect the ground water and the Floridan


     Aquifer water from chemical and radiological contamination.


           The next one goes further than existing EPA requirements


     We're saying recirculate contaminated and non-"contaminated
18
19
     water, or in the EPA effluent guidelines definition, this
     would be recirculate the non-processed water, as well as the
20

     processed water, using the same design surge capacity, which
21

     means to design for a twenty-five year rainfall event for
22

     both processed and non-processed waters,
23

           The next one is not an existing requirement.   11 is
24

     being done in a couple of instances in existing industries
25
                                                                    30

-------
      provide  for recovery of fluorine compounds from phosphoric-




2     acid evaporators.



3          The reasoning behind  this is with any polluting material




      that is  recovered and used as a product is a material that



5     definitely will not be discharged to either the atmosphere or



6     the receiving   waters or ground water.  It's no longer a



7     potential pollution problem if it's made into a product and



8     marketed.




9          That is the rationale behind that, and it is	




10     Technology is available to recover fluorine.  However, as




n     we were  going through, receiving comments on the recommended



12     scenario, the earlier selected scenario, industry pointed out




      to us that right now the market is saturated with the few



u     chemical plants that are recovering fluorine.  There is no



is     further  market for recovered fluorine products.




16          So we did change that wording from absolutely recoverin




17     fluorine to determine if, as I said, if a new source chemical



is     plant makes application for a permit, we would have to




      determine at that time if there is a market for fluorine.



20    We would ask the company and the consultant on the site-



21     specific study to make that determination, and if there is




?2     not	If it can be shown at that time that there is not a



2     market,  we would ask that the fluorine levels in the con-



2     taminated water system pond be controlled by some Other means




2     such as  one possibility would be recovering the fluorine as
                                                                    31

-------
2
2
     an insoluble material and stockpiling it, but some method of



2    removing the fluorine compounds, from the contaminated water



3    system so that the.emissions from the entire plant complex,



     including fluorine emissions to the air from gyp ponds,



     would not exceed existing emission limitations for the entir^



     plant complex.
O


7          And this next one I think is going to be easy.  It



g    seems that industry is going more and more — - I think



9    virtually all of the existing chemical plants right now are



     either in the planning, design or construction stages for



     recovering uranium from phosphoric acid, but again, you



     can't project, you know, since the next new chemical plant,



     if there is one, may be twenty years from now, we can't



     absolutely project that there will be a market for uranium



     then, so we are .leaving it so that the recovery of uranium



     would be encouraged through the site-specific EIS.



           I say that's a real quick, brief rundown of the proposed



     action or what we've been calling the selected scenario, but
18


     as we also said earlier, the primary, absolutely the main



     purpose of this meeting here tonight is to obtain your



     comments, so since I don't know if Mr. Traina announced it



     or not, we have to be out of here at 11:00, so I'll turn it



     back over to Mr. Traina.
2


                   MR. TRAINA:  Thank you,
                   MR. MCNEILL:  Thank you.
                                                                   32

-------
                   MR0 TRAINA:   As  you can  see, Gene  is  very


     involved in this study,  and he's  been  involved with it for


     a couple of years, and he  really  has this  thing  down to


     great detail,  but he's available, obviously, during,  after


     and has been before and  will continue  to be  for  any specific


     questions„


           Before getting into  your comments, a few notes -- a


     few comments,  rather.
O

           First, I have a list of  cards here of  people  who have


     indicated they wanted to speak.  If you do want  to  speak,


     we'd appreciate your filling  one  out and so  indicating on


     one of these yellow cards.that are available at  the registra-
12                                                                 '

     tion desk in the back.
13

           Also, if you don't want  to  speak but  if you would  like
1 4

     to receive a copy of the final impact  statement  when it  is
is

     published,  you'll have  to fill out one of  these  cards so you
16

     can get on our mailing list.


           There's also another place  on  the card if  you'd like to
18

     just get on the general  EPA mailing  list of  other activities,
19

     that go on in EPA, Region IV.   You can just  so  indicate  on
20

     one of these cards.  If  you haven't already  done so, please
21

     fill out a  card.
?2

           We're conducting  this public hearing pursuant to some
23

     federal regulations that require  this, and I think  I should
24

     add here that the requirement  is  based on  law,  the  Federal
25
                                                                     33

-------
i     Water Pollution Control Act, the Clean Air Act, and obvious Ij




2     the National Environmental Policy Act, all require the




3     agency, EPA in this case, to involve the public, to have




4     public hearings like this; not that we wouldn't probably




5     do it, but I just wanted to let you know that this is a




6     requirement of law, and certainly you should take advantage



7     of that requirement, and we're here to listen to what your




8    comments are tonight.




9          Again, just for the record, the notice of this public



10    hearing was published in the Sarasota Her a Id-Tribune on




n    May 8th, 20th and 21st, and the Tampa Tribune and Lakeland




12    Ledger on May 7th and the 21st, and then we did mail copies



)3    of the public notice to individuals and organizations on



14    the EPA mailing list, as well as to all the appropriate



15    local, state and federal agencies.



           We're going to conduct the rest of this,as we have




     earlier -- informally.  We don't have any rules of evidence




)8    or anything like that.



           Feel free to come up, say what you want to say.  We




     ask that if you have a prepared statement, if you'll provide




     it to me, and then I'll turn it over to the court recorder.



           We are recording this; we have a court recorder right
/2


     here, again for the recordf so that we will be  able to




     respond to these comments that you have in the  final EIS.



           As I call the name, I would like to ask the individual


25                                                                  34

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 8





 9





10





11





12





13





14





15





16





17





18





19





20





21





22





23





24





25
 to come up, identify themselves, and make their statement.




      As Gene indicated, we got a notice when we walked in




 here that we're to leave by 11:00.  Either that, or spend



 the night here, because they lock the doors at 11:00.



      I have fifteen people here who'd like to make state-




 ments.  I've made a quick calculation; that's approximately



 ten minutes per.  We've got about three hours.  We'd like




 to hear all you have to say, but try to keep it within the




 ten minutes.



      Certainly we will receive written comments.  The



 record will be open for several weeks after this, and I111




 get into that in a minute.



      Okay.  Without further ado, let me call on Mr. E.D.




 Estevez, Director of the New College Environmental Studies.




 MR. ESTEVEZ :



              Gentlemen, my name is Ernie Estevez.  I live




 at 409 Pine on Anna Maria; I am from New College.  I hope




 nothing I say will be held^against them.



              I have two comments.  One is a substantial




 contribution, I hope, or at least it's a reflection of what



 I think is an important contribution being made by the Fish




and Wildlife Service, having to do with wildlife management.



              Some themes that have emerged from their large



 study, which I certainly hope will receive a great deal of




 attention as this draft is improved, is that there is a need
                                                                35

-------
 i    beyond generic habitat protection.  That is, it's one thing



 2    to say that wetlands need protection, and perhaps wetlands



 3    can be classified into sub-groups and management policies



 4    developed for each of these sub-groups.  It's another thing



 5    to say that pine flatwoods are a habitat type which can or



 6    cannot be disturbed.



 7                  But it's another thing to take a wildlife



 8    approach and a species approach and an ecological approach



 9    that would recommend, as US Fish and Wildlife has, that the



)0    concept of refugia and corridors for the movements and the



n    dispersal of organisms be the operational procedure by



]2    which  land use management is effected.



)3                  That is, in the draft that I have studied,



14    there are ho operational procedures for wildlife and habitat



)5    management, only policies.



)6                  Perhaps that's appropriate for the goals of



     the draft EIS, but I would suggest and call to your attention



     that the US Fish and Wildlife Service has contained in its
18


     reports the themes of refugia and corridors, which can serve



     either at local, regional or state levels of resource man-
'20


2)    agement as effective means of insuring that habitats and



     the species of importance therein are not ,made to -- are not



     too discretely divided.
23                 J


                   My second comment, after having reflected on
24


     the diversity of subjects contained in the EIS, has to do


25                                                                  36

-------
 I

 2

 3

 4

 5

 6

 7

 8

 9

10
1

12

13

14

15

16

17

18
19

20

21

22

23

24

25
with more of an editorial comment.
              It seems like after several readings of this
thing, most of the important issues fall by the way, and
one's mind is preoccupied by less important things.
              But to get it off my chest, and it won't form
a  part of my written comments, but it is a view that I
would like to state, is the apparent reliance of the draft
EIS on the conduct of monitoring.
              Monitoring, then, is really the central point
of my comment tonight.
              Of the fourteen proposed actions, which are
drawn from a mixture of three different scenarios, over  half
demand close agency supervision and monitoring.
              These are:   one, that the industry meet all
of Florida's effluent standards.
              Two, that consumptive use permits, issued  by
the Southwest Florida Water Supply District,  be met.
              Three, that forthcoming EPA radiation standards
be addressed and adhered  to.
              Four,  that  local, and state reclamation schedules
be recognized and followed.
              Five,  that  some level of wetlands protection
be effected.
              Six, that new source performance standards are
followed.

                            1-37
T-3
                                                                    37

-------
                   And suggested by the EIS is seven, that tighter


2    water standards be imposed to protect Tampa Bay and Charlotte


3    Harbor.


                   Eight, that existing sources be retrofitted


5    for 1983 compliance with new source performance standards.


,                  And nine, that fluorides be monitored.


7                  Now, the dependence of this draft on existing

                                                                 i
8    state agencies and local agencies and their current functions!,

                                                                 j
     to me parallels in many ways the dependence of the Coastal


     Zone Management Plan on that same concept, and I think,  as


     with the Coastal Zone plan, it's fair to ask what success,


     if any, we've achieved in a decade of environmental sensi-


     tivity or action, a decade or an era which is, really, comingj
i *.*          •

     to an end or at least a temporary pause in the State of
1 4

     Florida.
15
                                                                  i
                   And the examples that I would suggest be examined
16                                                                 |

     to determine whether or not in the State of Florida at the
17

     present time we can expect effective application of state
1 8

     regulatory agencies, as they are structured and function,
19

     to the issues of phosphate mining, include the monitoring of
20

     the industry itself, and ancillary projects,  such as the
21

     deepening of Tampa harbor, the production of electricity,
22

     which supports the phosphate industry, and the issuance  of
23

     water use permits.
24
                   Now,  I've followed each of these  cases and been i
25                                                                 • 38
                                1-38

-------
i     involved with some in some detail, and from a privileged



2     perspective, having been privileged to participate, or at



3     least contribute to these efforts, I can say that neither



4     the harbor-deepening project nor the protection of local



s     environments around power plants that support the phosphate



6     industry or the philosophies engendered by the Southwest



7    Florida Water Management District have so far been models



e    of resource management, despite a plethora of rules and



9    agencies, many of which are involved, are seated here right



10    now.



n                  There has been no effective management or



12    monitoring of harbor deepening in the Tampa Bay estuary.



13    We have state agencies that have only recently become aware



14    that the project is going on.  We have others who have



)5    actively ignored it.



16                  With regards to power production, I would



17    simply say that most of the power generated by Tampa Electric



18    Company goes to feed the phosphate industry and that much



]9    has been made of the fact that power provided that industry



     is interruptable on a public demand.



21                  But I point out that, whereas the power may be



22    interruptable, the pollution produced by the plants are not.



23    No matter who uses it, the public or private industry, it is



24    still the public living in the coastal areas around Tampa Bay



25    far removed from the sites of the principal users of the
                                                                    39

-------
]     power, who suffer the health decrements and general decrease



2    in the quality of life, attending the power plants of that



3    company.



4                  It is in my opinion that as of this date,



5    there are no effective environmental protective measures



6    being implemented at the newest and largest plants of Tampa



7    Electric Company.



g                  With respect to the Water Management District,



9    I feel that the phosphate industry Is responsive and re-



,0    sponsible with respect to water management and has evolved



n    so over the last several years, and that they would follow



,2    consumptive use guidelines issued by the district.



]3                  The district, on the other hand, has apparently



14    chosen to adopt the philosophy that water will never be a



15    limiting factor in all of southwest Florida, and that,



)6    irrespective of all other considerations, water will be



     supplied for best, for reasonable and beneficial uses,



     however defined.
I 8


                   Now, I'm generally a strong supporter of



     environmental protection and regulatory agencies.  In the



     last ten years, much of the effort and the accomplishments



     of these agencies has been directly due to public support.



                   Unfortunately, in the last ten years the public
f. -j


     has enjoyed, perhaps, a greater than due measure of influence
24


     in the direction of environmental regulation agencies.

25
                                                                    40

-------
                   Accordingly, sometimes these agencies may have



      been misguided  in their efforts, but with respect to the



      practical goals and  policies, which are stated ii* the draft



      EIS, all which are commendable and very effective if executed



      we must not duplicate the mistakes made with the Coastal Zone



      Management Program,  which were, to restate them:  reliance



 7     on existing structures, institutions and operations without



 8     the support and without the funding required to see that



 9     they do their job«



10                  And my last comment would be that it might be



n     better that many of  these recommendations be left up to



I2     industry, instead of assuming that government will pursue



      them.



14                  The reason for this is that if industry accepts



1S     these requirements as part of their permits and then do not



16     follow up, there is recourse of the public through the courts



      It is part of their  permit requirements, and if they do not



      follow those standards, they are liable to legal action;



)9    whereas, if state regulatory agencies do not follow through



     with the monitoring and with the close management and



     supervision, which is required for this proposed action to



     work, federal agencies will not withhold money, and the publii



     has no recourse.
2 o


                   I thintc I'll close with those comments.



                   MR. TRAINA:   Those are very interesting points,

25                                                                   41

-------
     Mr. Estevez.



            (Applause)




            I just want to comment; there is such a thing as mal-



     feasance that all those governmental people have to face,



 5           Charles Covest?  I'm sorry; I can't get your name ---



 6                  MR. COVEST:  Charles Covest, but I'm going to



     pass and take advantage of your  offer that we may make a



     formal written comment to you in the future.



                   MR. TRAINA:  Fine, sir.



10                  MR. COVEST:  However, for Save Our Bays, Mr.



11    Fred Duisberg has a specific comment that I know he would



12    like to make, if he can do that in my place.



13                  MR. TRAINA:  Certainly, sir.



14           Mr. Duisberg?



                   MR. DUISBERG:  But I will have a card here, so



'6    I might just as well wait.



                   MRe TRAINA:  Well, you're next, so why don't



IB    you just come on up, sir?  I think you planned that.



'9           (Laughter)



20                  MR. DUISBERG:  That wasn't rigged.  It just



21    ha ppened tha t way.



22    MR. DUISBERG:



23                  As a matter of fact, my comment is very brief



24    and was to be a short note to go to John Hagan, as specified



25    in the letter that we received.
                                                                    42

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19
22
23
                   However, I felt that, well, I'd rather go through



2    this meeting and then perhaps enlarge on our comments.--



3    MR. TRAINA:



                   Certainly.



     MR0 DUISBERG:



                   — which we will do, but I will, in any case,



     read this very brief note that we had prepared



8                  It states:  "in consideration of the summary



9    of major environmental impact as stated in the draft Areawide



10    Environmental Impact Statement, Central Florida Phosphate



n    Industry, March 1978, by your agency — " and this is addressed



)2    to EPA, or, to John Hagan  -- "Save Our Bays Association,



13    Sarasota, Florida, wishes to be recorded as requesting United



14    States EPA that no further permits be granted for the mining



15    and processing of phosphate in the area covered by this



16    study, except for fully-established as essential -•* for those



17    fully-established as essential for use in this nation only



18                  "it is our sincere belief that the extension
     of phosphate mining and processing can only be detrimental
     to the best interests of the people of this  area and  to all



     of our nation.
              "In the words of the Florida Phosphate Council,



phosphate feeds you," and this (indicating) is their brochure.
                   "if we accept this as the truth,  we must also



     accept our obligation to protect this invaluable resource and
                                                                    43

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i     our responsibility to future generations."



2                  Now, that's sort of end of speech, but I would



3    point out that the phosphate industry and the Phosphate Counc



4    points out the importance of phosphate.



5                  In their brochure, they state, and this is



6    definitely a mis statement —- Well, they state that we



7    can1t —



e                  I'll quote just a few lines:  "The phosphate



9    industry is as vital as the food we eat because, quite simply



10    without phosphate, we wouldn't eat."



n                  Now, this is probably ttue as far as modern



12    agriculture is concerned.  There's no doubt in anyone's mind



13    of the value of phosphate in our agricultural processes.



14                  It does state, though, that -'By a quirk of



,5    nature, Florida, land of sunshine, golden beachef, crystal



)6    lakes and springs --" and I don't know; you probably saw



,7    some of the pictures that were shown on the slide here of



,3    the crystal lakes and the springs, and so forth, in the



,9    phosphate-mined areas, and I happen to have been a resident



20    in Polk County back in 1929, in the earlier days.  I've also



21    gone through the phosphate-mined areas, and to me they're



22    nothing but dangerous deserts.



23                  So, anyway, to go on, it says " •- Is also one



?4    of the world's largest phosphate reserves."



2S                  Well, now this is certainly entirely untrue.
                                                                    44

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     I believe  that we have,  in the study area, possibly 4 percent

 2    of  the world's reserves, and yet we make the statement, or

 3    the  Phosphate Council makes the statement tiiAt this is one

 4    of  the world's largest.

 5                  As a plain matter of fact, it's one of the

 6    smallest,  and it's one that is essential to the future of

 7    the  United States and the future of Florida, certainly,

 a    Florida agriculture.

 9                  We1 re going to be in a much worse bind when

10    we have to buy back phosphate from foreign sources than we

n    are  in the present bind when we're being squeezed by the

12    OPEC nations.

n                  Certainly, phosphate, if it feeds us and which

,4    it most certainly does,  is one of our most essential re-

,5    sources.  It behooves everybody to absolutely protect it,

16    and  I would urge that EPA make this their first point of

17    consideration.

18                  And I guess that'll do it for now.

,9                  Thank you.

20          (Applause)

21                  MR. TRAINA:  Gloria Rains?  It's always a

22    pleasure to have Ms. Rains.  I've known her for several years

23    and  I'm glad she's with us again.

24    MS. RAINS:

25                  I'm Gloria Rains of 5314 Bay State Road,
                                                                   45

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 i     Palmetto,  Chairman of Manasota-88.




 2                   Manasota-88 is a bi-county organization




 3     dedicated  to the preservation of environmental health.




 4                   Our members request the following changes




 5     and/or  additions be added to the final phosphate EIS state-




 6     ment.




 7                   (1)  On page 2.3,  the  statement says  there is




 8     no proof to date any activity of the phosphate industry




 9     causes  a radiation impact on the general populace.   Your




10     radiation  summary says radiation effects would be manifest



n     in cancer  statistics, especially lung cancer.   No mention




12     is made of readily available statistics regarding cancer




,3     on p. 1.52 and 1.53.



)4                   We suggest  you include the information that



15     Florida has the highest rate of  lung cancer  in the  United



16     States,  the statistics weighted  so incidences  are not




17     attributable to age.




)8                   It does not seem unreasonable  to assume,



19     based on studies by Goffman  and  others,  that these  lung




20     cancers  are related to the high  levels  of radioactivity in




2]     our  region.  Additionally, statistics readily  available from




22     the  Department of HRS  for last year  show that  Florida led



23     the  nation in  deaths  from cancer.




24                   (2)   We  suggest  the assumption,  based on  ad-




      mitted monitoring and other  informational deficiencies,  that  46

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      radium content in the water of the seven-county area is not




 2    due to contamination of ground water by the phosphate indus-




 3    try be deleted because it is unsubstantiated by credible




      evidence.



                    (3)  The statement should recommend both



 6    public exposure standards and environmental contamination



 7    standards  for the phosphate fertilizer industry and associa-




 8    ted uranium recovery operations.



 9                  Airborne aerosols enriched in uranium and



 10    polonium-210 as well as radium-226 in surface waters and



 11    both radium-222 and polonium-210 concentrations in biologi-



 12    cal systems should be given particular attention and stan-



 13    dards developed.



                    (4)  The statement should recommend that a



 15    determination should be made of the correlation, if any,



 16    between high ambient radiation and fluoride levels in areas



 17    of high incidence of cancer.



 18                  (5)  The statement on p.  1.48 that all radia-



 ]9    tion exposure is  considered harmful,  with adverse effects



 20    assumed to be proportional to dose and that long-term




 2)     effects of low radiation doses are not fully known,  conflicts



 22    with the statement on p.  2.86 that background radiation level



 23    may increase slightly in the immediate vicinity of the




24     uranium-recovery  modules but their increase will be insig-
25
      nificant.   We suggest the  latter  be  deleted.
                                l-4-t
47

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i                   (6)  We think it should be noted that existing



2     phosphoric acid plants are capable of producing up to



3,    4,570,000 pounds or almost 20 percent of the 1975 United



4     States uranium production and that this operation combined



5     with mining, other processing and redistribution of by-



6    products of phosphate ore creates concentrations and redis-



7    tribution of radioactive subsfcanpes'and release of radio-



8    active gases and particulates in close proximity to popula-



9    tions and in concentrations considered hazardous.



10                  (7)  The statement implicates radon gas and



11    its daughters as the prime radioactive hazard associated



12    with mining and processing.  There is no mention of radio-



is    active particulate alpha activity, proven in recent Studies



u    when found in the lungs to give rise to cancer.  Ambient air



is    samplings of gross alpha concentrations of wet phosphoric



16    acid plants showed concentrations 15 times background values.



17                  Inhalation exposure to high levels of radon



18    and its daughters were singularly ineffective in promoting



19    lung tumors but did give rise to life shortening and other



20    effects.



2]                  This readily available information should be



?2    included in the statement along with the recommendation that



23    more attention needs to be given to the role radioactive



24    particulates, as a by-product of phosphate mining and pro-



25    cessing, play in the development of cancer,
                              1-48
48

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 i                   (8)  The statement should also note that, as




 2     found in EPA volume LV-781', stack sampling of phosphoric



 3     acid plants show appreciable concentrations of the naturally




 4     occuring radionuc-lides are being discharged into the environ-



 s     ment and that elevated airborne radioactivity concentrations,




 6     with polonium-210 and radium-226, were found in several ad-



 7     jacent plant work areas.   Concentrations of polonium-210



 8     during ambient air samplings were approximately 100 times



 9     background values.  Thorium concentrations at 3.25.



 10                   (9)  Additionally, the statement should



 n     strongly recommend studies be done regarding the effects



 12     of radioactive particulates and other radionuclides  when



 ,3     Combined with our almost  nightly air-inversions.



 14                   The very significant area of inversions and




 is     their effect on area pollutant levels seems to have been



 ,6     completely omitted from the statement.



 )7                   (10)  The statement does  not adequately ad-



 )8     dress gypsum stacks and ponds.




 19                   Samplings of seepage from inactive gypsum



 20     piles show that they yield and continue to yield significant



 21     quantities of radium to surface streams and ground water



22     for years after the pile  is abandoned.   Because of the




23     solubility of the gypsum,  this problem is  analogous  to,




24     but more critical than the problem of stabilization of
25
     uranium mine  tailings.
49

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 i                   Quantities of radioactivity entering the en-




 2     vironment through gypsum waste contain approximately 80 per-




 3     cent of the product radium-222 that will enter the environ-




 4     ment as a potential polluter.




 5                   As an example, a relative amount _of gypsum




 6     contains 460 curies of radium compared to 77 for normal




 7     super-phosphate fertilizer.



 8                   No other industry in this country is permitted



 9     to pile mountains of waste hazardous to human health on



 10     the landscape and walk off and leave it to society to control




 11                   The statement should certainly recommend that



 12     the industry be required to stabilize gypsum stacks to pre-




 ;i3     vent further leaching and erosion and to provide other ^such



 14     maintenance encompassing all necessary pollution control




 15     measures for the life of the gypsum stacks.



 i6                   (11)  The statement suggests impervious lin-



 17     ings for gypsum ponds but also suggests clay, although not




 ,8     impervious, be substituted.  Clay is not adequate as is



 19     documented in Dr.  Sam Upchurch's  Study,



 20                   The surface and possible subsurface seepage




 21     that would result from the use of clay will  not likely,  as



 22     suggested, be solved by ditching, pumping, etcetera.




 23                   We ask the statement recommend only a com-



 24     pletely impervious material be permitted.
25
                    (12)   The statement does  not adequately address
50

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      the  effects  of wet process phosphoric acid plants, located



 2     on areas  that are underlain by limestone.  Acidic gypsum



 3     water  can react with  limestone resulting in the development



      and  enlargement of cracks, etcetera, permitting the move-



 5     ment of contaminated water into the ground water.  Many



 6     plants which report a negative water balance on the contam-



 7     inated water-system are actually discharging radioactive



 8     waters to aquifers.



 9                  We think the final statement should recommend



10     radiochemical contaminant monitoring of adjacent aquifers



n     and  shallow  ground water quality.



12                  (13)  With these facts regarding the damaging



13     effects of phosphoric acid plants, we request the final



14     statement recommend a moratorium on the expansion of present



      or creation  of new phosphoric acid plants until such time



)6     as methods and standards exist to control the further dis-



17     tribution of radioactive materials into the environment.



,8                  (14)  The subject of control of fluoride erais-



      sions  and recovery and its economic implications have not



20     been adequately addressed.  However, it is acknowledged



21     that through lax regulations and inspection,  fluoride levels



?2     have been permitted to increase.



23                  While most of us are familiar with the U.S.



24     Department of Agriculture's studies showing fluorides have



25     caused more world-wide damage to domestic animals than any    51







                              l-rt

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 i    other air pollutant, that fluorides have affected both



 2    phosphate workers and nursery operations, new evidence from



 3    a study by Dr. Bertram W. Carnow and Dr. Shirley A. Gonibear



 4    shows the extensive damage caused by exposure to fluorides



 5    and strongly indicates fluorosis must be redefined.



 6                  The results of this study, conducted at union



 7    request, show that a highly significant relationship was



 a    found between increasing levels of fluorides and other pul-



 9    monary irritants and obstructive pulmonary change.



)0                  The measure of fluoride exposure was displayed



n    in a history of muscular-skeletal symptoms.



,2                  The striking correlation of muscular-skeletal



13    symptoms, bone surgery and bony abnormalities and a high



M    bone risk index suggests that the disease fluorosis is more



15    than dense bone.  It is a clinical and pathological entity



16    in which the bone density changes are only one component.



17    The study suggested the disease be called muscular-skeletal



)8    fluorosis.



19                  The study also found a high incidence of



2Q    deaths from lung cancer, leukemia and lymptoma and recom-



21    mended an immediate program to sharply reduce emissions.



22                  No tests were done of people living in the



23    general area of the plant.



24                  We suggest the damage identified as being



     caused by fluoride emissions points up the need for the       52

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      immediate development of standards to reduce the levels of



      irritant gases and particulates in phosphate plants and



 3    surrounding areas.  The cost of the latter is insignificant



 4    compared to the damage presently being done to the human



 s    populace.



 6                  (15)  We recommend the deletion from the draft



 7    the statement that increasing numbers of phosphate pits



 8    have recreational potential if properly reclaimed.   It is



 9    questionable until definitive tests regarding the uptake of



 10    radioactive materials by fish and other marine life are



 n     accomplished that these areas can be safely used for fish



 12    management or recreational areas.



 13                  Additionally, because of partially completed



 u    studies it is very doubtful that reclaimed mine  lands  can



 15    be safely used for agriculture or  pasture.   We refer to



 16    the uptake of radioactive contaminants by the livestock



 17     and crops.   Hence, if new mining is permitted now,  we  will



 is     experience a substantial decrease  in agricultural lands and



 ,9     pastures.  It is  doubtful for the  same reason that  it  is



 20     advisable to permit even single-family dwellings to be



 21     developed on reclaimed lands.



22                   While the draft mentions this  problem, we



23     think the final statement should emphasize  that  as  more



24     tests results  are  coming in,  it may very well be that



25     phosphate mining precludes  further use of the land  for any    53







                               /-r*

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     purpose, that phosphate mining constitutes a permanent use
 2    of the land.
 3                  (16)  Phosphate processing plants are forecast
     to annually consume 94,490,000 gallons of water per day.
     Mining less.  In your study assessing the effects of this
     operation on the Florida  Aquifer, you admit that the study
     assumed that water pumpage by municipalities and agricul-
     ture will be at the same  level in 1985 and year 2000 as it
     was in 1975, in spite of  almost geometrically increasing
10    population forecast for this area.
                   Even under  this optimum circumstance, Manatee
12    County faces a drawdown of 10 feet with increased danger of
)3    salt-water intrusion.
14                  You further admit that the study results
15    would be considerably different if your projections for
)6    municipal use are incorrect.
]7                  We suggest  this section indicating no severe
)8    impact on water quantity be thrown out of the study.
19                  (17)  We request the same treatment for the
20    statement on p. 2.67 that secondary effects on water quality
2)    were taken to be potential effects for which there is in-
22    sufficient evidence for concern.
                   (18)  The study speaks of wastewater discharges
^O
     to be allowed from existing facilities and new facilities
     under certain rainfall or equivalent conditions as having to   54

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1    meet best practical technology standards.



2                  What the study fails to mention is that pres-




3    ent BACT effluent limitations for the phosphate industry




4    are identical to the best practical technology standards



5    mentioned.  We suggest the final statement make this clear.




6                  (19)  The final statement needs to more ade-



7    quately address the increased potential for slime pond




8    breaks threatening the water quality of Class I waters and



9    what this would mean to our area if we lose our reservoir.




10                  It should also be noted in the same section



11    that elimination of slime ponds is not technically achievable



12    until after year 2000.



13                  (20)  Wetland restoration has not been demon-



,4    strated and seems highly unlikely on a large scale.  There-



15    fore, the preservation of wetlands comprising 12.34 percent



16    of the land cover in the study area should be ensured.   Wet-




)7    lands we recommend be defined as including areas in which



18    the water table is at near or above the land surface for a



19    significant part of most years and shallow submerged lands



20    and to be expanded to include the definition and identifica-




21    tion of wetlands that are developed as a result of studies



22    by the U.S. Interior Department..



23                  Preservation is based on ensuring the source



24,   and quality of water necessary to keep these wetlands in a



25    biologically healthy state.                                     55

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 1                  Under present modes of mining operation, this



 2    is impossible because of changes in adjacent land terrain,



 3    alteration of the local hydrologic regime and changes In



 4    the particular constituents of the water.



 5                  Therefore, we ask you recommend the no-action



 6    alternative of this statement because without this recommen-



 7    dation, it seems highly unlikely that any wetlands will



 e    survive in the phosphate mining area with all this portends



 9    for the future of our area.



10                  (21)  The statement does not address the re-



n    duced water recharge areas which will result as a loss of



12    these wetlands and what effect this will have on our aquifers



13                  (22)  The draft needs to be corrected to re-



14    fleet the following:



15                  The impacts of supporting activities, such as



)6    electricity generation and transportation, will permit fur-



17    ther deterioration of our air quality, will increase thermal



,8    pollution, water quality degradation, etcetera.



19                  The statement on p. 2.67 dealing with power



20    plant impact should be changed from minor impact to accurate-



21    ly reflect the above.



22                  We find the statement that industry discharge



23    of high concentrations of inorganic nutrients are beneficial



24    and are responsible for the unusually high productivity of



     both Tampa Bay and Charlotte Harbor an inaccurate statement.    56
25
                               l-s-C.

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 i                  It should be corrected to indicate Charlotte



 2    Harbor is showing signs of deteriorating water quality as



 3    has Tampa Bay for some time.



 4                  (23)  To suggest phosphate mining is needed



 5    to support the continued development of Tampa Harbor because



 6    it's needed for area industries is a distortion of fact.



 7    The ability of private capital to support ports in the state



 8    of Florida unfortunately does not seem to be relevant to



 9    their existence.



10                  This is obviously a blatant special interest



n    statement and should be changed to reflect the fact that a



12    recent nationwide poll distributed by the Florida Department



13    of Commerce shows business executives revealed access to



,4    water transportation ranked last in a list of forty-nine



,5    determinants for industrial location and operation.



,6                  (24)  We request your statement recommend the



17    development of a non-renewable resource policy for the min-



)8    ing of phosphate.  As stated on p. 1.2, the demand by the



19    United States will exceed the domestic supply before 2010.



20                  It would seem both logical and imperative to



2,    have some control over the sequence of raining and the amounts



22    of phosphate permitted for overseas shipment.



23                  The long-term effect of this action on our



24    economy would seem to be slight.  As stated in the draft,



25    mining does not appear to have played a significant role in    57






                               Ar?

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 i     the growth of the region since 1960.   The tax revenues  real-
 2     ized are small when compared to the costs of the  damage the
 3     industry creates.
 4                   The average real earnings  of $7,914 per miner
 5     is  a relatively low wage and can probably be easily equaled
 6     as  these workers are readily absorbed by the much healthier
 7     to  worker environment,  the service  industries.  The latter
 8     cited as likely in the  draft p.  2.60.
 9                   (25)  Suggested as an adequate safeguard  in
10     the draft, to depend upon tests  to  maintain good  environ-
11     mental quality is unrealistic.   We  have  an inadequate num-
12     ber of regulatory personnel right now.   That water and  air
13     will be tested regularly, connector wells checked before
14     abandonment,  etcetera,  is not likely.
15                   To depend on adequate self-regulation is  not
16     realistic either.  We refer,  as  one example,  to the Brewster
17     mines,  supposingly exercising the latest state of environ-
18     mental control and when finally  checked,  it violated one
]9     regulation after another.
20                   (26)   Though we understand the  constraints
2]     of  time and money,  lack of adequate data in some  areas,
22     etcetera,  we  find that  readily available,  most important
23     information was  ignored and the  draft  is  very poorly organ-
0.     ized.
24
                    To help offset  this,  we  suggest the  final       58

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 i     statement incorporate information furnished at these and



 2     other public hearings and that the final statement include



 3     a section created by combining all the information on each




 4     subject in the draft, permitting each subject to be treated




 5     separately.



 6                   This is what we have done in our draft review



 7     and is the only way deficiencies, discrepancies and, most




 8     important, the full impact of the industry can be realized.




 9                   This form will enable the reader to fully



 10     realize the  projected destruction of all our wetlands in



 n     the mining areas, our forests, our agricultural lands,  that



 12     the carrying capacity of our area will be further stressed,



 ,3     our water quality and quantity further threatened,  our  air



 14     quality further deteriorated, our fossil fuel position



 15     worsened, our lives threatened and shortened by increases



 )6     in radioactive levels, threatened and endangered species



 ]7     further stressed -- all to permit the rapid depletion by



 ,8     mining of a  non-renewable resource.



 19                   Based on the latter,  we request you recommend



 20     in the final statement that the no-action scenario  be adopted



 21     until the serious environmental problems cited are  solved



      and until a  non-renewable resource  policy is developed.



                    Thank you very much.
i O



            (Applause)
24
25
                   MR.  TRAINA:  As  always  Ms,  Rains,  it's  a
59

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 i    very thorough and detailed statement.  We appreciate

 2    your bringing all those items to our attention.

 3          John Rains?

 4                  MR. RAINS:  I waived mine for Ms. Rains.

 5                  MR. TRAINA:  Thank you, Mr. Rains.

 6          Anwar Wessa?

 7                  MR. WESSA:  I pass.

 8                  MR. TRAINA:  Jeff Lincer?

 9    MR. LINCER:

10                  How do you follow an act like that?  That's

11    all right, Gloria, but I'll be careful of my sequencing

12    next time.

13                  I am Jeff Lincer of 4718 Dunn Drive,  Sarasota.

14    I'm an Environmental Specialist for Sarasota County.  I'm

15    appearing this evening at the request of Sarasota County

16    to comment on the draft Environmental Impact Statement as

]7    it relates to the phosphate industry in the seven-county

18    study area.

,9                  We can certainly appreciate the amount of

20    work and the energies that went into the preparation of

21    this draft EIS, and compliment EPA's staff and their

22    consultants for bringing it to its present stage.

23                  There are, however, some serious concerns

24    that Sarasota County has with respect to the draft  EIS,

25    and these are as follows:
                                                                   60

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i                   With respect to air and water pollution,
2     on page 1,9 the statement's made that "The industry's
3     air and water emissions are controlled by collection devices
4     or other treatment to meet state and federal effluent
5     standards."
6                   This may very well be the way the system
7    is supposed to work.  However, I think the question which
a    should be raised is whether or not the system and the
9    equipment is operating as envisioned to insure en v iron-
10    mental quality.
n                  With respect to the natural environment
12    and climatic conditions, the statement is made on page 1.10
13    that "Because of the area's, flat terrain and  steady
14    winds, incidents of extreme air pollution in  west central
15    Florida are not common and occur primarily only in
16    heavily populated or industrialized areas, such as Tampa."
17                  This may very well be generally true for
18    west central Florida, but it's our understanding that
19    Sarasota was to be included in this seven-county study

20    area'
                   Discussions with meteorologists at the
22    National Weather Service station in Ruskin Indicate that
23    inversions  occur in this area almost on a nightly basis.
24                  In this light, and given the average age of
25    our retirement community, we feel that additional
                                                                    61

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5





6





7





8





9





10





11





12





13





14





15





16





17





18





19





20





21





22





23





24





25
investigation ought to be made of what might be a unique



climatological situation in this area.




              Data do exist in the files of the National




Weather Service in Ruskin, which deals with parameters,




such as wind speed and direction, height of mixing  layer,,




etcetera, these things that relate to inversions.



              We would strongly request that these  and



other pertinent data ba reviewed to determine the im-




portance of air inversions in and to the county of



Sarasota.



              We can take little comfort in some of the




twenty-four hour SC>2 data, as reported on page 1,11, and



this was pointed out,  Although these remain below




critical levels, analytical problems uncovered by EPA




indicate that actual levels may have been two to three



times higher than those reported.



              The 1976 fluoride emissions by the phosphate




industry were reported at 315 metric or 346 short tons;




fluoride levels in vegetation, according to the draft EIS,



are dependent upon rainfall frequency, thereby explaining




the high, that is 60 part per million, levels in 1974.



              We feel that this would be acceptable to



explain the 1974 high fluoride levels, but the data



presented in figure 1.3 indicate a trend of increasing



fluoride levels starting in 1972, with ever increasing
T-T
                                                                    62

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i     levels of fluoride.


2                  We would like to be sure that these data


3    are subjected to rigorous statistical examination to


4    insure that the conclusions are justified.


5                  With respect to fluoride and uranium,           T- 6


6    recovery of these two compounds, based solely on


7    economic consideration, as implied on page 1.72, is


a    totally unacceptable in view of the documented damage


9    caused by these compounds.


10                  They should be removed from the waste


11    water as a simple matter of health protection.  If a


12    profit results, so much the better for the industry.
  I         '

)3    But placing such an emphasis on profit is neither


14    justifiable nor desirable from the public or environmental


15    health standpoint.


16                  As a matter of precedent, an historic


17    achievement of this action, USS Agri-Chemical and W.R.


]8    Grace are recovering fluoride from phosphoric acid, arid


19    the Uranium Recovery Corporation, Gardinier, a subsidiary


20    of Westinghouse, Agrico Chemical, and Freeport Minerals


21    are all performing a similar recovery for uranium.


22                  With respect to uranium, a savings in terms


23    of oil, energy equivalents, and therefore foreign


     dependence, would be considerable and is estimated to


25    be between 97 and 129 million barrels by the draft EIS

                                                                   63


                               >-& J

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i     itself.
2                   With respect to water use and with respect       „. -
3     to the recommended connector wells, as suggested on page
4     1.72, the utmost caution is encouraged such that existing
5     aquifer water is not degraded.
6                   If the use of floating dredges, for instance,
     which would not necessitate de-watering of a mining site,
8    can be shown to result in less overall environmental
9    impact, then this approach,, it should be encouraged.
10                  Water quality:  A misconception that has
n    been perpetuated by the draft EIS, as it stands now,
12    is that EPA, and I quote "has no direct legal authority
13    to change requirements for existing sources."
                   This is stated on page 1*74 and is virtually
is    hogwash.  One has but to turn to Section 102 of Pub-lie
16    Law 92.500 and find the following diametrically opposed
17    statement, which relates to specific point sources, and
is    I quote:
19                  "Whenever, in the judgment of the Administrator
20    this is the EPA Administrator, "discharges of pollutants
21    from a point source or a group of point sources, with the
22    application of effluent limitations required under Section
23    301.d(2) of this Act, would interfere with the attainment
24    or maintenance of that water quality in a specific portion
2s    of the navigable waters, and Industrial uses and the
T-IO
II
                                                                   64

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 ,    protection of public waters under cultural and industrial



 2    uses, and the protection and propagation of a balanced



 3    population of shell fish, fish and wildlife, and allow



 4    recreational activities in and on the water, effluent



 5    limitations, including alternative effluent control



 6    strategies for such point source or sources shall be



 7    established, which can reasonably be expected to



 8    contribute to the attainment or maintenance of such



 9    water quality."



)0                  Not only does EPA have the authority,



     they have the legal responsibility to improve existing



12    effluent guidelines, when studies like this support



     said corrections.
I -j


u                  Along these lines, Sarasota and the State



     of Florida are already on record as saying that the



     application of best practical technology would result



     in substantially more stringent effluent limitations.



                   With respect to habitat lost and in particular
1 8


     with respect to the wetlands, we are encouraged to see



     reference made on page 1.21 to the Florida Department of



     Natural Resources classification of mixed forest communi-
21


     ties, hammocks, and dry prairies as highly endangered,



     and emphasis being placed on their importance to



     wildlife.
24


                   Without a doubt, the area's wetlands -- that is



                                                                    65

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     the  bay  heads,  the hardwood swamps,  cypress  swamps,




2    mangroves,  wet  prairies,  wet water marshes and  salt




3    water marshes,  are the area's most'important ecosystems




     in terms of life support  or productivity„




                  Hardwood swamps and cypress are,  we concur,



6    number one  and  number two,  respectively, in  importance.




7                 As pointed  out in the  EIS, Darnell's '76



8    study indicated that the  loss of wetland habitat  is  the




9    most important  impact of  construction, activity,,   This  is




10    on page  3.3.



n                 We also concur that and emphasize  that these



     Florida  wetlands are of national significance,  because




     they, with  some of the similar habitat in southeast



14    Louisiana,  are  the remaining wetlands of significant



15    extent and  value in the United States.




16                 In speaking of expanses of natural



     vegetation  in "larger parks," mention is made of  the



18    Hillsborough  River State  Park, on page 1.20, but  no




19    mention  is  made of the Myakka River  State Park, which



20    is right on one of those  rivers likely to be the  most



21    impacted by plant phosphate mining activities.




22                 I think the Myakka is  the largest  in the



     State of Florida.



                  With respect to projecting the  changes  in




     land use, which will occur  in the future, table  1.31 on
                                                                    66

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 5





 6





 7





 8





 9





10





1 1





12





13





14





15





16





17





18





19





20





21





22





23





24





25
 page  1.63  is misleading.  It indicates that wetlands,



 which represent  178,268 hectars -- think metric --as  of




 1975  will  diminish very slightly, and in fact decrease



 only  1.1 percent  over the period 1975 to the year 2000.



              In  view of the interrelatedness of




 phosphate  deposits in wetlands, it would seem unwise




 to  project such a minimal change unless strong regulations



 are enacted and enforced.to protect these critical areas.




              If  this projected-decrease' is based in



 any way upon the  assumption that a significant amount



 of  the wetlands can be returned to their original



 structure  and function, then serious thought ought to




 be given to the embryonic state of the art of reclamation.



              That is, to our knowledge, no one has yet



 to demonstrate through reclamation of a hardwood awamp, ,



 a cypress  head, or any other category of wetland which



 takes tens, if not hundreds, of years to reach their



 ultimate degree of complexity and function, dependent



 upon as yet poorly understood and interrelated parameters •




 things such as drainage, organic matter, temperature,




etcetera.



              With respect to any DRI or site-specific




EIS, not only should a thorough inventory be made of the




types of habitat, but a scientifically credible assessment




of the interrelationships between those habitats and the
T-/3
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2





3





A





5





6





7





8





9





10





11





12





13





14





15





16





17





18





19





20





21





22





23





24





25
proposed development should be clearly stated, considering



the species a special concern.




              With respect to inventorying wildlife, and




it is too easy to simply include a list of species thought




to be there, special care should be taken to list rare



and endangered species and species of special concern




recognized by both the Federal Office of Endangered




Species and FCREPA which, as many of you know, is the



Florida Committee on Rare and Endangered Plants and




Animals.



              As a final note concerning reclamation



of these habitats -- that is, their habitats,,-- it




should be done in such a logical sequencing pattern




that both plants and animals are provided adequate



refugia for the life of the project.



              This is something Ernie Estevez pointed



to very nicely, I thought.



              With regard to sampling, as indicated on



pages 4.4 and 4,5, the water monitoring program and dam




inspection — that's dam inspection — program suggested



are the bare minimum which the public should expect to




maintain the quality of their environment and their




hea1th.



              With respect to the dams, I'm not sure I



understand why there's any needs for any dams if we're
T-/5-
                                                                   68

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i      not going to have above ground storage.  I'm not sure

2      that  there's even a need for initial above ground

3      storage.

4                   If, in fact, inspection, sampling and

5      monitoring are to reflect a normal situation, these

6      events should be unannounced.

7                  The resulting data would not only give

8     the Agency that much more confidence, but assuming

9     that  the results are positive, it would give the

10     industry a welcomed opportunity to show off the results

n     of its efforts to maintain a high quality environment.

12                  With respect to sampling frequency, that

13     is for source sampling and ambient water monitoring,

u     the sampling program should not be locked into a

15     quarterly basis, and provisions should be made for more

)6     frequent monitoring should the situation justify it.

17                  This same comment would hold, then, for

]g     the sampling of receiving waters at optional locations

]9     downstream from the discharges.

20                  If the objective of the annual composite

21     sampling of all discharges is to develop a picture of

22     the additive effects, the frequency of once a year

„_     would not be acceptable, since far too much damage

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10





11





12





13





14





15





16





17





18





19





20





21





22





23





24





25
that monitoring program.




              Any composite sampling, obviously, from a



variety of discharges should take into consideration




analysis which would be proportional to both flow and



time of operation.




              With respect to radiation, after Gloria




covered it I'm not going to go into any great length,




but with respect to radiation, the potential for human



health hazard is great.



              Because much of the data is still being



developed, with this EIS in mind, we'll reserve comment




on the subject until concrete figures on exposure^ chronic



effects, etcetera, over time, are available.




              Where the research has been done, human



hazard has been indicated.



              We will make additional comments on the



subject when additional data are available and are



analyzed.



              With respect to economics, we would like




to point out that inadequate consideration has been given




to the economic burdens which phosphate mining operations




place on the community services and the intra-structure



and, as we heard before, things such as a substantial




monitoring cost.



              On the national scale, as you've heard before,
T-/6
                                                                   70

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 2





 3





 4





 5





 6





 7





 8





 9





10





11





12





13





14





15





16





17





18





19






20





21





22





23





24





25
it seems utterly foolish to encourage exportation of




any finite and strategic resource, such as oil or phosphate,




and by doing so, we place ourselves in such a precarious




position with respect to the dependence on other countries.




              In view of the history on oil, we would



strongly recommend that no more phosphate be exported




until a sound national policy on this can be established.




              We will save additional comments on this



and radiation and inversion and a number of things for



our written comments, which will be submitted shortly.



              In closing, and with reference to the



basis of the scenario, the State of Florida has already




taken steps to provide more stringent protection against




the adverse effects of phosphate mining, which go bey,ond



federal requirements.




              We encourage you to strengthen the scenario



in the indicated areas so that EPA and other federal



agencies will be able to meet their responsibility in



re-enforcing the environmental protection efforts of the




state and local government.



              Thank you very much.




      (Applause)




              MR. TRAINA:  I might just say, Mr. Lincer,




that you more than adequately followed Ms. Rains, and I




thank you very much.
T-/7
                                                                   71

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           Jonathon Miller?



2    MR. MILLER:




3                  My name is Jonathon Miller.  I live at 1333




     Third Street in Sarasota.  I'm the Chairman of the Manatee-




     Sarasota Committee of the Sierra Club, and I hope we'll




     get around to forwarding you a written statement.  I don't




     think we could add too much to Gloria Rains' presentation



     on behalf of Manasota-88.




                   Manasota-88 encompas'ses approximately the



10    same region of interest, that is Manatee and Sarasota



11    County, that our group does, so I just wanted to .re-



12    emphasize some of Gloria's points.




13                  And I'd like to ask you how to best proceed.




14    I have a number of questions, and I'm wondering if it's



is    appropriate to ask questions and get  answers at this



     point or whether I should ask them rhetorically, and you



17    can deal with them —




ia                  MR. TRAINA:  If you would, maybe ask them



19    rhetorically.




20                  MR. MILLER:  Okay.




21                  MRv TRAINA:  Again, the reason --- We'd like




22    to hear the comments.  If those obviously are in the form



23    of questions7 get them in the record, and as indicated



24    earlier, they will be addressed in the final statement.




25          Certainly afterwards, if you'd  like to address
                                                                   72

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 9





10





11





12





13





14





15





16





17





18





19






20





21





22





23





24






25
 comments to the panel here or someone else, but any



 questions or comments that are made will be addressed




 in the final EIS, if you make them.



              MR. MILLER:  Okay.  That sounds good.  Thank



you.



MR. MILLER:




              I'd like to start on page 1.72 on the



categories of wetlands.




              You suggest here that the categories will




be defined for regulation.  Now, I don't know exactly



by what method they would be defined, whether this would



be just a strict definitional determination or whether



there would be some mapping involved.



              If you do go to a mapping, I assume it



would have to be areawide rather than a site by site



basis.  This would seem to be the best way to proceed,



and I hope that you'll choose an appropriate scale.



              I've noticed lately that the LUDA material



for land uses covered, in terms of wetlands, is just not



sufficient for this area.



              I recently was working on a piece of




property about 50 square miles.  The wetlands were quite



fuzzily delineated by LUDA, and we went out in the field




and found there were more than 900 small wet season ponds




on this tract of land.
T-/8
                                                                   73

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                   Now, these small ponds just don't show up



     with your units of mapping that LUDA has, and yet I do




     believe that they do have a significant function and role




     in both the hydrologic system and also habitat, which




     leads me to the Category 3 wetlands, which are described



     as isolated and normally intermittent in nature and have




     insignificant hydrological functions and minimal life




     support value.



                   I have a little trouble with this.  It's



10    hard for me to understand how you could prove an area,



n    a wetland, has an insignificant hydrological function.




12                  And I hope you can get in touch with the,




13    I guess it's the US Weather Service in.Miami.  They've done




]4    some work along these lines, and apparently are 	




15                  There's a possibility, and I don't think




)6    it's been documented to anyone's satisfaction at this



17    point, but the formation of thunderstorms in the summer



I8    in this area is, of course, dependent on the water, the



19    surface water conditions that prevail on the surface of.




20    the land.   And changes in the configuration of the surface




2)    water bodies, I believe, can have an effect on the




22    conditions that lead to the development of thunderheads.



23                  So even though you may have the same area



24    of wetlands, you may take an area that was a number, let's



     say, 1,000 small wet prairies or isolated ponds, and you

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 i    may take their total surface area and convert them
 2    into one large acreage, and they may not have the, same
 3    world in a meteorological sense, and so to say that the
 4    small, isolated intermittent ponds have an insignificant
 5    hydrological function, I think that's a possibility, but
 6    I haven't seen anything that could establish tiiat to my
 7    satisfaction.
 8                  Going back to the previous page, page 1.71,
 9    one of your -points in the proposed action is to provide
10    storage that allows recirculation of the water recovered
n    from slimes, ,and the surge capacity is to be determined
12    during the other site-specific EIS.
13                  And that takes us to 	 I'd like to speak
14    a little to that point.  I'd like to refer to page 2.27,
,5    Section 4.  It's titled "Require Reduced Water Usages."
.,                  It's not obvious to me that this is reduced
I O
)7    water use.  It appears more as though this is a concept
18    of reducing the water sheds in the area, and something
19    that is not entirely clear to me from the statement that
20    I think needs to be perhaps stated clearly is exactly
2)    how much of the site would be available for holding
22    this rainfall.
                   Would it be the entire site that could be
     used for collection of this water or some subset of the
24

25
properties?
                                                                   75

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                  What  I'm concerned about here  is the




    creation  of  internal drainages, where all  the water




    falling on an operation may be contained in  that area.




    It  may be recirculated and used by  the phosphate industry,




    but it may never get to the estuaries.



                  And I think this is a  pretty major problem,




    and you appear  to deal with it or attempt  to deal with




    it  on page 3.4, but that's a  little  coafiusing to me also.




                  This  is the section on quantity of water,




10   and the last sentence says, "As new  mines  come into



n   operation, the  amount of surface water existing in the



12   study area due  to slime ponds and slime-pond runoff




13   impoundments will tend to decrease,  resulting in less



M   evaporative  water loss in the areas  affected, which will



15   tend to increase rainfall runoff and surface-water recharge."



16                 Well, I think in view  of the proposal



17   to  changp the slime operation, that  makes  sense.  In other




]g   words, I  agree  with you that  the area's surface water



19   existing  in  slime ponds and slime-pond runoff impoundments



20   may decrease, but I think the real question  here is will



21   the total surface,  total area of the surface water on the




22   phosphate sites increase or decrease.



23                 And the previous sectipn, 2.27, deals with



    collection of the ten-year, twenty-four-hour storm, and the




25   twenty -five -year, twenty-four-hour storm, which suggests to
                                                                   76

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 i    me that perhaps the amount of surface water on the site

 2    will be increased rather than decreased and, of course,

 3    this is going to represent a loss to the water shed and

 4    eventually to the estuaries.

 5                  The only other point I'd like to bring up

 6    is, from the slides that were shown earlier, I got

 7    the impression that you relied to a fair extent on the

 ^   fish and wildlife study that was done of the seven-county

 9    phosphate mining area.

10                  And yet in your literature cited, you make

n    no reference to this study which, I believe, was something

12    in excess of 1,400 pages and dealt specifically with the

13    phosphate mining and wildlife in the seven-county area.

14                  It's true that your EIS does reflect and

IS    is based to some extent on this information.  I hope, then,

]6    it would be possible to cite it in the new literature.

17                  And if that is not the case, then I'm

]8    going to have to get in touch with some Fish and Wildlife

,9    people and ask them why that 1,400-page document didn't

20    have a larger role to play in the development of the EIS.

                   Thank you very much.

22                  MR. TRAINS:  Thank you.

23          (Applause)

24                  MR, MCNEILL:  Mr. Traina, could I make a

25    quick comment?
                                                                    77
                                A77

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                   MR. TRAINA:   It seems you've struck a

     responsive chord here.by our project leader.

                   MR. MCNEILL:  That very last statement he

     made, that was an oversight.  That Archibald report from

5    the Fish and Wildlife Service, contract report, it was

6    definitely utilized, and it was an oversight that it

7    did not get referenced in the -- that it was not cited

     in the references, but we  thank you for pointing it out.

                   MR. MILLER:   Thank you.

]0                  MR. TRAINA:   I'll say generally that it's

n    very unusual for one bureacracy not to get credits in

12    another bureaucracy's report, so it must have been an

13    oversight.

14          Jane Rose?

15          (No response)

16          Ann McCrainie?

17    MS. MCCRAINIE:

18                  I'm with the Citizens Against River Pollution,

     and I'm going to be very brief.  Our specifics will be in

     a written statement.

                   I want to speak specifically in regard to

22    the wetlands.  You acknowledge that the wetlands are the

     most important ecosystem in terms of life support and

     productivity and that the  Florida Department of Natural

     Resources has also indicated that wetlands probably are
                                                                   78

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17





18





19





20





21





22





23





24





25
the most valuable natural system from the standpoint




of benefit to society.




              So we therefore refer to your statement




on page 1.22 that wetlands are expected to decline.




              It is our understanding that the current



study being done by the US Department of Interior, the




Fish and Wildlife Service in St. Petersburg, are to be



considered in this draft, and that's been answered for



me.  Thank you.




              And we would also now request specific



recommendations be solicited from the federal wetlands




study, probably or possibly permitting in regard t'o




mining the wetlands.




              And noting that the study adopted the



Corps of Engineering (sic) criteria, which is the 5




cubic feet per second flow; we have one question in



regard to this recommendation.



              As the tributaries are destroyed, will



the Corps criteria not obviously decline, therefore




diminishing the areas of permitting and monitoring, and



what provisions are being made?




              Is there any inventory that you have



presently available as to the flow of 5 cubic feet per



second and in what areas of the seven-county area is this




being done?
T-22.
                                                                   79

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23





24





2
              MR. TRAINA:  Are you talking about streams



less than 5 cubic feet per second —



              MS. MCCRAINIE:  Yes.  What I'm saying Is



that, if you have adopted that criteria and then as the



wetlands diminish, as they are mined, then obviously



that is going to decrease the flow, so the jurisdiction



is also going to decrease.



              MR. TRAINA:  Okay.  I understand your point.



Thank you.



              MS. MCCRAINIE:  And we would like for that



to be clarified in some way, at what point.



              The point has been made, we want to reiterate,



that since successful reclamation of wetlands has not been



achieved over a period of time, we request that stronger,



statements be incorporated for the preservation of wetlands.



              Now, as far as the map in the land use



portion, in comparison to the projected mining areas,



specifically for Hillsborough County, there's tremendous



contrast, as far as the land use area, and the projected



mine use areas.



              Can we assume that this is a commitment on



the part of the industry that these areas will not be



mined until after the year 2000?



              I would also like to point out that you



stated you would support the county and state laws, and in
T-Z3
                                                                    80

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i     the Hillsborough County Conservation element adapted in

2    the horizon 2000 land use plan, we state that is minimize

3    the adverse impacts of mining by prohibiting mining in

4    rivers, streams and alluvial wetlands, except in extreme

5    cases of overriding public interest, and I would like

6    to leave this conservation element for your files.

7                  And I would also like to mention,  in  the

8    water section, just for the record, that the Alafia

9    River proper is greatly influenced by Lithia Springs and

10    Buck Horn Springs, and I would also like for EPA to note

n    that those two springs are owned and being pumped severely

12    by the phosphate industry.

13                  Thank you.

M                  MR. TRAINA:  Thank you very much.

15          Gordon Palm?

16                  MR. PALM:  I pass.

17                  MR. TRAINA:  Excuse me?

18                  MR. PALM:  I'll pass.

]9                  MR. TRAINA:  That's very unusual,  Mr.  Palm.

20    I always expect you to say something, at this point

21    especially.

22          You're sure now?

23                  MR. PALM:  Yes, sir.

24                  MR. TRAINA:  I just can't imagine  the industry

25    not having something, after listening to all this,  but
                                                                   81

                               /-si

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     so be it.   Does that presume that the document is




     satisfactory or is the council —




           (Laughter)




                   MR. PALM:   No, sir.




                   MR« TRAINA:  -- is  the council supposed to




     said us  some written comments?




           (Laughter)




                   MR. TRAINA:  Well then, I guess I'll presume




     the document is satisfactory.




,0          (Laughter)




n                  MR. TRAINA:  Mary Greer?




12                  MS. GREER:   The points have  been covered, but




     I would  like very much to read a  statement by Manasota-88
I o



14    and the  gentleman from Anna Maria	




                                 (Whereupon, a  discussion  was




           had  off the record  between  Ms. Greer and Mr. Traina)




]7                  MR. TRAINA:  Please do come  up.




     MS0 GREER:
I O



                   Mary Greer, citizen of Manatee County,  a




     former health education director.




                   I'd like to call your  attention to  the




     cause for my concern.  Most of our population in  Manatee




     County came here to preserve their most valuable  commodity  --
£. J



     hea1th.
24



                   We are anxious that this study and  the  EPA


                                                                   82

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 i    protect this healthful environment for those who have




 2    invested their all in this area.



 3                  Such an excellent job has been done by



 4    several people here, by most all.  They have




 5    most of the points that I have carefully thought




 6                  However, it seemed to me that the start o€




 7    dealings that would protect the air and the water




 s    degradation from exposure is a point that we would like



 9    very much to have accented.



10                  Also, a limit placed on the amount of



n    phosphate mining in particular areas.




12                  These are the only two points that I had



13    considered.  They were so perfectly covered I certainly




14    enjoyed both of them, all of them.



15                  MR. TRAINA:  Thank you very much, Ms. Greer,



)6    for coming up.



17          (Applause)



,8                  MR. TRAINA:  Archie Carr?




19    MR. CARR:



20                  Mr. Traina, gentlemen, good to see you again,




21    Ladies and gentlemen, my name is Archie Carr.  I'm Special




22    Assistant to the President for Science of the Florida



23    Audubon Society.




24                  I have reviewed the draft areawide impact



25    statement and submitted a letter of response to Mr. White
                                                                   83

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 !    the Regional Administrator of Region IV of EPA, and I



 2    think, as a matter of convenience, the best thing for me



 3    to do would be to read the letter into the record here.



 4                  I thank you for the opportunity to comment



 5    on behalf of the Florida Audubon Society on the Draft



 6    Areawide Environmental Impact Statement.



 7                  First, I find the areawide approach that



 8    EPA has taken with the EIS process in central Florida to be



 9    an interesting one and one I think will efficiently lead



10    to equitable environmental protection.  I hope history



n    will bear out my optimism.



12                  I would also like to compliment you and



]3    your staff for the admirable job of condensing the volumes



)4    of information developed by Texas Instruments and subsequent



15    proceedings into a very readable volume.



16                  I have several comments regarding the content



]7    of the EIS that are presented in no particular hierarchy of



)8    importance.



19                  The first of these is not listed here and



2Q    concerns endangered, species.  I get a sinking feeling by



21    reading the document, in consideration of this area.



22                  In the body of the text, Section 1, there is



     reference to endangered species with a general remark that



24    things will not fare well for that whole category of plants



25    and animals.



                                                                  '84

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25
              The concept, the group of animals, the



point is not raised again until we get to Section 6,



"irretrievable Commitments."



              In that section, it speaks to habitats.



Now, in other areas of concern, for example air and water



quality, there is greater elaboration of what EPA feels



it will do to achieve protection, concessions that will



be made, and so on.



              I do not feel that the impact statement



adequately expresses how endangered species will be



protected, as I believe they should be under existing



law, irrespective of events that are going on in Washington



at this moment.



              But I think that the final draft would be



greatly improved by more detail of exactly what we can



anticipate to be the impact on endangered species or how



those impacts will be avoided as a result of EPA's action.



              Now, to go on here, the first item is



fluorides.  It is stated under Environmental Impact of



Proposed Action, Section 3, page 3.1, that "no new



chemical plants are projected under the proposed action,



and consequently fluorine emissions will not increase."



              This, I understand, is possible largely



because existing processing plants will continue to be



used for the rendering of phosphate rock from new sources.
T-1S-
                                                                   85

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i                   It has become abundantly clear to us that




2    old plants retrofitted with fluoride pollution control




3    equipment are far  less efficient at controlling fluoride




4    emissions than new plants in which pollution control




5    equipment is designed into the plant from the beginning.




6                  The EIS would be improved by inclusion of




7    the fluoride pollution control capabilities of the plants



8    which are intended to process phosphate from new mines.




9                  (b)  I appreciate that EPA is recommending




10    biological monitoring of fluorides, Section 4, page 4.1,



n    ambient vegetative-fluoride sampling program.



12                  I believe it should be expanded, and I




13    submit for your consideration a research plan, enclosed,



u    authorized by EPA  to monitor fluorides potentially



is    emitted by the Occidental Chemical Company operation in




i6    the vicinity of the Suwannee River, north Florida.



17                  The results of the north Florida research



18    and the techniques developed there might be very useful




19    to a more complete monitoring iprogicam in central Florida.




20                  I hope you don't feel I'm setting you up,



21    Mr. Traina.




22                  MR. TRAINA:  No.  As a matter of fact, as



23    I recall the hearing we had up there, you suggested we



24    use the one down here, and I think that's fair.  That's



25    very fine, s ir .





                               t-8C>
86

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 3





 4






 5





 6





 7





 8





 9





10





1 1





12





13





14





15





16





17





18





19






20





21





22





23





24





25
       (Laughter)



MR. CARR:



              I will not attempt to outine a specific



monitoring program for central Florida, but I do ask



that you study the North Florida Research Plan with an



eye for its relevance to the central Florida area.



              Ms. Rains raised several points with



respect to public health.  I have not addressed them,



and I think that --- Well, I would be frightened to



find out all there is to know about fluoride pollution



in terms of public health.



              I believe that I would like to underscore



her remarks in that area.  If animals that I sampled



had fluoride contamination, I'm even more worried about



people.



              Under wetlands, I approve heartily of the



intent and justification to protect wetlands expressed



in the EIS.



              I notice that many, 36 or 39 archaeological



sites, are located within them, adding to the basic



ecological and hydrological good sense of protecting them.



              I don't elaborate on this more, by the way,



because I have elaborated with Gene McNeill and EPA at



great length over this subject, and our positions are



very well stated, I believe.





                           t-87
T-2L7
                                                                   87

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i                   However,  I am  very disturbed by  the
2     concept  of cutting  the  hydrological  throats  of the
3     wetlands expressed  under "Effects  of Controlling Activities
4     in Waters of  the US and Wetlands," page 2.90.
s                   And perhaps  I  should explain this point.
6    The  idea that's developed  in the EIS is that wa will vow
7    to save  the wetlands, so we'll  mine  around it, and  it .leaves
e    the  wetland  isolated, the  principle  that  the EIS stated.
9                  If leaving wetlands  on d«eiic«ting, padeetAls
10    spells their  doom,  then a void ding them  to  begin with becomes
n    nonsensical.  The environmental objective is lost,  and;the
12    sacrifice by  the phosphate industry  is wasted.
13                  I agree with the  conclusion that "mining
14    effects  on remaining or undisturbed  wetlands should be
15    addressed in  greater detail," page 2.91.
16                  I recommend  that  the principle of the
17    pedestal concept receive thorough  attention  in the  final
is    EIS, and that it be stressed that  the danger of wetland
19    garroting should be carefully addressed in site-specific
20    EIS  proceedings, which  will  follow the areawide, assuming
21    there  is a go alternative.
22                  Finally,  energy and  phosphate  conservation:
23    It is apparent that the huge energy  requirements for
24    phosphate mining and processing, described on  page  2.7,
25    is met only because the industry receives a  subsidy in
                                                                   88

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i     the form of  lower rates from TECO and Florida Power,



2                   Just as it Is said that fche industry competes



3     with  the public for aquifer water, so it can be argued  the



4     industry competes with the public for energy.



5                   From data presented on phosphate supplies



6    and demand,  on page 2.8 to 2.11, it is apparent that



7    more  energy  will be required to extract a given onit



e    of rock in the very near future.



9                  Jhibr economic resources are expected to



10    become economically recoverable wheiiathe market value



11    of phosphate increases.



12                  The fallacy and danger of this argument



13    is that not  only more money but more energy will be



u    required to  produce what are currently sub-econoaic



is    resources.   Energy, unlike the market, will not inflate.



i6    It will only deplete. Thus there will be two inter*



17    dependent and non-renewable resources following extension *



18    curves, and  the cost of phosphate, energy and food will



19    be presumably logrithmically increasing.



20                  I cannot help but envision a crisis emerging



21    from  these divergent curves.  I believe the history of



?2    fossil fuels  is a sufficient model to lead to this con-



23    elusion, but  I have every confidence that a complete



24    evaluation of current phosphate resource management



25    practices, combined with agricultural study, would  prove
                                                                   189

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     the  point.
 2                  In  view  of the above, I,look with great
 3    concern on the  industry's enthusiastic search for new
     and  larger phosphate markets abroad.   It is argued that
     the  national balance of trade is served by phosphate export.
     What fossil import  is  required to subsidize that export?
     I would be more content if in the final EIS the US Depart-
     ment of Energy commented on this ppint and on the compliance
     of phosphate mining expansion with national energy policies.
                   I'm inclined to believe  that American
     agriculture and the American consumer are being set up
     for  a  food-cost crunch in the near future, perhaps before
     2000.  This crunch could be at least postponed by
 I O
     domestic resource conservation commensurate with incentives
 14
     to Morocco to bring her massive resources on line rapidly.
                   In  summary, I believe EPA wrill succeed in
 16
     providing for a clean  industry in west central Florida if
     the  areawide EIS  is adhered to.
 18
                   But I am worried that EPA is becoming
 19
     innocently involved in gross resource mismanagement.  If
     I am correct, then the cleanliness will be a trivial
21                '
     accomplishment.
                   Sincerely, Archie Carr.
* \5
24                 MR. TRAINA:  Thank you, Mr. Carr.
25         (Applause)

                                                                   90
                                 /- 90

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 i                  MR. TRAINA:  David Rosen?



 2    DR. ROSEN:



 3                  My name  is David Rosen, M.D.  I've been



 4    living  in Sarasota,  the SarasotarBradenton area, for  the



 5    past year.  My address is 508 Bay View Drive, Longboat



 6    Key.



 7                  However, I've been coming to this area  now



 e    on vacation, I would say for the past twenty-five years.



 9                  I have practiced medicine in New York City,



10    and I would just like to acquaint you with something  that,



,,    as a physician, we knew for a long time.



12                  We know that the area of northern New Jersey



13    has been an area of very high cancer incidence.  Lately,



]4    it has appeared in the papers throughout the nation, but



)5    as physicians we knew that about ten to fifteen years ago.



]6                  The incidence of malignancy in northern



,7    New Jersey is about ten times as great as that in other



18    areas in the United States.



19                  We also have an area in New York State where



20    the incidence of malignancy is very high, and that's  in



2,    the area around Ossining, New York.



22                  The incidence of malignancy around the



23    Ossining area is about ten times as high as most areas



24    in the United States, and it compares to that of northern



25    New Jersey.
                                                                    91

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                   Northern New Jersey  is a  very highly



2     industrialized area.  We have  emissions  from cracking



3     plants, refineries, electric- plants, and various



      industrial complexes.



                   We have always thought that  this would



      be a  favorable area for the  development  of malignancy,



      and time has proven it has.



                   However, lately  we have had  several cases



      of leukemia in a very small  district, and  the health



10     authorities haven't been able  to put their finger on i t.



      We're very suspicious^ but we  cannot exactly prove  it.



12                  Now, in the area around Ossining, the



,3     factors are entirely different.  The area  around Ossining



14     in Westchester County is not industrialized, but the soil



      around there is highly radioactive, and  it has been like



16     that  for centuries.



17                  At first the public  in the Ossining area



18     tried to blame a lot of this high  incidence of malignancy



19     on Con-Edison's nuclear power  plant, but that has been



20     entirely disproved



21                  The point I wish to  make  is  that with



22     this  phosphate mining and the  radioactive  contamination,



23     not only of the drinking water, but of  the air, you may



24     reach a stage where it would be impossible for most of



2     the people to live here or want to live  here.
                                                                    92

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 i                  Now, we had an example of this about eight
 2    or ten years ago when it was discovered fchat the
 3    inhalation of asbestos fibers would produce lung
 4    malignancies and malignancies of the abdomen, anywhere
 s    from five to thirty years after these fibers were inhaled.
 6                  We know from our experiences with radioactive
 7    substances that the time between the exposure to radiation
 8    and the development of malignancies can be anywhere from
 9    one month to twenty or thirty years.
10                  As a matter of fact, the incidence of
n    malignancies among X-ray men is ten times as high among
12    just ordinary physicians not involved with a great deal
13    of X-ray work.
)4                  And that is what I want to emphasize.  You're
]5    actually playing with fire.  You're developing a high
16    incidence of radiation, both in the water that you drink
17    and in the air that you inhale.
18                  That's all I wanted to say. Thank you.
19           (Applauds).
20                  MR. TRAINA:  Thank you very much, Dr. Rosen,
2)    for taking the time.  I think those comments are very,
22    very significant.
23          Homer Greer?
24    MR. GREER:
25                  I'm Homer Greer.  I live at 350 Northshore
                                                                   93

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     Road, Longboat Key.  My first year in Manatee County was



2    in 1920 when no one, even the farmers, or anyone in the



3    community visualized anything pertaining to phosphate or



4    phosphate mining.



5                  I want to give each one of you men a



6    preparation we prepared for one of our local papers



7    consisting of twenty pages pertaining to phosphate mining.



e                  I don't think you had an opportunity to



9    see it.  Therefore, I'd like for you to read it when you



10    have time.



11                  MR. TRAINAj  I did have ar  opportunity, and



12    I'll tell you, it beats the heck out of government pub-



13    lications, and it's very well written.



,4                  MR. GREER:  Thank you kindly; I appreciate it.



,5    I didn't write it.



16                  MR. TRAINA:  Whoever did should be complimented




17    MR. GREER:



]8                  I'm particularly concerned about Manatee



19    County, because this is where I live, and this is the



20    which I intend to live for the next twenty years.  I'm only



21    seventy-seven, so I see some of you fellows may be gone



22    before I am.



23                  But as a matter of fact, I wanted to show



24    you the area pertaining to the phosphate mining in Manatee



25    County^.   I wanted  to show you the area the various phosphate
                                                                    94

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i     mining companies own  in Manatee County.
2                  In the  county itself, we have approximately

3    500,000 acres of land, and the phosphate companies  in

4    their entirety own  103,000 acres.
5                  As you  can see, this particular area here
6    is 43,000 acres owned by W.R. Grace.  They also own
7    another 11,000 acres  up at the Northern edge of the
8    county bordering on Hillsborough County.
9                  Then the other companies here are Swift,
10    Continental Oil, US,  the Becker Phosphate Company, the
n    First National Bank.
,2                  Down in the corner is the IMC company and

,3    the Phillips Company, and then here is our Lake Manatee
14    with the tributaries  coming throughout this area.
15                  Here is the Gardinier plant.
16                  This is the Florida Power and Light plant.
17                  This is the Borden plant, which is existing
18    at the present time.
19                  This is Port Manatee.
20                  This is a new area that will be occupied

2,    by the A His company and the Simons company vhen they
22    get it in operation.

23                  This is the Manatee County Utility Company,
24                  Clear down in the lower part of the county
25    here is Myakka State  Park.
                                                                    95
                                 /-

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 1                   The  major  important  factor,  as  I  see  it,



 2     pertaining to phosphate  mining  is  the  fact that if  all



 3     these  companies  start  mining at one  particular  time or



 4     near one  particular  time,  as Ms. Rains  told you,  they



 5     would  use approximately  94 million gallons of fresh water



 6     daily.



 7                   And  when you think of  this use  of fresh



 8     water  compared to  the  fact that our  new planning  depart-



 9     ment operating in  Manatee  County say that  in  the  next



10     twenty to twenty-five  years, we will have  a total of



n     200,000 people living  in Manatee County —



12                   At present there  are around  65,000  people



      living here,  so  as these companies begin to mine, if
I 3


      the  slime should get away  from  them, either through



      heavy  rainfall or  through  the loss or  the  break of  one



      of the dams,  our tributaries to the  Manatee County  River,
16


      where  we  get  all our drinking water, would be so  polluted



      that it would be impossible for us to have drinking water.
1 O


                    In addition  to that, if  in the  lower  part



      of the state, you  should have a slime spill,  then the



      Myakka River  would completely destroy Myakka State  Park



      and  all of the vegetation  and the  life  in  the river, as
22                                                        '


      well as the life around  the river.
23


                    Now, in  the  pictures that we saw  a while



      ago  that  were shown by the EPA  organization,  it showed

25                                                                  96

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i      that  there was  trees and vegetation growing along  land

2     which presumably had been worked over or reclaimed by

3     the phosphate company, but they didn't tell you that

4     only  a, short length of time back, the Peace River was

5     completely devastated by slime phosphate, and the animal

6     life  or  the fishing life in the river was completely

7     destroyed.

8                  I have flown over Hillsborough County,

9     a great  deal of Polk County, and as you saw the pictures

10     that  were represented or shown here earlier in the program,

n     they  showed big trees, pine trees, growing along, and

12     they  intimated, at least, that these were growing over

13     reclaimed land.

14                  Well, those pine trees must have been at

15     least fifty to seventy-five years old, and in my flying

16     over  Hillsborough County and Polk County, I saw no

]7     vegetation or any trees of this type.

18                  Now, it may be that these trees grew fifty

)9     or sixty years ago or even longer in some of the reclaimed

      land.  That I cannot disprove.

                   But in asking and checking with the Corps

22     of Engineers and the mining Interests, mining department

23     for the  State of Florida, about a year ago, they told me

      that  they had no realization or no idea of how many acres

25     of land  had been mined in the State of Florida, how much
                                                                    97
                                /-T7

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 i    was  being mined  in the  State of Florida,  and  no  idea
 2    of how much land  had  been reclaimed.
 3                   Therefore,  I'm very  skeptical about  the
 4    pictures  that were shown  showing these  very,  very  large
 5    trees.
 6                   In  the  past I've  seen pictures  showing
 7    fattened  cattle walking around  on  land  that had been
 e    reclaimed,  and recently I had one  of  the  people living
 9    right  out here in the edge of Hi11sborough  County where
10    the  cattle  begin  to go  down physically.
11                   They had  vets  come in and check their
12    cattle and,  because of  the pollution  of the grass, the
13    cattle had  lost all of  their teeth, and they  had to dis-
14    pose of their entire  herd before they died.
15                   These are actual  facts and  not  hearsay.
16                   I'm also  very  much concerned  about what
17    will happen  to we people  here in the county,  as time goes
18    on,  if all  of these people or all  of these  phosphate
19    companies are allowed to  mine.
20                   The money that they  use or  make  from the
21    mining process is not retained  in Manatee County.  Almost
22    In its  entirety it's  taken out  of  the county  and out of
23    the  state.
24                   So  we,  as individuals,,within  the county, have
25    no benefit,  with  the  exception  of  a small group of people.
                                                                   98
                                I-IB

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 i                  It's an established fact that one mining

 2    operation actually hired twelve men in a  twenty-four-hour

 3    period, twelve men; the salary of twelve  men is com-

 4    paratively small.

 5                  All of the rest of the operation of  these

 6    companies, as they would operate, is a mechanical  operation,

 7    and I don't like to have companies  of any kind or  people

 e    of any kind, including the  EPA,  insinuate that we  are

 9    going to have a mess of capital brought into our county

,0    or our community and it will remain here  or stay here

,,    because, as a matter of fact, that  is  not true, and I

12    wish to thank you very, very kindly for your interest

13    and your allowing me to speak.

14                  MR. TRAINA:  Thank you,  Mr. Greer.

15          (Applause)

16                  MR. TRAINA:  Mr. Greer,  there's  just one

17    comment.  As I understand the report,  I presume all these

18    areas are potential areas;  they're  not existing areas.

19                  As I understand the report, it would not

20    call for slime ponds.

2)                  MR. GREER:  Well,  at  the present time ---

22                  MR. TRAINA:  As I  understand  the report,

23    there would be no slime ponds associated  with  this new

24    activity.

25                  MR. GREER:  Well,  I can't say that there  will
                                                                    99
                                /-ff

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i     be no slime ponds.  I know at the present time there are

2     large slime ponds.

3                   Take the Borden plant, for example.   They

4     had purchased 	 They have a large slime pond, and it's

5     now at the present time about 40 feet	The  size of the

6     bank is about 40 feet high, and they can go up to  a

7    70-foot height in building up this bank.

8                  I can't tell you exactly which one of the

9    two companies, but one of the companies, they purchased

10    all of the air rights in the surrounding community so

n    nobody can bring suit against them.

12                  In flying over the area, as I did, the

13    citrus fruit was destroyed, either dying, or had been

14    destroyed for miles back away from the present slime ponds.

)5                  There were no trees any place in existence,

16    and I took this flight just a little over a year ago.

,7                  MR. TRAINA:  I know they exist now,  but the

)8    report deals with new sources and recommends that  there
   I
19    be no slime ponds.

20                  MR. GREER:   Well, I'm very  encouraged to

2)    have that kind of a recommendation, but I take facts as

22    they exist today, not hopefully as they will exist twenty

23    years from now.

24                  MR. TRAINA:  I understand,  sir.   Thank you

     very much, Mr. Greer.
                                                                    100
                                I- 100

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 i           (Applause)

 2          Jean Russell?

 3    MS. .RUSSELL:

 4                  Greetings.  I'm Jean Russell, Longboat

 5    Key, and I want to ask a question for one of the gals

 6    sitting there.

 7                  What is a new source?

 8                  MR. TRAINA:  Okay.  Let roe describe it

 9    as unlegally as I can.  Under the Federal Water  Pollution

10    Control Act, there are different requirements for existing

n    sources and new sources, and if the source is determined

12    to be new under those requirements, then the recommendations

13    contained in this report would apply to that source, and

14    all the things with regard to elimination of slime ponds,

15    and all the other items that Mr. McNeill talked  about,

)6    would apply to any permit issued to that facility, because

]7    it is a new source.

18                  MS. RUSSELL:  Okay.  I wanted to ask you,

19    who provided the pictures of all the great things the

     phosphate company has done, like the clean Peace River,

21    and reclamation and the cattle grazing?

22                  MR. TRAINA:  Well, Ms. Russell, I  don't know

23    who provided those, but you have comments to make on them?

24                  MS. RUSSELL:  I don't.  Honestly,  we are so

25    terribly worried here, and I know your requirements; as
                                                                   101
                               l-toi

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2
3
10





11






12





13





14





15





16





17





18





19






20





21





22





23





24
     Mr. White told me, you can just go by the requirements




     that the law states, but you do,not have to put on those




     pictures for the rest of us who are so terribly, terribly




     concerned.




                   I do think it's biased, don't you, a little




     bit?




           (Applause)



                   You don't see a picture of that Peace River



     where the effects of that went for a hundred miles, and




     the things all the others have touched on, and I'm not




     going to keep these darling people here by yakking, but



     I don't think you're being very fair to us.




                   Please don't do it again.



           (Applause)



                   MR. TRAINA:  Thank you.



           Catherine Fernald?




     MS. FERNALD:




                   I'm Catherine Fernald.  My husband and I




     have lived on Longboat Key and owned property since 1965.



     We've been interested in this area for a long time.




                   As a taxpayer in Manatee County, I have a



     question for the EPA.  Does EPA expect to address itself



     to the hidden cost of phosphate mining, the health, covered




     by lots of people, the water, the draw-downs, the salt
25    water intrusion, the loss of potable water?
                                                                   102

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i                   What will be the cost to transport water



2     from the Suwannee River?



3                   Air:  The medical expense will be borne



4     by the public when there's air pollution.



s                   The subsidization by taxpayers of the State



6    by the reduction of severance costs for phosphate shipping?



7                  In regard to the slime pond, if Becker



8    Phosphate is declared an existing source, then we are



9    stuck with slime ponds in Manatee County, so this is



10    another question.



11                  MR. TRAINA:  You're right.



12    MS. FERNALD:



13                  As the !environmental chairman for the



14    Longboat Key Garden Club, I was part of the adjudicatory



15    hearing before Judge Yost, and I felt very strongly that



16    the judgment handed down by Mr. White of the EPA in Atlanta



17    is completely unfair, and I'd certainly like to have a re-



18    hearing on the whole thing.



19                  Thank you.



20                  MR. TRAINA:  Thank you.



21          (Applause)




22                  MR* TRAINA:  I just might comment on that



23    list of items, Ms. Fernald, that there is provisions — I'll



24    be more happy to talk to you — on how a decision of the



25    Regional Administrator can be further reviewed by the
                                                                   103

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i     Administrator.  Those administrative procedures do —



2                  MS. FERNALD:  The big problem, sir, is that



3    we are single citizens in this county, and the expenses of



4    hiring attorneys and doing that is almost astronomical.



5                  Large phosphate companies multiply and multiply



6    the hearings and the hearings and the hearings and draw us



7    down to no money, and somewhere in the government we ougitt



8    to have someone who la ombudsman for us to take our side



9    of the question, and we think you should be the ones to



10    do that.



n          (Applause)



)2                  MR. TRAINA:  Our eminent! counsel .would like.



)3    to make a comment.



14          Mr. Phillips?



15                  MR. PHILLIPS:  Ms. Fernald, we appreciate



16    the comment, and would mention that Sarasota County has



17    appealed the regional decision to take orders, and they're



1g    now considering whether to grant that appeal.



19                  MS. FERNALD:  If you would, because it cost



20    $800 already, if you can provide us with a little help of



21    a lawyer, we'll be glad to do it as well.



22                  MR. TRAINA:  Thank you.



23          That concludes the list of the people that indicated



     on the cards that they would like to make a statement.
24                         J


           At this time I would ask if anybody else who has not
                                                                   104

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,     made one would like to come forward and make a statement..

2           (No response)

3           Is there anyone who has made a statement who'd like

4    to amplify or further comment?

5                  MS. RAINS:  We'd just like to thank you a 11

6    for coming down.

7                  MR. TRAINA:  Mr.' Carr?

e                  MR. CARR:  Just a question, Mr. Traina.

9          We're working with the areawide impact statement

10    here tonight, and it will be followed by site-specific

n    impact statements later.  I'm not 100 percent sure how

12    the areawide impact statement will relate to site-specific

13    impact statements in terms of, say, permits and that

,4    kind of thing.

,5                  MR. TRAINA:  Okay.  Let me ask Mr. Hagan to

16    comment on that.  I think it's an appropriate comment.  If

17    I don't care for his comment, I might add tome more to it.

,8           (Laughter)

19                  MR. HAGAN:  Feel free.  The areawide impact

20    statement was designed to cover just that, the areawide

21    impacts.

22          Were are trying here, through this process, to set

23    forth policy guidance, which we can then apply to Individual

24    site-specific mines or chemical processing plants .

25          It is our intention to use this areawide impact
                                                                   105
                            1-10

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i     statement as a policy direction for EPA.  Hopefully, it
2    will also be used as a policy direction by other federal
3    agencies in guiding their actions, so that we can have
     a consistent federal, state, local approach to the
5    regulatory processes that govern the phosphate industry.
6          Beyond the policy-setting activity, it will provide
7    some administrative forum for satisfying the National
8    Environmental Policy Act with respect to the individual
9    impact statement.
10          However, the individuals, I think, will be much
n    more specific in terms of impact on wildlife, impact on
12    wetlands, and the particular pollution control requirements
)3    for each individual plant or mine as they're developed.
14          Do you want to add something?
,5                  MR. TRAINA:  The only thing I'd like to add
]6    is the job that I have, as Director of Enforcement, I am
17    responsible for issuing the permits, not only to the
18    phosphate industry, but to any other industry, or any other
,9    point source, for that matter.
20          It certainly is my intent to follow very closely
2,    the guidance, if you will, that's in this document, and
22    certainly to follow the individual EIS's with regard to
23    specific recommendations as it relates  to things like
     gyp ponds and slime ponds and meeting various federal,
     state and local emission limits, be they air or water.
                                                                   106

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15    here.
      I'm very much aware, as I think everyone here,

 including the industry, of the past, and I think this

 document — I would like to think that this document

 represents at least a major turn in the way the federal

 EPA has been able  to, or not able to, as the case may

 be, regulate this  industry, and I don't need to comment

 in any great detail about the problems that the federal

 EPA has had in the past,

      And we hope  that with this document and the public

 reaction to it, and I do appreciate very much the public

 reaction tonight.

      I look forward to getting it on Wednesday and Thursday

 night -- we are having two other meetings — along with

 the written comments that come in to, maybe, turn a corner
      We have had many opportunities that haven't been as,

optimal as this one is with regard to putting sojne direc-

tion, more direction, into controlling and regulating

this industry.

      As they say, as far as the NPDES permits and the

other air — as well as the other environmental areas that

EPA gets involved in, the 404, although we do get involved

in the review with the Corps of Engineers on that one,

it's my intent to implement, not only the tone, but the
25    actual recommendations  of this  document.
                                                                   107
                            /-/o?

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           Are there any other comments?
2          Yes, sir?
3                  MR. GREEK:  I just wanted to make one more
     statement, and that's to the fact the dear phosphate
     companies operating, or intending to operate in this
     community, have hired some very, very attractive little
 7    girls to go around through Manatee County and Sarasota
 8    County asking the public to sign statements they think
 9    phosphate mining in this community would be a very, very
     fine thing, and I wanted you to know that.
                   MR. TRAINA:  Are there any members of the
     panel who'd like to make a comment?
            (No response)
 I O
 ]4                  MR. TRAINA:  Okay.  I'd like to thank, on
     behalf of all of us here, EPA and the others who are
 )6    involved with this study, thank you all for coming.
           Let me just make a few closing things here.
           The comment period, the written comment period, will
 I 8
     be  open until June 23rd, 1978.  Anyone who would like to
     make some written comments or amplify what you've said
 20                                        J      J
     tonight, please address those comments to John Hagan,
     Chief, EIS Branch, EPA, Region IV, 345 Courtland Street N.E.
     Atlanta, 30308.
 23           '
           As we indicated	
 24
                   MR. HAGAN:  I have cards; if anyone would like
 25
                             t-tos
                                                                    108

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     a card  to  get  the  address  correct,  I have it.
 2                   MR.  TRAINA:  We will  take the comments made
 3    tonight and any  comments  ---  'They will be addressed in
     the  final  EIS, which is scheduled for publication by
     July 31.
 6          Again, thank you for coming,  and the hearing is
 7    adjourned
 e                               (Whereupon, the hearing was
 9                               adjpurned at 9:55 p.m.)
10
n
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23                               -000-
24

                                                                     109
                             /-/Of

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                       CERTI.F][C_ATE

             This is to certify that  the attached proceedings

             before THE ENVIRONMENTAL PROTECTION  AGENCY,  REGION IV

             in the Matter of:

 s                 Draft Environmental Impact Statement Public
                   Hearing
 6
                   Manatee Junior College
                   Bradenton, Florida

 a                 7:00 p.m.

 9                 May 22, 1978

10           were held as herein appears and that this  is  the

H           original transcript for the file of  the Agency.

12

13
                                      Official IIRe/porter
14


15


16


17


18
                                -oOo-

19


20


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                 UNITED STATES  OF AMERICA
              ENVIRONMENTAL  PROTECTION AGENCY
                         REGION IV
A Public  Hearing:


  DRAFT AREAWIDE ENVIRONMENTAL  IMPACT STATEMENT

  CENTRAL FLORIDA PHOSPHATE INDUSTRY

  March 1978
                             Time:          7:00 p.m.

                             Date:          May 24, 1978

                             Location:      Bartow, Florida
                           -oOo-
                BAY PARK REPORTING COMPANY
                       COURT REPORTING
                     33 FOURTH STREET NORTH
                    ST. PETRRSBURG. FLORIDA  33701
                          (813) 823-8388

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APPEARANCES:
       THE CHAIRMAN:
       THE PANEL:
                      PAUL TRAINA
                      Director of Che Enforcement Division
                      Environmental Protection Agency
                      Atlanta, Georgia
                      DR. MARVIN COLLINS
                      Florida Department of
                       Environmental Regulation
                      Tallahassee, Florida

                      BILL STOWASSER
                      Bureau of Mines
                      Department of Interior
                      Washington, D.C.

                      BILL PHILLIPS
                      Office of Regional Counsel
                      Environmental Protection Agency
                      Atlanta, Georgia

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  1     SPEAKER                            PAGE



  2     Linda Campbell                       27




  3     Homer Hooks                          29




  4     George  Cornwell                      41




  5     E,  Edwacd Holloway                   62



  6     B.  J, Register                       64




  7     W.  M. Leaders                        69




  8



  9




 10




 11



 12



 13



 14




 15



 16




 17



 18




 19




 20




 21



 22



 23



 24



25









                             t't/3

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                      PROCEEDINGS.



 2                                 (Whereupon, at 7:12 p.m. the



 3          hearing was called to  order)



                   MR. TRAINA:  The hearing is open.



           Good^evening, ladies and gentlemen.  My name is Paul



     Traina, and I am Director of the Enforcement Division of the



     United States Environmental Protection Agency, Region IV,



     Atlanta, Georgia.



           The Regional Administrator, Mr. John C. White, has



10    designated me to run this hearing tonight.



n          I would like to introduce the other panel members



12    with me.



13          On my far left is Dr. Marvin Collins.  Dr. Collins is



     representing Mr. Jay Landers, who's the Secretary of the



     Florida Department of Environmental Regulation.



)6          On my immediate left is Mr. John Hagan.  Mr. Hagan



     is Director of the Environmental Impact Statement section of



     EPA in Atlanta.
 o


           On my far right is Mr. Bill Stowftsser.   Mr. Stowasser



     is with the Bureau of Mines.  He's representing the Interior



     Department from Washington



           On my immediate right is Mr. Bill Phillips.  Mr.



     is with our office of Regional Counsel with EPA in Atlanta.
/ ij


           Tonight's hearing is concerned with a two-year study
24


     on environmental,  social and economic effects of continued
25

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     expansion of the central Florida phosphate industry
2          The purpose of the study is to comply with the National
3    Environmental Policy Act of 1969.
4          Issuance of National Pollutant Discharge Elimination
5    System permits for new sources of phosphate mining and
6    chemical processing operations constitute a federal action
7    which significantly affects the human environment.
e          As sue);, the National Environmental Policy Act requires
9    development of an Environmental Impact Statement prior to an
)0    issuance of these NPDES permits .
n          It was determined in early 1976 the number of new
12    phosphate operations which would request permit applications
13    would make individual site-specific Environmental Impact
14    Statements ineffective in determining areawide and cumulative
)5    effects.
16          Each individual study would determine effects of that
]7    particular operation, and areawide and cumulative effects
18    might easily have been neglected.
19          For this reason, all new source permits were held in
     abeyance while the areawide EIS was developed.
           A draft of the statement has been prepared, and notice
     of its availability was published in the Federal Register,
     Volume 43, dated April 21st, 1978.
           The hearing tonight is for the purpose of receiving
     comments from the public on this draft Environmental Impact
                                                                    5
                            /-t/sr

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i     Statement.



2          All substantive comments on this draft EIS will be



3    considered by EPA and summarized and addressed in the final



4    Environmental Impact Statement.



5          As stated on the agenda, we will begin with a brief



6    presentation by EPA and the contractor of the study, Texas



7    Instruments, to summarize the major conclusions of the draft



8    EIS and how those conclusions were developed.



9          Those of you who have indicated on the registration



10    card that you wish to make oral statements will be given an



n    opportunity to do so.



,2          At this point I'd like to call for Mr. Gene McNeill,



13    who's the Project Manager of this study for EPA.



           Mr. McNeill?
I 4


15                  MR. MCNEILL:  Thank you, Mr. Traina.



)6          What we'll do next is just very briefly go through some



     of the highlights of the findings.



           As Mr. Traina said, the main purpose of the hearing
1 8


     here tonight is to hear you, to give you the opportunity to



     make comments, make statements, regarding this draft EIS.



           With that, I think I'll introduce the contractor,
21


     Texas Instruments, who was the prime contractor on this
22                     '


     study, and they will briefly go through the findings in the



     draft EIS, and then I will summarize the proposed action.
?4


           Larry Bowles is Project Manager of Texas Instruments,

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 '     the  prime  contractor  on  the study.
 2           Larry?
 3                  MR. BCWLES:  Thank you, Gene.
 4           I'd  like  to introduce Audrey James, a member of our
 5     staff  on the  program, and Dr. Arnold Stalder, and Arnold
 6     will give  the presentation this evening, so I'll turn the
 7     microphone over to him.
 8                  MR. STALDER:  This evening, rather than
 9     summarize  the results that are compounded and condensed in
10     the  draft  EI8,  which  were founded on some 1,500 pages of docu-
11     mentation  that  preceded  the draft EIS, I'm going to go
12     through just  briefly  what it was we did when we prepared
13     documentation to support the EPA in preparation of the EIS.
,4          We were studying a seven-county area in central Florida
)5     and  you can see, outlined in there, the area that is mainly
16     concerned  with  phosphate formations.
17          The  larger circle  includes the entire Bone Valley
18     formation;  the  smaller loop to the north, which includes the
19     gray shaded areas, which depict currently the mine or past
20     mine phosphate  industry  activities, is the atoea^of^the hlghes :
21     grade ore.
22          The  larger area, which includes the gray hatched regionn
„,     to the south, is the  area of lesser grade ore, which the
e. J
?4     phosphate  industry is now proposed to move into.
25          Those areas, which are gray hatched, are those which

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     had  permit  applications  submitted  to  the Florida DER.




2           If  you  look  at  it  in  a topographic relief,  you can




3    find that the study area includes  the Polk uplands,  and you'l




     find that there's  a ridge in the south edge of this,  and




     this area is  the area where the primary activity of  the




     phosphate industry has been in the past year.




            If  you  drop  on  down to the area in DeSoto and  Hard^e




8    County, you'll  find another slight drop in the topographical




9    relief, as  this area  seems  to afford  the next  best chance to




10 |   move phosphate  from the  ground from these deposits.




11           The study area  also included the Charlotte  Harbor area




12    and  the Tampa Bay  area.




)3           Ground  rules for Texas Instruments are summarized in




14    the  next  three  slides.




,5           We  were to use  existing data; that is, data that  had




,6    been prepared by the  phosphate companies for DRI's,  data




17    that had  been documented and published in one  form or another




19    on the study  area  for various and  sundry reasons.




19           We  were to receive help from EPA,  Bureau of Mines,




20    USGS,  and various  and sundry federal  agencies,  the Florida




21    DER,  SWFMD, and regional planning  councils  to  provide data




22    to support  the documentation on this  EIS.




23           EPA was specifically  furnished  material  on  laws and




24    regulations,  industry descriptions, water quality and air




25    quality.
                                /-tie

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           EPA was also to assist and perform studies and reports



2    on radiation as it pertains to the phosphate industry



3    activities in central Florida.



           USGS was to provide their Floridan Aquifer model to



     protect the impacts from the phosphate industry on the



     Floridan Aquifer.



           The Fish and Wildlife Service was to furnish a wild-



     life inventory and distribution data, which in fact they



     did by performing an independent study, which was then sup-



10    plied to Texas Instruments and incorporated into the docu-



n    mentation which we supplied EPA.



)2          Bureau of Mines furnished reserves, demands, produc-



13    tion data cm the phosphate industry, and population projec-



     tions were based on University of Florida estimates.



           There were two committees involved in this project:



     the steering committee that was formed of federal agencies,



     Bureau of Mines, EPA, Council on Environmental Quality, and



     several others, Corps of Engineers, and the Florida DER --
1 8


     not a federal agency -- provided the primary direction for



     this study, and there was an advisory committee that consiste<
20


     of representatives of the counties, Florida DER, and en-



     vironmental groups in the Florida area, who are quite speci-



     fically affected by phosphate industry activity, by their
Z J


     influence throughout the course of this study.



           The object of this was to review five alternatives

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     that were depicted by the steering committee and review the

2    relative effects of the alternatives.

3          The effects assessments methodology was to address a

     series of decision indicators.  Decision indicators, in this

5    case, were possible effects on air quality, ground water

6    quality, water supply, and so forth,

7          They were outlined by the steering committee, and the

     priorities with which these were to be considered were set

     up by the steering committee,and were somewhat limited in

10    certain cases by money limitations,

11          There were quite a few questions raised that couldn't

12    be answered completely based on existing data.  In that

13    case, priorities were set by the steering committee, which

     will be addressed specifically.

is          We were to assist EPA in the preparation of the draft

16    EIS and help to address comments on this draft EIS in

     preparation for the final Environmental Impact Statement.

is          To perform this service, we consulted with several

19    people, who are quite familiar with specifics in the Florida

20    area;

21          Dr. James Nicholas.on socioeconomics; Dr. Paul Urone,

22    University of Florida, an air quality chemist; Dr. Eric

23    Rifkin, on ecology and general effects; and Geraghty and

24    Miller, Peter Schroeder with Geraghty and Miller for hydro-

25    geology, primarily ground water quantity; and Tomasino and
                                                                   10


                                '- /

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,     Associates, Sam LocKwood with that organization,  to help



2     us flesh out the scenario description and discuss surface



3     wa ter .



4           We were to forecast resources and  demands  in the area



5     to the year 2000.   This involved  the phosphate  industry



     and other demands  on water supplies, land use, and so  forth.



           Baseline data and regulations, for the  most part, were



8     those that existed on 1 August '76, the  starting  point for



     this contract.



           We were to prepare preliminary findings in  the form



     of working papers, which would be distributed and disseminate^



     such that both the advisory committee, the steering committee



     and the general population of the area could  see  them  and



     comment upon them and get their inputs in before  the En-
14


     vironmental Impact Statement was  prepared.



           And the integrating theme for the  whole project  was,
16


     in effect, environmental land use planning, and there  were



     some adjustments made to the data,  and the land use data
1 8


     had not been projected out to the year 2000,  and  extrapo-



     lations from the distant data were made.
20


           Data of the  respective land use activities  of the
21


     phosphate were acquired through a land use questionnaire,
22


     which was submitted to the individual phosphate companies,



     who then responded, and this information was  incorporated


     into the EIS.
9S                                                                 I
                                                                   11

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           The Corps of Engineers regulations concerning wetlands,j



     which were finalized 1 September '77, which is an exception




     to the 1 August '76 rule with regard to regulations, were




     considered in the preparation of this document.



           And all phosphate operations that had not been permitted




6    prior to 1 August '76 were, for purposes of this documentatioi,




7    considered new sources.



8          We looked at two points in time:  the year 2000 and




9    then, based on phosphate production in the country and in




10    the Florida area, there's a peak around 1985; we looked at




n    the short term, 1985, and then again at the year 2000 in re-




12    viewing effects.



           What we have here is a list of the operators in the



14    area.  Above the first break are those existing mining



15    operations in the central Florida area.




16          The next small bunch are, with the exception of USS



)7    Agri-Chem, those which have submitted DRl's by 1 August '76.




lg    USS Agri-Chem was added to this section, because their



19    obligation appeared to be imminent.



20          The list on the bottom, and if you kind of slide up



21    the scale and look with regard to the top, production is



22    estimated to stay at nearly a constant level.  Most of the




23    activity at the top dies out by the year 1985, and you'll



     find that between the new batch and those at the bottom, it



     would tend to continue production at nearly a constant rate,
                                                                    12

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      moving the  mining activity from the  Polk County area south



 2     then,  as  the  reserve  depleted  in the northern area.




 3           The information that we  got, the  data that we  got,



      came  from a bunch of  sources,  and we'll go  over examples



 5     of  some.




 6           Air quality data we  got  through Dr. Paul  Urone and



      Chadbourne, one  of his colleagues.   This  data was basically




      data  supplied by the  Florida DER.



            There's some more air quality  data, in  this case, con-



10     cerned with fluorides, fluoride  emissions.  Data on  fluoride



n     was supplied  by  the Florida DER,  the Winter Haven lab.



12           We  also have some air quality  data  from the phosphate



13     industry.   We got  data from the  USGS, in  this case potentio-



14     metric surface maps,  in addition to  the aquifer  model.



is           We  got  data  from the  Army  Corps of Engineers in



16     regard to chemical types of water.



17           We  got  data  from the  planning  councils, Tampa  Bay,



is     and Central Florida Planning Council, Southwest  Florida




19     Regional  Planning  Council,  and this  is another  long  list



20     of water  quality data  pertaining  to  industry  discharges, and



21     this was  obtained  from the  Florida DER.




22           During  the course of  our operations, we got quite a



23     bit of data,  literature-type data,  We also went out and did




24     some field  surveys, primarily our biologists  and socio




25     economists,  and we  took pictures  of various aspects  of




                                                                     13

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 i    industry activity and general  activity  in  the  central  Florida




 ?    area.




 3          This,  for  those of  you who haven't been  around,  is




 4    obviously a  drag line strip mining  phosphate.




 5          This is a  beneficiation  plant, and this  is  a  chemical




 6    processing plant to make  chemical fertilizers  out of phos-




 7    phate rock.




 8          This is a  very old  mined-out  area that's been abandoned




 9    left alone,  and  re-vegetated naturally -




10          This is a  slime pond that is  part of the dewatered




11    area.  On the right is where it dried out.  To the  left there




12    is still water;  it hasn't evaporated.




13          Part of some of the area that has been mined  and/or




14    used for slime disposal areas, been turned into a sanctuary,




15    the Tenoroc Wildlife Sanctuary.




i6          This is inside the  sanctuary.  This  is a slime pond




17    that has naturally de-watered  and re-vegetated.




,8          This has been reclaimed and turned into  a recreation




19    park.  There's a ball park in  the background,  and an area




20    that has been r^-grassed  in the foreground.




21          This is the primary use of reclaimed land,  today, any-




22    how.  A great quantity of it has been turned into approved




23    pasture land.




24          This is some of the natural environment.  This is a




25    scrub pine bush0
                                                                    14

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 i          That's a hammock.




 2          This is a pasture  land.




 3          This is a sometimes wetland in the rainy season.




 *          A forest area —



 s          This is a natural  pasture land that's been approved




 6    as being farm land or vegetative.



 7          This is a crop land area, truck farm-type crops, and



 8    this  one is most obvious in the Florida area,  citrus groves.




 9          This is the Peace  River,  I believe  and  this is the




10    Tampa Bay area with our  Gardinier plant in the background and



11    a park in the foreground.



12          This is another form of  the  environment  in the area,



13    which is a developed coastline  area.



u          During the process of developing documentation, which



15    is also about 1,700 pages,  between the working papers and



16    the draft EIS,  we attempted to  have things that were distri-



17    buted to the public to be as plain as possible.




IB          We didn't always make it  completely.  There have been




19    comments,  and there have been  corrections, and we do have




20    a table on the next slide which will  be added  to the final



21    EIS and will clear up some questions  that  might arise in




?2    this  ecological section.




23                   MR.  TRAINA:   Well,  Mr.  Bowles  let me just




24    comment;  today I took a  helicopter ride over this area,




25    Polk  County,  and I  would have  to agree with the wotn^n the




                                                                    15

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 i     other  night at  the  other hearing,  that you might have gotten




 2     some more  representative pictures  of  the area.




 3           It wasn't till  I saw  today that I realized the full




 4     impact, at least in Polk County, of some of  these activities.



 5           Mr.  McNeill?



 6                  MR. MCNEILL:  Before I  get into  the proposed




 7     action, I'd like to make a  few  introductions.



 8           I already mentioned we had an advisory committee which




 9     consisted  of representatives from each county  in the study




10     area,  a representative from the Southwest Water Management



n     District,  an industry representative, and a  represenative



12     of  the Florida  environmentalist groups.




13           I  think,  just thumbing through  the cards, I might




14     have missed somebody, but I'm sure three of  them are here



15     tonight, members of our advisory committee.




)6           Mr.  Homer Hooks, woujxl you stand* for a second?



]7           He represented  the industry as  the President  of the



18     Florida Phosphate Council.




]9           Barbara Boatwright?




            Oh,  there she is.  She was advisory committee rep-




21     resentative for the Southwest Florida Water  Management




22     District.



23           And  Archie Carr is here.



            He was here.  There he is outside.  He and Charles Lee




      took turns representing the Florida Audubon  -- representing
                                                                   16

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 i     the Florida environmentalist  groups  on the advisory committee




 2           There are  a few others  here  who  have been a tremendous




 3     help,  and,  I/'m not sure,  after some  of the conro«nts we may




 4     get tonight,  they may not want to  admit having helped, but




 5     I  want to  thank  them anyway.



 6           One,  I see Bill Wilson  from  the  USGS from Tampa is here




 7     That office was  a tremendous  help  in supplying information




 8     regarding  the effect on  the changing potentiometric surface




 9     of the Floridan  Aquifer.



10           Dan Williams from  DER:  Dan was in the Winter Haven



11     office,  one of the slides that were  mentioned.   We got quite




12     a  bit  of data from the Winter Haven  office.  He's  now in




13     the Tampa DER office.



u           Otis  Smith.   Otis  also  was in  the Winter Haven office



15     of DER,  and is now in Tampa.



16           And I see  Bud Hendry, the state  geologist,  is here.



17     Bud?  He's  also  supplied us quite  a  bit of useful  informa-



is     tion.



19           Okay.   What  I'll do is  very  briefly  — and I mean it




20     this time --  tonight go  through what the proposed  action is.




21     A  few  of you  were  over in Bradenton  the other  night,  and I




22     got  up and  said  I  was  going to briefly summarize the proposed



23     action,  and then I  commenced  to elaborate  on quite a bit of




24     detail.




25           Thumbing through the cards here,  I think most of you
                                                                    17

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 ,    if not all of you here tonight, have been on our mailing list

 2    and received the working papers and our newsletter we put

 3    out all along, so I don't see any real need here tonight to

 4    go into much detail, so instead of that, I'll save moat of

 5    Che time for presentations from you.

 6          I'm just going to hit the high spots of the proposed

 7    action and what we, up until the draft EIS, are ".calling the

 8    selected scenario.

 9          First, for mining operations, any new source mining

10    and beneficiation operations -- and when I say new source,

n    I mean based on issuance of EPA NPDES discharge permits.

12          First, we say that, under this proposed action, any,

,3    new source mine and benef iciation plants will eliminate

14    rock-drying for rock to be processed into phosphoric  acid

15    in central Florida.

,6          All of these that I'm reading off, there will be

]7    provisions for some exceptions, which would result during

18    the site-specific environmental impact study.

19          I should mention here that any new source mine  or new

20    source chemical plant will have to do a site-specific EIS.

21    This areawide draft has addressed areawide and cumulative

22    effects of the entire industry, as it is projected, under

     this proposed action.
* O
24          The second one, and again, I'm still talking just to

     mine and benef iciation operations, is to meet Florida's
25                                                                  18

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 ,     effluent  limitations, which are more stringent than EPA's

 2     effluent  limitations, but during the study, we found that

 3     meeting the Florida effluent limitations for mining opera-

 4     tions would meet zsceivlng water quality standards.

 5          Third, eliminate conventional above-ground slime

 6     disposal  areas.

 7          Four, this one really is sort of a repeat, because we

 g     started out with meeting all existing local, county,

 9     regional  and state requirements; the fourth one is to meet

10     the Southwest Florida Water Management District requirements

n     for the consumptive use permit.

,2          We  go, what may be a little beyond that, when we say, i|n

)3     the next  one, to provide storage capacity for water recovered

)4     from slimes for re-use, which may, in some cases, result

15     in a reduced pumping rate from the Floridan Aquifer, even

16     moreso than meeting existing Southwest Florida Water Man-

17     agement District requirements.

ID          Six really states to allow continued use of connector
I O
      wells for de-watering the shallow ground water table prior

      to mining, but with precautions and adequate monitoring

      as provided by the industry and the state to protect ground

      water quality, to assure that the quality of the water

      drained from the shallow water table is adequate to be
23
     discharged directly into the Floridan Aquifer.

           And seven, unfortunately EPA guidelines on radiation,
                                                                    19

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      on reclaimed  land, has still not been completed.  They were



      put  out  in draft form, but it will be published in the



      Federal  Register in June, in two sets, part in June and



      part in  July  of this year.  They'll be published in proposed



      and  final form, so we'll be leaving the SETS when these



      guidelines are finalized and adopted, and they will be met



      by the new source mining operations.  And in all probability,



8     they'll  apply also to additional mines.



9                  MR. TRAINA:  Mr. McNeill, could you just, at



10     this point, clarify what part of that particular recotn-



n     mendation — Talk about the second part of that DRI for



12     site-specific EIS.  You also developed a recommendation plan



      which considers radiation of spoil material.
I \j


           What did you have in mind, what did this report have



      in mind  with  regard to that recommendation?



16                  MR. MCNEILL:  Okay.  We're saying that in the



      site-specific study, and it would have to be determined on



      a site-specific basis, based on core sampling of the soil
18


      and  the  material of the ozorten and the matrix.
19


           The determination needs to be made on methods of
20


      reclamation to minimize radiological material remaining near



      the  surface.
22


           As I say, it would have to be done in the site-specific
£ J


      study --
24         J


                   MR. TRAINA:  This plan ---

                                                                    20

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i                   MR. MCNEILL:  --to have mining and reclamatioi




2     methods which would allow the overburden to be placed back




3     in such a manner that the top three or four feet of the




4     soil or material would not contain the radionuclide material




s     there in the strata.




6                  MR. TRAINA:  Thank you.



7                  MR. MCNEILL:  We have been asked	Some




8    comments have been made that we need more detail, and just



9    how we would go about doing that.



10          It would have to be done on a site-specific study at




n    a given site, mining site, based on core tests and analysis



12    of radionuclides in the samples prior to establishment of



13    mining and reclamation plans.




)4          Okay.  The next one is to meet existing county and



)5    state requirements.  Again, that's repetitive; that was




16    given on reclamation.




17          Plus, we're asking, in the site-specific study, that




)g    a determination is made on existing wildlife habitat on the




     mine site and in surrounding areas in .the site-specific




20    study and the mining and reclamation plan have provisions



2)    for protecting wildlife habitat, existing wildlife and




22    wildlife habitat.




           And the next one is to provide for protection and/or



24    restoration of wetlands, which falls under Section 404 of




     the Federal Water Pollution Control Act, and also for water
                                                                   21

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     from mining and beneficiation operations.



2          Under our projected scenario, we're stating, where :we



3    project effects, we're stating that there will be no new



     source chemical plants in the study area.



           This is based  on information we've gotten from the



     industry, plus other information which  indicates the



     chemical processing  capacity that is needed, as long as



 8    mining will occur  in this area, that the' chemical processing



 9    capacity is already  here; no new capacity is  projected to



10    be  needed.



n          However, you know, there's no way to assure that



12    someone won't tomorrow request a permit for constructing



13    a new chemical plant, so we,.as I say, under the scenario,



14    we're not projecting any new chemical plant, but we do



     in  the proposed action list requirements for any new



16    chemical plant operation, which would require a new source



     NPDES permit.



)8          The first one, which I don't have exactly in the order



     that they are in the EIS	I'm going to clarify a couple



20    of  points a little bit.



2          The first one  I have listed here is to meet existing



?2    standards of performance for new sources for air emissions.



     But in addition to that, either recover fluorides or provide



     for control of fluoride levels in gyp ponds to assure that



     fluoride emissions from the entire plant complex don't exceec
                                                                    22

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1





2





3





4





5





6





7





8





9





10





11





12





13





14





15





16





17





18
allowable fluoride emissions from the plant complex.



      And this would include gyp pond emissions.  This,



of course, would have to be determined- in a site-specific



study, as to what levels of fluorides would be allowed from



gyp ponds.



      The second one is, also on water, we say to meet



existing standards of performance for new sources, and in



addition to that, we say provide for recirculation of



non-processed, as well as processed water, and to provide



the same surge capacity for non-processed water that is



required for processed water for new sources.



      And we're further stating that, during times, during



rainfall events when that surge capacity is exceeding and



treated discharge is required, that, in all probability,



more stringent or more concentrations of the pollutants



will be necessary to protect receiving waters into Tampa



Bay and the Peace basins than are listed in the current



EPA effluent guidelines for new sources.
           The  third  one  is  to  provide for  lining  the  gyp ponds



     with an  impervious substance,  unless it can be demonstrated



71 j  1..'--. the site-specific study  that  lining is not needed to



     p:r "f.ect:  ground water quality.




            >nd  then the last  one, we're saying encourage  recovery



M j|  "i .noivi an  wider current marketing conditions.  This



     o,;l x.iiL •>   '.. '-1 be done, even  if most, if not all of the
                                                                     23

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i     existing chemical plants in central Florida right now are
2     either in  the planning, design, construction or operation
3     stages of  uranium recovery processes from the phosphoric
4     acid.
5                   MR. TRAINA:  Excuse me.  Let me ask you one
6     another question.  With regard to the items on fluoride and
7    uranium recovery, is it the intent here of the document to
g    have the source address those two items in the site-specific
9    EIS's?
,0                  MR. MCNEILL:  Yes.
n                  MR. TRAINA:  From an economic standpoint, they
]2    would have to address both fluoride and uranium?
]3                  MR. MCNEILL:  Uranium recovery, right.
14                  MR. TRAINA:   Thank you.
15                  MR. MCNEILL:  Okay.  With that, as I say, just
)6    a brief summary of the proposed action, I'll turn it back
)7    over to Mr. Traina.
18          As far as what we're saying, it is indeed the most
19    important  part of the hearing tonight, to hear comments
2Q    from you.
21                  MR. TRAINA:  Thank you, Mr. McNeill.
           Before we get on to the next part of the program, and
     the most important part, I would like to make a few comments
23
     with regard to public participation.
24
           Not  only is it the agency policy to involve the public,
25                                                                   24

-------
i      frankly,  it's a  legislative requirement; it's in the law,




2      Both  the  Federal Water Pollution Control Act, the Clean




3      Air Act,  as well as the National Environmental Policy Act,




4      have  provisions  in there that there will be public par-



5      ticipation in a  host of activities that the agency under-




6      takes, not the least of which is this activity tonight



7     involving development of impact statements, so if you




8     want  to look at  it	You have an obligation under the




9     law,  if you will, to come forward tonight and express



10     yourself  publicly.



n          We  would like to say that the hearing is being




,?     conducted pursuant to regulations that EPA's put out,



I3     and those regulations call for other things, that notice



14     of the hearing be put in the local press, and we had




15     notice of this public hearing published in the Sarasota




16     Hera Id-Tribune on May 8th, 20th and 21st; and the Tampa




17     Tribune and Lakeland Ledger on May 7th and 21st, 1978.




18          In addition to those notices, copies of the public



19     notice were mailed to each of the individuals or organi-



      zations on our EPA mailing list, as well as to all the



      local, state and federal agencies involved.




           I would ask at this point that those of you that
72


     haven't yet done so, fill out a registration card, especially



      if you want  to speak tonight.  There's a place on  that card




25     to indicate  that you'd like  to be a speaker.

-------
i           Also on the card is indicated if you'd like to be

2     on the EPA mailing list to receive, not only the final

3     results of these proceedings, but any other activities

4     that EPA is conducting in this area.  There's a place

5     to put yourself on our mailing list, and we would ask

6     that all of you fill out a card so that we'll know who

7    was here tonight and also who we would notify with regard

8    to the final EIS on the subject.

9          The hearing will be from here on, as it has been,

10    conducted informally.  There are no rules of evidence.

n    We ask that as you come up to identify yourself and the

)2    organization, if any, that you represent.

]3          If you have written statements, I'd appreciate re-

)4    ceiving a copy so we can give it to our court recorder.

15    This meeting is being recorded tonight.  The transcript

16    of it will be available in our offices in Atlanta, and

|7    I believe at the office in Tallahassee, but certainly in

     Atlanta, and you can make your arrangements with the court

     recorder if you'd like to get a more immediate copy.

           Okay.  I would like to now call on Linda Campbell.

2)    MS. CAMPBELL:

                   I'm here to present a statement relative to

     the Draft Areawide Environmental Impact Statement on behalf

24    of the Florida Chapter of the Wildlife Society, a group 
-------
 i                   We have  always been  interested in wild land



 2     areas  and  we  are particularly concerned about landscape



 :)     alterations and reclamation associated ---



 A                                 (Whereupon, the proceedings were



 5                                 interrupted for an acoustical



 6                                 adjustment)




 7                   MR.  TRAINA:  I'm sorry to disturb you.  Could



 e     you start  again, please?



 9     MS. CAMPBELL:



10                   I'm  here to  present a statement relative to



11     the Draft  Areawide Environmental Impact Statement on behalf



12     of the Florida Chapter of  the Wildlife Society, a group of



13     professional wildlife  biologists in this state.



u                   We have  always been  interested in wild land



is     areas  and  we are particularly concerned about landscape



i6     alterations and reclamation associated with phosphate



17     mining in  Florida.



18                   We will  submit a written statement for your



,9     consideration  prior  to the June 23rd, 1978, deadline,



20     but we would also  like to  take this opportunity to publicly



21     comment on this report.



22                   Basically, we are concerned about the lack



23     of  a thorough  discussion of the impacts of phosphate



24     mining on  fish and wildlife habitats.  Throughout the



25     report there are references to the relative value of
                                                                   27

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     various habitat types without reference to the  source of



 2 |   this information or value judgment.



 3 I                 With the exception of a  statement like



     "high habitat diversity supports a diversity  of wildlife,"



     it is very misleading and inappropriate to indicate that



     a particular habitat type has high or  low value as wildlife



     habitat.



                   Another related point is that above ground



     slime ponds do have value as wildlife  habitats  and add to



10    landscape diversity, but discussion of these  benefits are



n    minimal in the report.



12                  As professional wildlife biologists, we



]3    support the concept that above ground  slime ponds are



     beneficial to wildlife, particularly wetland  species,



]5    and we discourage the total elimination of these areas.



)6                  We would also like to see changes  in the



]7    current state regulations, which would allow  shallower



     slopes along edges resulting in wider  littoral  zones.
I 8


                   Finally, we would like to see more con-



     sideration given to fish and wildlife  in your criteria for



     wetlands restoration.



                   As stated on page 2.34 of the report, good



     wetlands restoration has yet to be demonstrated  and we
L- 
-------
 i     research  into restoration of fish and wildlife habitats



 2     on phosphate mined  lands.



 3                  In summary, we are disappointed in the report



 4     as  it  fails to  provide a comprehensive, objective, full



 5     disclosure assessment of the impact of phosphate industry



 6     activities on fish  and wildlife habitats.



 7                  Thank you for your attention.



 8                  MR. TRAINA:  Thank you, Ms. Campbell.



 9           Homer Hooks ?



,o     MR. HOOKS:



11                  Thank you, Mr. Traina.



,2                  My name is Homer Hooks.  I'm President of



13     the Florida Phosphate Council.  I appear here tonight on



14     behalf of the following companies:



15                  Agrico Chemical Company j Borden, Incorporated;



16     Brewster Phosphates; Conserv; Electro-Phos Corporation;



17     Farmland Industries; Freeport Phosphate Mining Company;



,e     Gardinier; W.R. Grace and Company; International Minerals



]9     and Chemical Corporation; Mississippi Chemical Corporation;



20     Mobil  Chemical Company; Occidental Chemical Company;



21     Royster Company; Stauffer Chemical Company; Swift



?2     Agricultural Chemicals Corporation; T/A Minerals Corporation;



23     and USS Agri-Chemicals.



24                  Before proceeding in my comments, Mr. Traina,



25     and gentlemen, I have some good news for all the people of
                                                                   29

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     Polk County and, indeed, central Florida.




2                  I was advised late this afternoon that the




3    State Senate today passed by a vote of 35 to 0 the land




4    reclamation act, bill, which was before them and which




5    is the product of the Land Reclamation Study Commission

  i


6 1   appointed by the Governor.




7                  Mr. Bud Hendry, who was here, was Chairman.




     I think we all be gratified at this overwhelming passage
O



     of this legislation which, incidentally, was jointly




10    supported by the Audubon Society, the Florida Phosphate




     Council, many others, the Governor, because I think it




     once and for all assures the ultimate and expeditious




     reclamation of the old lands about which we've had so
I J



     much problems through the years.




                   Further, it sets up an institute of phosphate




     research for the first time in the history of this state,




     which will permit long range, basic, and applied research




     to be conducted on a very sound and scientific basis.for
18        f                    J



     this industry, and I think we're all pleased about the




     passage of this legislation, which now goes to the Governor




     for his signature.




                   I'll be very brief in these comments.  It
2?


     will be followed b" submission of a more detailed written
23


     statement for inclusion in your record.
24


                   Perhaps a brief bit of history to get us to




                                                                  '30

-------
 1
      get  us  to where we are:  On March 4, 1976, you will recall
2     that  President Ford  instructed the Council on Economic
3     Quality  to  conduct this survey, this study.
4                  At  that  time,  the Florida Phosphate Council
5     strenuously opposed  the expenditure of public funds for
6     this  study  on three  grounds:
7                  First, we contended that there was sufficient
g     information and data available through the DRI process and
9     otherwise which,  upon  collation, would provide the in-
1Q     formation needed  for this kind of interdisciplinary
n     analysis of the impact of the phosphate industry in
      central  Florida in the seven-county area.
                   Secondly, we argued that there was already
      sufficient  enforcement and permitting authority at
14
      all levels  of government, federal down to municipal, to
      sufficiently protect and safeguard the interest of the
16
      public and  the environmental impacts of phosphate mining.
                   Third, we argued that this would, in effect,
1 8
      impose a de facto moratorium on the beginning of new
      phosphate mining, which was badly needed.
                   We were  overruled.  The order was given to
21
      proceed with the  study.  We cooperated in good faith with
      it.
23
                   Two years and 1 million dollars later, we
24                                                       '
      now have the, draft Environmental Impact Statement before us.
                                                                    31

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                   We have participated actively, as I

     indicated, on the advisory committee.  I personally

     have attended every meeting of that committee, and I

     think only Bucky down in Punta Gorda has been to all

     of them as well.

                   We've reviewed thirteen working papers

     and five scenarios and given very close attention at

     all steps of the process.

                   What is the draft EIS we now have?  We've

10    been told repeatedly by EPA that it is essentially a

n    guide, a report on the anticipated impacts of mining

12    for use by EPA and other permitting authorities; in

)3    effect, an effort to balance the effects, primarily

     environmental, but taking into account, as well, socio-

     economic, balancing the effects of these influences of

16    phosphate mining on the area, not to be considered a

     fixed and rigid regulatory document.

                   The proposed action section, which appears

     on 1.70 to 1.72 in the draft, is a synthesis or an

     evaluation of what kinds of steps appear desirable to

     achieve this balance of effects.

                   And we feel very strongly that through all

     this, we must keep in mind that the bottom line is the

     site-specific EIS.  This is where the final judgment must

     be made  on. the application  of  a  particular mining  site, on
25                                                                 32
                                  I-14*-

-------
      the particular environment of that area.
2                  So we approach an analysis of this
3     document  on two, levels; first, the draft EIS itself;
      secondly, the proposed action.
5                  Now, we've done this, I think, in a very
6 |    systematic and careful way.  We submitted these documents
      to a  panel of consultants, one of whom will speak to  you
8     tonight,  Dr. Lester G. Bromwell, whose major projects
9     have  included earth dams, hydraulic fills, dredge
|0     material, excavation, cofferdams, strip mining, mining
n     waste disposal, has headed up the industry's solid waste
      clays disposal project;
13                  Dr. George W. Cornwell, head of Eco Impact,
      Gainesville, an acknowledged international authority  in
      aquatic ecosystems, ornithology and wildlife management;
      much  of his experience involves assessing environmental
      impacts and regional resource planning;
                   Also Dr. Henry Fishkind, Assistant Professor
18
      of the Department of Economics, at the University of
      Florida, who has investigated the socioeconomic aspect
      of the EIS.  He's done consulting work for the Florida
2)
      Defenders of the Environment, .Environmental Science and
22
      Engineering, Florida Sugar Cane League, and the State of
4 J
      Florida;
24

                                                                   33
Benjamin W. Breed love,  presently a  consultant

               1-142

-------
!     with Breed love and Associates in Gainesville, specializing



2     in aquatic ecology, terrestrial ecology, water quality



3     analysis, ecosystem energy modeling;



4                   And Gordon F. Palm of Lakeland, who is



5     a specialist in plant design, start of construction,



6     expansion, modernization, control of air and stream,



7    pollution control, and solid waste disposal.



8                  Now, I cite these gentlemen simply to



9    indicate the credibility and the kind of people who have



10    reviewed these documents, and they've done it thoroughly.



n                  In addition to them, we've submitted the



12    documents to our own overview committee, Mr. C.A. Campbell



]3    of International Minerals and Chemical; Mr. Jene Terry of



14    W.R. Grace; Mr. Richard Murphy of Farmland; Mr. Bruce



     Galloway of Borden; Mr. Spencer Roberts of Mississippi



)6    Chemical; and Mr. Dick Timber lake of Brewster Phosphates.



                   So that very careful review had a very



     high level of expertise.



                   Now, as to the draft EIS, we find some very
19                     '                                      J


     favorable comments in it, and I want to be sure that I



     single them out lest anyone allege that we're only here



     to attack the product, because we're not.



                   Additionally, increasing numbers of phosphate



     pits have recreational potential if properly reclaimed, and



     many have been transformed into private and/or public

25                                                                  34

-------
 \    fish management areas and parks.



 2                  Going further in the draft EIS, a significant




 3    beneficial effect on fresh water sport and commercial




 4    fisheries will be the increased acreages of surface water




 5    resulting from reclamation of mining pitsc



 6                  This additional surface water represents



 7    significant potential for establishing good commercial



 8    and recreational fisheries.




 9                  Local alterations of the flow regimes of



10    three major rivers, the Peace, Alafia, and Little Manatee,




n    will be minor and obscure to normal flow variations.



12                  Minimal impact has been assigned to slime



)3    placement, since the ponds temporarily support a variety



     of wildlife and since terrestrial habitat eventually will
14                                                       '



     develop or be reclaimed in the slime areas.



                   Several abandoned slime areas are now used
16


17    as wildlife sanctuaries.



                   Also not necessarily advantageous is the
18


     elimination of the relief of slime pond embankments.



     Actually, vegetational zonation associated with these




     slopes is more desirable for a terrestrial bayou.




22                  Finally, land use plans must reflect needs



     projected beyond reclamation and incorporate fish and




     wildlife values by leaving some pits for reclamation by
24                                                          J

                                                                   35

     natural processes and by insuring a. mixture of surface

-------
     water and storage, meandering streams, vegetative flood

2    plains and forested uplands.

3                  However, beyond these citations, we find

     several errors  of fact and conclusion in the draft EIS,

5    which will be addressed specifically in the written

6    comment which will follow.

                   The important thing  is, in par judgment,

     that if this draft EIS is to be used, as it has been

     described to us,it will be used, as a guide to be in-

)0    terpreted by other enforcing agencies, it must be an

,,    accurate and scientifically defensible document, because

]2    these agencies  who will be using this as a guide have

13    not been privy  to the evolution of the scenario or

14    examination of  the working papers.

15                  Therefore, it's very important in our

16    judgment that the draft EIS, and certainly the final

)7    EIS, be scientifically accurate and defensible.

                   And it's our purpose, in the submission of

19    our comments, to make it so.

                   Now, as to the proposed action, let me say

21    at the outset that we're gratified that EPA's conclusion

22    is that phosphate mining ought to be allowed to continue

     and expand to meet US and world demand for fertilizer and

     food.

                   I must say at this point that EPA's  conclusion
25                                                                  36

-------
 i    is not popular with many people, as we heard in Bradenton

 2    Monday night, but it should at long last put to rest the

 3    fears raised at the inception of this study and repeated

 4    again and again as to, for instance, the quantity of

 5    water, which EPA finds to be adequate with no new restraints

 6    necessary.  Radiation is well within tolerances.

 7                  Reserves appear to be adequate; hence,

 e    permission to go forward with expanded mining.  Air and

 9    water pollutants are manageable and under control.

10                  Temporary disturbance of land which, inc-

11    cidentally, is projected to be 2.8 percent of the total

12    land area in the seven-county study area, is just that --

13    temporary, and that reclamation requirements are adequate

14    at all levels of government to restore the land, although

15    the draft, 1 must say, in some cases implies destruction

16    of the land.

,7                  And finally, the economic vitality of this

,8    industry is recognized in the proposed action, the 61>QOO

19    employees, the $2 million annually put into the state's

20    economy.

21                  We recently conducted a survey of the thirteen

22    proposed mine sites.  We find that these are not net

23    figures for the whole industry, but they're real numbers

24    of what these proposed mines mean economically to the state

25    and the nation.
                                                                   37

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                   They will provide 3,000 new construction



     jobs, a financial payroll of $8 million.  They will pro-



     vide 3,200 permanent operating jobs with an annual payroll



     of $64 million.



                   And taken altogether, they will put $545



6    million annually in the state's economy for goods and



7    services, so this is what we're talking about, really, in



8    terms of expansion of the industry economically,



9                  The application of the guidelines in the



10    proposed action should be flexible enough to take into



n    account the special considerations of the specific site,



12                  Now, that's pointed up in two specific



13    areas of the proposed action that I want to describe very



14    briefly, that give us great concern.



)5                  And here again, we underscore the common



)6    sense need for local site judgment.  First, the elimination



17    of conventional above ground slime disposal areas; and



)8    secondly, the wetlandr provisions .



]9                  With respect to minimizing the need for



20    slime ponds, the industry and the US Bureau of Mines have



2]    been involved together in a project to accomplish this



22    since 1972 at a cost of $1,650,000 to the industry and



     $385,000 to the federal government



                   It is sure to be addressed by the new phosphate




25    research institute, which passed the legislature today.  We
38

-------
i     are firmly committed to solving this problem, but  the



2     vast differences between soil types of the percentage



3     of clays in the matrix from one mine to the other, making



4     uniform technology impossible, or at least unknown as of



5     today .



6                   Moreover, the industry's bureau of research



7    has pointed us toward many new options for dealing with



a    waste clays.  These would allow a range of reclamation



9    alternatives to optimize a good program for a single mine



10    or for a larger area.



11                  We would lose these options if we are



12    forced, as the proposed action might prescribe, if in-



13    terpreted that way, to place all clays below ground.



u                  As a matter of fact, these clay ponds offer



is    a potential for high-quality wetland sites, so this



i6    particular element of the proposed action will certainly



17    require a specific evaluation of the local soil conditions



18    at each site and flexibility to implement the best



19    reclamation plan.



20                  With respect to wetlands, I fear we are



21    in danger of becoming emersed in emotional reactions



22    before we have separately addressed the known scientific



23    facts .



24                  Similarly, the impact of mining on the



25    habitat is fast getting bogged down in emotional overtones
                                                                    39

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     We fully share concern for protecting wetlands.   Further,



2    we are interested in how the valuable phosphate  can be



3    extracted from many wetland areas,  and after mining,



     these wetlands can be restored.



5                  As a matter of fact,  phosphate mining



6    offers the single greatest potential for significantly



     increasing the wetland acreage in the seven-county area.



 8                  We dispute the contrary implications that



 9    run through the draft EIS and the proposed action.



                   Dr. George Cornwell,  with your permission,



     Mr. Traina, will follow me and elaborate particularly on



     the subject of the wetlands and  on the habitat.



                   MR. TRAINA:  Thank you.



           Can I just ask you 	 You addressed two items that



     the council of the companies you represented objected to.



     Does that assume that the other  part of the scenario that



     Mr. McNeill reviewed is not objectionable to the industry?



                   MR. HOOKS:  We will have more detail, comment,



     in our written statement.  These, I would say, highlight



     those matters that we wanted to  call your particular



     attention to tonight.



?2                  MR. TRAINA:  Fiwr instaocey the eliaiLnaeion  of



     rock drying, is that —



                   MR. HOOKS:  We have no comment on  that at this



     time.
25
                                                                   40

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i                   MR. TRAINA:  I see.  Okay, thank you, Mr.



2    Hooks.


3          Dr. Cornwell?


4    DR. CORNWELL:


5                  Mr. Traina, gentlemen, I'm George Cornwell,


6    I'm a wildlife biologist and president of Eco Impact, Incr,


7    an ecological consulting firm in Gainesville, Florida.


8                  I've been retained by the Florida Phosphate


9    Council to review the draft impact statement, and in some


10    fifty-five-page detail, comments on that document will be


n    forthcoming to EPA shortly.


12                  Just as background, I'd like to state I have


13    worked in and with wetlands, from Alaska to Argentina,


14    over  the past twenty-five years.


15                  I feel that wetlands and waterfall biology


16    are my formal specialty.  I've been much taken and at one


17    time  I held very firmly to the myth that phosphate mined


18    lands are and by necessity had to be wastelands.


)9                  I was well conditioned to that belief, but


20    I found over the years that nature very often provides


2)    ecological experiments for us to interpret and use, and


22    it's definitely done that in Polk County.


23                  The impressive, biological virtues of the


24    naturally-restored mined lands in Polk County cannot be too



25
                                                               41
often extolled, and I think it's unfortunate that the
                                l-tn

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i     draft  impact statement does not draw more heavily on



2     that information base.



3                    I note  that Appendix C of the Archibald



4     Biological Station study on this subject offered by John



5     Edscorn is omitted entirely to this copy.



6                    My own  experience over the past several



7    years  has been to look quite closely at the Christinie site



8    near Lakeland.  In that site, there's a mesic hammock of



9    very high diversity,  about fifty years old, and I seriously



10    doubt  that most experienced Florida biologists in that



n    community would recognize if they were standing on the



12    banks  of a slime pond.



13                   It's most impressive of what nature can



14    achieve when left to  her own devices.  I think most every-



15    body in this area are familiar with Saddle Creek Park



)6    which  again, although heavily used for recreation is sub-



17    stantially the way the mining left it.



)8                   Probably the least known site that could be



]9    looked at to reinforce this is the Tilghman mine southwest



20    of Fort Meade.  This  was mined around 1910, 1920, and it



2)    has to me absolutely  incredible diameters in the slash pine,



22    oak trees, on  that site.



                    I wouldn't be surprised if there's record



     specimens in the State of Florida therein, so as an applied
     ecologist, I ask myself why are these spectacular results.





                                  J-/JTI

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i     occurring on mining lands, and I think a clue occurs in



2    the impact statement, on page 1.16, which I'd like to



3    read "Most soils of the study area are young and under-



4    developed, nearly level or gently sloping, acidic, very



5    sandy with high permeability, and generally low in clay,



6    organic matter, and plant nutrients."



7                  I think that's an accurate, precise state-



8    ment of the unmined environment of much of the county.:



9                  Now, in the mine lands, those that have not



10    been reclaimed into man-dominated systems, those that have



n    been allowed to revert to nature, it seems to me several



12    things happen.



13                  First of all, you have the increased clays



14    in the upper soil horizons, and these reduce permeability



15    and make the soil conditions moister, which favor forest



i6    species, like those that came in on the slime pond at the



i;    Christ in ie site.



is                  They also favor such wetlands as fresh water



,9    marshes, as our University of Florida wildlife graduate



20    told you at the start of this hearing.



21                  The second thing that happens is that a



22    certain amount of phosphate matrix is left in the upper



23    horizons within the root zone of the vegetation that comes



24    in after mining.



25                  It's been well established that most Florida

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     forest communities are limited or,'Starved for phosphate,



2    and the application of rock phosphate to pine flatwoods




3    is standard forest management procedure, so the mining




     accomplishes this.



                   A third thing that I think is very important



     to wildlife is that we have an increased variability in



     the topography and slope.




                   This provides both potential for more niches




     for a greater variety of species, and very importantly,



     better sanctuaries.




                   From human disturbances, probably the most



     lacking components of wildlife habitats in Florida is



     a place where they escape man.



                   And the mining land in Polk County is one



     of the few places where they can still do that, if they've




     not been reclaimed by man and not being used.



                   I'm sure there are other reasons.  One that



     seems fairly evident, when you dig around in these sites,




     is that there's a surprising amount of humus accumulating



     in the eight varieties of soil; even ten years after




     abandonment and the soil is taken out, there's a very high




     percentage of humic material, and this is an index to



     biological productivity and speeds, the values that we're




     talking about here,,



                   I think that, really, none of this kind of
10





11





12





13





14





15





16





17





18





19





20





21





22





23





24





25
                                                                    44

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i     analysis of material is in the draft statement, and I



2     think the statement would be more useful, in terms of



3     assessing restoration, if some< analysis of this type



4     was included.



5                   I also think the lakes that occurred



6     by accident, as abandoned mining pits, are badly mis-



7     understood.  Most of them have an excellent support



8    fishery.  The fishery biologists in this region often



9    select them as their prime site for bass fishing.



10                  Contrary to much opinion, many of them



n    have good sHnorelines.  They don't have as extensive a



12    littoral zone as you would plan if you were going to



13    re-dig them, but they do have very healthy and very pro-



14    ductive shorelines, by and large, again a function of time



,5    since they were mined, and,these shallow beaches of the



16    shoreline become wetland systems associated with the



17    aquatic systems and are highly productive.



i8                  Also I'm concerned about their depth being



19    attacked.  The life of Florida lakes and wetlands is often



20    very short because they are so shallow, and they serve



21    as nutrient traps, and the depth of the mining pits is a



?2    real asset in terms of both longevity of the lakes and in



23    terms  of ecological health.



24                  And finally, before leaving lakes, I'd like to



25    point out that the idea of restoring the pre^mining contour   45

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,      and filling the mine pits with clay and- .waste materials



2      to grade  level would eliminate a  potential lake and



      wetland habitat area, and I  think this  is a serious loss



4      in restoration potential and  is,  more or  less, just a hang-

11
12
       over  of  closed,  strip mining  thinking, where  there's
       something hallowed about  getting back to  the  pre -mining




       contour, which isn't always  the case,  and  this  points  to




       why  there has  to be a  site-spec ifLc restoration program.
 8


                     My overall  impression of natural-restored




       lands  is  one  of increased diversity over  most of  the
ratural systems in the mining area  and  increased bio-



logical diversity over all the man-dominated  systems.
                     Now,  I  think we  should not  lose  sight  of
I o


       possibly  80 percent of the area  consists  of  man-dominated



       systems.




                     The naturally-restored lands are extra-



]7      ordinarily  high  in  the wildlife  value, and particularly  --



]fl      perhaps not of great  importance  to  the biologists  — but



       particularly of  the animal life  that people  value  as part



       of  their  esthetic background.
20



2|                    I'm thinking of  the harriers,  the hawks  and



       owls  and  eagles, or the wading birds, that have been the



       only  predators, and incidentally the biggest rattlesnake



       that  I ever walked  within  6  inches  of.
24


                     To my best knowledge, there is no spoken  or


25                                                                   46

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 !     written report  of a decline of a plant or animal species

 2     in Polk County  that a biologist has attributed to be the

 3     direct  result of phosphate mining in the last eight years.

 4                  Certainly none is offered in the draft

 5     statement.

 6                  We have in Polk County a real, again, an

 7     experiment  that's been going on a long time, and I think

 8     that  if there are species that can be documented to have

 9     declined as a result of phosphate mining, the draft impact

10     statement should point this out.

n                  Now, I would like to turn to the central

)2     point of all this, which is the wetlands, and I must

)3     address  in  some depth the statement that occurs on page

M     2.34  of the draft impact statement.

15                  It's a brief paragraph which I'll read so

16     my comments can best be understood:  "No feasible means -- "

17     this  is  from the impact statement -- "No feasible means of

18     restoring wetlands has been demonstrated, although

)9     reclamation can result in wet lands."

                   Now, here you see there's some real distinction

21     between wetlands and wet lands, but that distinction has

22     never been clarified biologically as to what the report

23     has in mind as being different, one from the other.

24                  "To restore wetland habitat in order to

25     protect and propagate all the fish, shellfish and wildlife
                                                                   47

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       just  listed  --" and  most  of  this  page  is  a  list  of



2      species,  many  of  them  species  of  marine animals  and



3      out in  the  open areas  --  "To .restore wetland habitat



4      in order  to  protect  and propagate all  the fish,  shellfish,



       and wildlife just listed  would require management of



       variables needed  for the  creation of wetlands, which



       some  believe occur only naturally over a  period  of approx-



       imately 4,000  years  of natural processes.11



                     And then a  citation occurs  which I'll refer



10      to in a moraai t.



n                    "Only  nature can create  a wetland," and



       the citation occurs  again.



)3                    This paragraph,  more  than any other in the



       draft statement,  brings into question  the resource man-



       agement aspect of the  document, in  my  opinion.



                     It  has been the  human experience that if



       man,  lake or landslide or whatever  causes land to be wet



       long  enough  to sustain hydrophytic  vegetation, which is



       a  jargon  term  for aquatic plants, a weapon results.



                     The Department of Agriculture and  Department



       of Interior  had been urging  and funding the construction



       of man-made  wetlands for  over  fifty years.
22


                     The beaver  is  the only mammal in North
23


       America to make more wetland acres  than man.
24


                     With built-in  water management controls,

25                                                                  48

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i       man-made wetlands can exceed natural wetlands  In pro-




2      ductivity.



3                    One USDA administrator estimated  that




4      3.3 million of our ponds  will have  been constructed  in




5      the US by 1980, averaging about 1 acre  each.



6                    The total acreage of  man-made reservoirs,




7      impoundments and marshes  far exceed that of farmed ponds.




8                    While natural wetlands often are  superior




9      to man-made wetlands in their overall quality,  the



)0      difference is usually attributable  to construction,  man-



n      agement, design and use.




)2                    Man can and has constructed large acres  of



13      wetlands with superior natural system value.  The potential



14      for doing so as part of the strip mining process  is



15      enormous.




)6                    The draft impact statement seriously errs



17      in suggesting otherwise.




)8                    Unfortunately, most of the 3,567,723 acres



w      in the study area is poor wildlife  habitat because man




20      has put so much of the area into alternative  land uses



2)      to provide higher yield cash crops.




22                    Now, the logic of habitat is so simple.



23      Without, it, management of the wildlife  resources  is  fruitless



24      because life is divided.




25                    Conversely, wildlife  can  stand an incredible
                                                                    49

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      array  of attacks  if its habitat remains intact.



2                    Ironically and quite by accident, much



3     of  the best remaining wildlife habitat in the. mined



      areas  is also  man-made  in the form of unclaimed land.



s                    Equally ironically to me, public interest



6     groups most concerned with wildlife habitats  preservation



7     fail to recognize  this and were instrumental  in passing



e     the 1975 reclamation act, which goes about reclaiming



9     this excellent wildlife habitat and converting it to



10     more man-dominated and  intensively-used, agriculture,



      commercial, industrial and residential land.



12                    Well-intentioned conservationists, en-



      vironmentalists,  government leaders, even professional



      ecologists and resource managers are in practice missing



,5     the habitat message.



16                    It  can be abundantly read from  the previously-



]7     managed landscape  in Folk County.



                     Modern man is a super destroyer of wildlife



      habitat, but he can be just as efficient in restoring habita



20     We  seldom have a  chance because restoring habitat is so



2,     much more expensive than destroying.



22                    This is why strip mining can be such a



23     powerful source of habitat restoration, since restoration



24     costs  can be built into the pricing of the phosphate matrix



2     and restoration of natural systems can be part of the
                                                                   50

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 i    mining process itself.
 2                  The intention of those wanting to maximize
 3    natural habitat should be directed toward restoring more
 4    and better acreage behind the mining, rather than preser-
 5    vation from mining of often severely-impacted habitats.
 6                  The best can-do examples of massive wetland
 7    habitat restoration can be credited to Ducks Unlimited.
 8    I'm hammering into this because so many times in the
 9    statement we're told that man can't create wetlands,
10    man can't restore wetlands.
n                  In forty years, Ducks Unlimited has
12    spent over $40 million to build 1,347 wetland habitat
)3    projects in Canada resulting in 2.5 million wetland acres
14    with 10,000 miles of wetland uplands added.
15                  The 1977 program alone spent $10 million
)6    for 118 new habitats, adding 60,000 acres.  In many
     drought years, a preponderance of water fowl production
     occurs in the man-made marshes that hold water, no
     structural control, when the natural wetlands have gone

20      ^ °
21                  Our US water fowl program is $100 million
     annual budget, a good part of which goes to creating
     wetlands and maintaining them.
L. *J
24                  Some fifteen states now sell the state duck
     stamps to raise revenues to do the same thing.   The literatur
                                                                    51

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     is full of case histories that establish that man can




2    and has built high-*quality wetlands.




3                  Finally, I would quote the excerpt from




     "The Fisheries."  This is taken from an opinion editorial




     and is in no way representative of a scientific paper.



                   "God or nature does: cBedCe. the wetland t




     but man clearly can and often does saturate the land with



8    water, which immediately starts the creative process," and




9    it's terribly misleading and damaging to leave you folks



10    with the idea that that can't be done.




                   MR. TRAINA:  I must say something.  I'm glad



12    "The Fisheries" recognizes that God still has the ability




13    to create wetlands.  For a minute there, I thought just



14    the phosphate industry was.



15           (Laughter)



16                  DR. CORNWELL:  I don't think the phosphate



)7    industry has been directed or guided in the direction of




     creating wetlands, and I think that's one of the functions




19    that this impact statement will do in future reclamation.




                   In terms of restoration, I would reiterate



21    the statement that the greatest potential for significantly




22    increasing the areawide inventory in the seven counties



     is through phosphate mining activity.




24                  None of the other major land uses are going



     to have the potential built into them to create any
                                                                   52

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i     significant acreage of wetlands, and furthermore, I




2     believe it's much easier to restore wetlands than



3     virtually any of the other natural systems that are




4     present on the land to be mined.



5                   Now, in the proposed action section dealing



6    with wetlands, I have a very great concern; that is that




7    it's going to be extremely difficult to protect wetlands



8    and mine around them, and even if you should have a



9    nourishment project to keep them alive during the mining



10    process, there's a very real probability for many of



n    them that I've seen in areas to be mined of their being



12    purged and surrounded by any kind of compatible type of



)3    land.




)4                  So in the proposed action, I think that



]5    we need a quality basis for distinguishing between Category



16    1 and 2 wetlands; in other words, this needs to be very



17    carefully developed.



)8                  And then secondly, the potential for each




)9    Category 1 wetland to survive mining must be determined.



20    It would be pretty heartbreaking to wind up with wetlands



21    that were preserved and then went dry.




22                  I think both of these considerations are



23    best relegated to site-specific DRI or EIS process.




24                  However, an areawide guideline for assessing




25    these individual wetland characteristics should be put
                                                                   53

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i     together by the concerned parties.




2                  MR. TRAINA:  Are you saying, Br. Cornwell,



3    that you do recognize that wetlands should be identified




4    and protected in this area that you would relegate




5    consideration	




6                  DR. CORNWELL:  Very definitely.  I would put




7    the riverine systems ahead of that category, and I'm sure



8    there are others that would definitely fall into a high




9    enough quality to weigh the preservation question and then --



10                  MR. TRAINA:  You recognize that some wetlands



n    should be preserved?




12                  DR. CORNWELL:  Oh, I'm all for preserving



,3    every high productive, high quality wetland system we can.



14          I'm also very much for increasing the inventory



)5    of those type systems.




16                  MR. TRAINA:  Let me ask you a more or less



17    technical question.  I'm not a biologist, so please excuse



]8    me if I don't get the right words.



)9          On the question of diversity, as I understand it,



     that is one of the essential elements, looking at the



2]    productivity of the value of any area, the wetland included.



22          Are you saying that biological diversity has been



23    increased because of phosphate mining into these areas?



24                  DR. CORNWELL:  I'm saying that's very




25    definitely the case for many of the lands that have been —
                                                                   54

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i     I'm saying I feel that's very definitely the case for



2     many of the lands that reverted naturally to, and had



3     time for diversity to develop.



4                   MR. TRAINA:  In other words, the wetland



5     that before was less diverse than the wetland that was



6    subject to mining, is that what you're saying?



7                  DR. CORNWELL:  I'm saying that a fresh water



s    marsh system can come in following a mining operation given



9    adequate time because the diversity develops over time



10    than that wetland, for the reasons I started out with, the



n    why aspects.  It can have a higher diversity because it



,2    has a. higher productivity, and it has more niches, than



13    a natural system fresh water marsh prior to mining.



14                  MR. TRAINA:  Is there data that confirms



15    this or just something that you —



,6                  DR. CORNWELL:  No, sir, I don't believe there -



,7    Unfortunately, these types of things have not been studied.



18    There is some limited data on the lake edges that the Game



,9    and Fresh Water Commission has.



20          Their studies show them to be very healthy.



2,                  MR. TRAINA:  From the beginning of the mining



22    process to the point where you say that you have restored



23    wetlands, what period of time are we talking about?



24                  DR. CORNWELL:  It would depend on — For



25    wetlands, it would depend on the wetland.  The fresh water
                                                                   55

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       marsh could come in very quickly, within two to three




2      years, particularly if the^siteis shaped, to have




3      a fresh water marsh come in.




             On forested wetlands, for species  like cypress




       trees and gum trees going toward the swamp forest-type




       community, that would depend on your propagation unit




       and how much energy you put into planting, but in




 8      Louisiana and Mississippi, where the Forest Service has




 9      researched these species, you can get 15-inch DBH of




10      diameter from cypress ten years after they're planted.




n                    MR. TRAINA:  Ten years pfter, in this case,




12      the pond would be abandoned or not used  any .langey,




       in that	




                     DR. CORNWELL:  Right.




15                    MR. TRAINA:  Now, how long does the pond




16      usually work?




                     DR. CORNWELL:  Well, I think we have the




18      option in restoration to structure areas being restored  in




19  ,    terms of topography and water supply to  fit the system




20      we want to come in.




             Now, in the past that hasn't been  so.  The natural




       succession  has come in, and on the Tenoroc site, for




       example, you can see the ponds moving out, closing in, and




       the shrubbery coming out, but they haven't gone yet to the




       tree stage system.
                                                                    56

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                  MR.  TRAINA:   When was  that  site  first developed
    or used  ---
                  DR.  CORNWELL:   These ponds  that  I'm  thinking  of
    on the Tenoroc site  are  probably  twenty years  old  that are
    now having tree species  moving  out onto the  land.
6                 MR.  TRAINA:   So in  that case,  it was a twenty-ye,
    lapse --
                  DR.  CORNWELL:   Yes.
8
                  MR.  TRAINA:   -- before it was  just beginning  to
10
                  DR.  CORNWELL:  But again, this is because there
    was  no  management,  except abandonment.  There was no design
    of the  abandoned base .
I J
                  MR.  TRAINA:  But  if you did design these as you
    had  suggested, how long a time  do you think it would take to
15
    develop this  area  that again is more diverse or as diverse as
    it once was?
17
                  DR.  CORNWELL:  I  think that for most of the
    aquatic and wetland  types, twenty years would be --- You'd
    have  them well on  the way to where you want them to be.
         For the  fresh water marsh types, five years, and it'd
    be well mature .
22
         The mesic hammocks, like at the Christ inie site, it may
    take  longer,  not to establish them, but they just take longer
24
    to develop, whether they're planted by man or naturally.
                                                                   57

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                  MR.  TRAINA:  What happens  to  the water in land
    that  is  supported  by  the wetlands area  in that twenty-year
    period?
                  DR.  CORNWELL:  Well,  that  would depend on the
    water crop approach and, you know,  all  the  aquatic factors
6   and  the  shaping of the water sheds  that  feed into systems you
7   design,  and I  think in a restoration  plan you can plug all
    that  in.  You  shape and configure the land, the upland portion
    of the sites,  to support your wetland components, and you use
10   things like sand tailing to go for  the dry  site communities.
n                 MR.  TRAINA:  Can this be done on existing areas?
,2                 DR.  CORNWELL:  Yes, sir.
]3                 MR.  TRAINA:  Has it been done, to your knowledge
M                 DR.  CORNWELL:  No.  There's been, for example,
15   there's  been very  little experimentation with the sand tailing-
    type  habitats,  and the pine that's  been  planted on them have
    done  fairly well.
          They haven't really done much with the right kind of
    vegetation,  in terms  of re-vegetation.   I think that ought to
    come  with  experimentation.
          We have  	  It's not widely recognized, but we have
    hundreds of experience^ in what could be  called the art of
    managing land,  drawing heavily on European experience.
L J
          And  we have  had historic background, both to the
    capability of  doing this, and the fact that it hasn't been
                                                                   58

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 ,      funded  and  done  experimentally in Polk County or in  the



 2      seven-county area  is not  in any way saying it can't  be done,



 3      and there isn't  anything  mystical or magical about it.



 4                   MR.  TRAINA:  As an ecologist, would you



 5      suggest that you work on  the existing areas and see whether



 6      you can restore  those, hold off on new areas, to see whether



 7      a  program like this could work in Polk County?



 8                   DR.  CORNWELL:  Well, I think that there shoulc



 9      be some experimentation,  and some experimentation's  under-



,0      way right now, but I feel that for much of it, particularly



n      in the  wetland types, that for 20 or 30 percent of them,



12      the best thing you can do is just to allow them to revert



13      without doing much of anything, because you would have



)4      that rough  terrain sanctuary that's proven to be so



15      important.



)6           The areas  that you  designate for marsh, much of it



,7      being slime pond management areas, that would come out



18      very quickly, and  that could be done right away.



19           When  you start talking about reforesting, to go to



20      a  forest, wetland  situation, because that's going to be



2)      costly  and  labor-intensive, you know, so I think you should



22      experiment  with  it some locally.



23           But I think  if you do it and design it right and do



24      it intensively enough, in two or three years, you'll know



25     where you're going and you're ready to put it out in large
                                                                   59

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       use.

2                    MR.  TRAINA:   Thank you,

3                    DR.  CORNWELL:  Your questions have taken me

       further  along in what  I  had  to  say, and  I'll just close

       now.

             A  couple of  thoughts  on the wildlife  impact aspects.

       It's  difficult for me  to envision any  possible  long  term

 8      adverse  effect areawide  on  any  particular wildlife species

 9      or on man and wildlife interface, in terms  of game animals

10      and pest animals,  and  this  sort of thing.

             Now, unfortunately that's probably one of the

12      greatest weaknesses of this  impact statement, as has

13      already  been pointed out to  you, and that is the discussion

       and the  rationale  	

             I  mean, it's one thing to say there ate twelve species

       or whatever that are endangered, threatened to be adversely

 )7      impacted, whatever the number.

             But you can't find anywhere in the discussion  of
 I O
       how or what or what's  their  rationale  for that, but again

       I'm looking at the experience we had in  Polk County, and

       I'm trying to see  what species  of this county have been

       adversely impacted county-wide  that can be attributable to

       mining.

             And I have a lot of trouble pinning down one species.

       I  think  that it's  clear  to man, looking at the  naturally -
 25                                                                   60

                                 '_ f7O

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      scored land from a wildlife standpoint, the net overall
      effect is just going to be a big plus to wildlife; whether
      it's just left to revert naturally, it would be a big
      plus, or we're going to man-dominated systems.
            And just remember what the mining's taking out is
      principally man-dominated systems, and the report breaks
      down; and you have an awful difficult time pinpointing
      what specific natural systems are going to fall into the
8
      mining areas .
            But if we take this jump that I'm talking about in
      restoration, really go after restoring natural habitats,
      plus providing wildlife sanctuary for man and domesticated
      predators, this seven-county area could be the African
I O
      belt of Florida.
14
            Thank you.
15
                    MR. TRAINA :  Thank you, Dr. Cornwell.
16                                      J
            I'd just like to make just one comment before  we
17                                 J
      get to the next speaker, and that is it would seem to me
18
      that the industry might want to look at the existing areas
      in terms of some of the suggestions you had and see  what
20
      they can do with existing areas.
            I understand your comment is with regard to the
22
      recommendation that on new areas, if the Indus try-could
23
      demonstrate on existing areas these lands could be restored,
24                                                                *
      certainly I think it gives us the best data base.
25
                                                                    61

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             Thank you  very much,  sir.

2                   DR. CORNWELL:  Yes,  sir.

3                   MR. TRAINA:   Pete Edward Holloway.

       MR.  HOLLOWAY:

                    My name  is Edward Holloway.   I'm here as

       an interested citizen.  I'm not here because I'm an

       expert witness or I'm  being paid.

                    I  have owned  some mined land  for about

       twelve years.  I'm a developer.  I own some citrus,

10      some cattle land, involved  in some agriculture.

n                   I've had some practical experience in

12      working with these phosphate lands, or the  equivalent.

13      I've farmed it.  I've  planted grass.  I raised cows, and

M      I  take issue with lots of the things that I find here in

15      your impact statement.

16                   On page  2	Well,  first, let rue say that

 7      I  agree just about 100 percent with our last speaker,

]8      George Cornwell, and it's been my  practical experience

]9      in working  with  these  lands that he is —• My experience

       tells  me, bears  out just what he has been telling you.
                                                           «
21                   My working these lands tells me the wildlife

       habitat and populations are improved, and I can look at

       some of these flatwood lands down  in Sarasota County and

       south  of here, and in  my opinion, mining perhaps would

       improve these lands.
                                                                   62
                             1-172.

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i                    And  ray  experience  tells me  that  the digging

2      and  mining  of these  lands, bringing these clays  to the

3      surface, where  they hold moisture, these  lands become

4      very,  very  productive, and my recommendation here to this

5      review committee,  I  think the mines have missed  an op-

6      portunity to be creative with their mining, and  they've

7      truly  missed an opportunity to take advantage  of what

8      they could  do with respect to making more lakes  and making

9      more wildlife areas.

10                   And  it  would be my opinion that even these

n      unmined areas where wildlife is very plentiful,  that

12      perhaps the tops of  the docks could be leveled and a way

13      made for people to get into these areas to actually see

14      what is there.

15                   And  I do think that we're on the right

16      track  here, and Dr. Cornwell certainly brought this out

)7      very,vividly.

18                   Paragraph 3(b) on that page 2 says pro-

)9      ductivity of the mined area will be reduced even after

20      reclamation.  I do disagree with that.  I think  I can

2)      substantiate my statement.

22                   I agree that the recreational resources

23      will be reduced, and  that esthetic aspects will  change,

24      and  my experience  has been with respect to the wetlands.

25      I don't think it will take as long as Dr. Cornwell said
                                                                    63
                              /-/7J

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!       for  the wetlands to actually come back.  These lands

2       are  very  fertile by reason  of the clays, and they hold

3       the  moisture, and you start off with a heavy vegetation,

4       willows,  and  it surprises you when you.Beally get into

5       it and study  it.

6                    I came down here because I read last night

7      about the wetlands, about the companies not being able

8      to mine the wetlands, and that concerned me greatly as

9      a  land owner, and I can see where a farmer or a rancher's

10      individual rights are being threatened, where he perhaps

n      owns some low lying areas.  Perhaps these areas have

12      valuable  phosphate deposits worth several thousand dollars

)3      an acre.

M                   Next door there's an owner with high lands

]5      with the  same type of deposits.  One is permitted to be

16      mined; one is not permitted to be mined.  This concerns

]7      me greatly as an owner.

18                   Should this take place and land be con-

       trolled,  in my opinion, the owner of those low lying lands

       should become saved in some way, and I think the restriction

       of that wetland area by land use control, compensation,

       certainly in my mind would be unconstitutional, I would

23      hope.

                    And that gives me concern.  The other cause

       of concern that scares me, when I read, even look at this,
                                                                    64

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 i      as  a buyer of phosphate  fertilizer,  and  knowing what's

 2      happening in the  prices  of food  and  farm products,  it

 3      scares  me as to what  could happen, by  reading  of the

 4      action, you know, of  so  much regulatory  measures.

 s            Thank you.

 6                    MR. TRAINS:   Thank you very much, sir.

 7            B.J. Register?

 8      MR. REGISTER:

 9                    My  name is B.J. Register.   I live at

10      Bartow.  This (indicating  jar) is a  specimen of water

n      that I  got this afternoon.

12                    I would like Mr. Hooks to  come up and give

13      me  an estimate on what he  would  think  if finding that

14      wa ter.

15                    MR. TRAINA:   I couldn't  get Mr. Hooks to do

,6      that, but would you describe where you got the  water, or

17      whatever it is?

)8                    MR. REGISTER:   From 1952,  about  1952, until

19      they mined out across 555, for the most  we had  perfectly

20      good water.

21                    I complained to IMC.  He said the trouble

22      was  in  the pump.

23                    MR0 TRAINA:   Is that water from  your  pump?

24                    MR. REGISTER:  This is water from my  pump

25      that I  got this afternoon.
                                                                    65

                               /-/7.S-

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i                     MR.  TRAINA:   Did you have  anybody  look at

2       that water?

3                     MR.  REGISTER:  Beg your  pardon?

4                     MR.  TRAINA:   Have you ever had anybody look.

5       at what was  in that water?  It doesn't look too  good from

6       here.

7                    MR.  REGISTER:  Let me just pass  it down

8      here.  Look  down in the  bottom of it.

9                    MR.  TRAINA:   This is  water from  your well

10      that's  on your land?

n                    MR.  REGISTER:  It's  from my well,  right out

12      of my spigot this  afternoon.

,3                    MR.  TRAINA:   Oh, from your spigot  that's  in

]4      your house?

,5                    MR.  REGISTER:  Right.

,6                    MR.  TRAINA:   How long has  it  been  this way?

)7                    MR.  REGISTER:  It's  that way  or  worse  all

]g      the time.

,9                    MR.  TRAINA:   All the  time?

20                    MR.  REGISTER:  All the time it's ---

21                    MR.  TRAINA:   I  hope you  don't drink this

22      water.

23            (Laughter)

24                    MR.  REGISTER:   No,  no.

25                    MR.  TRAINA:   Are you  close to one  of these
                                                                   66

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i      mining or chemical plant areas?
2                    MR. REGISTER:  Beg your pardon?
3                    MR. TRAINA:  Are you close to one of these

4      mining or chemical plant areas?  Why do you think the

5      water looks this way?
6                    MR. REGISTER:  I think it's caused from

7      mining across 555 from where I live.
8                   MR. TRAINA:  How deep is you* well?
9                   MR. REGISTER:  I don't know.  I didn't measurt

10      ifc'
n                   MR. TRAINA:  I'm afraid to even open this to

12      smell it.
13            (Laughter).
M                    MR.  REGISTER:   Go  ahead and  open  it.
15                    MR.  TRAINA:  Am I  going to taste  it?
,6            (Laughter)
,7                    MR.  REGISTER:   They sent somebody  out and
18      said that  our  pump was  giving us some trouble.
]9                    MR.  TRAINA:  Your  pump was giving  you trouble?
2Q       How long  have you had  this water that looks  like this?

21                     MR. REGISTER:   Since ttoey mined  over across
22       the road.

23                     MR. TRAINA:  How  long ago was  that,  sir?
24                    MR, REGISTER:  About three or four years.

25                    MR. TRAINA:  Three or four years ago you
                                                                   67
                                - Ill

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      had water  like  this?

2                   MR. REGISTER:  Yes, sir.

3                   MR. TRAINA:  Did anybody  look at the well?

                    MR. REGISTER:  Yes, sir.  They sent someone

5     out,  and they said  that  the  trouble was in the pump.

6                   MR. TRAINA:  Did you have your county health

      people  or  somebody  come  look at your well?

                    MR. REGISTER:  No.
o

9                   MR. TRAINA:  Well, I don't know what the

      reason  is,  but  since water like this shouldn't be in a
10
11
18


19
       house,  you ought  to get  	
                    MR. REGISTER:  I don't, either.

13                   MR. TRAINA:  Is there anything else, Mr.

14     Register, you'd  like to tell us?

15                   MR. REGISTER:  No, sir.  Until that mine

      across  555  there, we never had a bit of trouble with the

      water.

                    MR. TRAINA:  Is there a pond or something
close by, a big pond?
2Q                  MR. REGISTER:  No, sir.  There's a standard
2)      pond.
22
                    MR. TRAINA:  That's used by the mining area?
23                  MR. REGISTER:  Yes.  We're just across the

      road from where they did mine.

                    MR. TRAINA:  Are they still mining there?
                                                                    68

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,                    MR. REGISTER:  No, sir, not in that particula

2       area;  on the  other  side.

3                    MR. TRAINA:  But your water still looks this

4       way, water  still  looks  like  that?

5                    Well,  I appreciate your bringing it to us.

6       Again, I can  only suggest to you that certainly don't

7      drink  it under any  circumstances, and maybe you should

8      get your health department to come out and check it and

9      maybe  they  can make  some studies as to why it is the way

10      it:  is-

n            (Discussion off the record)

12                   MR. TRAINA:  Thank you very much for coming,

|3      sir.   Appreciate  it; thank you very much*.
               .
14            That  concludes the speakers that we had cards for.

15      At  this  time, I would like to ask, anyone else who  hasn't

       made a statement  or  anyone who	

             I'm sorry;  excuse me,  sir.  You did hand me a card.

18      W.M. Leaders?

                    I'm W.M. Leaders, Technical Assistant to the

       President of  the  Uranium Recovery Corporation, somehow

       referred to several  times in this report.

                    I'm disturbed  by the lack of economic

       evaluation and the  impact of the regulation and of the

24      fertilizer  industry  of the United States of America,

       particularly how  it might affect our international balance
                                                                   69

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i       of payments,  especially  since  this report  indicates that

2       the foreign reserves  are some  ten times what  they are

3       in the  United States, most  of  them in Moslem  countries.

4                     And  most,  I'm disturbed by the  lack of

s       economic  evaluation of the  proposed requirements for

6      lining  ponds  with  impervious membranes.

7                    This has been going on  in the water supply

8      industry  in the  United States  for many years.  Its

9      economic  evaluation fe obviously known to the  United States

10      of America.

n                    And  I'm also  concerned  with  the lack of

12      economic  evaluation of a requirement  for uranium recovery.

13      People  who evaluated  our industry, we are  the only

u      operating people taken for  granted that we're  making a

is      tremendous profit.

16                    I'm  also very concerned with the lafek of

17      economic  impact  on human life  in  this area, if the

is      industry  were shut down.

19                    Specifically, I  would like to take exception

20      to paragraph  (sic) 1.50. This is concerning  low level

21      radiation, long  term  effects in the second paragraph on

22      this  page at  the top.

23                    Low  level  effects,  long term effects of

24      low radium levels, doses, are  not fully known.  I want to

25      call  to the attention of the EPA  that the human body
                                                                   70

                               I- /BO

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,       contains  and  has  contained  for  many  centuries  .35  percent

2      of potassium.

3                    Many of you who have been reading about

4      these crash diets may have  heard about the  potassium sodium

5      that causes death in  people.

6                    The human body has  .35 percent of potassium

7      in the system, primarily in blood deposits  and the nerve

8      tissues.

9                    What most people  don't know,  including

10      your doctors, is  that all potassium  in nature is radio-

n      active.

12                    This was  used very recently to date the

,3      moon rock.  I published a paper in the American Chemical

M      Society Journal in 1941, "The Use of Potassium to Date

15      Meteorites."

)6                    This content  of potassium in  the human body

17      contributes 1,335 disintegrations per minute per pound of

18      body weight to date.   In 150-pound human being, this is

19      200,000 disintegrations per minute in your  blood stream

20      and  at your nerve endings.

21                    Your greatest exposure  to extra radiation,

?2      ladies and  gentlemen,  is when you are very, very close to

       another human being.  Now,  I'd  like  Mr. Nader to outlaw

       that action.
24
             (Laughter and applause)
                                                                    71

                                - te

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i                     As  a comparison,  the  gamma  ray  from the

2      radium-226,  which is  highly publicized  in this  report,

3      is  .19 MEB or 190,000 electron  volts.   The gamma  ray

4      from K-40, the isotope in your  body and my body,  has

s      energy, 1.5  million electron volts, roughly twice the

6      energy of radium-226.

7                    I don't want to get near  these  people.

8      The gamma ray energy, sometimes reported  in the old

9      industry as  being phosphoric acid and reported  as radium-

10      226, is not  true.

11                    The gamma ray energy  in the phosphoric

12      acid, which  we treat  as a by-product of the phosphate

13      industry, is the  gamma energy of the natural  isotope

14      of  uranium U235,  which has energy equivalent  of 187

15      thousand electron volts or just 3,000 electron  volts

,6      different than radium-226.

,7                    And until the discovery of  the  radium

i8      lithium centimeter, it could not be distinguished from

19      radium-226,  so the old literature is in error.

20                    I am also quite disturbed that  this report

2,      does not include  radiation surveys  on unmined land in

22      Polk County, Lake County, Orange County,  and  other

23      counties along the shoreline of the geological  formation

24      that runs from Orlando, Okeechobee  north,  through Georgia .

25                    This is known to  the  radiological department
                                                                    72


                                 - (8

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i       of HRS  in  the  State  of Florida.  My children went to




2       school  in  Lakeland on unmined  land, which has just as




3       high a  background as the so-called reclaimed land in




4       Florida.



5                     That's all, gentlemen.



6                     MR. TRAINA:  Thank you very much, sir.



/            I think  that concludes the cards I have of people



8      who indicated  they wanted to make statements.



9           Is there anyone else who would like now to come



10      forward?



n           Yes,  sir?



12                    MR. CARR:  Mr. Traina, I made a presentation



13      in Bradenton.  I am Archie Carr with the Florida Audubon



)4      Society, Lakeland, Florida.



)5           I do not wish  to take the time of another long



)6      treatise.   I would like to perhaps, if it's permissible,




17      to ask  Dr.  Cornwell a couple of questions that will



18      perhaps expand on the testimony that we had here.




)9                    MR. TRAINA:  Certainly it's all right with



20      me, but I'll have to defer to  Dr. Cornwell.  I found his




21      statement  rather intriguing.   I don't want to get into a



22      discussion here.




23                    MR. CARR:  I can assure you that I'm not



24      going to be antagonistic to my former professor at the



25      University  of  Florida.
                                                                   73

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i                     MR.  TRAINA:   I  think you've  gotten his

2       attention now.

3             (Laughter)

4                     MR.  TRAINA:   If others  can bear  it,

5       certainly I can.   I  think  I might  learn  something;  I

6       was  rather fascinated  by what he had  to  say.

7            For the  record,  they  just shook hands.

8                    MR.  CARR:  I'd  like  to  say that  one of  our

9      principal advisors on  the question of restoration,  Dr.

]0      Jim  Lane  of the Archibald station,  has generally ad-

n      vocated to us  that a no-reclamation or minimal-reclamation

12      procedure is certainly the  most favorable  one,  for  the

]3      reasons that Dr. Cornwell has espoused,  that if habitat

u      is created, then wildlife would be  enhanced.

15            There are a  couple of items  I'd  like Dr.  Cornwell

16      to try to expand on.

]7            First is a philosophical one, that we in  the

)8      Audubon Society are, of course, concerned with  ---- :We

19      are  environmentalists; we view native  Florida habitats

20      as important,  per  se.

2,            I accept that a  great deal of the  terrain that will

22      be mined  is modified countryside,  farms  and so  on,  but a

       certain amount of  it will be  somewhat  native habitat.
24
            You seem to be suggesting that if we exchange that
       for  very modified habitat, which  indeed may be richer, but
                                                                    74

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i       a  very  different habitat  --- Now,  if we adopt that as a

2       philosophy,  then modification  in the State of Florida

3       becomes permissible.

4            We end up with a cultivated  ecosystem from one end

s       of the  state to the other.

6            How do we resolve that problem philosophically?

7       Should  we permit any type of modification of the en-

8      vironment, even if the consequence of that modification

9      is a richer  and Improved habitat, no longer a native

10      Florida habitat?

n           So there's a philosophical question that I'd	

12      Perhaps you'd like to comment  on that.

13           The other is quite brief.

14                    DR. CORNWELL:  Yeah, I think they ought

,5      to be one at a time.

16           Philosophically, I've been committed in my lifetime

17      to causes of the Sierra Club and Wildnerness Society,

)8      Natural Parks Association.  I've been a naturalist for

)9      the National Park Service and  a biologist for the Fish

20      and Wildlife Service in Alaska, and certainly natural

2)      systems are  closer to my heart than man-disturbed or man-

22      dominated systems.

23           But you cannot study the history of man's occupancy

24      of land without recognizing that one of the hallmarks of

       our species  is changing our environment, and indeed
                                                                   75
                                I- 18

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       that  is  a  trait  common to virtually  all born into




2      animal life.




3            I  think that  we  have a  capacity  that we rarely




       use,  Co  intelligently  evaluate  the ways in which we




       modify our environment, and this  discourse tonight  is




       a  painful  exercise  in  our trying  to  improve  on the way




       we've done it in the past.



             I  feel  there's a great  deal of room for improvement.



             Now, there are few portions, even in Florida, that,




10      in terms of human impact	I  would feel the seven




n      counties are  among  the most impacted by man  of any



)2      block of seven counties in Florida.




13            The  gold coast counties have larger acreages of



14      natural  systems.




15            The  consequence  of this,  when  we  look  at the 20 per-




]6      cent  more  or  less,  is.  that a  lot  of  it  is disjunct; it's



]7      isolated parcels, and  its productivity  falls  way off.



             I  think that  it's also  clear,  from the  land analysis




       in the impact statement,  that we're  talking  about 3 to 4



   ,    percent  maximum  of  any natural  habitat  in the area that



       is  going to be impacted or eliminated on the  short term




       by  mining.



             I  believe  that —  Well,  one of the habitats that



       we're  most concerned about is the sand  pine  scrub, which




       has been used  for,  you know,  for a great variety of
                                                                    76

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,       human indulgences,  and  the  forestry.  You know,  they use

2      this  to the extent  that they're  in  real trouble,  but most

3      of the sand pine  scrub  in the  seven-county area  —  and

4      it'll be just  a few hundred acres --  is  not  on lands

5      to be mined.

6            The only parcel I know of, after  looking at all

7      the DRl's they have done, is a ssiall  4  or  5-acre  piece

8      in ^natee County among the closed  mine  sites.

9            Now, I think  that's a clear cut example  of  where

10      the site-specific impact statement  would  recommend  non

n      mining of that; whereas, the focus  of this impact

12      statement as discussed  has been wetland, wetland,

13      wetland.

14            I would  say that  rambling beech and  sand pine

15      scrub there is more Important ecologically than the

16      wetland acreage on  the  site .

)7            But for  the great bulk of the land  to be mined,

)8      or  virtually all  of it,  I think the natural systems

19      they  go under  are the trade-off for the  potential that

20      you have  to create  acreages, net acreages, that function

21      In  terms  of biota,  do everything that you want that  eco-

22      type  to do.

            And  I  think if you're looking for straight  pre-

24      servation  use, you  need  to go to the  public ownership

       parcels and  —
                                                                    77

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i            And, you know, when I was a member of the Sierra

2      Club  twenty-five years ago, they used to say, "How much

3      wilderness should there be?"

4           And the Sierra Club would say, well, we would like

5      half  of  1 percent committed to that type of use, and now

6      it's  10  percent to  preservation use so, you know, these

7      things change, but  we are dealing basically with private

g      lands with a very important resource underlying them,

9      and there has to be some combination of the preservation

10      philosophy and the  trade-off you can get for mining land.

n                   MR. TRAINA:  Do you want to continue 	

12                   DR. CORNWELL:  If the next question is

)3      simpler, my answer  would be	

14                   MR. TRAINA:  Well, a philosophical question

)5      certainly deserves  a philosophical answer.

16            (Laughter)

)7                   MR. CARR:  Endangered species and habitats;

       many  endangered species are endangered because they have

       a  very unique habitat that is satisfactory for their

       natural history.

2)           Should we	You're not suggesting that we

22      eliminate endangered species habitat and restore -- allow

       some  sort of natural restoration to occur?
e. \5

            The point is  it's very likely that you will not

25      restore anything useful for, say, one of these unique
                                                                   78
                               l-iee

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 ]      little plants  that are  involved.



 2            Could you clarify your  call  for  natural



 3      restoration versus endangered species  habitat  pro-



 4      tection?



 5                    DR.  CORNWELL:   All right.  Again, well,



 6      I'll point out that one of  tthe great gaps  in the draft



 7      impact statement is identification of  these species



 8      beyond an enormously-long table. Chat's headed  "important



 9      Species," and  to you and I, every  species  is of equal



,0      importance in  the chain of  life, so that's a nisnomer



n      unto itself, so I don't know  at this point what species



12      the biologists in this  report are  really saying will



13      be adversely impacted by mining.



14            And I don't  know  what their  rationale is.  I'm



15      saying that standing here right now, I could not name



16      one that I know as a fact would be endangered  further



17      by the proposed action.



)8                    MR.  CARR: I'd,  ask for further elaboration



19      on endangered  species,  next to myself, as a matter of fact.



20            With respect to wetlands, is there a difference



21      between restoring  wetlands and creating a new  one?



22            We can look  at some of  the slime ponds,  as you've



23      said,  and indeed they have water fowl and fish value,



24      wildlife value.



25            Isn't there  a hydrological and ecological difference
                                                                     79

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!       in  procedure where  one  creates a new wetland and one




2       restores a  cypress  swamp  or river basin that exists




3       there  now,  with  the EIS argument that one cannot




4       create the  organic  basis,  the drainage system, and




5       ecological  organic  systems that evolve on top of that




6       and therefore  the strong  precautionary language in




7      the EIS?




8                    DR. CORNWELL:  Well, again, I would




9      believe that you and  I  and whoever went to school in




10      wildlife management,  at some point in their background




n      would  feel  confident  in taking almost any piece of




12      real estate, and, if  they can make the soil haavy




)3      enough to hold water  and could share a water supply,




14      they would  feel  confident  in the ability to create a




]5      wetland, the sophistication of which would only depend




16      on  how much money they  spent, starting from scratch,




       starting with  never a wetland at that site.




             And of course,  there are all kinds of wetlands,




       twenty-some different kinds, and this general in-




       terpretation has to be  modified when you address each




21      wetland type.




             There certainly is a difference between restoring




       and  creating,  but much of the so-called restored wetland




       was  indeed  destroyed as a wetland, the Horicin Marsh




25      in  Wisconsin being a  good example.
                                                                   80

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 i            I mean,  it was  drained, and  it was  farmed;  the




 2      hydric soils were burned  away, blown away, and  gotten




 3      down to a bare scene, but through  water control and




 4      through management, a marsh was again  put there,  and



 s      you might call that restoration, but really you're



 6      starting from  scratch with just a  former wetland  site




 7      that no longer had wetland characteristics till you



 8      went in there  and put in  structures for water and



 9      managed it.




10            And I think that's  really a  fine point and  not



,1      particularly relevant to  the data  base.




12                    MR.  CARR:   Well, again,  it's relevant if



]3      you're a purist ecologist.  We might have a new species



14      evolve, a slime pond  darter, for example.




is            (Laughter)




,6                    MR.  CARR:   And that, then, would  be



,7      creation, but  again,  to fall back  on the philosophical



18      argument	




19                    MR.  TRAINA:  Mr. Carr, could I ask you just



20      to conclude this  subject?  I don't want to get  into this



2,      in any  great detail.




22                    MR.  CARR:   Okay.  Thank you very  much.



23                    MR.  TRAINA:  Would you summarize, if you



24     want  to  summarize, if you like?




25                    MR.  CARR:   I might make  this point  on




                                                                   81




                         I- IK

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i       development,  that we  are indeed  interested  in pro-



2       tecting what  we  conceive of  as native  Florida habitat,



3       and  we, for example,  our organization, has  advocated



       the  environmentally-endangered land  bill protecting --



5       sought to obtain a native injunction to the Florida



6       landscape, and we see a  qualitative  difference between



7       highly-modified  lands, all be  it productive lands;  it's



e      good for the  general  wild lands of various species  of



9      wildlife, but there's a  qualitative  difference between



10      that and the  native habitat, even if it is  a pine  flat-



n      wood or a scrub  versus a very rich hammock.



12            And I think that society needs to consider those



13      things when we consider  the  alternatives, the options,



14      that we are presented with in the course of a major



15      mining event  such as  this.



16            Thank you  very  much.



17                    MR. TRAINA: Thank you,  Mr. Carr.



IB            Does anyone else care  to make  a  comment at this



19      time?



20            (No response)



21                    MR. TRAINA: I'd just  like to say --  I  say



22      this a bit of tongue  and cheek -- that I always  learn



23      something in  these public hearings.



24            Tonight I  learned  that the phosphate  industry rather



25      than God created  wetlands and that man is more radioactive
                                                                    82

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       than uranium is .

 2            (Laughter)

 3                   MR. TRAINA:  Be that as it may, we're

       going  to keep the comment period open until June 23rd

 5     so those of you who would like to send us written

,6     comments, please do so, and those should be addressed

 7     to Mr. John Hagan, Chief of the EIS Branch, EPA,

       Region IV, 345 Courtland Street N.W., Atlanta, Georgia.

             As I said, we'll take into consideration all the

10     comments and statements that were made and will be made

       and we will address those comments in the publication

12     of the final EIS, which is scheduled for July 31st.

13           Again, all persons on (he mailing list would

,4     receive a copy of those findings.

1S           I want to thank you all again for coming.

,6           The meeting is adjourned.

                                   (Whereupon, the hearing was

)8                                  adjourned at 9:25 p.m.)

19

20

21

72

?3
                                 -oOo-
                                                                    83

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25
          C_ERT;iFI_CATE

This is to certify that the attached proceedings

before THE ENVIRONMENTAL PROTECTION AGENCY, REGION IV

in the Matter of:

      Draft Environmental Impact Statement Public
      Hearing

      City of Bartow Recreation Department
      Bartow, Florida

      7:00 p.m.

      May 24, 1978

were held as herein appears and that this is the

original transcript for the file of the Agency.
                               JAP'
                          Official
                   -oOo-
                            /-  /f 4-

-------
                 UNITED STATES  OF AMERICA
              ENVIRONMENTAL  PROTECTION AGENCY
                         REGION IV
A Public  Hearing:

  DRAFT AREAWIDE ENVIRONMENTAL IMPACT STATEMENT
  CENTRAL FLORIDA PHOSPHATE INDUSTRY
  March 1978
                             Time:       7:30 p.m.
                             Date:       May 25, 1978
                             Location:   Punta Gorda, Florida
                           -oOo-
               BAY PARK REPORTING COMPANY
                       COURI RhPORTING
                     1.) FOURTH STREET NORTH
                   ST. PETERSBURG. FLORIDA 33701
                         (813) 823-8388

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      APPEARANCES:

             THE CHAIRMAN:
                            PAUL TRAINA
                            Director of the Enforcement Division
                            Environmental Protection Agency
                            Atlanta, Georgia
             THE PANEL:
 8


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16


17


18


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25
DR. MARVIN COLLINS
Florida Department of
 Environmental Regulation
Tallahassee, Florida

BILL STOWASSER
Bureau of Mines
Department of Interior
Washington, D.C.

BILL PHILLIPS
Office of Regional Counsel
Environmental Protection Agency
Atlanta, Georgia

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      SPEAKERS                        PAGE




 2    Robert Shedd                     27




 3    C. R. Johnson                    30




      Joseph R. Roach                  31




 5    Dr. M. H. Bigelow                39




 6    S. R. Stedman                    43




 7    Samuel Wapner                    45




 8    M. W. Chesson                    51




 9    Jim Kelly                        58




 10    David Wilson                     63




 11    Robert McQueen                   65




 12    Jonathan Miller                  77




 13    Vasco Peeples                    86




 14




 15




 16




 17




 18




 19




 20




 21




 ?2




23




24




25

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 2                                (Whereupon, a,t 7:35 p.m. the
 3          hearing was called to order)
                   MR, TRAIM:  The hearing is open.
           Good evening, ladies and gentlemen.  My name is Paul
     Traina, and I am Director of the Enforcement Division of the
     United States Environmental Protection Agency in Atlanta,
 8    Georgia.
 9          The Regional Administrator of Region IV,  Mr. John White,
10    has designated me to conduct this hearing tonight.
           I would like to introduce the panel members.  On my
12    far right is Mr. Bill Stowasser; Mr.  Stowasser  is with the
13    Bureau of Mines in Washington and is  representing the Depart-
]4    ment of Interior.
|5          On my far left is  Dr.  Marvin Collins.   Dr.  Collins  is
16    representing Jay Landers,  the Secretary of the  Florida
17    Department of Environmental  Regulation.
18          On my immediate right  is Mr.  Bill Phillips,  who is  with
19    the Regional Counsel'r office of EPA  in Atlanta.
2Q          And on my immediate  letL is Mr.  John Hagan.   Mr. Hagan
21    is  Director oi the EIS Branch in Atlanta,  Georgia,  with EPA.
22          I also,,at thia time,  would like to  have  the	I
     understand there's a number  of county  commissioners and
£. J
24    perhaps city officials here.
           I believe the chairman of the county commissioners  is

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      here.  Would you please get up, sir, and identify yourself?




2                   MR..SCHADE:  Schade.



3                   MR. TRAINA:  Yes, sir, Mr. Schade.  Thank you




      sir, and we sure appreciate the room tonight; it's very




      nice, and we appreciate it.



6                   MR, SCHADE:  Happy to have you here.




7                   MR. TRAINA:  Are any of your other county



8     commissioners up here who'd like to be recognized?



9                   MR. SCHADE:  I have Commissioner Bob Shedd




,0     right here.  I think he's coming.




n                   MR. TRAINA:  I understand there's some busines



12     here in the courthouse, so you've been going back and forth.



)3           Are there any city officials here?



14                   A VOICE:  Mr. Johnson, ,City Councilman.



)5                   MR. TRAINA:  Thank you, sir, for coming.




16           Any other elected officials here with us tonight? •



)7           (No response)




18                   MR. TRAINA:  Tonight's hearing is concerned



19     with a two-year study on environmental, social and economic



20     effects of continued expansion of the central Florida



21     phosphate industry.




22           The purpose of the study is to comply with the Nationa]



23     Environmental Policy Act of 1969.




24           Issuance of National Pollution Discharge Elimination



 25     System permits for new sources of phosphate mining and

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i     chemical processing operations constitute a federal action
2    which significantly affects the human environment,
3          However, as such, the National Environmental Policy
4    Act requires development of an Environmental Impact State-
5    ment prior  to  the issuance of these NPDES permits.
6          It was determined in early 1976 that the number of
7    new phosphate  operations, which would request permit
a    applications, would make Individual site-specific en v iron-
9    mental  impact  statements ineffective in determining area-
10    wide and cumulative effects.
11          Each  individual study would determine effects of that
12    particular  operation, and areawide or cumulative effects
13    might easily have been neglected.
u          For this reason, all new sources were held in
is    abeyance.  All new source permits were held in abeyance
16    while the areawide EIS was developed.
17          A draft  of this statement has been prepared, and
is    notice of its availability was published in the Federal
19    legister, Volume 43, dated April 21st,  1978.
20          The hearing this evening is for the purpose of
21    receiving comments from the public on this draft Environ-
22    mental Impact Statement.
23          All substantive comments on this  draft statement will
24    be considered by EPA and summarized and addressed in the
25    final Environmental Impact Statement.
                                                                   6

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 i           I might just say at this  point  that the  comments
 2     we received so far -- this is  the  third  meeting we've
 3     had -- have been rather substantive,  and we are going to
 4     be considering those  in some detail.
 s           As stated on the agenda,  there  will be a  brief
 6     presentation by EPA and the contractor of the  study, Texas
 7     Instruments, to summarize the major conclusions of  the
 8     draft EIS and how those conclusions were developed.
 9           Those of you who've indicated on the registration
10     card that you wish to make a statement,  you will be given
n     that opportunity.
12           At this point I would like to introduce Mr. Gene
13     McNeill.  Mr. McNeill is  the Project  Manager for the
14     phosphate study and will give us a little sunmary of the
is     study and then introduce  our contractor.
16           Mr. McNeill?
17                   MR. MCNEILL:  Thank you, Mr. Traina.
is           First, before I get started, I'd like to  make a
19     couple of introductions.
20           During this study we have had an inter-agency
21     steering committee consisting of the  federal agencies who
22     are  involved in any sort  of regulation or permitting of
23     the  phosphate industry.
24           And on that we  had  representatives  from the US Army
25     Corps  of Engineers, several of the interior agencies, CEQ,

                            /•Jo/

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 i    and Department of Agriculture and, of course,  EPA,  and also



 2    the State of Florida was represented on the steering com-



 3    mittee.  The State of Florida representative was J^y Landers,



 4    who also happens to be the Secretary of the Florida Depart-



 s    merit of Environmental Regulation.



 6          In addition to the steering committee, we had an



 7    advisory committee, which consisted of representatives from



 8    each county.
  I


 9          We asked each of the county commissions, wi^intfehe



10    study area, to designate a representative for  the advfypry



n    committee.



12          Also on the advisory committee we had a  representative



13    from the Southwest Florida Water  Management District and a



u    representative from industry and  a representative from the



is    Florida environmentalist groups.



16          Of those committee members  here tonight, I've seen *<•«



17    I know Bucky McQueen is  here; I'd like to introduce Bucky.



is    Most of you, I'm sure, already know him.



19         The industry representative  is Homer Hooks.  I saw Htimer



20    here.  Yeah, Homer Hooks, who is  also president of  the



21    Florida Phosphate Council.



22          And I would like to mention at this point,  it just



23    happens that these two that are here tonight had  perfect



24    attendance; Bucky and Homer were  the only two  that  attended



25    every advisory committee meeting  we had,  and since  most of
                                                                    8

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 i     you are  from this  area,  live  in  this area,  I'd  like  to



 2     mention,  at  this point,  special  thanks  to Bucky  for  the



 3     assistance he's given  us throughout  the study.   He's  been



 4     pretty pointed  in  some of his comments.  I  couldn't  say



 5     he's been totally  nice.   (Laughjzer)  He tells us what he



 6     thinks of us, but  he's also been extremely  helpful.



 7          I'd Also  like  to thank him, at this time,  for helping



 8     arrange  this auditorium  for the  meeting.



 9          Okay.  At this point I'm going to turn it  over  to



10     the prime contractor on  the study, Texas Instruments,  to



11     make a real  brief  presentation pn how the information in



12     the study was developed.



13          With that, I'll  introduce  the Project Manager of



u     Texas Instruments, who was our prime contractor, Larry



is     Bowles.



16                  MR.  BOWLES:  I have two of my colleagues



17    with me I'd  like to  introduce, Dr. Arnold Stalder and



is    Dr.  Audrey James.



19          All total, during  the peak staffing there were about



20     twenty of us involved  in  the program, twenty Tl-ers, and  then



21     there were nine of us  that constituted  the  core  that are



22    still working different  phases of the program.



23          I'd like to very briefly make a presentation on sane



24    of  the ground rules that we operated under  in the study



25    and  our approach to developing the information that

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25
eventually became the draft Environmental Impact Statement,



and then show you a few of the slides of pictures that we've



taken in the seven-county study area, showing the various



land uses that we had to deal with, and then I111 turn it



back over to Mr. Traina.



      First of all, as you all know, it was designated a



seven-county study area, including a tier of four counties,



Polk, Hardee, DeSoto, and, of course, Charlotte County,



Sarasota, Manatee and Hillsborough County.



      You see here this area designating the higher grade,



generally higher grade of bone phosphate of lime, where the



majority of mining has occurred at this point.



      And then this area here is designating a little grade,



and you can see this cross-hatched area, which probably



appears gray to you, represents mines that are represented



by OKI's.



      In topographic relief,  this reveals a little more



information, what we're dealing with, in the Polk Uplands.



Primarily,  the mining has occurred here.



      There's some new mines  being proposed along this



ridge here and then again along a ridge here on the DeSoto



plains, where the grade seems to be a little better.



      We also included, of course, Charlotte Harbor and



Tampa Bay in our study.



      The major emphasis was  to use to the maximum extent
                            /-104-
                                                                    10

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 i    possible existing data.  We received help from various
 2    tiers of governmental agencies, including EPA, Buare*u<.'6f
 3    Mines, USGS, Corps of Engineers, Fish and Wildlife Service,
 4    the Florida DER, SWFMD, regional planning councils and, in
 5    many cases, county planners.
 6          EPA furnished us a considerable amount of material,
 7    laws, regulations, industry description, water quality and
 a    air quality.
 9          The majority of the studies related to radiation
10    were done by the Environmental Protection Agency.
11          USGS assisted us in developing information about
12    the Floridan Aquifer and the ground water, as well as
13    making available to us a recently-developed model  of the
u    Floridan Aquifer, which we were allowed  to use to  predict
is    impacts.
16          The Fish and Wildlife Service with the contractor
17    conducted an extensive survey of the wildlife in the area
is    which we used.
19          The Bureau of Mines furnished information about the
20    industry projections about future demands and future
21    production,  and our human population projections were based
22    on the University of Florida estimates.
23          Gene mentioned to you the function of the steering
24    committee and the advisory committee. This program started
25    i out being,  in a  very real sense,, a grand experiment  in  the
                                                                    11

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 ,    public participation and the use of the Environmental

 2    Impact Statement process as a public planning tool.  I

 3    think it's been a fairly effective experiment, and we were

 4    to perform, not only an assessment of just one alternative,

 5    but there were a total of five alternatives that we had

 6 ,   to assess the environmental impacts of.

 7          The methodology that we used had to address a set

 8    of decision indicators, which were listed in our statement

 9    df work, which resulted primarily from the steering com-

)0    mittee with advice from the advisory committee, and then,

n    where priorities were required, we did have a series of

12    meetings.

]3          Then that direction was given by the steering

)4    committee again with advice from the advisory committee,

15    and,,of course, funding limitations are always present.

)6          Then we assisted the EPA with the preparation of

17    the draft Environmental Impact Statement.  We also will

18    be assisting them with addressing the comments that have

)9    been received and will be received on the draft.

20          And there were a set of working papers, a total of

21    about 1,700 pages of documentation resulting from our work,

22    and we are now preparing those, incorporating comments

23    received on them, in the fina^, form, and they will be

24    entered into the National Technical Information Service

25    system so that they will be available to the public.
                                                                   12
                            /-

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 i           In conducting this  study,  the history  of  the



 2     phosphate industry  and  the  issues associated with it are



 3     very complex and  go back  quite some time, and we felt  it



 4     was  advantageous  to EPA and  ourselves to have some con-



 5     sultants familiar with  the Florida scene.



 6           Dr. James Nicholas  assisted Dr. Louise Young and



 7     Carl Hice of II1s staff in socioeconomics.



 s           Dr. Paul Urone and  his colleagues assisted Dr.



 9     Arnold Stalder on air quality.



10           Dr. Eric Rifkin assisted Audrey and Dr. Michael



n     McDaniel in ecology and general  effects.



12           Geraghty and  Miller assisted with hydrogeology with



13     Bill Lancaster and  Bill Underwood of our staff.



i/t           And Tomasino  and  Associates assisted myself and



is     other staff members in  the description of the scenarios



16     in a more operational form,  as well as water, surface



17     water resources.



is           Now,  the next set of ground rules are  very important



19     to understand  when  you  evaluate  the draft Environmental



20     Impact Statement, because they set the time  frame in which



21     we had to estimate  what; the  environment would be like in



22     the  future.



23           First  of all,  we  projected resources and demands in



24     the  environmental setting as would exist under the different




25     alternatives to  the year  2000, and  the base  line of  the
                                                                   13

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,     data was as it existed on 1 August  '76, including the
2    regulations as they existed.
3          Now, there are some exceptions to that.
4          We published the preliminary  findings in the form
5    of widely-distributed working papers, and the purpose of
6    that was to stimulate comment, as well as comment from
7    the steering and advisory committee members such that we
8    could assure an adequate and valid  information base on
9    which to develop information to the decision makers.
10          And the major integrating theme that we used was
n    that of environmental land use planning, because we were
12    dealing with, actually, a very major land use planner in
]3    the area.
14          We did have to make some adjustments, refinements
15    in the data base.  One was that future land use gawp*.?did*
16    have to be developed to represent the year 2000.
)7          With the assistance of individual phoaphate companies
)8    in response to a letter that TI sent them, we refined the
19    information about their specific land use plans, and the
20    Corps of Engineers'  regulations regarding administration
2)    of Section 404 permitting, which has to do with dredge and
22    fill, we took one exception of the 1 August '76 date in
23    that they were fully implemented 1 September '77, so we
24    used those regulations.
25          -For the purposes of the study, we had to assume that
                                                                   14

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 1     all operations,  phosphate operations  that  were  not




 2     permitted as of  1 August '76 would  be classified  as  new




 3     sources.




 4           We  focused on two time intervals.  One was  between



 5     the present and  1985,  because of  this  peaking in  production,




 6     and the other one, of  course,  was 2000, Which was the end




 7     of the time frame which we were forecasting •



 8           The cast of characters under  those that were existing




 9     operators is this set  of mines.  A  footnote here, that



10     based  upon the information we  developed, there are no



n     presently-announced plans for  development  of chemical



12     processing plants.  Of course, that could  change  in the



      future, so we're primarily dealing with plans for mining.
I o



            The next set has  to do with permitting new mines.




)5     There  were a set of applications at the state level, the




      DRI  process.   In addition to that, from the land use



      questionnaire we sent  to  the  individual phosphate companies,




      we discerned  that the next one, besides represented by the
I 8


      DRI, would  probably  be  USS Agri-Chemical in their plant



      near Fort Meade.




2)           And  then there are a set of others, and we call this




22     the  industry  view;  in other words, perhaps taking exception



      to the Bureau of Mines  forecast.




24           If  all  these were permitted, you can see some of these




     would  play  out in the future, and some would continue











                               /-l 09

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     production.  Then there would have to be new mines to come




 2    into play.



 3          I mentioned that we did use existing data.  We



     received assistance ftfom several Agencies, individuals,



 5    and so on.




 6          I just want to give you a sampling of those to give



 7    them credit.  We were assisted by DER, who provided  in-



     formation through our consultant.



           Again, DER, on vegetative fluoride data.   We received



10    information from the phosphate industry as well.



n          USGS, as I mentioned,  in this  case,  with  potentio-



12    metric surface maps showing  changes  occurring over this



13    time interval, and they also let us  use their	We



14    submitted data to them; they used their model for  pre-



15    dieting impacts.



16          The US Army Corps of Engineers  assisted us in



17    developing general information about  the water  quality



     and quantity in the area.



19          We did focus on Tampa  Bay,  as  I mentioned, and



20    received assistance from Tampa Bay Regional Planning



21    Council.



22          We also were assisted  by the Central Florida Regional



23    Planning Council and the Southwest Florida Regional



24    Planning Council here with nitrogen and phosphorous  data,




25   and besides  developing information about the  environment,








                              /- HO
16

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 i     the  phosphate  industry  is part of that environment, because



 2     they're  presently  operating, so we, of course, needed



 3     information  on just some of their emissions and effluents.



 4          During the course of the study, our staff was in the



 5     area quite a bit of the time.  We did conduct aerial and



 6     ground photo reconnaissance and took some samples and



 7     made several observations.



 8          And I  just want to show you a sampling of some of



 9     the  pictures we took that represent some of the major



10     land uses in the seven-county study area.



n          First  of all, you recognize this strip mine; there's



12     a forest in  the background.



13          This is  a beneficiation plant,



14          A chemical plant	



15          This is  an abandoned strip mine that was mined



i6     approximately  twenty-five years ago, and without much



17     intervention from man has been reclaimed by nature, you



IB     might say.



19          This is a slime pond --a similar circumstance --



20    a little water.  Some de-watering has occurred.  You can



21     see the wildlife in the area.



22          This is an old slime pond that's being used by the



23    Florida Audubon Society.



24          This is  the interiors;  some natural de-watering has



25     occurred and vegetation.










                             /-*//
17

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            This  is  pa,:t  of  the  scene around  your  country.




            Here  we  have  a reclaimed  mine  that's being used  as



     a  recreational park.




            The majority, the  greatest percentage  of subsequent



     use  of phosphate  mined land  is  cattle grazing.




            Some  of  the natural  scenes where  mining hap not




     intervened  includes this sand pine scrub.



            A hammock 	




            Range land  —



10           Here's a wetland.



n           And another type of  wetland	




12           There are several  types in the seven-county study



,3    area.



M           Agriculture is a major  land use.   Of course,  that




15    Includes cattle grazing, truck  crops., citrus  crops.




i6           You,  of  course,  have rivers, this  being the Peace



,7    River.



18           The bay, and  you can see  the use  of industrial,




19    technical generation.



20           And of course, the resort community development.




21           These are just a sampling of some  of the major land




22    uses in the area.



23           We, at TI and EPA, strive hard to  make  sure that




24    reports are all very informative and without  error.  We



25    try  to excel,  but we don't claim to  be  perfect.   We have
                                                                    18

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i     made some errors.
2          And this next slide will be incorporated in the
3    final Environmental Impact Statement and will clarify
4    some of the textual material regarding the impact on
5    terrestrial wetlands threatening endangered species.
6          I would like to comment that it's been professionally
7    and personally enjoyable to work with EPA on this program,
8    es pec ia lly Gene McNeil! and \ A
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     which is the basis of the environmental effects which are

     described in this draft Areawide Environmental Impact

     Statement, and as such they will become the basis for any

     new source mines or new source chemical plants, as well

     as the basis for the site-specific EIS's, which will be

     required for new sources.

           Okay.  First of all, I'll go through the proposed

     action for new source mine and beneficiation plants.

           The first one is we're saying that the cora/entional

10    rock drying process will be eliminated for all rock which

n    will be processed into phosphoric acid in Florida,

12          The second one is to meet the State of Florida's

13    effluent limitation which, in the case of mining and

14    beneficiation, are more stringent than EPA's, but one of

is    the ground rules of this study is, we stated that all

16    local, state and federal regulations, which existed at

17    the time of the study, would be met.  That was one of the

ia    ground rules of the study, and we found that Florida's

     effluent limitations for mining and beneficiation are

20    adequate to protect receding water.

21          The third one is to eliminate the conventional

22    above-ground slime disposal areas.  Now, this one does

23    have an allowance for temporary storage of slimes,  when

24    the companies, the mines, get into situations where the

25    percentages of slime are so high that one of the  methods
                                                                   20

                                 - L/4-

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      for using the slime for reclamation, instead of conventional




 2     slime ponds, cannot be used for that incremental difference




 3     in slimes.



           So we're only allowing temporary storage of




      For the most part, we're saying eliminate conventional




 6     slime-settling ponds.                                        I




 7          The next one is to meet the existing Southwest



 R     Florida Water Management District requirements.  That's




 9     being sort of repetitive, because I said one of the ground



10     rules was to meet existing requirements.




11          But we're saying, in addition to that, which in many



12     cases we feel will further increase water recirculation,



13     recirculation of the water at the mines, which will in




      turn reduce the pumpage of water, in some cases, further



,5     than would be required by SWFMD.  We're saying to provide




16     storage for water recovered from the slimes by utilizing



,7     one of the methods of eliminating the slime pond.



18          So this will allow further water recirculation and




19     decrease water consumption.



20          The next one is sort of	We're saying to allow



2)     continued use of connector wells, but we do qualify this




22     and say with careful monitoring during operation of these



23    wells and careful monitoring to determine that once they're



24     closed down, they're adequately sealed off




?5          Continued allowance of the connector wells; it helps
                                                                   21

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     the companies in that it's a good way to de-water the

     area to be mined; plus it is a water conservation measure.

     Instead of pumping the water out to surface streams for

     de-watering, the water is drained into the Floridan Aquifer,

     so we say to continue to allow that careful monitoring.

6          The next one, unfortunately, as Larry mentioned, the

7    EPA Office of Radiation Programs provided the information

a    on any of the radiological aspects of the study, but

9    unfortunately the part on the guidelines on land recla-

10    mation are not yet complete.

11          They have been put out in draft form, but they have

12    not yet been published as proposed guidelines in the

13    Federal Register, so we're leaving that.

           When these guidelines are finalized, they will be

15    incorporated into the final EIS

16          The next one is, in addition to meeting existing

17    county ,and state reclamation requirements, we're stating

18    that during the site-specific studies, DRI and site-specific

,9    EIS's, to inventory existing wildlife habitat and wildlife

20    populations and to take these into account in the mining

21    and reclamation plan for any new source mine and assure

22    that, during the mining process, this wildlife habitat and

23    wildlife populations are protected

24          And the next one, and final one.,we have on new source

25    mine and beneficiation plants is to protect or restore
                                                                   22

                                  - It

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     wetlands which fall under Section 404 of the Federal



     Water Pollution Control Act.



           Okay.  As I say, that was very briefly, but that



     was the requirements we have listed for the mining



     operations.



 6          For any new source chemical plants, I should mention



 7    here that the proposed action, while we list requirements



 n    for new source chemical plants, we do not have any new



 9    source chemical plants projected.



10          All the information we were able to get from the



n    industry and from the Bureau of Mines indicates that



12    there currently is adequate chemical processing capacity



13    in central Florida, which would last until the deposits



14    in central Florida are mined out*



15          But in the study we did feel a need to list



,6    requirements in case some company sometime in the future



     does make application for a chemical plant.



18          The requirements for the chemical plant:  First of



19    all, in addition to meeting existing standards for



20    performance for new sources on air, we're saying, since



2,    there are fluorine emissions from the gyp ponds, or the



22    recirculated contaminated water systems,  we're saying



23    that the new source chemical plants will either provide



24    for recovery of fluoride, which would be narketed as a



25    product, or in cases in the future, if there is no market
                                                                   23

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     for this fluoride, at  least for reducing  fluorine con-




     centrations  in the gyp ponds, so that  the fluorine




     emissions from the entire plant complex,  including the




     gyp pond, don't exceed the standards of performance for




5    new sources.




6          The way the standards of performance are currently




7    written, they only include emissions from the stacks at



     the plant and not from the gyp pond.




           We're  saying to include the gyp  pond emissions in




10    the maximum  allowable quantity.




11          The next one for chemical plants is to, in addition



     to meeting standards of peformance for new sources for




13    water discharges, we're saying in addition to this to



14    recirculate  the non-processed water as well as processed



15    water and to provide the same amount of surge capacity




i6    which is adequate for the twenty-five year rainfiall event,



)7    to provide this same amount of surge capacity for non-



ie    processed as is currently required for processed water.




19          One further thing in addition to requiring re-



20    circulation of non-processed water, we're saying during



21    these rainfall events, twenty-five-year-.rainfall events,




22    or equivalent rainfall events which would require treatment



23    and discharge, that more stringent requirements be set



24    on the allowable concentrations for the pollutants in




25    these discharges, based on protecting water quality in
                                                                   24

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      the Tampa Bay and Peace basins, which are the two basin*



      where any of the industry in central Florida would dis-



      charge .



            The next requirement for chemical plants,  we're



      saying the gyp ponds for any new source chemical plants,



      the gyp ponds would need to be lined with an impervious



      material unless, in the site-specific study, it  can be



      demonstrated that lining is not needed to protect ground



      water quality.



 10          And then the final one would  be, in the site-specific



 n    studies, to encourage recovery of uranium from the phosphoric



 12    acid in any new source chemical plants.



            Okay.  As I said, that is very briefly hitting thfe



 14    high spots of the conclusions of the study or the proposed



 is    action for which this draft EIS lists environmental



 16    effects.



 17          I'll turn it back over to Mr.  Traina.



 )8                  MR. TRAINA:   Thank you, Mr.  McNeill.



 19          Before I call for comments, I'd like to just make



 20    some of my own comments with regard  to public participation.



 21           Not only is it the policy of EPA, its  own  rules  and



 22     regulations, but public participation is  called  for in



 23     various  federal acts that  EPA operates under.



24           The Federal Water Pollution Control Act, the Clean



25     Air Act, as well as  the National Environmental Policy  Act,
                                                                    25

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 1     all have  provisions  instruction EPA to involve the public
 2     in its  decision making,  and this is the reaflpo we're here
 3     tonight,  and  we've had public hearings on this subject
 4     in other  areas this  past week,  so that I could say in a
 5     way that  the  public  is almost obligated by law to come
 6     forward and make  some statements to us tonight.
 7             We certainly  waat to hear from you.
 8             With regard to tfur own rules and regulations, far the
 9     record,, notice of this public hearing was published in the
 10     Sarasota  Hergld-Tribune  on May 8th, 20th and 21st, and in th
 n     Tampa Tribune and I^keland Lgd^r on May 7tb and the 21st.
 12             In addition,  copies of the public not&ce w*r« mailed
 13     to each of those  individuals and organizations on the EJP&
 14     mailing list, as  wall as to all the appropriate local,,
 15     state and federal agencies.
 16             1  would ask that  those of you who would like to natce
 17     a statement,  if you  haven*t already done so>  plaaae fill
 18     out a registration card.   From these cards  I  will ea^l on
 19     in asking people  to  come forward.
 20            We're  not  under any formal rules of  evidence here.
 21     We want you to come  forward;  if you would,  stafce your
 22     name,,  if you're  affiliated with an organization, who that
 23     organization  is*
 24             I  would also  ask,  too, that  for those  of you,  even If
25     you're  not making a  statement,  fill out the
                                                                    26

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 i    card.

 2          This will give us a list of individuals that we

 3    will mail our final determination on with regard to the

 4    study.

 5          There's also a place on this card if you want to get

 6    on the EPA mailing list to receive information regarding

 7    other activities EPA has in this area.

 8          With that, I might also comment, too, that we'fce

 9    having this hearing recorded tonight.  There is a court

10    recorder here.

n          Copies of the transcript will be available in our

12    offices in Atlanta.  Any of those who'd like to make some

13    special arrangements with the court recorder to get your

u    own transcript, of course you're welcome to do so.

15          At this point I'd like to call on Commissioner

16    Robert Shedd, Charlotte County.

17    MR. SHEDD:

is                  Mr. Chairman and members of the Hearing

19    Commission, I would like to read a statement that was

20    developed by Bucky McQueen, who you were already intro-

21    duced to, by Mr. Mike Best, who is the Senior Planner

22    with the Charlotte County, Punta Gorda Planning Council,

23    by Mr. Rick Cantrell, who is with the Florid« Department

24    of Environmental Regulation,-and myself.

25          The statement was developed at the direction of the
                                                                   27

                               u I*.

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16






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18






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22






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25
Charlotte County Board of County Commissioners.




              The Charlotte County Board of County Commis-



sioners, at the regular weekly meeting of May 23rd, 1978,




requested that a statement for public record be made at




the Environmental Protection Agency's public hearing.




              Several of the following concerns were




expressed at this meeting.




              (1)  Without adequate, proper and timely



monitoring by the federal and state environmental agencies,




all proposed actions and existing rules, regulations and




requirements are worthless and ineffective.



              Therefore, we request that adequate surve.illanc




programs be instigated with an appropriate ftmding level in




order to accomplish those goals which should be of the high-



est priority.



              (2)  We endorse the recommendation that




process modification and control of equipment for existing



operations to meet all water discharge requirements by 1983



be implemented.  Only a small percentage of the total




mining area and impact operations will be new sources.



              (3)  Encourage and assist in the compilation




of more specific and useful information on the quantity and



usability of the marine biological information for the Peace



River, Myakka River and Charlotte Harbor.



              In summary, since discharges that occur on the
7I.TO
                                                                    28

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 i    headwaters of the Peace River may have an adverse impact




 2    on  our community, we are extremely concerned with the




 3    contamination of our surface and ground water.




 4                  The highest priority should be placed on an



 5    expanded monitoring program in order to prevent potential




 6    devastating slime spills.



 7                  Of equal concern is the monit^ing of critical




 B    synergistic mineral and nutrient combinations which can



 9    lead  to massive algae bloom.



10                  Sincerely yours, Robert Shedd, representing



n    the Board of County Commissioners.




12                  Thank you.



13                  MR. TRAINA:  Thank you, Conraissioaer.



u          May I ask, Commissioner, is your comment with regard



is    to  the existing source -- that the recommendations of thia




16    report be applied to existing sources?  Is thdt ---



17                  MR. SHEDD:  By 1983.



is                  MR. TRAINA:  By 1983.



19                  MR. SHEDD:  Yes, sir.




20                  MR. TRAINA:  Do you have a copy of your



21    statement so I can give it to the court recorder?




22                  MR. SHEDD:  Yes, sir.  We 'have an ordinal,



23    which I'll give to you.




24                  MR. TRAINA:  All right.  Pine, sir.  Thank you



25    very much.
                                                                   29

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 i          Councilman C.R. Johnson, City  of  Funta Gorda,
 2    MR.  JOHNSON:
 3                  Chairman and  members of the Hearing Commission,
 4    the  City  of Funta  Gorda  sanitary  plant,  built  during  the
 5    period  197 1-1 73, was at  that  time held  out by  EPA as  a
 6    major advance in waste water  treatment.
 7                  It is now  operating under  a consent agreement
 B    because of its  inability to consistently meet  the effluent
 9    nitrogen  limits Imposed  by  the 1971  Wilson-Grizzel Act.
10                  Although break  point chlorination would meet
11    the  letter of the  law, we find little enthusiasm for  this
12    because of, first, its cost and,  second, its adverse  effects
13    of  the  by-products on the marine  environment*
u                  As an alternative,  the City is developing an
is    effluent  land spreading  program.  Even with federal par-
16    ticipation, this multi-million dollar program  represents a
17    very significant financial  burden for this community.
is                  This would be commendable  if such action
19    resulted  in a real and substantial improvement in the
20    environment of  Charlotte Harbor.
21                  However, we are advised by recent 208 studies
22    that 85 percent of the pollutants entering Charlotte Harbor
23    are  by way of the rivers, and from a technical point  of view
24    the  contribution of our  sanitary  plant is insignificant.
25                  Thus, our  efforts will be  wasted unless a
                              /-
                                                                   30

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 i     major  effort  is made  to reduce the pollution of our rivers.

 2                   In closing, I wish  to emphasize that these

 3     studies,  reports,  guidelines and  recommendations are of no

 4     avail  unless  a properly-funded and staffed monitoring

 5     program is  placed  into effect to  enforce the laws relating

 6     to  discharges into our rivers and harbors.

 7                   Thank you.

 8                   MR.  TRAINA:  Thank you very much, Mr. Council-
  I
 9     man.   Again,  do you have a copy of your statement?

10           I just  might comment to you that as the Enforcement:

11     Director, I certainly — I do know the value of monitoring

12     and surveillance.   Without it, you don't have an en£or
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                    The most significant matter affecting the



 2     statement is  the fact that the ink was  hardly dry  on the



 3     scenario when actions by  the EPA Administrator and the



      phosphate industry virtually assured that the operating



      restrictions  of the scenario cannot be  attained by the



      administrative procedures contemplated.



                    Firstly, as to phosphate  chemical plants, the



      scenario contemplates much more  protective effluent limit-



 9     ations  than are contained in either the federal or state



10     rules.



n                   However, it is conceded that these can only



12     be  legally applied to new plants and, since the study finds



13     that  there will probably  never be any new plants in the



14     area,  they may never  be applied.



is                   What we are left with, then, are the existing



16     plants  subject only to the EPA 1926 final rules, which hive



17     been adopted  by reference by the State  of Florida, and that



is     contain only  some very liberal effluent concentration 11-



19     mitations, identifiable  for both BPT,  existing source,  and



20     BAT, new source, and  which are not within a country mile



21     of  the  protective limitations proposed  by the scenario and



22     used  in the projections.



23                   This fact will take on even greater  sig-



24     nificance when we get into some  possible inaccuracies  in




25     the working papers.
                                                                   32

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              As  to  the mine effluent  limitations, repeat



 mine,  the  scenario and all the  impacts developed rely On



 the more restrictive effluent limitations adopted by the



 State  of Florida  in  1977.



              However, these rules are being aggressively



 litigated  by the  industry, at both the state and federal



 level.



              On  January 16th,  1978, the EPA and DER issued



 jointly NPDES permits to five existing phosphate mines,



 which  incorporated, for the first time, the more protective



 BPT effluent limitations of the State of Florida.



              I am advised that the mines involved have



 requested  adjudication, thus staying enforcement of these



 effluent limitations.



              On February 16th, 1978, EPA, Region IV,



 issued a notice that certain of these effluent iJumitatiojijs



 were to be made binding on those mines even during a ten-



 year storm, which could contradict both Florida and federal



 guidelines and assure that the mining companies' plea for



 adjudication will be successful.



              If this were not enough, on Maych 6th, 1978,



 the EPA Administrator signed the final rule for phosphate



mining BAT which sets BAT, new source, effluent limitations



 for Total Suspended Silence at 30 milligrams per liter, 30-



day average, which is identical to the BPT, and twice as
T-s-4-
                                                              33

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 ,     permissive  as  the  Florida  rule  and  totally  silent  on any



 2     other  pollutants except  pH.



 3                   In his  findings,  the  Administrator,  in effect,



 4     denied the  request for more  protective  Florida  effluent



 5     limitations, which were  requested by  certain Florida



 6     regulatory  officials, during the comment  period for  the



 7     proposed  rule;  thus,  practically assuring the success of



 8     the  phosphate  mine adjudication proceedings.



 9                   Further, by  promulgating  a  BAT rule  with



10     identical effluent limitation concentrations  of the  BPT



n     rule,  the Admistrator is saying that  the  industry  is



12     already operating  under  BAT  conditions, no  further im-



)3     provements  are  economically  achievable, which happens to



H     be in  conflict  with the  information in  the  impact  statement,



15     in my  view, and therefore  no improvement  may  be expected



)6     in 1983.



17                   It is my view  that the  scenario on which the



,8     whole  impact Uraftwoent was developed  is now Inoperable, the



19     impact statement as presently drafted is  incorrect and, as



20     a matter  of fact,  seriously  understates the environmental



2,     impact on surface  waters which  will prevail  in  the real,..



22     world  of  environmental regulation if  this draft statement



23     is adopted.



24                  As to possible inaccuracies in  the working



25     papers underlying  the statement, I  am referring primarily
                                                                  34

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 ,     to Water, Volume V, Water Quantity and Quality, Section  1,
 2     draft January  1978.
 3                   On page  1.140 the effluent  limitations used  in
 4     the projections are set out which, in my  previously «xplftirin
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 i    going to be permitted  to  discharge  in  the next  several
 2    years and  ignore  the potential  pf'»probable  discharges,
 3    which will be permitted new mines coming into the
 4                  On  page  1.144 using highly inferential
 5    assumptions,  the  working  paper  estimates the phosphorous
 6    loading into  the  Peace River by the  industry,
 7                  The industry total of  some 4,055  pounds per
 8    day does have a remarkable correlation to the EPA, February
 9    1977 study.
10                  However, little solace can be found here
11    since the  working paper attributes nearly 70 percent $f
12    the phosphorous to mines, while the empirical EPA data
13    seem to indicate  that nearly 90 percent of  the  total
14    phosphorous loading can be attributed  to chemical plants.
is                  With this anomaly unresolved, the whole
16    projection needs  review since the questions of wherfk t&tg
17    pollutants are originating can make a  profound  difference
is    in the quantification projections.
19                  On  page  1.148 we find the consultant;*8
20    conclusion that the "high nutrient concentrations are
21    indicative of runoff from the large amount of agriculture
22    in the study area."
23                  This statement is in serious 'conflict with
24    the conclusions of the Southwest Florida Regional Planning
25    Council, 208, Charlotte Harbor Water Quality Study and

                             /- 2*0
36

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      recommendations which indicate  that  "total phosphorous



2     loads  from the phosphate  industry are  presently  about



3     52  percent phosphorous  loads  from the  Peace River  and



      about  45  percent  of the phosphorous  loads  from all



5     sources to the uppermost  part of Charlotte Harbor."



6                  The 208 consultants fuxther  recommend  a



7     reduction of  phosphorous  loadings from all sources of



8     83  percent.



9                  A local independent laboratory,  using



,0     different data and  comparing  water quality  in  presently



n     undisturbed streams draining  phosphate rich land in  this



12     area,  suggest a reduction of  phosphorous concentrations



13     in  the Peace River  of 69  percent.



14                  This  is a rather fsmarkable  correlation of



15     results in view of  the  fact that entirely  different water



16     samples and methodologies were employed-«



17                  In  conclusion,  it is my  view  that  the'.impact



)8     statement has been  fatally flawed as a result  of the



)9     basic  scenario having subsequently been rendered in-



20     operable  and also the possibility of error  in  the  impact



2)     projections in one  or more of the working  papers.



22                  It  is  my  considered opinion  that the need



23     for a  new scenario has  been dictated by subsequent events



24     and that  the statement  needs  substantial revision  in order



25     to accurately reflect the real world environmental impacts
                                                                    37

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 i    that are going  to occur.
 2                  By a correct reassessment of the phosphate
 3    industry impact on the w*fcer quality of the Peace Rivet
 4    under  the current status of regulatory capabilities, the
 s    integrity of the original EIS scenario for m0re protective
 6    effluent limitations can be restored and the necessary
 7    controls on existing,, as well as new,, sources established
 e    as provided under Sections 208, 302 and 303 of the Federal
 9    Water  Pollution Control Act,
10                  Now, gentlemen, £ have almost all the docu-
11    mentation underlying this presentation here tonight, and
12    I'm available for questions.
13                  MR. TRAINA:  Thank you.
14           I'd like to ask you one, Mr. Roach, or, make a
15    comment.  I think the report does recognise the fact that
16    EPA'a  effluent guidelines are less stringent than the state's
17    effluent guidelines, and therefore, the report does recomfiend
is    for new sources, the state limits apply*
19          We do recognize the difference In Ctee two.  The report
20    is recommending that the state's limits apply.
21                  MR, ROACH:  Yes.  That's for new sources,
22                  MR. TRAINA:  Yes, sir.
23                  MR. ROACH:  But we still have the old
24                  MR* TRAINA:  We understand.  The report is
25    only addressing itself to new sources, and for those new
                                                                   38

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 1     sources,  the more stringent standards would apply.

 2                  MR, ROACH:  Thank you.

 3                  MR. TRAINA:  Thank you, sir.

 4          Any questions?

 5           (No response)

 6          Thank you very much, Mr. Roach.

 7          Dr. M.H. Bigelow?

 8     DR. BIGELOW:

 9                  Mr. Chairman, and ladies and gentlemen, most

10     of those people don't know me, and that's the hot seat; I

11     used  to sit there for four years,

12                  This is going to be a little history, because

13     I think I'm the grandfather of this outfit with respect to

14     the Charlotte Harbor.

15                  First of all, my Ph.D. is in science, and I'm

'6    a retiree of the fifth largest chemical company.  We won't

17    name names.

18                  I'm also secretary and a member of the board

19    of directors of the South Central Florida Health Systems

20    Agency, which covers the ten counties, of which a couple

21    are involved tonight, but I'm not speaking on their behalf,

22    because they have committees involved.

23                  In 1943 when I was in the Army, I was given

24    a B-25 and some men and a bunch of DDT that we had stolen

25    from the Germans  and asked to use this area as a study for
                                                                   39

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     the efficiency of DDT to take care of mosquitos and other



2    insects.



3                  And we were based at Bushnell.  We used to



     fly over this harbor at 175 feet almost daily.  You could



s    look down, and all you could see was beautiful, clear



6    water -- no slime, lots of fish, and based on that I moved



7    to Charlotte County fifteen years ago,



8                  I'm practically a Charlotte Countian, not by



9    birth, and I decided this is going to be a wonderful place



10    to fish, a wonderful place to live, and then I discovered



     that we no longer had clear water.  It was brown, but it



12    was brown originally from the tannic acid, and the fish



13    were rather scarce, and I thought it'd be a good idea to



14    try to get our harbor back up to where it was, as a fishing



is    area.



16                  And in 1970 I established what is known as the



17    Charlotte Biochem Research Laboratory, Incorporated, on



is    which board I have some very prominent engineers, Che residen



19    engineer that put a rotunda on this map, with the idea of



20    using this harbor to set up new fishing, a new fishing



21    empire, if you want to call it, bringing in new types of



     fish, not just sticking with mullet, and what have you.  I



23    wanted to get rid of the pink shrimp and get down to the



24    Japanese prawn, which don't have to go through five cycles,



25    don't have to have the black mangrove enzyme for the eggs
                                                                   40

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      to continue with their  growth.




                    So I set  up,  before  doing anything  of  the




      nature of bringing in any exotic fish,  test  stations



      throughout the harbor,  because  I realized what we  needed



      to know was the background  of this body of water,  changes




 6     in pH, changes in solidity,  changes  in  tepidity,  changes




 7     in microorganisms, changes  in the amount of  slime  that




 8     was built up,  and what  have  you.




 9                   Because without knowing that,  to try to




10     bring fish here would be trying to do something stupid



n                   I won't give you  the problems  involved in




12     trying just to maintain a dozen stations for testing.



13                   The state wasn't  very  cooperative.  The



      local people liked to steal  my  markers, because I'd have



,5     a  special kind with sea lamps on, but the thing that



16     bothered  me more than anything  else  was the changing



17     characteristics of this body of water.




is                   And we  are at  a point  right now, with  our



      Charlotte Harbor, that  reminds  me of the situation that



20     it must have been like  when  this world  started creating




21     life  --a large body  of protein soup ija which nothing was




22     living, but something came along --  maybe the clouds



23     separated and  a light ray came  through  -- and catalyzed




24     activity.



25                   And right now,  as far  as  I'm concerned,



                                                                  141

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     this Charlotte Harbor here  — what  is  it,  163 square miles



     of water?  --  it's just  that; it's a  protein soup, and  I




     am worried  to death  that something  is  going to come along




     and almost  overnight catalyze the activity of this harbor




     into the growth of materials that we do not want.




6                  Now, it doesn't take  very much.  Now, in toy




7    studies —  of course, I ran studies  on trace elements, and



     what have you -- it  doesn't take very  much to do this.



9                  For example,  in the dental profession right




'0    now they have a mixture of uranium methacrylate, a solution,




     which they  can put in your  tooth for a filling, and it




12    only takes  one wave  length, 474 nanometers, to catalyze




13    that into a high solid.  Nothing, either side, will change



     it.



                   And one little thing  --- I'm not going to




16    point the finger at  the phosphate people or the people



17    whose septic  tanks run  into our harbor out here or the



18    people that come into our place and  put chemicals in




19    all of our  canals to get rid of phyceae.



20                  Somebody  one of these  days is going to put



21    that catalyst in, and it's going to  make the red tide that




22    we see out  in the Gulf, which is due to iron, it's going



23    to make that  look silly compared to what is going to




24    happen in this harbor.



25                  I don't want to be an alarmist, but I — I
                                                                   42

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 i      have  stopped.   I'll work out  there*
 2                  After December  1971 when I couldn't  find
 3     my  samples  anymore because they were all sludged in under
      phosphate spills ---
 s                  But I just  would like to have  the people
 6     that are. engaged in all this mining up here, all these
 7     chemicals,  and  the people that come around here and treat
      our roofs with  chemicals, knowing it's going to run off
 9     in  the water, to keep  in  mind  somebody one of these
10     days is  going to put the  catalyst in that water.
                   Thank you.
12                  MR. TRAINA:   Thank you very much, sir.
13           (Applause)
                   MR. TRAINA:   S.R, Stedrattn?
15     MR. STEDMAN:
16                  I'm the  president of the Venice Area Audubon
i?     Society, and I've got  a few things here that strike me as
is     a little bit peculiar.
19                  You have several alternatives considered,
20     When you have an alternative,  you use one or the other,
21     but now  it  seems to me B  and C are to be combined, instead
22     of  ---
23                  In other words,  if you use B, then you can't
24     use C.   If  you  use C,  you can't use B.
25                  It seems to me that ought to be one alternative
                                                                   43

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      instead  of  two.




2                  MR. TRAINA:  Can you reference that, sir?




3     I  don't  know  exactly what area you're  talking about.  Maybe




      Mr. McNeill can clarify that.




                   MR. MCNEILL:  I think I can clarify your




      comment  for Mr. Traina anyway here.




           Mr. Traina, what he's saying is, under the alterna-




e     tives considered, we have listed the scenarios that were




9     looked at throughout the study, and we had six scenarios.



10          Let's see, are you talking about this?




11                  MR. STEDMAN:  No, I'm talking about B and C.




12     I  don't  see why they should be two different ones.



13                  MR. MCNEILL:  Okay.  Let me go ahead and




14     finish what I was saying.



15          We did not select one of those six scenarios to



16     become the  basis of the impact statement.




17          What  was finally selected was a combination 	




IB                  MR. TRAINA:  That's what I thought it was.



19                  MR. MCNEILL:  -- of, realty, the four middle




20     scenarios,  and I think	




21          Does  this help some?




22                  MR. STEDMAN:   All right, yeah.




23                  MR. MCNEILL:   You're right; your comment was



24     right.   We  didn't select one alternative.  We selected a



25     combination of alternatives based on what were the best
                                                                   44

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 6





 7





 8





 9





10





1 1





12





13





14





15





16





17





18





19





'20





21





?2





?3





24





25
aspects of each of the scenarios.




              MR. STEDMAN:  All right.



              MR. TRAINA:  So they were combined, sir.




              MR. MCNEILL:  They were combined, right.




              MR. STEDMAN:  Well then, you know, Ifm



looking at this chart you have here showing the phosphate




production, and you have said an awful lot about the




economics of it, and of course economics are very important




to this region.




      But we have our curve going up and then down again.




      Why couldn't it have been a straight line curve or



a straight horizontal line?




      My idea is when one phosphate mine is used up, open



up another one instead of piling them all on.



      Now, at the end of all this phosphate mining you're




going to have an awful drop in the economy.  At least this



way, if you had straight production, you would extend the



production over a longer period.




      Now, there's' a statement in here also about it's




uneconomical to extract fluorides.  I think that's entirely




beside the point.



      It's uneconomical to extract fly ash in a coal burner




from a stack that burns coal, but it has to be done.  I




think fluorides have to be done, whether it's economical




or not.
V*" 7
                                                                   45

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,           And  there are a couple  of  places  in  there where you
2     mention  the  information  isn't sufficient to  make a con-
3     elusion.   Then you make  a  conclusion, but  it's always in
4     favor of the  phosphate people.
5          That's  all  I have  to say.  Thank  you,
6                   MR.  TRAINA:   Thank you very  much, Mr. Stedman.
7          (Applause)
8                   MR.  TBAINA:   Samuel Wapner?
9     MR. WAPNER:
10                   Members of the  board, my  name  is Samuel
11     Wapner,  and  I speak as a citizen and resident newly
12     arrived, who  came  into Florida about the middle of November
13     of  '77.
14                   I feel rather humble in following Dr. Bigelow,
15     because  I  know something about his background, and also I
,6     must say I don't  know whether my voice  is  carrying or QO*: --•
,7                   MR.  TRAINA:  Yes,  it is.
18     MR, WAPNER:
,9                   I have not attended previous meetings; there-
20     fore I'm not  in a  position to comment on your impact
21     statement, which  is very comprehensive  and would require
22     quite a  bit  of study and reading and review by me before
23     I could  properly  make the  sort of statement that I'd like
24     to  make.
25                   In  lieu of that, would I  be  permitted to make
                                                                   46

                              /- \4o

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 i    some general  observations?



 2                  MR. TRAINA:  Certainly, sir.  That's the



 3    reason for the meeting tonight.  I might also add if you'd



 4    like to take  some time later, we will be receiving written



 s    comments after this meeting.



 6          I'll tell you later, I'll tell everyone later where



 7    to address those written comments, but certainly we would



 8    like to hear  general observations,



 9                  MR. WAPNER;  The first question I'd like to



10    ask, since all of my information is based on what I've read



11    in the newspaper, is it a fact that Florida has resources



12    of phosphate  calculated on a world basis of somewhere



'3    between 2 and 4 percent?  And yet our industry is producing



14    approximately one-third of the world's output of phosphate.



is          is this a fact?



16                  MR. TRAINA:  I don't know whether we're in



17    a position to comment or answer your question, sir.



is                  MR. WAPNER:  Am I In the ball park?  Is this



i?    more or less  generally so?



20                  MR. TRAINA:  I think Mr. Stowasser will have



21    to comment on that.  Mr. Stowasser has some information on



22    that.



23                  MR. STOWASSER:  Mr. Wapner, we estimate that



24    We have in the United States perhaps 3 and a half to 4 billio^i



25    tons of phosphate reserves at today's cost and selling prices
                                                                    47

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            I don't have a crystal ball clear enough to tell



2    you what  the cost and prices will be in the future.



3           However,  I would expect that these reserves,



     economic  reserves, will  increase in the future.



                   MR. WAPNER:  Well, unfortunately, you've



     not answered my question pointedly.  What I'm trying to



     arrive at is what reserve do we have here in Florida



     compared  to the world reserve?



9           Now, I know that economics are a very important



10    part,  and I'll  come to that in just a moment.



n                  MR. STOWASSER:  To be more specific,



12    economic  reserves today  are estimated somewhere 1.5 and



13    1.7 billion tons in Florida.



                   MR. WAPNER:  Well, this still doesn't give



is    me the picture, so I'll  have to make an assumption, rightly



16    or wrongly.



17                  MR. STOWASSER:  Mr. Wapner, we may have



     anywhere  from 20 to 30,  that broad a range, of economically



19    attractive phosphate reserves in the world.



20           There's no one who knows the answer to that question.



21    We'd like to know the answer as well.



22           There's a great deal of material, and it probably



23    will be developed as time goes on.



24                  MR. WAPNER:  Well, what I'm trying to say



25    is that with a  limited amount of phosphate reserves, we
                                                                  148

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 i     are producing, in my opinion,  too much,  and we are



 2     following the route of the petroleum industry, which,



 3     in my opinion -- remember I'm  expressing an opinion  -- I



 4     think we are following the route  of  the  petroleum



 5     industry which, with the  encouragement  of the  automobile



 6     industry, produced in great abundance.



 7           We had cheap petroleum products.   We use them, not



 e     only for automobiles, but also in the chemical industry,



 9     and now we find ourselves more or less at the  mercy  of



10     certain foreign nations who raise prices in not the



n     customary business-like fashion,  but at  one point I



12     think they jumped prices  approximately 400 percent.



13           Now, if our reserves in  Florida dwindle  so  low



14     that Morocco or some other country can act in  a fashion



15     similar to OPEC,  I think  we are defeating our  own pur-



16     pose,  but we'll come to that a bit later if we're talking



17     about  money.



is           Before I came to Florida, I was a  resident  of New



19     Jersey,  which is  unfavorably referred to as  the cancer



20     state,  and perhaps some of you folks have read about the



21     recent incident at Rutherford,  where they're finding aa



22     high incidence of cancer  in young children,  a  most dread -



23     ful situation.



24           In the neighboring  state of New York,  there is a



25     county  —  its  name escapes  me  at  the moment  since New York
                                                                   49

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     State  is a rather  large  state  -- but  in  this  particular



2    county,  they have  a  large  deposit  of  radioactive rock,



3    and  unfortunately  in that  particular  county  there's a



     very high incidence  of,  shall  we say,  defective children.



5           I  speak  on behalf  of no  organization,  but for



6    myself.  tto.f6rtunately,  I  am the father  of a retarded



7    daughter, so this  rather hits  home, when for one reason



     or another a so-called defective child is born, which



     is both  a burden to  the  family in  many ways  and also



,0    to the community.



n           Now, when we come  down to the question of economics,



12    I have seen formulas  that  state one has  to offset



13    tourism  and agriculture  versus the income which comes



14    from the phosphate industry



15           Now, please  understand my position.  I'm for free



16    enterprise.  I worked in industry  for  many years, and I



17    approve  of our current manner  of doing things in general,



18    but  it seems to me that  this particular  formula is lacking



     one  very important element.  Tourism plus agriculture is



20    not  the  total  side of one  formula  in the equation.



21           To that  one must add new residents.  Now, who will



22    these  new residents  be?  By and large, retirees, many of



23    whom are rather vulnerable  to  cancer,  and I  speak whereof



24    I know.



25           In addition, we have young couples who are just
                                                                   50

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 i     beginning  to raise a  family.  A pregnant woman, again, is



 2     very  vulnerable  In that either she or her offspring might



 3     produce an undesirable characteristic.



 4          Therefore, I say to you, as a new resident, In



 s    weighing the advantages of the phosphate industry, and I



 6    don't waut to belittle their contribution in the past,



 7    and I don't want to eliminate them, either — I say to



 a    you let us take a balanced view in promulgating new



 9    regulations in enforcing these „



10          As our commissioner said, without enforcement,



n    you're absolutely nowhere.  You can have the best laws



12    on the books, but unless you have properly trained



13    personnel who will enforce these statutes, you are



u    nowhere at all.



is          So J, close by saying I'd like to have this particular



16    group, in reviewing the whole question, take a rather



,7    balanced point of view of this most serious question.



18          Thank you.  I have no prepared statement.  This was



19    spontaneous.



20                  MR. TRAINA:  Thank you very much, Mr.  Wapner.



21    We appreciate your coming forward.



?2          (Applause)



23                  MR. TRAINA:   M.W. Chesson?



24    MR. CHESSON:



25                  Mr. Tralna, members of the panel, my name is
                                                                   51

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     Maywood W. Chesson, Jr.  I was recently employed by




     Mississippi Chemical Corporation as Manager of Phosphate




     Project Development, and am in the process of changing my




     residence from Lake City, Florida, to Wauchula, Florida,




     in Hardee County.




                   Mississippi Chemical Corporation is a




     farmer-owned cooperative based in Yazoo City, Mississippi.




     Our principal business is manufacturing and distributing




     fertilizers to approximately 250,000 farm operators




10    located largely in the southeastern states.




11                  Mississippi Chemical Corporation's major




12    production facilities include nitrogen plants in Yazoo




13    City, Mississippi, and Donaldsonville, Louisiana, potash




14    mines and beneficiation plants in New Mexico, and in




15    Pascagoula, Mississippi, a large phosphate rock processing




16    plant with associated granular fertilizer facilities to




17    prepare the final products containing NPK-nitrogen,




     phosphorus, potash, as required by our farmer-owners.




,9                  A few years ago, Mississippi Chemical became




20    gravely concerned about a secure long term supply of




21    phosphate rock,,




22                  In 1975 MCC arranged to acquire a large




23    phosphate deposit on some. 14,800 acres, just west of




24    Wauchula in Hardee County«




25                  Since that time, we have been involved in
                                                                   52

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      appraising the deposit,  evaluating various  mining and




 2     beneficiation processes,  assessing environmental




 3     matters,  pursuing permits, and worrying  about  economics.




 A                   We find  many alternatives  with some



      fascinating features,  but when the bottom line reads




      higher cost,  without compensating benefits  in  the pro-




      duction of food and  fiber, we  must restrain ourselves.



 a                   Unless something of real value is  obtained




 9     when we expend labor,  resources,  dollars, we contribute



10     to inflation  which many authorities consider to  be our



11     gravest threat today.




12                   MCC's phosphate  development is a new source.




13     Consequently, the  areawide EIS has been  viewed with much




14     concern.




is                   We recognize the objective is to determine



16     and  appraise  the effects  of  the phosphate industry's



17     southward  movement on  a seven -county area and  on a



      cumulative basis.




19                   We appreciate  the importance  of  the study,



20     but  have been very apprehensive about the findings because



21     of the great  complexities of the  study.




22                   Mississippi Chemical Corporation is a




23     member of  the Florida  Phosphate Council and supports the




24     council's  observations and comments, which  you heard last




25     night,  and which will  be  supplemented later in the written
                                                                   53

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 i     record,



 2                  Nevertheless,  there  are  several  points which



 3     warrant  specific  comment as  they particularly  concern MCC:



 4                  First,  an areawide study covering  some 3.5



 s     billion  acres in  a  period  of time  greater  than a hundred



 6     years causes one  to lose perspective  for a  specific



 7     15,000-acre site  and  what  to do now.



 8                  We  urge that no action be taken  as a result



      of  the areawide EIS  that will prohibit proper  action on



10     a specific site at  a  specific time  following a thorough



u     study of the then available  and discernible alternatives.



12                  One thing we can place great confidence on



13     is  man's  ability  to develop  new and better ways  to



14     accommodate his changing desires.



is                  Until the specific site  effects are



16   .  determined and evaluated, none of  the  alternatives should



17     be  obviated or restricted.



is                  Areawide  EIS findings and recommendations



19     should be set forth as  guide  posts  fior future  site



20     selections, not prohibitions  or prerequisites.



21                  Second, elimination  of dryers may  be a



22     meritorious objective under  some circumstances, but it



23     could be  unwise to  limit the  determination on only the



24     energy of transporting  water  in wet rock versus  energy




25     for drying.
                                                                   54

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 i                   There are  many  other very  important



 2     considerations  that also concern energy.  For example,



 3     introduction of additional water in chemical plants with



 4     wet  rock where  climatic  and process conditions require



 5     it to be chemically treated and discharged can cause



 6     very serious  effects and consume a lot of energy.



 7                  Also, adverse effects on chemical processes



 8     can  result  in higher raw material losses, which consume



 9     a lot of energy.



10                  Again, specific cases should be determined



n     on factors  relating to that specific case, using the



12     areawide findings as guide posts.



13                  Third, elimination of above grade clays



u     storage.  A great amount of knowledge has been developed



is     in this  subject during the past few years, but often,



16     as our base of knowledge broadens, our rate of learning



17     is increased.



is                  Future decisions and actions should be



19     based on an evaluation of all known alternatives in the



20     light of knowledge existing at that time.



21                  Certainly, no one wants to create earthen



22     dams  simply to store semi-fluid clays at super elevations,



23                  It has been done only because it was the



24     best available alternative at that time.




2s                  We are learning to reduce the hazards of
                                                                   55

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      doing that,  and  we are  learning also how to  evaluate  the




      overall effects  of disposing the clays  in that  manner.




                    Some of these effects  may be very valuable




      when we learn how to  quantify them.




                    I'm not defending and  trying to say  that




      storage of clays above  grade is the  only way.   I just say




      that is an alternative.




                    Also, we have other alternative disposal




      methods that are being developed that are, as yet,  largely




,o     untried but  appear very  promising.




,,                   I  urge  you not to close out any alternative.




      Elimination of above  grade  clays storage is highly  de-




13     sirable, but simply may  not be  the best alternative for




14     some site  not  yet defined.




                    Fourth, wetlands .   A phosphate rock miner




u,     prefers to mine  high, dry,  sandy ridges.   The wetlands




      are  much more  trouble, causing  the cost of removing




18     phosphate  lying  thereunder  to be greater .




19                   But phosphate  can  be recovered only from




20     where  it is.   To leave it may cause an  irreversible and




21     irretrievable  loss of a  valuable resource.




22                   The  magnitude  of  this  loss  must be weighed




23     against the  value  of  the wetlands to  be  disrupted.  Each




24     specific site  must be studied thoroughly, and all the




25     pertinent  facts  considered,  including the  phosphate values,
                                                                   56

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      the wetlands values, the restoration alternatives, and




      then determine the proper course of action.




                    I think in that matter we agree, and on




      that I really close, with the caveat that,  while these




      remarks reflect some of our immediate concerns, MCC must




      reserve the right to comment upon any aspect of the




 7     areawide EIS during site-specific EIS reviews.




 B                   I thank you for considering our points  of



 9     view.




10                   MR. TRAINA:  Thank you, Mr. Chesson,,   Let



ii     me just comment,  because this bothered me last night.



            I think Mr. Hooks raised it;  I think  it was  raised



13     the first night,  while certainly this is  an areawide




14     document addressing general issuance, it's  the intent



is     of EPA to use this in a very specific manner when  it




16     begins to issue permits.




            And I think to say otherwise  would  be misleading



is     the industry and  misleading everyone else here.  We



19     understand thatywhen we look at  a specific  project, we're



20     going to have to  make some  choices  here,  but things  like



21     elimination of rock drying  and elimination  of slime  ponds




22     is something that the Agency's going to implement  through




23     all the processes, enforcement and  regulatory processes




24     it has «



                    This is just  not a report that's going  to
                                                                   57

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      look nice some place.  This  is a report that is intended




      to be  implemented by the Agency.




            I just wanted to make  that comment, so that you



      all understand that while we look at these things on a




      case-by-case basis, certainly the recommendations on




      this document are going to be implemented within the




      regulatory structure of EPA.




            Thank you very much, Mr. Chesson.




 9                  MR. TRAINA:  Jim Kelly?



10     MR. KELLY:




11                  Mr. Chairman, Jim Kelly representing the




i?     Charlotte County Conservation Council.



13                  First I'd like to say that we are very




u     proud  of trying to maintain high environmental quality




15     in Charlotte County.



16                  The Charlotte County Conservation Council,




vi     with the aid of our Charlotte County Commission and our



IH     City County, our City-County Planning Council,  our local



19     legialative delegation,and working with the Department of




20     Natural Resources, for some five years,, we've recently




21     completed state acquisition of approximately 20,000 acres




22     of marshlands in Charlotte Harbor.  Basically,  we're




23     talking about the beautiful, undisturbed shoreline from,




24     more or. less, Highway 41 bridge on west and south to the



      county line.
                                                                  58

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                     So we  do  feel  that we  do have  something



 2      to be  proud  of, and  we  are concerned about the harbor.



 3      We feel  it  is  probably  the finest  eatuarine  system  left



       In Florida  :i.n  productivity and absence of damage.



                     You  just  don't get that many miles of



       natural  shoreline  In many places anymore.  We're talking



       about  close  to 30  miles  of natural mangrove  shoreline.



                     On the other hand, as  Dr. Bigelow pointed



       out tonight, he said he's lived here for fifteen years.



10      Well,  I've  lived here forty-four years, and  I can see



n      the water quality  degrading in the  harbor in spite of



12      the protection of  the natural shoreline.



n                    When I was a little  younger than I am



M      now, we  had  a  pier in the harbor in  the Peace River,



is      and I  can remember in the spring of  the year walking



16      out on that  pier and the water quality was so good in



17      the spring,  before the rainy season  started, it was so



IB      clear, you could see the stripe on a snook's side in



19      five feet of water,  and now you. can't even see the



20      snook.  In fact, now you can't even  see the bottom.



21                    So water quality —



22                    MR.  TRAINA:  You're  still catching snook?



23                    MR.  KELLY:  Well, yeah, we catch some, yeah.



24      We  give  it the old college try there.



25                    But  water quality has  — We are concerned
                                                                   59

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     about it.  We are naturally concerned about what




     happens in the upper Peace River and possibly what will




     happen in the future in the Myakka River when new plants




     or activities could develop, because, of course, what




     happens up there goes into Charlotte Harbor and affects




     us.




                   And as Tiny Johnson with our City Council



     brought out tonight already, according to the 208 study,




     why, about 85 percent of the major pollutants in. Charlotte




]0    Harbor right now are coming from up river.



                   So we are concerned.  Our primary concern




)2    in Charlotte County, as far as the phosphate industry



     is concerned, is water quality.




]4                  Of course, the things that Mr. McNeill




15    brought out tonight in the proposed actions, we would



16    certainly endorse these recommendations.



17                  We're certainly for anything that would



)8    eliminate or drastically reduce the possibility of




)9    degrading the environment through phosphate spills or



20    phosphate accidents or any other kind of activity.




2)                  So we are certainly in favor of these




     recommendations that Mr. McNeill pointed out tonight.



                   It only makes -- and this is something




24    that's been brought out earlier, but I think it's note-



25    worthy, bringing it up again -- it only makes common sense








                                  A i s-4
60

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 i     to have  existing  operations meet all air  emission  and

 ?     water  discharge requirements  listed for new  sources

 3     by 1983  as  is recommended  on  page  1,74, paragraph  2.a.

 4     in your  draft.

 s                  And of course,  you've said  tonight that

 6     in some  cases maybe the state requirements are already

 7     more stringent.  Well, in  that case, naturally, the

 8     more stringent regulation  should apply.

 9                  But we are in favor  of incorporating

10     these  requirements by 1983 as your draft recommends.

n                  Furthermore, it makes no sense to have

12     rules  and regulations if they aren't carried out.  We

13     would  highly recommend that a very active monitoring

14     program  be  initiated in all streams involved with

is     phosphate industry discharges, as well as bays and other

16     bodies of waters that these streams might flow into.

i;                  We would like to have an active monitoring

IB     program  in  the harbor itself, as well as Peace River and

19     Myakka River.

20                  °n page 4.5  it  states "Make unannounced

21     inspections of company dams and company maintenance and

22     inspection  program to see that they comply with DER

23     Chapter  17-9 requirements."

24                  There again, this is just good common sense.

„     May  I  put  it  on a personal basis  for a  few minutes.
                                                                    61

                                  t-l S-JT

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                   We own a hotel, and we have a dining room

     and a kitchen, and we don't object to the hotel inspector,


     restaurant inspector, health inspector, coming out and


     making an unannounced inspection of our dining room or

     kitchen.


                   We feel that's in the best interests and the


     psychology of it	That is really the only way to get


     the proper results.  We never have had a health inspector


     phone me the day before and say, "Hey, Jim,  we're going


10    to have an inspection tomorrow.  You better  get the open

     metal cans out of your refrigerator and put  them in some


     other container, non-metallic container, or  ypu better


13    make sure you've got thermometers in all your  refrigerators

14    and the thermostats read 140, or you better  make sure


is    there's no dirt in your meat slicer."

i6                  We never have had them do that to us,  and

17    we don't feel that we're being harassed, so  we 	


,8                  MR. TRAINA:   Mr. Kelly, that certainly is


,9    an enlightened attitude on that*  I really appreciate

20    hearing that as an enforcement official.


21                  MR, KELLY:   So we don't feel  that the

22    phosphate industry would be being harassed  if  unannounced


23    inspections took place.  In fact, that is the  only way

24    to have the psychological impact there so everybody's  on


25    the ball all the time, so we would highly recommend  that.
                          '                                       62



                                /- zrc.

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      This  is  in the  best  interests  of  public health  and




      environmental quality.



                   In  closing, we'd like  to say  that we




      certainly, and  I  don't mean  to imply  that we are



5     picking  on the  phosphate  industry, per se;  we all



6     realize  we need phosphate for  food production,  and so




7     forth.




                   However, as I brought  out, we highly




      endorse  and are in favor of any recommendations pre-



10     sented in  this  draft that would eliminate or cut down




n     the possibility of environmental  pollution, whether it



12     be phosphate spills, slime spills, or pipes breaking



13     or whatever, because, as much  of  us in the  seven-county



14     area  know, we have had quite a history of these mishaps.



15     In fact, we've  got quite a little information on it.



16                  So  in closing, we'd like to say that




      maintaining a good environmental  quality is good business



IB     for all  Florida.  We should all be interested in it.



19                  Thank you,,




20                  MR. TRAINA:  Thank  you very much, Mr. Kelly.



            (Applause)




?2                  MR. TRAINA:  David Wilson?




23     MR. WILSON:




24                  I'm David Wilson.   I'm president  of the



25     Peace River Audubon Society, which is located  right in
                                                                    63

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     Punta Gorda.  It has members from Charlotte and DeSoto



2    County.




3                  The most recent phosphate mine that I can




     see is Mobil Oil Company digging right up to the road




     three blocks from the southern residential section of




     Fort Meade  in southern Polk County.




                   This area used to be a  lovely oak hammock



     with trees, some fifty to seventy-five years old.  I think




     it's one of the last in this area on Highway 17.




10                  Homer, this is very bad PR.  I'm talking to



     Homer Hooks.




12                  I kind of feel like the lorisch in Dr.




     Seuss.  Our proposal is for another means of reclamation



14    of mined land, other than pasture land.




15                  Before the mine is mined, I believe that



16    the top soil should be stripped off and set aside, and




     after the mining, the land should be filled in and then




is    the set-aside top soil should be put back.




19                  And guess what I'm going to propose gets




20    back on it?  Then, instead of grass, plant native trees




21    and shrubs.  Pine would be a good start, and phase in




     the laurel and live oak, and let Mother Nature do the



     rest.



                   I mentioned this to you before,  now, Homer,




25    and you're going to hear it again.







                                 t-is-8
64

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 i                   Thank you very  much.




 2                   MR.  TRAINA:   Thank you very  much.




            (Applause)



                    MR.  TRAINA:   Robert M.  McQueen?




      MR.  MCQUEEN:



                    Homer does know that at the  end  of  the




      Peace River,  there is  salt  water, Homer.   It's not all




      fresh.



                    Listen,  I would just like  to briefly say




10     that it  has  definitely been an educational experience




      working  on this study, and  I  am very  pleased at the



12     professional  capabilities and credentials  of all  the



13     people we've  had  to work with from TI, all the way to




14     the  Agency.



is                   A couple of comments, just kind  of  in




16     summary,  is we are concerned  about the water quality




17     down here; not only is the  Peace  River a regional




is     drinking  supply but a  supply  for  DeSoto, Charlotte,



19     Sarasota,  Boca Grande  area, which is  our prime concern.




20                   We feel  that  the water  quality issue




21     primarily  should be addressed in  our  208 plans, which




22     are  contracted from EPA to  our regional planning council.




23                   The  Central Florida Regional Planning




24     Council did not address the Peace River in their 208 plan.




25     We feel that  it should be done.
                                                                    65

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                   On  the  other  one,  on you, Marvin, I

 2    personally  feel that  DER has not  done  their job on

 3    revision of 17-3.   It's been going on  for  years and

     years and years,  and  it looks  like it  will be going

     on  for years and  years and  years, on the reclassification

     standards,  on the new standards  of classification of

     not only the harbor,  Class  2,  Class 3  waters, but the

     Class 1 waters  for  a  potable supply.

                   So  you  can pass  that on  to your boss that

10    we  have been pushing  it down here.  I  know that there is

11    a hold-up;  it's a very controversial issue, but we feel

i?    still that  somebody's going to have to make a decision

13    sometime, and we would like to urge that DER press for

     this decision by  the  commissioners„

15                  On  the  water  quality aspect, the runoff

16    from the streams  is also a  management  responsibility of

17    the water management  districts.

is                  We've been pointed  out here  that SWFMD

19    and the water management districts were supposed to have

20    been on this advisory board, an<3  I would like to make the

21    comment that, of all  the meetings that I have been to --

22    now, if I'm wrong, someone  correct me  — I have not seen

23    the first representative from  a water management district.

24                  They  not only are  involved in the consumptive

25    water use permits,  but by the  ruling of the Attorney General
                                                                   66


                                 /- 2 C, O

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i      of  Florida,  they are also  to be  involved  in water quality.

2                  The  district  permits on consumptive water

3     use permits  must take  into  consideration  water quality.

4                  Mining in  the wetlands, the definition  of

5     the three categories of wetlands.  There's one little

6     statement in there on Category 3 wetlands, which states  --

7     I'm sure  it's just an oversight or something -- Category 3

8     wetlands have insignificant hydrological  functions.

9                  There may be a degree of significance, but

10     I don't think the  statement "insignificant" to me —

}}     This  is improper and incorrect.

12                  The existing sources of mines have a greater

,3     total effect on the Peace River Basin than all of the

14     new sources  that have been proposed, so we're concerned

15     here that 	 It's not what's coming on the linej we

i6     feel that that will be regulated, but it's what's already

17     there that's going to continue to affect us down here, not

IB     only in water quantity and quality, which are prime

19     considerations down here.

20                  The running-stream communities we are very

21     much interested in.  Page 2.56 states " — the running-

22     water communities,  streams and rivers, will experience the

23     greatest effects from phosphate mining activities ."

24                  By the year 2000, 76,600 acres will be mined

25     in  the Peace River  Basin alone.  "This magnitude of activity
                                                                   67

                                /-*«/

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     will measurably affect runoff  patterns and  flow




     regimes of headwater streams within the Peace River."




                   Now, this was quoted out of your study.




     And we have some questions that we'd like to throw back




     to Gene.




                   Are these decreased runoff figures stated




     based on annual flow, peak flow, or at low  flow periods?




     And we think it should be clarified, because if they are




     at low flow periods, then it could reduce the flow in




]0    some streams and creeks by as much as 30 percent.




n                  So if you would just 	




1?                  MR. TRAINA :  Gene, do you know the answer




13    to that?  Do you want to comment on that?




                   MR. MCNEILL:  I'm sorry, I don't right now,




,5    but we will	




16                  MR. MCQUEEN:  Gene, what has come up is




17    some of the information, like you pointed out the other




)8    night, that it ended up in the draft EIS and was not in




)9    the working papers.



20                  And when we go back to try to find the




2i    information in the working papers -- like you said the




     other night, it has been revised and you're going to




     revise your working papers --




24                  MR. MCNEILL:  Right




25                  MR. MCQUEEN:  -- and it was not clearly stated
                                                                   68

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i      in  this document.


2                   MR. TRAINA:   I think it'll be addressed


3      in  the final document.                                        !


4                   MR. MCQUEEN:  Yes, sir.  So we just would


5      like  for you to clarify that fact.                           j
                                                                  i
                                                                  i
6                   Also, on these same lines, we feel this


7     document, or I personally feel this document is not


8     adequately addressing the impact on the retaining water


9     requirements for the ten and twenty-five-year rainfall


10     requirements on the amount  of water to be withheld.


11                  We feel that  it should also address the


12     total number of acreage that you're going to impound


13     here, you know.  This sounds good on the surface, im-


14     pound and retain this much water, but I'm not sure


is     that we aren't doing more harm than good by retaining


16     thousands of acres of water that should go into a runoff.


17                  So let's look at the amount of water,


is     how much cubic -- or flow or surface acres, or however


19     you want to measure it, that we're talking about, because


20     it is a significant area, and this not only pertains to


21     new sources, new sources you're going to a twenty-four-hour


?2    rainfall in a twenty-five-year period; on existing you've


23     proposed it on a ten-year period.


24                  So it's not only going to have an effect


25     on the new ones but also the existing ones and, you know,
                                                                   69


                                 A

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     if it rains in Polk County, we'd like to have some of




2    the water eventually end up down here, and it could have




3    some adverse effect on our flow pattern.




                   We also wish to emphasize on site-specific




     EIS's that these questions be addressed in more detail,



     and also, another thing is all of this stuff is worthless




     if it's not adequately and properly monitored.




8                  Our other prime consideration is the effect




9    of mining on the Peace and the Myakka River basins, which




10    we have now on the Myakka -- the effects on the Charlotte




n    Harbor estuarine system, which has  previously been dis-



12    cussed here tonight.



13                  So with all of these, our whole philosophy,




     I think, here in Charlotte County,  and you know,  we aren't



     asking you not to do something that's unreasonable.



16                  I'm in the ranching business, and no one




     more than myself knows that we need phosphate.  I bought



ift    a lot today; Homer didn't send it down to me for  nothing,




19    so I know that we do need it.



20                  So I think, to kind of summarize our philosophy)



21    down here is we have a dependency on the fresh water, on




22    the harbor estuarine system, and the people from Polk County




23    and Hardee County, from DeSoto County, love to come down



     here and get the oysters.  They love to come down here and




25    fish, and they love to do all these other things, and we're
                                                                   70

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     all basically in the same system.



2                  I think if we just kind  of look at it  from



3    the Golden Rule, you know, do,unto others  as  you would



     like to have them do unto you,  don't do anything upstream



     that you wouldn't want us doing down here.



                   So in light of that, I think we just kind  of



     take that approach.  I think the report is very  good.  It



s    has some very good ideas in it, true.   You can pick  any-



9    thing apart.  If you get a document and you give/.lp,000



10    people a chance, everybody can  pick one sentence they



n    don't like.



                   I think basically it is  a good  document,



13    and hopefully something we can  live with.  It does,  as



14    I've seen in the last three hearings,  there are  things



is    pointed out, I think, that a little clarification is



16    needed to be made on the document,  but basically I think



17    it is a very good document.



is                  And that's all I  have to comment on that.



19                  Mr. Stowasser, one other comment,  that I would



20    like to comment on, the gentleman  had  a while ago.  He



21    asked you a question on the  Florida reserves  in  comparison  to



22    the world reserves, production,  and also what percentage



23    of reserves we have.



24                  On page 1.23,  the  statement  is  made in there




?s    that we are producing 80 percent of the US production and
                                                                    71

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     33 percent of the world production in 1976, and I have




     been made to believe, through this two-year course of study,




     that Florida does only have between 2 and 4 percent of




     the total known phosphate reserves in thewrld.




                   MR, STOWASSER:  Well, all I can do is



     give you the latest information that we have.




                   MR. MCQUEEN:  Yes.  Well then, this document



     should be corrected and updated if your figures are not




     true.




10                  MR. STOWASSER:  This changes every six



11    months as more information is acquired.  We can update




12    the document.



,3                  MR. MCQUEEN:  All right, sir.



,4                  MR. STOWASSER:  Yes.




,5                  MR. MCQUEEN:  All right, sir.  I think you




16    should, because it was pointed in there, it was documented,




17    and it was dated, and that was my belief also on these



is    figures, so you know, I realize that as new technology




19    comes on and new reserves are discovered, etcetera, so ---



20                  That's really all the comments I have to



21    make, and we really enjoyed having y'all come to Punta




22    Gorda.  I know you couldn't even spell it before you came




23    down here.



24                  MRU TRAINA:  John Hagan was sure that I could




25    spell it and pronounce it.
                                                                   72

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                   MR. MCQUEEN:  John taught you how.  So listen,




2    I've enjoyed working with the advisory committee and with




3    EPA, TI, Larry and his people, and if you have any ques-




     tions or if there's any way we can assist you, I think



     you pretty well know what our concerns are down here,



6    being that we are at the end of the two basins, and we




7    do have concerns over the water, primarily, the water



     quality and quantity.




           Thank you.




10                  MR. TRAINA:  Thank you.



11          (Applause)



12                  MR. TRAINA:  I think Mr. Hagan ---



13                  MR. HAGAN:   I'd like to pursue one point.--



                   MR. MCQUEEN:  Yes, sir.




is                  MR. HAGAN:   -- that you mentioned there.



16    You mentioned that D and  R,  or, DER,  I guess, has  not



17    aggressively pursued the  reclassification of water.



is                  MR. MCQUEEN:  I did not specifically  say  the




19    reclassification request.  I said the re-writing of 17-3,



20    because they aren't going to do anything on any reclass -




21    ification until after they have re-done 17-3, and  this has




22    been going on	.It'll be three years in August this has



23    been	




24                  MR. HAGAN:   What is the objective here in




25    doing  the  revisions  of the standards  and then doing the
                                                                   73

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     reclassification.   I mean, what  is the county's objective



     in aiming  for-a revision?




                   MR. MCQUEEN:  Okay.  We have never made a




     request for any revision to 17-3.  This came, evidently,




     from the commissioners, or the man out in the hall will




     have to answer that question for you.




                   Our request down here was, number one,



8    water classifications are based  on usage.  This is the




9    only body  of water now, I think  -- Marvin, correct me




10    if I'm wrong -- in  the State of Florida that has been




n    permitted  to be used for a potable water supply that  is



1?    not Class  1 waters.




                   There were a couple of others; the DER




     came in	



15                  MR. HAGAN:  You're talking about the Peace



16    River potable water?




17                  MR. MCQUEEN:  Peace River, right.  For a



18    regional water supply, they have received permits from




,9    the Department of Health, from DER, from the Corps of



20    Engineers, from all permitting agencies, for a regional



21    water supply on the Peace River, and our concern here



22    is water quality on the Peace River.



23                  The water in DeSoto County do meet the




24    criteria for Class 1 waters, and therefore we felt that




     because it was being used for Class 1 waters, that the
                                                                   74

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 i     waters  there  should be rec lass if led according  to  their




 2     use.



 3                  MR. HAGAN:  Why was the Peace River



 4     specifically  chosen as the ffigional water supply source?



 5                  MR. MCQUEEN:  It's the only supply of



 6     potable water that we have.



 7                  Now, if the industry supply in DeSoto



 8     County, all the area north —



 9                  Well, to answer your question, we have found



)0     out that we cannot depend on a well system nor our canal



n     system when the surface water breaks for a potable water



12     supply based  on our demand.



)3                  Plus, also we have some problems in our



14     well system with salt water intrusion, and the next, the



,5     most logical  place to go for them up there was the Peace



16     River.



,7                  The recommendations now from the consultant



18     that comes to the city — I think the City can probably



19     answer this better than I can -- is to first go to Shell



20     Creek, and eventually we are recommended south of the river



21     to go to the  Peace River or the Telegraph Cypress.



?2                  So we're going to have, to look sometime in



23     the future, also at Peace River.  Some stations upstream^



24    as water was drawn out of the Peace River, and because of



25    various events,  phosphate spills,  etcetera, they could not
                                                                   75

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     depend upon the surface water for a dependable water
     supply .
                   Then they had to go to a well, such as
     Arcadia, etcetera	
                   MR. HAGAN:  When you speak of a regional
     supply ~-
                   MR. MCQUEEN:  I mean multi-county area.
 B                  MR. HAGAN:  -- on this, you're talking about
 9    a multi-county area for DeSoto County ---
10                  MR. MCQUEEN:  DeSoto, Sarasota, Charlotte,
n    and eventually going back into the Boca Grande system,
12    which they're all on well fields.  They're all on well
13    fields in this part of the county --•-
                   MR. HAGAN:  Do you have a rough estimate
15    of how many people would be served eventually by such a
16    regional water supply?
,7                  MR. MCQUEEN:  I can give it to you in
IB    capacity.  Their initial permit from SWFMD is for 6 million
19    gallons, and the plant is being built for a capacity of
20    30 million gallons, and as plants come on the line in
21    increments and stages up to a capacity of 30 million
?2    ga lions .
23                  MR. HAGAN:  Up to 30 million gallons a day?
                   MRo MCQUEEN:  Yes.
25                  MR. HAGAN:  Out of the Peace River?
                                                                    76
                                 /-

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                   MR. MCQUEEN:  Yes.




                   MR. HAGAN:   Thank you.




                   MR. MCQUEEN:  Now, that's just  for  this




      one  utility  company,  only  for the utility companies north




      of the river.




 6                  MR. HAGAN:   Thank you.




 /                  MR. TRAINA:  Thank you.




 8           (Applause)




 9                  MR. TRAINA:  Thomas W. Letson?




10           (Pause)




11                  MR. TRAINA:  Mr. Letson?




12           (No response)




13                  MR. TRAINA:  That concludes the cards of




14     individuals who indicated  by card they'd like to make




15    a  statement.




16          I'd like to ask at this time if there's anyone




17    else who'd like to come forward and comment on what




     they've heard tonight or anything else relating to the




19    study, anyone else who made a statement.




20          Yes, sir?




21    MR. MILLER:




22                  My name is Jonathon Miller.   I handed in a




23    card; I guess it got lost  in the shuffle,  and you have my




24    address because I spoke	




25                  MR, TRAINA:  I'm sorry; it's right here.
                                                                   11

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                   MR. MILLER:  You may have some other cards



     from some other people that'd like to speak.



     MR. MILLER:



                   What I'd like to speak about this evening



5    is the wetlands.  Apparently, from listening to the other



6    two hearings, the question of restoration of wetlands



7    seems to be a sort of crucial point in this whole DEIS,



a    and I think it's pretty easy to see why.



9                  If, on the one hand, it is possible to



10    restore wetlands, and the results are as good or better



n    than the original wetland, then there's really not a lot



12    of limits on where you should be mining.



13                  In other words, if the phosphate industry



14    can create a good wetland, then they can go into some



is    of these wet areas and get the phosphate that's in there.



16                  I know they said that they prefer to mine



17    on the drier side, but the whole beginning of the industry



     was the history of them floating around outside the Peace



19    River eating away at the plants  and tearing up the stream



20    bed,  and that sort of thing.



21                  So there has been a lot of phosphate connected



22    with wetlands.



23                  If, on the other hand,  it's impossible,  im-



24    probable or infeasible to restore wetlands, or if it turns



?5    out that they're inferior to natural wetiands, then it
                                                                   78

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i     would seem that there would have to be some major  limits

2    to mining.

3                  And I'm not solely here to speculate

4    tonight on the feasibility of restoring or replacing

5    wetlands.  I am, I guess, naturally skeptical at some

6    of the comments that were made yesterday regarding the

7    state of the art in creating wetlands.

8                  But what I really came here tonight to

9    do is to talk to you or introduce the thought that

10    natural wetlands 	 They serve as indicators of the

n    health of ecosystems in general.

12                  And I suspect that when I talk about

13    indicators of health, that may ring some bells.  It's

u    similar-type language that's used sometimes in regard to

15    endangered species.

16                  In other words, sometimes people talk

17    about endangered species, and so these species can be

IB    used as indicators of the health of ecosystems.

19                  In effect, there seems to be two basic

20    different types of arguments that are used, and the

21    arguments to preserve endangered species —

22                  One of these arguments is centered on the

23    concept that the species itself is important.  It's either

24    important to the ecosystem,  or it's important because we

25    may get new medicine from it, it's important because we
                                                                   79

                                  /•  18*

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     like it estheticaily, but the organism itself is important.

                   But the other argument that you hear used

     is that the. organism is important as an indicator.  It

     may have importance unto itself, but it's important as

     an indicator,

6                  So if we find that we have a viable

7    population of wood storks in south Florida, then we can

8    say that the hydro periods and the functioning of some

9    of the wetlands down there are still somewhat viable,

10    that basically the system's still working because the

n    wood storks can still feed, so you use the wood stork

12    as an indicator of the health of the ecosystem.

,3                  Now, both of these types of arguments are

14    valid, and I'm sure you have lots of information that

is    show the wetlands, in and of themselves,  are important;

16    in. other words, they're important as a habitat, clean

17    water, and all the different functions that -we're all

is    aware of as the importance of wetlands.

19                  But what I'm asking that you think about

20    tonight is what ,,thdi health of the-.natural wetlands  suggests

21    about the ecosystem in general; in other words,  what .their

?2    function is as indicators, and I personally believe that

23    we can infer five things, at a minimum, about naturally

24    occurring, healthy wetlands, in this portion of Florida.
                                                                   80
25

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,                   In the first place, existence of an



2     established vetland community implies there's been some



3     continuity; in other words, for as loag as that wetland



4     system's been there, there's been some continuity of



5     conditions.  I think that's important.



6                   Another thing that I believe we can infer



7    is that there's some hydrologic integrity of the



8    surface water system and frequently ground water system.



9                  In other words, there has to be -- I guess;



10    this is related to this concept of continuity — but the



n    water shed has to be working, water has to be flowing,



12    surface water has to 
-------
i       really  reducing the  probability  of having healthy,



2       fresh water  systems  or  healthy esuarine  systems.  You



3       can see this in the  Kissimmee River.



                     And  I  would  alao maintain  that  a healthy



       existing wetland says  something  about  meteorological



       health.  In  other  words, what I'm talking about  is  the



7      weather patterns.



8                    If the wetlands existed  for a very  long



       period  of time, it says something about  the rainfall



10      conditions that have made  that possible.



                     And  as I  tried to  say in Bradenton  --  I



12      don't  think  I did  the best job -- I'm  not really



13      satisfied with the half page that you  devoted to



]4      climate in the EIS,  and I'd like to suggest that  you



15      contact the  Meteorological Environmental Research Lab-



)6      oratory in Coral Gables and talk to them to see what i£.



       is  they might have about  the possible  effects of



is      phosphate mining on  the weather.



]9                    I'd  also  Just like to mention in passing



20      that in your reduced water use scenario, you're using



21      rainfall data from the  period of 1931  to 1960, and  it was



22      after that time -- or since that time, I should say  — that



23      we  have had  lower  than  normal rainfall,  and the question



24      is  whether this lower than normal rainfall is going  to be



2      the base line for  the future, but I really don't  think we
82

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      should avoid  looking at  the  1960 or  1978 rainfall



 2    patterns and, you know,  ascertaining what the surface



 3    water systems are going  to be working on.



                   At any rate, what I'm getting at is



 5    I  think that healthy, natural wetland systems tell



 6    us  something, and I am opposed to their removal, even



 7    if  they may be replaced .



 8                 Now, we have a court case, a suit, where



 9    a man is injured, and later he gets money back, and



10    that's supposed to be some sort of compensation.



                   I don't personally believe that replacing



12    a swamp forest with a forest of seedling cypress or other



13    trees is a Just compensation.



                   Now, the meeting last night in Bar tow,



15    the industry spokesman said they don't want to end up



16    seeing isolated wetlands that are surrounded -- they're



17    up  on pedestals -- surrounded by dried out areas.  These



is    wetlands are going to decline.  They didn't get to use the



19    phosphate in the wetlands themselves, so are really of no



20    use to anyone.



21                  I don't think anyone does want to see this



22    happen, so there's going to have to be some sort of



23    insurances to, not only  leave these swamp forests, but



24     also insure that they're going to get some water, and I



25     guess at the Bradenton meeting a woman broughtaup the point
                                                                   83

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,     that we're going to be using this 5 cubic feet per second

2    flow as some sort of determination of what's flowing

3    water, etcetera, etcetera.

4                  If you chop off all the upper portions of

5    the water shed, you can reduce the flow sufficiently so

6    that a stream that will fall below 5 cubic feet per

7    second -- then that would be available for mining.

8                  So what I'd like to ask you is that you

9    think about requiring some sort of flow standards for
  I
10    mining.  In other words, that during the mining process

n    and afterwards, there would have to be a certain flow.

12                  Now, it could be expressed on an average

13    basis, a minimum — I don't know how you do it.  I don't

)4    know whether you want to base it on 1930 to I960 or on

15    more recent information, but I really think: it's important

16    that we  do have some of these assurances that the surface

,7    water will continue to get into the streams and into the

18    estuaries.

19                  And I think we had, a few other  people

20    tonight talking about this.

21                  I hope you'll pursue this idea,  some sort

22    of guarantee or assurances that the flow rates  will be

23    maintained through the mining process and afterwards.

?4                  Now,  the only other thing I'd like to talk

     about tonight is the concept of people who would like to
 5
                                                                   84

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i     stop using ground water resources and perhaps use more



2     surface water; in other words, collecting rainfall, storing




3     it and using that for a water supply.



                   What I'd like to suggest is that, rather



     than having people store this water as it falls and then



     when the rainfall exceeds this certain amount, avoiding



     that or getting rid of that to the streams, that you



     let the water that falls flow into the creeks and streams



     and rivers and estuaries, but when rainfall exceeds a



10    certain amount, then a flood gate or a dam or a wheel,



11    or whatever structure can be closed at some point, and



12    people would be allowed to retain that excess water.



13                  In other words, it may be possible to prove



14    that water, fresh water, in excess of a certain amount



is    does significantly stress an ecosystem. There may be some



16    flood stage that can be proven to be	An ecosystem



17    can't really, it can adjust to it, but it can't adapt to



is    it.  It's too sporadic.



19                  And so, if the water that people need, or



20    they would like to start using more fresh water as opposed



21    to ground water	I hope you'll consider this concept of



22    letting the normal rain patterns reach the wetlands and



23    estuaries, and the greater than normal events, the out of



24    the ordinary ten-year storm and twenty-five year storm, that




25    those waters, once they exceed an average, that those can
                                                                    85

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     be retained.

                   I'd just like you to consider that.  I'd

     like to thank you very much for listening to me twice.

                   MR. TRAINA:  Thank you very much, Mr.  Miller,

     for coming twice.  Thank you very much, sir.

6                  Is there anyone else here that I haven't

7    called —•

                   Yes, sir?  Would you please come up and

     identify yourself?

10    MR. PEEPLES:

n                  My name is Vasco Pe.eples.  I live In Punta

12    Goirda.  I've lived here since 1933, before most of you

13    came around.

14                  I  don't like  phosphate spills.  I don't

15    like the things  we've had to h^jspen to  us.  I  certainly

16    believe in conservation, and I spend a  good many foours

17    a  year studying  our water problems.

18                  Now, I'm not  as highly educated  in a

19    technical sense  as a lot of these  people  who spoke here

20    tonight, so I can only make, a practical comment.

21                  We need the conservation.  We need our

22    protection,  but  we don't need stagnation.

                   And another thing,  from a practical stand-
£. -J

     point,  I buy food, I have  children that  buy food, I have

     grandchildren that buy food, and  if restrictions are ever
25                                                                   86

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     made so strong that we couldn't get phosphate for

2    fertilizer, you'd cut about 30 percent of the world's

3    food supply off, and where in the heck would we be?

                   Where would the people living on a pension

5    be if your food prices double?  Talk about inflation,

6    if we can't produce the food as much as we're doing

7    now, we would have more inflation.  Then we'd have a

e    chaotic condition.

9                  I want our waterways protected, but I

10    don't want to see restrictions so restrictive until

11    phosphate would not be available in quantities needed

12    to fertilize our soils to produce food.

13                  Thank you very much, sir.

14                  MR. TRAINA:  Is there anyone else who

is    cares to make a comment at this time?

16          (No response)

17                  MR. TRAINA:  As I said at the outset, this

is    is the third and final of the public hearings that we've

19    had on this issue.

20                  I must say, and I expected this having been

21    to this  area before, the depth of the comments have been

22    such that I certainly learned a lot, and I do believe

23    that the people that prepared this report have learned a

24    lot, and while EPA was scheduled to put out this final

25    report by July 31st, it's my view that we're going to have
                                                                    87

                                 /-

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     to go back and do quite a bit of further review of




     the various things in this report to address the comments,




     as they should be addressed, that were made during these




     last three days8




                   So I don't know whether or not, frankly,




     this report will be finalized by July 31st.  We'll




     certainly shoot for it, but the main objective from here




     on in is to get back -with our staff, our contractor,




     and to address the very significant comments that were




10    made on these past three days, and I think that we have




11    some way to go before we put a final report out in this




12    area.




13                  We are going to keep the record open till




14    June 23rd to allow any of you here, who either have or




15    have not made a comment, to write comments to us.  Those




16    comments should be sent to Mr. John Hagan, and John is




17    the Chief of our EIS Branch,  EPA, Region IV, 345 Courtland




is    Street, Atlanta, 30308.




                   Mr, Hagan has a card that he'll give you




20    if you want thac later.




21                  As I said, EPA  takes these hearings seriously,




22    takes your comments seriously.  We will address the comments




     that have been made tonight and the otter two nights.




24                  Those comments  and our response to those




25    comments will be included in the final EIS, and when we
                                                                   88

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 i    make that determination and put out that final EIS, we




 2    will be sending that to all of you that have registered




 3    tonight, so again I would urge that if you want to get




 4    a copy of that document to please indicate on the card




 5    or something.



 6                  As I said earlier, it's EPA's intention



 7    that this document not be one that'll sit in the library



 e    somewhere; that, in fact, it will be used in the various




 9    regulatory actions and permitting processes in water and




10    air and the other activities that EPA conducts in radiation




11    and other activities involving the environment.



i?                  And we intend to use this document to



13    base those regulatory decisions on.



u                  And again, I'll stress to you all that this




is    is a document that we are not taking lightly,  and we




16    have a number of comments, and the quality of  those comments



17    we're sure not taking them lightly, either.




is                  Again, I want to thank the people here in



19    Punta Gorda for inviting us.  It's been a very useful



20    period for us.  We've learned a lot, and we hope that you



21    have learned some, too.




22                  This hearing is now adjourned.




23                                (Whereupon, the hearing was




24                                 adjourned at 9:40 p.m.)




25                              -oOo-
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25
          CERTIFICATE

This is to certify that the attached  proceedings

before THE ENVIRONMENTAL PROTECTION AGENCY,  REGION IV

in the Matter of:

       Draft Environmental Impact Statement  Public
       Hearing

       Commission Meeting Room, Courthouse
       Punta Gorda, Florida

       7:30 p.m.

       May 25, 1978

were held as herein appears and that  this is the

original transcript for the file of the Agency.
                  -oOo-

-------
                     SECTION  2
        RESPONSES TO PUBLIC HEARING COMMENTS
(Note:   Responses are numbered T-l through T-67.   Numbers
        are assigned to  substantive comments in the margin
        of the Hearing Transcripts in  Section 1)

-------
T-l and T-2 - Mr. Ernie Estevez' comments regarding need for generic
habitat protection.

          The U.S. Fish and Wildlife Service (FWS) report referenced is
titled Fish and Wildlife Inventory of the Seven-County Region.  It was com-
piled by the Archbold Biological Station, Lake Placid, Florida for the FWS.
The report, as indicated in working papers Volume XI, Section 2, (Volume VII-
NTIS), was intended as an up-to-date inventory of the 7-county region included
in the Central Florida phosphate industry areawide impact study.  It contains
detailed accounts of important vertebrate species including potential effects
of mining on them, as well as general recommendations for further wildlife
surveys and mitigative mining methods.  The report has not been published by
the FWS and has had limited distribution.  It was completed in September 1977
and made accessible only in time for a review prior to issuance of this EIS.
The EIS and the FWS report are quite similar in assessment of the effects of
phosphate mining on important wildlife species and habitats.

          The proposed action herein calls for site-specific inventories of
Wildlife habitat to be mined or disturbed and mining and reclamation plans
that take into account the protection and restoration of habitat so that
important species of wildlife will be adequately protected during mining and
reclamation.  Thus, resource management, including wildlife and habitat
management, will be addressed for each new source mining area and should
include the preservation and restoration of movement and dispersal areas.

T-3, PP. 37-39, Bradenton Transcript - Mr. Ernie Estevez' comments on
monitoring.

          Monitoring by local and state agencies will certainly be necessary
to assure compliance with the Proposed Action, as stated.  The reliance of
this EIS on monitoring does not necessarily mean that existing monitoring
programs are adequate.  As Mr. Traina stated at the hearing, citizen input is
also needed to assure regulatory agencies at all levels respond adequately to
statutory duties.
                                      2-1

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T-4, pp. 43-44, Mr. Fred Duisberg - (Request that permits only be granted
for phosphate to be used in this nation only)

          The Interagency Steering Committee determined at its first meeting
that the consideration of limiting international trade of phosphate products
was beyond the scope of the Areawide EIS.

T-5, Ms. Glorida Rains' comments, involving 26 points.

          Point #1:  No comment.

          Point it2 takes exception with the EIS statement (based on the
ORP-LVF report on radium in ground water) that radium in the ground water of
the seven county area is not due to contamination from the phosphate industry.
The available data base does not, in fact, substantiate widespread adverse
impacts on the principal potable aquifers as a result of the industry, but
the data base is very limited and the foregoing conclusion must be regarded
as a preliminary, conditional finding.  We would suggest that we all re-read
paragraph three of the preface to that report (EPA/520-6-77-010).  Additional
studies are recommended, a point which many reviewers of the EIS also endorsed.
The naturally high radium levels in Sarasota and Manatee Counties necessitate
very stringent monitoring, coupled with action programs to eliminate or reduce
water quality problems if they develop.

          Points #3 through #8:  See text of Volumes I and II, FEIS.

          Point #9:  Primary phosphate industry pollutants (particulates, SCv,
and fluorides) were considered with respect to State and Federal source emission
standards and State and Federal Ambient Air Quality Standards.  Emission reports
indicate that all sources are In compliance with source standards, or on an
approved plan to attain this status.  Air quality data available for this
study were for the most part 24-hour samples which preclude isolation of any
effect due to diurnal inversions.  Data from continuous monitors in Hardee county
show little correlation between the'highest readings and diurnal inversions.  A
more detailed modeling study of any specific area to isolate the short-term
                                       2-2

-------
effects of diurnal inversions on local sources and the dispersion of their
pollutants was beyond the scope of this areawide study.  Such modeling should
be part of any new source applications, and should involve adequate detail
to address both long term (24 hour annual ave.) and short term 8hr, 3hr, Ihr)
pollutant levels that would be associated with the source.

          Point #10:  To our knowledge, there has been no study to substantiate
that "Samplings of seepage from inactive gypsum piles show that they yield...
significant quantities of radium to surface streams and ground water for years
after the pile is abandoned."  Such a study should be done and efforts are
underway involving EPA, the State of Florida, and selected gypsum ponds which
will be studied intensively to determine whether ground water is affected and
to what degree.  Gypsum pond seepage to ground water has reportedly occurred
in north Florida and North Carolina, but we have not seen the study results.

          The Final EIS requires stabilization of gyp ponds upon abandonment
P. 2.5, Vol. I).

          Point #11:  We agree with the statements made.  The emphasis of
gypsum tailings pile management should be on reduction or elimination of
infiltrating surface water which, in turn, causes leachate production and need
for interception and other control measures.   Measures that result  in dry
tailings or at least greatly reduced water content will worsen radon exhalation.
Management should strive for maintenance of optimum moisture content, i.e.,
wet enough to reduce radon diffusion and not so wet as to allow for gravity
drainage or recharge' through the pile.

          The type of pond lining required will be determined in the specific
studies.

          Point #12:  We agree with the recommendation for monitoring of
ground water beneath gypsum ponds in limestone terrains.  Ground-water sampling
from wells located and designed for shallow ground-water monitoring has been
a missing element at most, if not all, chemical processing plants.  Proof that
gypsum piles do or do not contribute to ground-water contamination has not been
developed despite the long-term, widespread nature of the industry.  This is
unfortunate.
                                      2-3

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          Point #13:  As stated in the DEIS, no new phosphoric acid plants
are projected.  If one were proposed, the Final Areawide EIS, along with a
site specific study and EIS would be required to assure adequate protection
of air, surface water, and ground-water from radioactive or other harmful
materials.

          Point #14:  Both in-plant and external air emissions of fluorides
from the Florida Phosphate Industry decreased drastically between 1965 and
1972.  Vegetative fluoride results indicate an increase of fluoride from
1973-1976, possibly due to lax maintenance of control equipment.  Indications
are that maintenance of control equipment improved significantly beginning
in the fall of 1977.  In any event, there have been no documented human health
effects due to fluoride to either workers or residents.  There have also been
no documented reports of fluorosis in cattle since 1964, although there were
some unsubstantiated reports in 1976 and 1977.  There is indeed a need for
further research on effects of fluoride on human health, livestock, vegetation,
and wildlife.

          Point #15:  Proposed radiation protection recommendations are
forthcoming.  The recommendations are intended to provide health protection
for persons exposed to radiation from phosphate-related land in Florida.  They
will provide guidance to Federal, State and local agencies and the public
regarding unacceptable levels of radiation exposure in existing and new
structures constructed on these land types.  They should aid these groups in
determining whether action is warranted to reduce levels.  Guidance will be
proposed at a later time to aid in radiological evaluation of undeveloped
phosphate-related land.  Such guidance would be directed to methods for
estimating post-construction levels in structures to be built on these lands.

          In developing the present recommendations only exposure due to
radiation in sturctures was considered, since at present this appears to be
the primary public health hazard.  Potential crop uptake, soil runoff, and
other  pathways may be addressed at some future time if evaluations show these
pathways to be important also.  The limited available data do not show these
other  pathways to be a significant problem at this time.
                                      2-4

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          Point #16:  Limitations of the ground-water model are delineated
in the EIS.  We feel it is better to include results along with limitations
than to ignore the results.

          Point #17:  Text revised.  See Volume II of FEIS.

          Point #18:  See text of Volume I and II, FEIS

          Point #19:  See text of Volume I and II, FEIS

          Point #20:  In consideration of the fact that wetlands restoration
has not been demonstrated and does not seem imminent, the proposed action
calls for protection of wetlands included in Category I (those within and
contiguous to rivers and streams having an annual flow exceeding 5 cubic
feet per second and those determined to serve essential environmental
functions).  As pointed out in working paper Volume XI, Section 2 (Volume
VII-NTIS) available maps of the study area do not adequately depict wetlands.
It is anticipated that the as yet incomplete FWS (DOI) wetlands inventory
will more clearly define wetlands habitats and their extent.  Site-specific
wildlife habitat inventories should also include characterization of wetlands
on new source mining areas.

          A reference to the possible effects of mining on adjacent lands is
in working paper Volume XI, Section 2 (Volume VII-NTIS).  As indicated in
that volume (section 3) and in this EIS, Florida Development of Regional
Impact (DRI) regulations do not mandate addressing the effects of mining on
adjacent wetlands as similar effects (e.g., amount of drawdown, significance
of flow regime alternation) on nearby water-bodies must be addressed.

          Point #21:  There is no data to support the thesis that wetland
areas to be affected by proposed mining plans are critical recharge areas
for the Floridan aquifer.  Recharge is primarily a direct function of the
soil leakance value and the difference between the head of the  surface
water table and the potentiometric surface of the underlying aquifer.  The
presence of surface water does not in itself imply that extensive recharge
will occur in that area.  (Volume V, Section I/Volume V-NTIS)
                                      2-5

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          Point #22:  The current level of phosphate industry activity uses
approximately 15% of the electricity generated in the Tampa area.  Projections
for future phosphate industry activity show an increase until 1985, followed
by a general decline.  This increase is not expected in itself to require any
increases in generating capacity in the Tampa area, because of the constant
level rather than peaking requirements of the phosphate industry.  Hence, the
future development is not expected to increase power requirements.  Similarly
for the case of transportation facilities, the level of phosphate industry
activity will not change sufficiently to cause significant deterioration of
the existing environment due to its activities. (Volume VIII, Sections 4 and
5/Volume I-NTIS)

          The statement indicating that nutrient discharges are beneficial has
been revised.  In the case of estuaries ultimately receiving phosphate industry
discharges, any additional plant nutrient material is indeed detrimental.

          Point #23:  The development of Tampa Harbor is clearly for the
primary purpose of handling greater amounts of bulk cargo.  Phosphate is the
only significant bulk product under consideration for export from Tampa
Harbor.  It is unlikely the harbor would be developed to such an extent for
general cargo only.

     Point #24:  See response to T-4

     Point #25:  See response to T-3

     Point #26:  The organization of the FEIS is responsive to this comment
since the impacts of the proposed action are described in Volume I and the
alternatives effects assessment is described separately in Volume II.

T-6 - Dr. Jeff Lincer's comment regarding inversions

          The existence of diurnal inversions in Sarasota is not uncommon,
as is the case throughout the 7-county study area.  Since the purpose of
this study was to characterize the future impact of the phospate industry on
the area relative to the existing environment, the existence of pollution
trapping inversions would have been of concern if large quantities of new
                                      2-6

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phosphate industry air emissions were likely to be trapped in Sarasota.
Existing air quality data indicate that this has not been the case in the
past, due to the distance between major industry sources and Sarasota.
The expansion of mining southward from Polk county will have the effect
of adding a small amount of particulate matter to the atmospheric dust
load, but this is generally a local effect and not apt to affect Sarasota.
It is quite likely that the mining activity in the southern counties will
only replace the dust currently generated by agricultural activity on the
same land in some areas, and be less than agricultural emissions in other
areas.  In any event, it is highly unlikely that the proposed action will
contribute measurably to an increased pollutant load in Sarasota, much less
contribute to "episodes" due to trapping by the regular diurnal inversions.

T-7 - Dr. Lincer's comment regarding SCL and fluoride data

          Any errors due to sampling methodology in the Sarasota S0_ data
would still place the ambient levels below 10 micrograms per cubic meter,
which is well below the federal and state air quality standards.  These
standards were designed to protect the health and welfare of the population,
                             3
and levels as low as 10 ugm/m  should be no problem when the state standard
           3                                     3
is 60 ugm/m  and the federal standard is 80 ugm/m  (annual average).

          The fluroide data presented in Figure 1.3 was prepared by the DER.
There appears to be no direct correlation between Industry emissions and the
reported vegetative levels.  The sampling methodology and subsequent analysis
used to generate the data shown in Figure 1.3 allow a considerable margin of
error to exist within the reported numbers.  A more extensive and better con-
trolled method and sampling program for vegetative fluorides would be more
meaningful than a "rigorous statistical examination" of the data presented in
Figure 1.3, which was already examined  statistically by the DER.  (Volume VII,
Section 2/Volume III-NTIS)

T-8 - Dr. Lincer's comment regarding recovering of uranium and fluoride

          The site specific EIS's, to meet conditions of the Areawide, will
establish the need to recover both uranium and fluoride.  In the case of
                                      2-7

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fluoride, it may need to be stockpiled if  there  is no market,  but  recovery
will be necessary to adequately lower pond water concentrations.

T-9 - Dr. Lincer's comment regarding water use

          Agency agrees with comment.

T-10 - Dr. Lincer's comment regarding EPA  authority  to change  requirements
for existing sources

          The quote was taken out of context.  EPA has no authority  to  change
legal requirements for existing sources  through  the  EIS.  NEPA only  allows
development of EIS's for New Sources.  Dr. Lincer is correct in that there
are indeed provisions in the Clean Water Act for revising effluent guidelines.
The requirement for new as well as existing sources  to meet water quality
standards, which may result in more stringent requirements than effluent
limitations, has existed since initial adoption  of water quality standards
in 1969.  This means that water quality  standards already are  a requirement
for existing sources.

T-ll - Dr. Lincer's comment regarding habitat loss

          Additional information on the  Florida  Department of  Natural
Resources (DNR) classification of endangered lands as well as  other  factors
considered in evaluating the importance  of wildlife habitat types is  found in
working paper Volume XI, Section 2 (Volume VII-NTIS).

T-12 - Dr. Lincer's comment regarding Myakka River State Park

          Myakka River State Park has been added as an example of a  larger
park.  Additional information on the park  is in  working paper  Volume  XI,
Section 2 (Volume VII-NTIS).  The Florida  Division of Recreation and  Parks
cites  it  as  one of  Florida's  largest state parks; it is by far the largest
state  park in  the  7-county study area.
                                      2-6

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 T-13  -  Dr.  Lincer's  comment  regarding  area  of wetlands  affected

          Future  land  use  projections  for the study  area were  based on the
 U.  S. Army  Corps  of  Engineers  Four  River Basin  Study (1976).   Both the
 extent  of wetlands and water projected for  the  year  2000 are considered
 unrealistic based on land  proposed  to  be mined  and the  state of the art of
 reclamation (working paper Volume XI,  Section 2 [Volume VII-NTIS]).   In this
 EIS,  it is  documented  that an  estimated 10,850  hectares,  or 6  percent,  of
 the area's  wetlands  would  be lost from mining;  however,  unrealistic pro-
 jections of future areawide  wetlands extent precluded an estimate  of the
 areawide change attributable to mining.  If conditions  of the  proposed action
 are implemented,  the estimated loss of wetlands will be  mitigated.

 T-14  -  Dr.  Lincer's  comment  regarding  wildlife  and wildlife habitat  inventories

          In this EIS, special status  categories of  fish and wildlife  species
 in  the  study area are  cited, including designations  of  the Florida Committee
 on  Rare and Endangered Plants  and Animals (FCREPA).  Since these species are
 included among the area's  important species, the proposed action stipulates
•that  their  management  on mining areas  be addressed in site-specific  EIS's.
 Refer to responses T-l and T-2.

 T-15  -  Dr.  Lincer's  comments regarding monitoring and dam inspection

          See response to  comment T-3.  The agency agrees with  this  comment.

 T-16  -  Dr.  Lincer's  comment  on economic burden  on community services

          There is no  evidence of "economic burdens  which phosphate  mining
 places  on community  services and infra-structure."   Quite the  contrary,
 evidence shows clear economic  value and support of the  infra-structure.

 T-17  -  Dr.  Lincer's  comment  on limitation on exports.

          A National policy  restricting export  of phosphate would  have  to be
 implemented before such restrictions could  be imposed.   (See response  to
 Comment  T-4).
                                      2-9

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T-18 - Mr. Miller's comment on defining categories of wetlands

          The three categories of wetlands will be mapped for each new
source mine, since categories will be determined on a site-specific basis.
The scale will be larger than LUDA maps.

T-19 - Mr. Miller's comment on importance of wetlands, or surface water, on
climate.

          If there is an effect on climate, it would be roughly proportional
to surface area.  If anything, area of surface water is greater after mining
than before.

T-2Q - Mr. Miller's comments on water conservation

          To answer the questions raised, the Proposed action will result
in less total area within dikes (water storage plus slime ponds), a reduced
surface water discharge beyond normal surface runoff quantities, and a
reduced pumping rate from the Floridan Aquifer, compared to operations at
existing mines.  The statements regarding retention of 10-year and 20-year
storm events apply to chemical plants, and not mines.

T-21 - Mr. Miller's comments regarding citation of the Fish & Wildlife Study

          Failure to cite the Fish and Wildlife STudy  in the DEIS was an
oversight.  It is cited in the FEIS.

T-22 - Ms. Ann McCrainie's comments regarding destruction of tributaries,
which reduces flow below 5 cfs

          Mining and reclamation plans will be accomplished in site-specific
studies for new sources prior to mining, and will establish and map areas for
which Section 404 jurisdiction exists.  This will not  allow destruction of
tributaries prior to determination of jurisdiction, as has happened on some
existing source mines.
                                   2-10

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T-23 - Ms. McCrainie's comment on land use map showing areas to be mined

          This was the most complete information we were able to obtain on
industry's plans, holdings, leases, and options.  If anyone has additional
information, we would appreciate receiving this.  These maps do not prohibit
industry from future mining outside the areas shown.

T-24 - Ms. McCrainie's comment regarding Hillsborough County's requirements

          The Clean Water Act does not allow EPA to be less stringent than
local or state requirements.

T-25 - Mr. Archie Carr Ill's comment on need for more detail on how impact on
endangered species will be avoided

          Additional detail on prevention of impact on endangered species will
be developed in site-specific EIS's.

T-26 - Mr. Carr's comment on need for fluoride study

          The agency agrees that additional study is needed on effects of
fluoride on vegetation, wildlife, and human health.  As long as control
equipment is continually maintained, and emission limitations are met, the ambient
and vegetative fluoride levels will be much lower than pre-1965 levels, and
will not cause adverse effects on vegetation, cattle, or human health.  Effect
of air emissions on wildlife are admittedly unknown; however, since no adverse
effects have been documented in the past, it is anticipated that effects with
reduced emissions are minimal if they exist.  A sampling program sponsored
either by industry or regulatory agencies which would lead to a determination
regarding effects on vegetation and wildlife would certainly be worthwhile, and
is recommended in Volume I.

T-27 - Mr. Carr's comment on leaving wetlands as pedestals

          As mentioned previously (response T-5, point #20), mining effects
on off-site adjacent wetlands, and, in the case of the proposed action, on
                                    2-11

-------
on-site preserved wetlands, are largely unknown since previous permitting
processes have not required such an assessment.  The potential effects of
current mining and reclamation procedures are presented in this EIS.
Modifications of current procedures will be necessary in order to comply
with the proposed action.  Site-specific studies will be required to consider
protection of wetlands from mining in adjacent areas.

T-28 - Mr. Carr's comment on limiting marketing abroad because of energy
conservation considerations

          See response to comment T-4.

T-29 - Dr. David Rosen's comments regarding health effects of radiation

          See text of Vol. I and II, and response to Comment W-301.

T-30 - Mr. Homer Greer's comment regarding effect of slime pond dam breaks

          The Proposed Action, which provides for elimination of slime ponds
at new source mines, will substantially reduce the potential for slime pond
dam breaks.  Increased regulation and State inspections since 1971 at
existing mines has also obviously reduced the potential for dam breaks at
existing mines.

T-31 - Mr. Homer Greer's comment regarding recent fluorosis in a cattle herd
in Hillsborough County

          This incident was apparently not reported to Hillsborough County or
to the Florida DER.

T-32 - Mr. Homer Greer's comment regarding economic effects

          Primary and secondary economic effects due to employment are
delineated in the FEIS, Volumes I and II.

T-33 - Ms. Catherine Fernald's question regarding EPA addressing the hidden
cost of phosphate mining, the health, the water, the drawdowns, the salt-water
intrusion, the loss of potable water.
                                    2-12

-------
          We believe these questions have been addressed in the Areawide
EIS, and will be answered more specifically in each site-specific EIS.

T-34 - Ms. Catherine Fernald's comment regarding Becker being declared an
existing source.

          As an existing source, Becker does not have to comply with the
Areawide EIS, nor develop a site-specific EIS.

1-35 - Ms. Linda Campbell's comment regarding a concern about the lack of a
thorough discussion of the impacts of phosphate mining on fish and wildlife
habitats.

          Additional information on the effects of mining on fish and wildlife
habitats is in working paper Volume XI (Volume VII-NTIS).  Rationale for
importance ranking the terrestrial/wetlands habitat types is included (Volume XI,
Section 2/Volume VII-NTIS).

T-36 - Ms. Campbell's comment about slime ponds providing wildlife habitat and
adding to landscape diversity

          The decision that conventional aboveground slime-disposal areas
should be eliminated was based on the judgement that potential and actual
adverse effects on water quality and land occupancy outweighed their value as
wildlife habitat.  Several references to habitat value of slime ponds as well
as naturally dewatered slime pond areas are included in working paper Volume XI
(Volume VII-NTIS).  A summary of these views is found in this EIS.  Added to
these views is the suggestion that properly managed slime ponds are probably
the most feasible replacement for Category 2 wetlands.  Unless, an abandoned
slime pond is intensively managed, however, it will not continue to provide
these benefits.   The trend is to dewater abandoned slime ponds, and develop
agricultural areas.

T-37 - Mr. Homer Hooks'  comment about losing options if the Proposed Action
prescribes placing clay below ground.

          The wording of the Proposed Action does not preclude any options
for alternatives to conventional above ground slime settling ponds.
                                   2-13

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T-38 - Mr. Hooks' comment regarding clay ponds offering high quality wetlands
sites.

          See response to comment T-36.

T-39 - Dr. Cornwell's comment about Appendix C of the Archbold Study

          As mentioned in Response T-l and T-2, the FWS report generated by
the Archbold Biological Station and this EIS contain similar assessments on
the effects of phosphate mining on important wildlife species and habitats,
including the view that natural revegetation is preferable to reclamation as
currently practiced (working paper Volume XI, Section 2/Volume VII-NTIS).
The theme of the Edscorn paper appendixed to the FWS report - wildlife values
may be negated by reclamation - is expressed several times throughout the
effects assessment (working paper Volume XI, Section 2/Volume VII-NTIS) and
summarized in this EIS.  As indicated in the FWS report, following the
call-out of the Edscorn paper (p. 1276), a detailed inventory of these lands
and surveys of their wildlife populations are needed to evaluate their overall
significance as fish and wildlife habitats.  Regardless, unless modified,
current mining methods and reclamation practices will not produce habitats
like those on long-abandoned mined land.  Also, it is expected the naturally
restored habitats will not support a diversity of wildlife resources equivalent
to forested wetlands.

T-40 - Dr. Cornwell's comment regarding lack of documented adverse impact on
wildlife

          The Archbold Biological Station concludes in the FWS report (P. 1273)
that the overall effect of mining the majority of mineable lands now owned
by phosphate companies will be a serious reduction in both diversity and
abundance of the wildlife resources of the 7-county area - notwithstanding
modification of current reclamation practices and priorities.  In a letter to
the EPA (referenced in working paper Volume XI, Section 2/Volume VII-NTIS),
the FWS stated:  1)  the Archbold study indicated that wildlife species
diversity appears to be significantly less in the areas of past and current
                                     2-14

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phosphate mining than in new areas that are expected to be mined, and
2)  much of this greater diversity may be attributable to the existence of
natural wetlands 	 floodplains and aquifer recharge areas, not mine pit
lakes and slime ponds.

          In a letter to Archbold Biological Station (appendixed in the FWS
report), the Bureau of Environmental Protection of the Florida Game and
Fresh Water Fish Commission indicated that mining or disturbance to sensitive
wetland areas results in permanent habitat losses and drastic population
reductions for many wildlife species of the area.

          These observations were made in the context of the present environment
of the study area, which includes Polk County and long-abandoned mining area.

T-41 - Dr, Cornwell's comment on lack of documented wildlife impact in Polk
County

          Most species current declines in the study area, as well as in Florida
and elsewhere, are attributed to habitat loss, which, in certain parts of the
study area, is a result of past mining.  Indications are that most land use
changes in the immediate future in the inland study area will result from
mining.  To the extent possible, estimated changes attributable to mining are
clearly presented in the EIS, and in no case is 100% change attributed to
mining.  Nevertheless, phosphate mining has been an important contributor to
terrestrial habitat loss in the past, especially in Polk County, and will be
the major contributor, except along the coast of the 7-county area, in the
immediate future.  A point of prime consideration, besides upland reclamation
possibilities and practices, is the fact that approximately 30% of mined land
unavoidably becomes closed waterbodies - not wetlands or uplands.

          As pointed out in the effects assessment (working paper Volume XI,
Section 2/Volume VII-NTIS), mining is expected to contribute to the decline
of several species other than threatened and endangered ones; the species are
indicated therein.
                                    2-15

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1-42 - Dr. Cornwall's comments on wetlands restoration

         The conclusion of the DEIS that true wetlands restoration on mined
land is not feasible within a reasonable length of time stands.  Both the
biological and hydrological distinctions between Florida wetlands and wet
lands are given in this EIS (p. 1.21, 3.4).  Additional characteristics of
the study area's wetlands, including terrestrial vertebrate associations and
important plants, are found in Section 5 of working paper Volume VI (Volume
VI-NTIS).

          The species listed as potentially affected by mining or development
of facilities in U.S. waters or wetlands meet the importance criteria set
forth in the guidelines under which the areawide impact assessment was
conducted.  They are listed as water inhabitants or wetlands inhabitants, but
incorrectly were lumped as wetlands inhabitants in the sentence quoted.  This
has been corrected and "shellfish" removed since the lists obviously include
none.  However, the implication that marine animals and those out in the
"open areas" could not be affected by mining inland waters or wetlands is
misleading although potential impact is minimal.  Several references to dis-
ruption of flow regime, increased sedimentation, and turbidity among other
disturbances from mining, are found in working paper Volume V, Section 2
(Aquatic Biota) (Volume V-NTIS) and working paper Volume XI (Volume Vii-NTIS).

T-43 - Dr. Cornwell's call for areawide guidance on assessing wetland
characteristics

          It is agreed that areawide guidelines for determining wetlands
classification should be compiled.  Riverine wetlands, as mentioned in the
proposed action, are included in Category I.  The preservation of highly
productive, high quality wetland systems is presently the only assured method
of maintaining their inventory.  Increasing their inventory within the fore-
seeable future is unlikely; estimates of 5 to 20 years for development to
equivalent conditions are unrealistic.
                                    2-16

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T-44 - Dr. Cornwall's comment regarding diversity of mined areas

          In the letter referred to in Response T-39, the Bureau of Environ-
mental Protection of the Florida Game and Fresh Water Fish Commission indicated
that the loss of regional wetlands is not compensated by the creation of
extensive lake systems.  At a public meeting held in St. Petersburg, Florida
during this EIS study for discussion of wetlands, the Florida Game and Fresh
Water Fish Commission, Lakeland, Florida, indicated that mining pit lakes are
indeed unhealthy and their estimated term as a viable life-support system is
a mere five years.  The Commission further indicated that Polk County needs
no more aquatic habitat of the kind produced by mining,  partly, because the
lake edges are not acceptable life-support habitats.

T-45 - Dr. Cornwell's comments regarding restoring wetlands

          Designing a functional drainage pattern for wetlands systems seems
to be problematic, but as pointed out in working paper Volume XI (Volume VII-NTIS) ,
physically unsuitable substrate apparently poses the most difficult of several
problems in establishing particular wetlands vegetation.  These problems
were identified by the U.S. Army Corps of Engineers, which is experimenting
with wetlands restoration all over the county.  Other problems in restoration
are found in the above citation.

T-46 - Dr. Cornwell's comment on uplands restoration

          It is agreed that little experimentation on restoration of native
upland communities has occurred.  However, similar restoration problems exist,
especially substrate structure (working paper Volume XI, Section 2/Volume
VII-NTIS).  Although we hesitate to agree with a Phosphate Council spokesman
that "it's much easier to restore wetlands than virtually any of the other
natural systems that are present on the land to be mined" (Dr. Cornwell's
statement at Bartow, Florida Public Hearing - p. 53), we do agree with the
implication that native upland communities cannot be readily restored on mined
land.  Additional information on uplands habitats and mining is contained in
the above cited working paper.
                                    2-17

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T-47 - Dr. Cornwall's comment on experimentation on wetlands restoration

          Although which 20 or 30 percent of habitat types to allow natural
reversion of is not made clear, we repeat that reversion to any natural
system now present on land to be mined is precluded by irreversible alterations
in topography and soil structure during mining.  Communities that will develop
naturally on the mined land will be conversions rather than reversions.  In
relation to wetland types, natural conversion of mined land to wetlands has
not been been documented.  Naturally developing slime pond areas are "marshy"
but not wetlands and, unless artificially maintained, will in 20 to 30 years,
as demonstrated at Teneroc Wildlife Sanctuary, convert to dry sites.

          We agree that further research in restoration of suitable habitat
is needed and local testing necessary.  As stated in this EIS (p. 1.27):
although diversity will decline primarily because hardwood swamps and mixed
forests (sandhills, sand pine scrub habitats) can neither be reclaimed nor
naturally restored on mined land, establishment of similar habitat is possible
and necessary to maintain much of the area's important biota.

T-48 - Dr. Cornwell's comment on impact on endangered species

          Refer to Response T-41.  A list of threatened and endangered species
likely to be affected by mining is included in this EIS.

          Additional information on these species, including their reported
presence on proposed mining areas, is in working paper Volume XI (Volume VII-NTIS)

          The reference to naturally-scored land is unclear.  Our evaluation of
certain existing habitat types in the mining areas as modified but still
productive and essential for many wildlife species, including threatened and
endangered ones, is supported by the Bureau of Environmental Protection of the
Florida Game and Fresh Water Fish Commission in the letter appendixed to the
FWS report  (see Response to Comment 40).  Our overall assessment of impact to
wildlife, along with that of the FGFWFC, is based on current mining methods and
                                    2-18

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reclamation practices not those of the past.  Additionally, we considered the
projected areawide extent of habitat decline attributable to current and
proposed mining.  We disagree that the managed systems occupying currently
reclaimed land will support wildlife diversity even nearly equivalent to that
existing, and, as pointed out previously (Response to Comment 40), naturally
restored lands of the past are not currently supporting equivalent diversity
nor are they expected to in the foreseeable future.

T-49 - Mr. W. M. Leaders' comments on radiation

          In response to Mr. Leaders' only substantive comment concerning the
absence of radiation survey data for unmined phosphate land in the Central
Florida counties, refer to response W-301.

          With regard to his other comments, two are patently incorrect and/or
misleading.  For example, while Mr. Leaders' statements concerning potassium-40
are at face value correct, his manner of presentation was misleading.  Potassium
is radioactive by virtue of its constituent isotope, potassium-40, which makes
up 0.01% of its natural elemental occurrence.  This element, in natural homeo-
stasis within the body, has a total activity of about 0.1 Ci.  His contention
that an individual's greatest exposure to "extra" radiation is due to proximity
with other individuals is, of course, ludicrous.  Exposure from potassium-40 is
part of our natural background exposure, with almost all of the dose received
internally, the exposed organ being primarily muscle (not the circulatory system).

          His statement to the effect that unmined phosphate-related land may
have as high a background as reclaimed land is misleading.  The exposure related
to reclaimed land is not "natural" background radiation exposure by definition,
as is the background associated with nonmined land.  The efforts of man have
modified the environment with the effect of increasing terrestrial radiation
levels.

T-50 - Charlotte County Commissioner Robert Shedd's comments regarding monitoring

          See response to Comment T-3.
                                    2-19

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T-51 - Councilman C. R. Johnson, City of Punta Gorda, comments regarding City's
efforts, and need for monitoring program

          The City of Punta Gorda is certainly to be commended for its program
to remove the treated discharge from the Peace River and go to landspreading.
If all sources in the Peach Basin were to take a similar attitude and approach,
the Peach River and Charlotte Harbor would undoubtedly again become pristine
waterways and outstanding fisheries.  (See response T-3 for response to comments
regarding need for monitoring.)

T-52 - Mr. Joseph R. Roach's comment that proposed action is only applicable to
new plants, and that the study states there will not be any new plants.

          This statement is true for chemical plants only.  New mines and
beneficiation plants are projected.  The 1976 rules mentioned are for mining
discharges.

T-53 - Mr. Roach's comment regarding State effluent limitations on mining being
aggressively litigated.

          This is true, but as of the date of this writing, the Florida effluent
limitations are still applicable.

T-54 - Mr. Roach's comment regarding EPA final rule for effluent limitations for
mining.

          The statement is correct.  However, the EPA standards are National
Standards, and had to consider conditions at phosphate mining operations both
inside and outside the State of Florida.  As is allowed by Section 511 of the
Clean Water Act, the State of Florida can adopt more stringent limitations.
In the case of phosphate mining, Florida has exercised this option.  Section
301(b)(l)(C) requires EPA to include the more stringent State limitations as
enforceable NPDES Permit conditions.  Since the EPA effluent limitations have
a national basis, and are not necessarily protective of watersheds as sensitive
as the Tampa Bay and Peace Basins, the State is encouraged in its endeavors to
adopt more stringent limitations for phosphate mining and chemical processing
operations.
                                    2-20

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T-55 - Mr. Roach's statement that no improvements may be made because BAT
limitations are no more stringent than BPT

          As stated in an earlier response and in the FEIS, protection of
water quality in the Peace and Tampa Bay Basins requires more stringent
effluent limitations than the BPT and BAT standards.  Existing mines and
chemical plants in the Tampa Bay and Peace Basins have consistently dis-
charged much lower concentrations than allowed by EPA's BPT and BAT.  Existing
Source NPDES Permits need to be revised to reflect quality of existing
discharges and the need for water quality protection in the Peace and Tampa
Bay Basins.  While the FEIS has no legal implications on existing sources,
it is hereby recommended that EPA, Region IV, take appropriate action toward
revising and reissuing permits to the existing chemical plants based on water
quality protection of the receiving waters.  This course of action will
necessitate an intensive water sampling survey during the wet months of 1979
by EPA and/or DER.  The survey, along  with data from routine sampling by
DER and USGS, will document pollutant loadings from all existing sources, and
effects on water quality in the two basins.  Results can be used for revision
of all existing permits.

T-56 - Mr. Roach's statement regarding conflict between the Southwest Florida
208 and statements in the Draft EIS regarding sources of nutrient concentra-
tions in the Peace River.

          Text has been revised (p. 1.2B of Volume II, FEIS).  Mr. Roach is
correct in asserting that phosphate chemical plants are the leading source of
plant nutrient materials in the two basins.  However, there are only two
chemical plants in the Peace Basin, where there are twelve mines.  In the
Tampa Bay Basin, there are twelve chemical plants and seven mines.

T-57 - Mr. S. R. Stedman's comment regarding economics of extracting fluoride

          The requirement to lower concentration of fluoride in gyp ponds
will result in the need to extract fluoride, whether or not it is marketed.
                                    2-21

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T-58 - Mr. Samuel Wapner's comments on phosphate reserves

          Latest Bureau of Mines Projections received by EPA as of
September, 1978, are utilized in the FEIS.

T-59 - Mr. Maywood Chesson's comments regarding flexibilit> of EIS

          We believe that wording in the FEIS is sufficiently flexible to
allow for changing technology.

T-60 - Mr. Jim Kelley's comments regarding monitoring

          See response to comment T-3 .  We certainly agree that unannounced
inspections are needed.

T-61 - Mr. David Wilson's comments regarding reclamation

          See text of Volume 1 for reclamation requirements.

T-62 - Mr. Robert M. McQueen's comment regarding "insignificant" hydrologia
functions of Category 3 wetlands.

          Text has been revised.  See page 2.3 of Volume I.

T-63 - Mr. McQueen's comment about existing source mines.

          See response to comment T-55.

T-64 - Mr. McQueen's question as to basis of reduced runoff

          Reduced runoff is based on low flow periods.  Peak flows will also
reduce somewhat, but annual flow remain approximately the same.

T-65 - Mr. McQueen's comments about revision of working papers.

          The working papers have been revised and reissued.
                                    2-22

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T-66 - Mr. McQueen's comments about retention of runoff in Polk County

          While retention will decrease low flows,  it will not have a
significant effect on annual average flows.  Precise predictions of effects
on flows will only be possible after site-specific  studies are completed.

T-67 - Mr. Jonathon Miller's comments regarding wetlands,  maintenance of
minimum flow, and storage

          Text of FEIS and Working Papers have been revised to respond to
these comments.  The FEIS does not require maintenance of  a minimum flow
from mining operations, but this could well become  part of the SWFWMD Permit
provisions, as established through individual DRI's and site-specific EIS's.
Storage to be provided to meet water re-use requirements will  have to be
determined in site-specific studies.
                                    2-23

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   SECTION 3






WRITTEN COMMENTS

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                                 SECTION  3

                                 CONTENTS


      Letter                                                         Page

Florida Phosphate Council                                            3-1
CF  Industries,  Inc.                                                  3-95
Beker Phosphates Corp.                                               3-98
Florida Chapter of the Wildlife  Society                              3-105
The Izaak Walton League                                              3-107
Citizens Against River Pollution                                    3-111
Florida Audubon Society                                              3-113
State of Florida, Dept. of Administration                            3-118
State of Florida, Dept of Environmental Regulation                   3-159
Tampa Bay Regional Planning Council                                  3-198
County of Sarasota                                                   3-202
Mary L. Jelks,  M.D.                                                  3-218
General Development Utilities, Inc.                                  3-219
Mrs. Martha Kjeer                                                    3-225
U.S. Dept. of the Interior                                           3-227
Mrs. E. K. Ervin                                                     3-252
James R. E. Smith                                                    3-257
Manatee County  Planning & Development Dept.                          3-258
Manatee County  Health Department                                     3-260
C. F. Industries                                                     3-264
Gardinier, Inc.                                                      3-271
Swift Agricultural Chemicals                                         3-273
Save Our Bays Association, Inc.                                      3-276
The Fertilizer  Institute                                             3-278
Mississippi Chemical Corp.                                           3-281

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      Letter                                                         Page
Mrs. Jean M. Flavin                                                  3-288
Carl T. Zimmerman                                                    3-289
U.S. Dept. of Health, Education, and Welfare, CDC                    3-290
U.S. Dept. of the Air Force                                          3-291
David 0. Munson                                                      3-292
C. F. Industries                                                     3-296
Dorr-Oliver, Inc.                                                    3-298
Hillsborough Co. Planning Commission                                 3-300
Robert N. McQueen                                                    3-307
AMAX Chemical Corp.                                                  3-315
EPA, Air Strategy Development Section                                3-319
U.S. Dept of Health, Education, and Welfare, Region IV               3-320
U.S. Dept. of the Army, Jacksonville District,
     Corps of Engineers                                              3-321
U. S. Dept. of Agriculture, SCS                                      3-323
EPA, Effluent Guidelines Division                                    3-324

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•"'    »  1
        pKosprvate
          feec
               syou

Hor«r -looks
                                                         Suite 24, Executive Plaza
                                                         4406 5. Rondo flvenue • PO. Box 5530
                                                         lakeland, Florida 33803
                                                         Telephone 813/646-8583
                                 June  20,  1978
           Mr.  John E. Hagan, III
           Chief,  EIS Branch
           Environmental Protection Agency
           Region IV
           345  Courtland St., N.E.
           Atlanta, GA  30308

           Dear Mr. Hagan:

                     Subject:  Comments  on the Draft Area-wide
                               Environmental Impact Statement for
                               the Central Florida Phosphate Industry,
                               March  1978

                     We submit as Attachment A herewith the comments  of
           the  Florida Phosphate Council,  Inc., on the above document.
           The  comments are intended  to  provide you with information
           generated by individuals directly familiar with the seven-
           county area and the phosphate industry.

                     The submission is a page-by-page commentary ex-
           tending over a broad range of topics, identifying sections
           in which errors of fact occur and pointing to shortcomings
           in the treatment of ecological  considerations, such as  the
           failure of the Draft EIS to communicate the extent to which
           the  study area is presently man-dominated and failure to
           recognize that phosphate mining represents the single
           greatest opportunity for increasing the inventory of wildland
           communities, either wetland or  upland, within the study
           area.

                     The conclusion of the Draft EIS that phosphate
           mining should continue and expand in the study area is
           appropriate.  Maintaining  environmental awareness on the
           part of the industry will  prevent potential adverse impacts.
           The  Proposed Action of the Draft EIS includes many useful
           concepts that the Florida  phosphate industry is already
           implementing.

                     Several statements  concerning the Proposed Action
           should be reiterated.  Mining should not be precluded on  any
           categorical basis, for example, as in "Category One" wetlands,
           Although the Area-wide EIS may  discuss policies or general
           findings, restrictions on  site-specific activities should
                            Choirmon of the Boord' fl. G. Gorcra, flgrico Chemicol Co.
                                                            r-McGea) • Conserv. Deportment of Philipp
                                                                "iomponv • Gordinier, Inc • LU R
                                                                I Chemicol Compony • Occidental
                                                                rpoiotion • USS flgn-Chemicols

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Mr. John E. Hagan, III     -2-            June 20, 1978


not be proposed until EPA, the Corps of Engineers, the Fish
and Wildlife Service and other agencies have been consulted
regarding detailed plans for development and restoration
submitted by the applicant.  Similarly, site-specific factors
are of overriding concern in the matter of waste clay disposal.
Decisions regarding implementation of alternative methods
must be based on such considerations as quantity and types
of clay in the ore body, value of a balanced reclamation
plan, and utilization of clay disposal areas as managed
wildlife habitat.

          Related discussion regarding implementation of the
EIS is enclosed as Attachment B.  This attachment includes a
letter dated April 18, 1978 from Alan W. Eckert, Acting
Associate General Counsel, Water Quality Division EPA, and a
copy of the response of the Florida Phosphate Council, Inc.,
to this letter dated June 19, 1978.

          For your records, we have included as Attachment C
copies of previous submittals by the Florida Phosphate
Council, Inc., during the development of the EIS.

          We appreciate the opportunity to present these
comments and hope they will be helpful to you in developing
the Final EIS.  We will be glad to discuss any of our comments
in more detail with you if you desire.

                                   Sincerely yours,
                                   Homer Hooks

HH: jb

Enclosures

cc:  Steering Committee
     Advisory Committee

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                  ATTACHMENT A



Comments of the Florida Phosphate Council, Inc.
Contents:



Comments labelled pages 1 through 47

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ii        "Land surface will be altered by surface mining and recla-
          mation;  soils and vegetation removed from the mining and
          associated areas; wildlife habitat and populations reduced."

          As in all other cases where surface mining and reclamation
     effects are discussed, the time frame considered for comparison
     with the premining conditions is the immediate, postraining time faj	I
     frame.   No consideration is given to the type system that will
     appear on mined and reclaimed areas many years after mining.


ii        "Livestock forage will be reduced during mining operations,
          and productivity of the mining area will be reduced even
          after reclamation."

          No data were presented to indicate that productivity of
     the mining area would be reduced after reclamation.  Field
     observation shows that productivity is increased with or without  ii__
     reclamation,'probably due to the soil disturbance with provision
     of additional nutrients and resources to the newly created
     surface soils.


ii        "Recreational resources will be reduced, archeological
          values may be destroyed, and aesthetic aspects will change."

          Mined and reclaimed areas should be as suitable for small
     game based recreation as the premining condition.  The created
     land and lakes habitat is productive for waterfowl and as a
     pond or small lake fishery.  These uses represent an addition   /i _ •?
     to the recreational resources of the area.   The archeological
     values should not be destroyed because each site specific
     DRI/EIS requires an archeological survey.   Significant sites
     require excavation prior to mining.
                                 -1-
                                3-4-

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 1.1        "Polk County  is  the  site of most  of  the  current
           phosphate  industry activity, but  several chemical
           plants  and one mine  are in operation in
           Hillsborough  and Manatee counties."

           Several chemical plants and two mines are in
      operation in Hillsborough County, and  one chemical  plant
      is  in operation in Manatee County.


 1.2        "The chemical plants are expected to remain in
           their current locations."

>^          The statement is unclear as written,  but suggests
 \     that no new  chemical  plant construction will  be undertaken W
'     which is an  unwarranted conclusion.


           "Figure 1.1:  Phosphate Rock Supply-Demand
           Projections."

           A linear upward  sloping demand curve for phosphate
      is  unrealistic.  It ignores the influence of  price  on
      demand and no explanation as to why phosphate demand
      will rise unabated in the future is provided.   At some point
      decreasing returns set in with ever increasing applications  /_ <"
      of  phosphate based fertilizers.                             '*'
           The forecasted levels of Florida  phosphate output may
      not decline  after  1985, as the industry applies improved
      recovery techniques.  Additionally, the author's assumption
      of  reduced Florida phosphate production is contradicted  on
      pages 1.1-1.2 of the  draft.


 1.3        "The phosphate industry currently owns either  the
           land or mineral  rights on enough  phosphate deposits
           to continue the  present rate of production beyond the
           year 2000."

           There are  several phosphate rock  supply-demand
      projections  available that indicate larger resources than
      the DEIS.  Mr.  J.  L.  Weaver, a recognized authority on    A/— (f
      phosphate geology  and mining, stated in a paper to  the
      American Chemical  Society on April 6,  1976:

              "The three mining areas of the Southeastern
              United States:   Central Florida  - North and
              South; North Florida; and North  Carolina;
              all have  adequate reserves to support expanded
              production for more than 50 years."


                             -2-

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1.3       "Table 1.1:  Estimated Phosphate Rock Reserves
          and Resources in 7 - County Study Area."

          The estimate of phosphate rock reserves in the
     7 - county study area is low.  The calculation of
     "Subeconomic resources" is technological and price
     determined.  With no analysis of future phosphate prices,
     little credence can be given to these calculations.
          Regional and world reserves of minerals are not       .    _
     static and accuracy demands frequent updating,  Worldwide  *v — f
     known reserves of phosphate increased 45-fold in the
     twenty year period preceding 1970 (Council on International
     Economic Policy, 1974) as the demand for chemical
     fertilizers increased and incentive was lent to exploration.
     The expense of prospecting and land acquisition will generally
     not be borne until justified by market conditions.  The
     status of known reserves is intimately linked to that fact.


1.4       "Mining has not appeared to have played a
          significant role in the growth of the region
          since 1960."

          This conclusion is not supported by the facts.
     Phosphate mining continues to be a propulsive force in Polk
     County.  Since 1960, its payrolls and expenditures have
     increased rapidly.  The industry is capital intensive and
     the direct employment effects have been modest.  However,
     the industry is a vital component of the area's export base.
     Secondary effects from the industry are substantial.  As
     mining activities move south into Hardee and DeSoto,
     economic growth in these counties will be stimulated.
     Employment, income, population growth, and tax revenues
     will all increase.


1.5       "Table 1.3:  Phosphate Industry Ad Valorem Taxes
          Paid, 1972-76."

          Ad valorem tax adjustment on mineral value currently
     being promoted in Hardee and Hillsborough counties would
     have a significant effect on the figures shown.


1.8       "The tailings or waste from this fraction is used
          in dam construction or land reclamation.  The fine
          fraction is processed through a flotation section to
          recover a fine concentrate.  The waste, a clay, slime,
          is impounded in areas that have been mined."

          Fine phosphatic clays are separated from the combined
     feeds before the sizing and flotation process.  The sand
     tailings from both coarse and fine flotation are used in
     dam construction or land reclamation.

                             -3-

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1.8       "Even then, the uses to which the land may be put are
          restricted to light-load applications such as pasture
          or other agricultural activities."

          The land use limitations are established only by economics.
     Construction on such land can be accomplished using techniques
     commonly applied for other cases in which high clay soils
     present difficult foundation conditions.


1.9       "Wastewater is treated initially with lime to raise the pH
          and is subsequently treated as necessary to meet effluent
          standards. "

          Only contaminated water from chemical processing plants   *^     ,
     that is discharged to surface waters must be treated with lime
     prior to discharge.


1.12      "Figure .1.3: Vegetative and Ambient  Fluorides in Polk County."

          The figure fails to show ambient fluoride levels or data on   /*/— / 2.
     emission or vegetative fluoride more recent than 1974.   The average
     data for vegetative fluoride are: 1975, 47 ppm; 1976, 48 ppm;
     1977, 52 ppm.


1.16      "Most soils of the study area are young and underdeveloped,
          nearly level or gently sloping, acidic, very sandy with
          high permeability, and generally low in clay, organic
          matter, and plant nutrients."

          This factual statement underscores some of the most fundamental,
     long-term edaphic changes associated with mining which results in
     increased biological productivity and regional species diversity.
     These are:
     •  increased clays in the "A" and "B" horizons, reducing permeability
     with a net gain for forest species adapted to more mesic conditions.
     •  increased phosphate concentrations in  the root zone of the
     invading plant life, providing for greater fertility and increased
     productivity.
     •  increased variability on topography and slope, providing the
     potential for more niches and better sanctuary from human disturbance.
     •  increased aquatic habitat niches and increased wetland inventory
     resulting from lake edges and slime ponds.
     •  rapid accumulation of humus in the "A" soil horizon because of
     the increased biological productivity.
     •  deposition of sand tailings provide a  potential for establishing
     scrub,  sandhill, and xeric hammock communities.


1.20      "The distinctive Florida environment - sandy soils, low
          relief and elevation, poor drainage, and a mild climate
          with relatively even temperatures, frequent lightning and
          rainfall characterized by great seasonal differences - is

                                   -4-
                                 J-7

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          a major influence in shaping a spectrum of terrestrial
          biota that is unique within the United States."

          The above statement relates to peninsular Florida and is not
     specific to the areawide study unit.  All biological assemblages
     are shaped by their environment and also help shape their
     environment.  The statement is true of all regional ecosystems ^/
     and provides the basic rationale for man's management of his
     environment.


1.20      "Among the particular biota of central Florida are many
          temperate-zone species at their southern limits, some hardy
          tropical species at their northern limits, and numerous
          species that are endemic to the state."

          The only vertebrate species endemic to the study area are:
     sand skink, short-tailed snake, and Florida mouse.   These hardly
     qualify as "numerous."  Nowhere are the endemic biota specifically
     identified, a major oversight in a DEIS of this scope.  The three
     endemic species are listed in the working paper concerning land
     (TI 1977 e), Section 5 (p. 5.95, par.  1), as well as the three
     subspecies (p. 5.95, par. 2), but this important information has
     not been transferred to the DEIS.                                l*J
          This endemic species point is made several times throughout,
     but is not well explained or documented.  Certainly, this would
     apply more to floral and invertebrate species than to vertebrate
     fauna.  Florida does have several additional endemic subspecies
     vertebrates.  The Section 5 working paper (on p. 5.95) notes
     that, "the Florida mouse is ... the only mammal species restricted
     to Florida."  The weighted use of endemics in the text is
     disproportionate and misleading.
          The DEIS rightly emphasizes the importance of flagging endemic
     species so they can benefit properly from appropriate management.
     Unfortunately, the endemic vertebrate species are not so
     identifiable in Table 1.11.


1.20      "The 7-County study area is predominantly agricultural land
          and rangeland  (more than 450,000 hectares, or 1,000,000 acres
          of each); wetlands comprise approximately 178,000 hectares
           (440,000 acres), and forests comprise about 70,000 hectares
           (175,000 acres)."

          This brief breakdown in land use, at the outset of the DEIS,
     fails to communicate the extent to which the 7 counties are now
     man-dominated.  Most of the remaining natural systems, regardless
     of quality, occur in the 779,000 acres (22% of total region) of   l*
     forests, wetlands and water areas.  Of course, this intensive human
     use of land makes the remaining extent of natural systems all the
     more important.  Reversion to nature and restoration of natural
     habitat from mined lands appears to be the only economically
     viable method for increasing the quantity and quality of wildland
     habitats in the study area.


                                   -5-
                                3-6

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          Because so much emphasis is given in this section and others
     to the generalized,  descriptive aspects of the natural ecosystems
     within the study area,  the reviewer has considerable difficulty
     in grasping their actual extent or location relative to past,
     present, and proposed mining.  Likewise,  a useful quantitative
     and qualitative assessment of the described natural habitats is
     generally lacking.


1.20      "Approximately  75  percent of the study area's agricultural
          land is cropland and improved pasture;"

          In effect, this paragraph tells us that the 1,128,563 acres
     (31.5% of the study  area)  of agricultural land are "intensely
     managed," have "comparatively few plant species," and "have less W— \
     wildlife value."  A  major part of the lands proposed for mining
     will be in this cover type.   Knowledge of the extent is vital for
     assessing impact, since the  postmining condition is certain to
     increase natural system values over the present man-dominated
     agricultural'system.


1.20      "Most of the rangeland  of the study  area comprises modified
          pine flatwoods."

          The 1,116,238 acres (31.3%)  of "modified pine flatwoods"
     rangeland, as intensively managed in the  study area,  typically
     are low in natural system plant and wildlife values.   If a pre- I*/~~ 18
     ponderance of the lands to be mined are of this type,  then the
     net effect of mining will be an increase  in natural system diversity
     and productivity over the existing land use.   Knowledge of the
     extent of the present and proposed mining in this land type is
     crucial to an accurate  projection of mining impact.


1.20      "Of somewhat greater wildlife value  and of considerable
          biogeographical significance is the  comparatively small
          amount of rangeland that is natural  dry prairie,  or palmetto
          prairie;"

          The "natural dry prairie" or "palmetto prairie"  presentation
     as a unique habitat  type is  ecologically  debatable,  as is its
     being an endemic Florida habitat.   This concept is apparently
     derived from Kuchler's  (1964) map,  which  is a macroscopic mapping uj
     of the "major potential natural vegetation types of the coter-
     minous United States."   Kuchler's map shows this "palmetto prairie"
     type occurring in the southern portion of the region as a large
     block in Charlotte and  DeSoto counties and two smaller areas in
     Sarasota and Manatee counties, virtually  none of which is scheduled
     for mining.   Much of this vegetation type may actually be typical
     cut-over pine flatwoods.   If this cover type is endemic, unique
     and so ecologically  important, it ought to be quantified and
     mapped.
                                   -6-

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1.21      "By far the greatest amount of remaining forest in the study
          area is typical pine flatwoods."

          Knowledge of the extent of the 172,101 acres of forest that
     is typical pine flatwoods is a significant factor in the impact
     analysis.  Similarly, the "small amount of deciduous forest" is
     not quantified.  Throughout the DEIS, the consistent assessment of
     a net loss in diversity is based heavily on an unsubstantiated
     mining impact on the deciduous forests, sandhills, sand pine scrub,
     and dry prairies.  The concern centers on over-all areawide
     biological diversity.  However, the failure of the DEIS to
     address the matter through standard resource inventory and cover W"
     mapping techniques is a major shortcoming.
          Postmining restoration potentially can reestablish all
     the forested communities destroyed through mining and so influence
     succession, species distribution, and niche formation in order
     that the mined-communities diversity will approximate that of an
     equivalent natural community within about 50 years.


1.21      "The study area's wetlands include bayheads  (dominated by
          broad-leaved evergreen species), hardwood swamps (dominated
          by broad-leaved, deciduous species), cypress swamps, mangroves,
          wet prairies (emergent herbaceous species), freshwater marshes
          (emergent and floating herbaceous species), and saltwater
          marshes."

          One must know at the outset the relative acreages of wetlands
     of each type.  A certain portion is within present and projected
     mining areas.  Some portion is the result of mining.  A percentage
     is saltwater marsh that is subject to only a remotely possible
     impact from mining many miles inland.  Part of the wetland acreage
     is degraded.  A portion is ephemeral, as the wet prairies which    .
     often lack dominance by hydrophytic flora.  The  generalized      W"
     valuation and the importance of many true wetlands is justifiable.
     However, many ephemerally wet areas lack the hydric soils or
     hydrophytic vegetation normally used to classify an area as
     wetland.  Phosphate mining and restoration has a great potential
     for increasing the inventory of viable wetland habitats over
     the premining condition.


1.22      "These wetland types - hardwood swamps, wet prairies, and
          freshwater marshes - are classified as highly endangered
          lands in Florida."

          The value of an "endangered" label is weakened if the       /4/~
     resource is not, indeed, endangered.  The U. S.  Fish and Wildlife
     Service inventoried Florida's wetlands in 1954 and arrived at a
     total wetland acreage of 17.778,100.  A new inventory is currently
     underway.  If Florida has lost one-half of its wetlands since
     1954, the total would still be about nine million acres.  This
     would not seem to warrent a "highly endangered"  designation.


                                   -7-

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1.22      "On a broader scope, all of central and south Florida's
          wetlands are important since they comprise, along with those
          of southeastern Louisiana,  the remaining wetlands of signifi-
          cant extent and value in the United States."

          This statement is not true.  The 1956 USDI inventory of fc/-^ 5
     "Wetlands of the U.S.," Circular 39,  identified 74,439,300 wetland
     acres in the U.S., of which 17,185,300 were in Florida and
     9,647,300 in Louisiana, or about 1/3  (one-third) of the U.S. total.
     The relative abundance of Florida wetlands, incidentally, points
     to the erroneous impression communicated by a "highly endangered"
     categorization.


1.22      "Wetlands extent is expected to  decline in the seven counties,
          as is the extent of all terrestrial habitat types."

          This projection depends heavily  on the percentage of the
     areas's wetlands in the lands to be mined, the rehabilitation
     methodology, and the success of  wetland protection throughout the
     study area.  Phosphate mining offers  the single greatest potential
     for significantly increasing the wetland acreage.   Slime ponds
     offer a dramatic potential for an extensive acreage of managed
     freshwater marshes in which water level's can be manipulated to
     maximize fish and wildlife values.  Hundreds of millions of
     dollars have been spent by the U.S.,  Canada, and private organi-
     zations such as  Ducks Unlimited  to create and manage waterfowl
     production wetlands not unlike the potential marsh management
     units that could be established  in reclaimed slime ponds.


1.22      "Habitat types of greatest  decline will be those of greatest
          importance  to wildlife."

          This prediction is obscure, if not simply unfounded, since
     the habitat types of greatest decline are not identified.  However,
     the prediction does seem to relate to the projected areawide
     land use with continued increase of man-dominated acres.  Land-
     use regulation will help check that trend.  Phosphate mining and
     reclamation offers the best hope for  locally maintaining and
     increasing the habitat types of  greatest importance to wildlife.


1.22      "More than  500 species and  subspecies of vertebrates
          (excluding  fishes) are represented or have been represented
          in the recent past in the 7-county area; they include some
          28 amphibians, 68 reptiles, 384  birds, and 55 mammals."

          This general statement lacks a realistic perspective of
     expected occurrence and, therefore, potential mining impact.
     Of the 384 birds, for example, 59 are "accidentals" (vagrants)
     that are unlikely to be affected at all by mining.  A dozen of
     these accidentals are listed among the important birds of the
     study area (Table 1.11).  An additional 59 birds are migratory,
     so that about one-third of the birds  listed for the study area
     are exposed to the region only briefly or rarely.

                                   — 8 —

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1.22      "Nearly half of the species are of special interest or
          concern..."

          If almost 50 percent of the vertebrate species found in the .     ._
     seven-county area are of special interest or concern, it would   W~ *- '
     appear that the criteria for including species of special interest
     or concern in the list are unrealistically broad.  The fact that a
     relatively small percentage of the listed species are actually of
     significant interest in conducting mine planning is not emphasized.


1.26      "Further development of the Florida phosphate industry will
          significantly affect the seven counties'  existing uplands
          and wetlands biota, including many important floral and
          faunal species."

          While the "significant affect" of mining is indisputable,
     the net ecological impact can be far more positive than visualized
     by the authors,  dependent entirely on the reclamation, restoration,
     and reversion of mined land.  The art of natural resource manage-
     ment is sophisticated and predicated on several centuries of
     experience.  This is particularly true in terms of the management
     of renewable biological resources.  Foresters, fish and wildlife
     biologists, and others consistently have been more limited by
     economics than knowledge.
          The implication that some species are "more important" than
     others clashes with such basic ecological principles as food
     chains, webs of life, community structure, dependence, and so on.
     The endangered species concept is predicated on the importance
     and interdependence of all species.  Human priorities for the
     management of biological resources may be determined by abundance,
     scarcity, economic use, pest status, and other such interfaces
     with man, none of which relate to the relative ecological impor-
     tance of a species functioning within its niche.  The suggestion
     that some species are more important than others occurs frequently
     in the DEIS.


1.26      "Beyond the effects of devegetation or disturbance, as much
          as 30 percent of the terrestrial habitat in mined areas
          becomes aquatic habitat (lakes and ponds), permanently dis-
          placing the associated flora and fauna."

          The percentage change in cover of a particular premining
     habitat depends entirely on the postmining restoration program.
     Wetland inventories can be increased following mining, as can
     sandhill or scrub habitats.  The preponderance of existing ter-
     restrial habitat in the area has been so severely and adversely
     impacted by man, that an effective and extensive natural system
     restoration program will increase significantly the extent,
     diversity, and standing crop of native flora and fauna.       //t/~" 2L ^f
          Even with no improvement by the industry in the planned
     restoration of natural ecosystems over that which occurred for-
     tuitously in the past via abandonment, the mix of aquatic and
     terrestrial communities results in species diversity, biological
     productivity,  and natural system values far exceeding those

                                   -9-

                                 J-/2-

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     associated with timber, food, and fiber production, the now
     prevailing land-use.  To most of Florida's ecologists and natura-
     lists, the aquatic and wetland habitats created by mining,
     especially following few years of maturing and revegetating of
     the watershed, would be considered a net gain over improved
     pasture, citrus, or a pine plantation.
          Flora and fauna are rarely "permanently displaced", other
     than through evolution and extinction.  The fossils of tropical
     species have been found in the Arctic, while North Temperate
     fossils are common in Florida.  During an Ice Age, temperate-
     requiring species retreat from the growing glaciers, while arctic
     species advance and invade with the glacier.  Classical ecolo-
     gical literature is replete with successional case histories, old
     fields in the midwest being one of the best known.  Similar to a
     natural geomorphic process, strip-mining returns land to a bare
     surface.  Nature abhors bare surfaces and revegetates them as
     quickly and efficiently as possible, beginning the successional
     process yet again.  With man's growing resource management knowl-
     edge and the practical economics associated with mining phosphates,
     the rate of natural revegetation and succession can be advanced
     substantially.  Often, the basic edaphic changes brought on by
     mining can result in a more "complex," or "diverse" mature,
     postraining community.  For example,  a premining cut-over flatwoods
     (partially identified by the DEIS as "palmetto prairies")  is
     destroyed by mining.  The soil hardpan is gone, clays and avail-
     able phosphates increase in the new soil, and with planned restora-
     tion, a mesic hammock can replace improved pasture or native
     range within 50 years.  The Christina site near Lakeland is an
     excellent example.
          "Permanent displacement" is an obvious concern held by the
     authors and most environmentalists.   Few biological species
     display locational continuity through geologic time.  Vegetation
     and animals, through successive generations of individuals,  are
     surprisingly mobile.  Landforms change in time, meteorological
     conditions change, pathways and habitats expand and contract,
     genetic material undergoes change, all these factors pointing to
     the great resilience of most plants and animals in response to
     change.  Alterations brought about by strip mining are within the
     tolerance range of most of the regional biota, as well-documented
     by the biotic communities now occupying the older, previously-
     mined areas.  The DEIS cannot identify either a species or
     assemblage of species "permanently displaced" by Florida phosphate
     mining in this century.  Conversely, aquatic biota in the mining
     area have been significantly enriched as a direct result of
     mining, and many species of terrestrial wildlife have benefited
     from the sanctuary provided by mined lands reverting to nature
     without reclamation.  Indeed, strip-mined lands under ecologically
     sound management have enormous potential for producing lakes,
     wetlands, forests, and their associated wildlife populations.


1.26      "Irreversible alterations in local topography and soil
          structure of remaining land preclude the reestablishment of
          certain existing plant communities, including associations
          within typical pine flatwoods,  dry prairies, hammocks,  sand-
          hills,  sand pine scrub, and forested and nonforested wetlands.'


                                   -10-

                                  2-13

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          There is no technical reason,  when given overburden,  clay
     and clean sand as raw materials,  why satisfactory soil structure
     for most existing plant communities could not be formed.   There
     is evidence to indicate that the  role of soil development  in
     primary succession has been exaggerated, in any case (Drury and
     Nisbet, 1973), and the data of Olson (1958)  suggest that  the
     availability of water and nutrients may be more important  limiting
     factors in the establishment of vegetation than soil structure.
          The authors erroneously feel that the "irreversible  altera-
     tions"  in geomorphology and soils will "preclude the reestablishment,"
     in effect, of most of the former  existing natural plant communities.
     Logically, this can only be true  when the alterations cause changes
     beyond  the tolerance of the biota.   The degree of irreversibility
     can be  adjusted via land shaping  and variations in the sand-clay
     soil composition.   Future restoration technology can provide the
     topographic and soil conditions required for each of the plant
     communities identified in the DEIS  sentence.   Most ecologists
     would prefer increasing the freshwater marsh and aquatic  system
     inventory rather than committing  reclamation resources to  re-
     establishment of pine flatwoods and palmetto rangeland which
     are so  regionally abundant.


1.27      "Although diversity declines primarily because hardwood
          swamps and mixed forest can  be neither reclaimed nor
          naturally restored on mined  land,  establishment of habitat
          similar to existing types is possible and necessary  if much
          of the area's important biota  is to be maintained."

          On any given proposed site in  the area,  50 years after mining,
     the postmining diversity conceivably could be significantly higher
     than before mining.   "Diversity"  is a much misused and misunderstood
     measure of environmental quality,  as expressed,  for example, by
     Hurlbert  (1971) .   Species diversity is an evolutionary product
     of such variables as time, environmental stability,  environmental
     suitability, community structure,  niche formation,  dominance,
     competition, succession, displacement,  replacement,  and other
     factors.
          Mature "climax" communities  may have a lower diversity than
     one of  the serai stages enroute (Whittaker,  1953).   Stability
     is not  necessarily linked to diversity,  and various perturbations
     can increase diversity.   In terms of a large area (i.e. +  20,000
     acres), a mosaic of different plant communities,  each in various
     successional stages, with contiguity between younger and older
     elements will result in a near maximum diversity.   These  conditions
     can be  incorporated readily in a  site-specific restoration plan,
     including a component that is not directly disturbed by mining.
     The idea that on an area-wide basis,  biological diversity  is
     assuredly reduced by mining is unlikely.   Long experience  with
     the older mined lands suggests just the opposite (Edscorn, 1977).
          Several examples of natural  succession of mined lands into
     mixed forest can be seen on older mined lands,  such as at  the
     Christina site and the Tilghman Mine southwest of Fort Meade.
     The mesic hammock now occupying the Christina slime pond  would not

                                   -11-

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     be vegetationally distinguished by most experienced naturalists
     as other than a natural hammock.   The hardwood swamp "forested
     wetland" type could occur on small acreages of previously mined
     lands,  but it has not been observed with certainty.  A small
     cypress head community that appears to be post-mining occurs
     within the dike of a Teneroc Mine area now undergoing reclamation.
     Successional species found on slime areas mined in the 1950 "s
     indicate that hardwood swamp communities can be restored by pro-
     viding the necessary annual hydroperiod on heavy soils and stocking
     with cypress, gum, bays,  and similar species.   Foresters in
     Florida and the South have demonstrated the suitability of using
     nursery trees for reforesting favorable wetland sites.


1.29      "Contaminating the water table aquifer locally are nutrients ^j ^
          from fertilized agricultural land, sewer leakages, and
          seepage from industrial lagoons, septic systems, and landfills."

          Data are not presented in support of the statement.


1.32      "Hydrogeologic conditions favor entrance of contaminants to
          at least the water table and upper Floridan Aquifers.
          However, contamination is generally poorly documented due at
          least in part to monitoring deficiencies."

          Evidence is not presented to support the statement that
     hydrogeologic conditions favor entrance of contaminants to the  Lj
     aquifers.  Radiological data show the quality of water in the
     water-table aquifer to be within EPA drinking water limits and no
     significant differences exist between mined and unmined areas.


1.42      "These lakes generally have steeply graded sides and narrow
          littoral zones of comparatively -low diversity."

          There is no data presented that shows a lower species diversity
     for the mining lakes as contrasted to nearby natural  lakes.   It
     appears that a comparison is being made between -a relatively
     young aquatic system and a premining community which  may have had
     a relatively unlimited period of time in which to achieve its
     degree of diversity.  The deeper water bodies have the ability to
     maintain water throughout the year as well as during  periods of
     significant drought.  The ecological life of the mining pits is JJ-
     much longer than that of shallow, natural lakes because of the
     depth available for detritus and nutrient sink storage.  The lake
     systems occupying reclaimed areas, as well as those of unreclaimed
     areas,  are probably of greater utility to man for recreational
     and sport purposes than were the extremely shallow, periodically
     dry systems which they replaced.   The ability of the  mined areas
     to support a wider range of recreational and sports species, the
     ability of mined areas/reclaimed areas to maintain higher popu-
     lations of recreational species after mining and during droughts
     than in the premined or natural condition will probably be greater.


                                   -12-
                                  J-/.T

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     Further,  maintaining portions of the mined areas in an unreclaimed
     and therefore,  relatively inaccessible state, should preclude
     disturbances by man in the future and allow a refuge area for
     certain species.


1.44      "Phosphate mining within the study area might potentially
          affect only three of the 13 threatened and endangered
          species."

          This comment is much more in perspective than the listing of
     approximately 50 percent of the vertebrate species of the area
     which gives the superficial appearance of a high degree of concern
     for most of the vertebrate species in the area.   That mining might
     potentially affect only three protected aquatic species is signifi-
     cant when considering a region of such extensive aquatic habitat.
     Even more important, and not adequately addressed, is the extent
     and nature of potential impacts.
          Although the narrative does recognize that the alligator "is
     not seriously threatened in Florida," it does not quote from the /.•/._ 3 <""
     terrestrial biota working paper (TI, 1977e, p. 5.55) that it is
     "abundant in optimum habitat within the study area" which includes
     much of the mining-created aquatic habitat.  An impact assessment
     later in the DEIS (p. 2.53). states that "Land preparation and
     mining...will cause some loss of habitat and displace the American
     alligator, but likely will have no adverse impact on the area's
     alligator population."  It does not mention, however, that this
     species'  population probably will expand as a result of a net
     increase in aquatic habitat due to mining.  Further, much of the
     mining-created wetlands can have a higher sanctuary value than the
     generally more accessible natural system wetlands.  Hunting was
     the major factor in the alligator's decline.
          Mining activity is not likely to directly disturb any of the
     recognized manatee habitat within the study area, which includes
     portions of the downstream reaches of the Myakka, Little Manatee
     and Peace Rivers, as well as coastal areas.  Some 500 of these
     animals have been estimated to occur along Florida's Gulf Coast.
     The impact assessment (DEIS p. 2.53) states that mining alterations
     are expected to have "only very minor effects on the...manatee
     through a potentially altered distribution of food plants" (via
     possible slime spills, not mining per se ) .
          The narrative indicates that "the Suwannee cooter...is
     apparently limited to the Alafia River and particularly in the
     Lithia Springs area."  The DEIS provides no specific study area
     figure with a composite of the natural system habitat features
     and the proposed mining areas.  Therefore, it is difficult or
     impossible to correlate species-specific habitat ranges with pro-
     posed mining activity.  This type of graphic is normally considered
     to be required and essential base-line information in a document
     of this type.   The appropriate working paper (TI, 1977e, p. 5.56)
     does note that this species "apparently is quite rare in the study
     area" and the impact section of the DEIS  (p. 2.53) indicates the
     same "very minor effects'1 from mining as it does for the manatee.
          When assessing the available information given for threatened
     and endangered aquatic species in the study area, the evidence

                                   -13-

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     indicates that mining activity will have a negligible impact on
     the continued population viability of the three aquatic species
     of immediate concern.  The alligator population will, in fact, be
     positively affected by the proposed action over the long-term.
     The overwhelming threat to the continued survival of all three
     species is detrimental human activity involving guns and boats,
     both intentional and unintentional.  Nowhere in the text can one
     find such bottom-line conclusions derived from the given information.


1.46      "Perhaps the most severe nuisance of the fresh waters is the
          prolific growth of exotic hydrophytes including..."

          The excessive growth of nuisance species also occurs in   frj- J S
     unmined waters and should not be considered a problem peculiar
     to, or more difficult to control in, waters created as a result
     of mining.


1.48      "...the phosphate industry currently mines slightly more
          total uranium than does the uranium industry-"

          The phosphate industry handles large tonnages of clay annually,
     compared to the clay mineral industry, but this in no way suggests
     that the phosphate industry is engaged in clay mining.  The word
     "mines" in reference to uranium should not be confused with       L^
     "processing" or "chemical refinement" of the element.  Use of the
     term represents a misleading statement concerning ease of recovery
     and level of industry activity.


1.49      "Figure 1.15: Average Uranium Concentrations as U3O8  in
          Typical Central Florida Phosphate District Profile."

          The U308 equivalents are given for "high BPL" and "low BPL"  t*J ~ 3 B
     without definition of the ranges of BPL involved.  Uranium con-
     centrations in phosphate rock vary as a function of the BPL content,
     the higher the BPL the higher the uranium, but the relationship
     may vary according to the phosphate rock size fraction.


1.52      "...the average annual dose equivalent in excess of the average
          natural background for persons living on reclaimed land within
          the study area is calculated to be 540 millirems per year
          to the whole lung, 36 millirems per year to the bone marrow,
          and 22.5 millirems per year to the gonads.  The average     LJ
          gamma exposure on reclaimed land is 88 millirems per year."

          The bone marrow dose in excess of background is 4 millirems
     per year and average gamma exposure is 70 millirems per year.  The
     reference for the gonad dose is not indicated in the text.


1.58      "...especially in Hardee and Polk Counties..."

                                   -14-

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          Change Hardee to Hillsborough.


1.59      "Mining does not appear to have played a significant role in
          the growth of the region since 1960."

          See comments concerning page 1.4.


1.61      "Table 1.30: Generalized Land Use, 7-County Study Area,
          1975."

          Percentages shown are for study area, not county.      [*J ~- 4
1.62      "Under the Level-I category 'Barren Land,1 the Level-II
          category 'Strip Mines, Quarries, and Gravel Pits' comprises
          only 3.12 percent of the entire study.  Polk County has a
          noticeable concentration, however; 12.5 percent of the
          county is in this land-use category."

          This categorization does not allow notice to be taken of the
     age of the mined areas nor the value of the system reestablished 1
     on the older mined areas.


1.65      "Water, which includes all surface water, will increase over
          the 7 county study area between 1975 and 2000 by only 0.9
          percent. "

          The 0.9 percent translates to 1,550 acres, presumably lakes
     created by phosphate mining.  It would be surprising if a great
     deal more lake acreage did not result from projected mining based l
     on past experience in Polk County.   Tables 2.5 (p. 2.13)  and 2.7
     (p. 2.14) show much larger increases in water areas for all
     scenarios than the above projection.


1.65      "Wetlands"

          The projected decline in wetlands of -1.1 percent should be
     presented here and discussed.  This projection is most likely to
     be erroneous assuming (1) state and federal protection of existing
     wetlands, and (2) the creation of new wetlands via phosphate
     mining.  The "Barren Land" discussion reflects projected increases
     in area mined; therefore, this should be reflected in aquatic and
     wetland increases.


1.65      "Archeological, Historical, and Recreational Resources."

          Most of the 791 known sites would not be of sufficient
     importance to cause a professional archeologist to recommend that
     they be protected from mining.  Very few are within the area pro-
     jected for mining.  These might have to be "worked" for structure


                                   -15-

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     and collection of artifacts prior to mining.   A few might require
     preservation.   These are decisions provided for in the site -
     specific DRI  and EIS process.   Mining,  itself, often yields
     important data and finds otherwise buried from discovery, a posi-
     tive impact not identified in  the DEIS.


1.66      "Table 1.32: Extent of Recreational Areas in the Seven Counties
          of Study."

          Nearly one-half of the recreational acres in the study area
     occur in Polk County as at Saddle Creek Park,  largely as a result
     of reclamation and the creation of aquatic systems which form the
     primary natural attraction for outdoor  recreation.   While this   «.•
     acreage can be expected to increase dramatically as a result of  **/
     future mining,  no such positive impact  is identified here.


1.67      "It was .concluded that the most useful and manageable way
          to analyze the impacts of present  and proposed phosphate
          development is through reliance on existing information and
          studies."

          Since little significant  information has  been accumulated
     on mined areas, the lack of consideration of existing literature
     for other systems which indicate their  rate of recovery from
     disturbance would indicate that the conclusion to rely primarily
     upon existing  information was  much too  narrowly applied.   Reasoned
     extrapolation  of available literature on comparable problems was
     not applied.   Further,  the utilization  of existing literature  is ,\^
     heavily biased toward an extensive examination of the premining  »J~
     condition with relatively little attention on  the possibilities
     and potential  for utilization  of the postmining systems.
                                   -16-

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2.3        "...  the effects were added algebraically under each
           environmental element."

           The methodology involves, predominantly, subjective
     assignment of values to impacts within each scenario.
     These ordinal rankings are then summed algebraically.
     The result is a quantity that has no objective meaning and
     that is not subject to replication.
2.4        "Dry conveyor for matrix from mine to beneficiation."

           There is no possibility of producing dry matrix at the
     mine face.
2.5        "Any disturbed wetlands are to be restored to provide
           at least an equivalent habitat for any species on the
           Important Species List for which habitat existed prior
           to mining.  Restoration is to be accomplished so that
           no more than ten percent of such habitat is destroyed
           at any one time."

           It is doubted that the "Important Species List" is
     ecologically viable.  In terms of community structure and
     ecosystem dynamics, all species should be considered equally
     important.  Importance is not to be confused with dominance
     or frequency, and is usually applied in terms of relationship       .
     to man rather than ecosystem function.  Maintaining natural   U)5  /
     system values in the area will involve the variety of habitat
     types, not just wetlands.
           The 10% figure is arbitrary.  Keying mining rate to
     the rate at which wetlands can be restored is an impractical
     approach.


2.11       "Table 2.1: Assessment of World Phosphate Reserves and
           Resources."

           The following table entries seem to be in error:
           Africa - Total Resources - Metric Tons
           World - Other Resources - Metric and Short Tons
                                 -17-
                                   3- 2.0

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18       "...and the land cannot be used for industrial or
         commercial development involving structures larger
         than most single-family dwellings."

         See comments concerning p. 1.8.


18       "Elimination of Slime Ponds."

         Because of the unique potential of phosphate mining to
   create aquatic and terrestrial ecosystems economically as part
   of the expense of mining and because these mining operations
   take place in counties already so heavily impacted by man that
   the natural habitats are seriously diminished in quantity
   and quality, it is believed that the interests of society,
   the industry, and Nature would be best served by maximizing
   the creation of natural systems in the postmining environment.
   The DEIS often appears to favor reclamation for agricultural,
   industrial, commercial, and residential uses.  This diverts the
   large cost of reclamation to subsidize man-intensive land
   uses already abundant throughout the study area, whereas the
   regional ecosystem would be most benefited by the creation of
   natural systems to provide the support and services
   necessitated by the present preponderance of man-dominated
   uses.
         Both slime ponds and sand tailings serve as the soil
   building blocks for forested and marsh wetlands on the
   clays, and scrub, sandhill, and xeric hammock habitats on
   the sands.  Abandonment of the use of slime ponds entirely
   would represent a serious loss of potential wetlands.  Filling
   the mine pits with clay and sand precludes their possible
   use as lakes.
20       "Subsequent subsidence could occur,  limiting subsequent
         land uses to those in which overburden pressures are     .
         no greater than those resulting from agricultural      I*'
         production."

         There is no indication that subsequent land uses on
   sand-clay reclaimed areas will be so limited.
21       "The term 'dry conveyor'  is a misnomer."

         The term has no current meaning in the industry.     I*/—" S> 5
                               -18-
                                   -2 I

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2.27      "Because of the lack of data on the extent, if
          any, of surface and subsurface seepage and the
          feasibility and adequacy of impervious linings to
          control this potential source of pollution, effects
          assessment did not include an objective and
          quantitative evaluation of this process modification."

          It must be assumed, therefore, that any recommendations
     relative to gypsum pond linings are subjective and unsub->
     stantiated.  Extensive study in the area is being conducted
     jointly by the Industry and the Florida Department of
     Environmental Regulation.  Recommendations should not be bJ'
     made prior to analysis of data generated by this study.


2.27      "For transporting the ore from pit to wash plant,
          a conveyor belt system is being tried at one
          location as an alternative to the conventional
          matrix slurry pipeline, resulting in a decrease in
          (water use) and electric power consumption (Hoppe 1976)."

          The specific disclaimer by Mr. Timberlake, manager
     of the o'nly company which uses a matrix conveyor,  indicates
     that decreased water use does not result from use of the  t+J-JS?'?
     matrix conveyor.


2.28      "To determine the net result of rainfall
          containment..."

          The analysis is oversimplified to the extent that a
     generalized conclusion cannot be drawn from the calculation.


2.33      "One recent applicant was given boundaries in
          Hookers Prairie that encompass approximately 50
          percent more area than indicated on the USGS map."

          The Hookers Prairie area has been significantly
     modified by adjacent phosphate mining operations without
     similar modifications being made on available maps.  Further,
     the Corps of Engineers' determination was based on a recent
     observation of suitably vegetated areas.  The discrepency  /jJ
     between the observed wetted area and available maps is no
     doubt an extreme case, but serves to point out the necessity
     for site-specific work to determine the vegetative structure
     of an area.  It is even more important to determine the
     functions served by an area and make certain that they are
     sufficiently valuable to justify not mining an area.

                             -19-

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2.33      "Those in wetlands potentially affected by
          phosphate industry activities are as follows:"

          Many of the listed species listed as wetland range
     over a variety of terrestrial and aquatic communities,   W~<*
     such as particular snakes,  hawks, woodpeckers and mammals.
     Also, the diamondback terrapin is a creature of mangroves and
     brackish water, and should  not be listed among the upland
     wetland species.  Whether the eastern indigo snake, southern
     hognose snake, hairy woodpecker,  sharp-shinned hawk,
     American woodcock, pileated woodpecker,  and bobcat should be
     listed among animals endemic to wetlands is highly question-
     able, as well.  Given sufficient time, unreclaimed mining
     lands have demonstrated capability to produce habitat
     suitable for most, if not all, of the listed species.  With
     modern knowledge about site preparation and habitat manage-
     ment, equivalent habitat establishment for these and  other
     species should be readily achievable over time.


2.34      "No feasible means of  restoring wetlands has been
          demonstrated, although reclamation can result in
          wet lands."

          It has been the human  experience that if man, glacier,
     landslide, or whatever causes land to be wet long enough
     to sustain hydrophytic vegetation,  a wetland results.  The
     USDA and USDI have been promoting and funding the construction
     of man-made wetlands for nearly fifty years.   With built-in
     water management controls,  man-made wetlands can exceed
     "natural wetlands" in productivity.   One USDA administrator
     estimated that 3.3 million  farm ponds will have been
     constructed in the U. S. by 1980, averaging about one acre
     each.  The total acreage of man-made reservoirs, impound-
     ments, and marshes undoubtedly exceeds that of farm ponds.
     While natural wetlands often will be superior to man-made
     wetlands in their over-all  quality,  the differences are
     usually attributable to construction, management, or  the
     designed use.
          Man can and has constructed large acreages of wetlands
     with superior natural system values.   The potential for
     doing so as part of the strip-mining process is enormous.
     The DEIS seriously errs in  suggesting otherwise.  The
     bottom-line concern stated  in the DEIS,  and held by con-
     servationists, regulatory agency staffs, and many others
     is that of holding the line on the loss of wetland habitat,
     and secondarily that of scrub, sandhill, and hammock
     communities.   The logic of  habitat is so simple:  without
     it management of the wildlife resource is fruitless
     because life is denied.  Conversely,  wildlife can with-
     stand an incredible array of attacks if its habitat remains
     intact.


                             -20-

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     Unfortunately, most of the 3,567,723 acres in the
study area is poor wildlife habitat because man has put
so much of the area into alternative land uses that provide
a higher immediate cash crop.  Ironically, and quite by
accident, much of the best remaining wildlife habitat in
the minded areas is also man-made in the form of unreclaimed
land.  Well-intentioned conservationists, environmentalists,
government leaders, even professional ecologists and
resource managers may be missing the habitat message that
can be abundantly read on the previously-mined landscape of
Polk County  (for example, Edscorn, 1977).  While the Edscorn
paper was available to the authors and to the Archbold
study team, it had little or no apparent impact in shaping
the opinions and conclusions in either report.
     Modern-man is an effective destroyer of wildlife
habitat, but he can be just as efficient at restoring
habitat.  He seldom has the chance because restoring habitat
is far' more expensive that destroying it.  This is why strip-
mining can be such a powerful force for habitat restoration,
since restoration costs can be built into the pricing of
the phosphate matrix, and into the mining process itself.
The attention of those wanting to maximize natural habitat
should be directed toward restoring more and better acreage
behind the mining, rather than preservation from mining of
often severely impacted habitats.
     The best example of massive wetland habitat restoration
can be credited to Ducks Unlimited.  In 40 years, Ducks
Unlimited has spent over $40 million to built 1,347 wetland
habitat projects in Canada, resulting in 2.5 million wetland
acres with 10,000 miles of wetland-upland edge.  Their 1977
program spent $10 million on 118 new wetland habitats, adding
60,000 acres.  In many drought years, a preponderance of
waterfowl production occurs on the man-made marshes that
hold water due to structures when the natural wetlands are dry.
     The U. S. waterfowl program has a $100 million annual
budget, part of which goes into establishing new, man-made
wetlands.  Some 15 states now sell state duck stamps to raise
revenues to create and restore wetlands.  These and many
other case histories establish that man can build high
quality wetlands.  He certainly can do so as part of the
phosphate mining process.
     The quoted excerpt from Fisheries, Volume 2 (4):7
(DEIS p.2.35) is taken from an"opinion" editorial and not a
scientific paper.  Perhaps Nature does create the wetland,
but man can and does saturate the land with water,  which
immediately starts the creative process.  Wetland succession
through maturity and senescence can be very rapid or very slow,
depending on the specific wetland.

                        -21-

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2.35      "Only nature can create a wetland."

          I'f it is true that only nature can create a wetland,
     then it seems to be obvious to natural resource managers
     in the state that nature cannot maintain a wetland.  The
     St. Mark's National Wildlife Refuge, Paine 's Prairie
     Loxahatchee and virtually any other federally or state   i*J— 6> "^_
     owned wildlife management area, particularly those with
     wooded areas, are under a management program of one sort
     or another to modify and/or maintain a certain composition
     of vegetation and associated organisms


2.37      "Table 2.8: Environmental Impact Summary."

          The economic "score" for each of the scenarios
     is equal, a glaring indication of the failure to seriously U/~ £ £
     consider economic effects of the different scenarios.


2.38      "If decision weighting factors for social and economic
          environmental elements had been as high as many of
          the weights for natural environmental elements,       U/
          summary results probably would have shown net positive
          impacts. "

          This bias in favor of environmental elements prevents
     analysis in a manner that would permit a balancing against
     socioeconomic benefits.


2.40      "Large clay-slime storage impoundments and stacking
          waste gypsum load the surface, causing the primary
          effect.  No data exist, however, to support quantification
          of the potential for collapse of a slime impoundment
          of gypsum stack."
          No data exists to support the potential for collapse
     since a cause-effect relationship is unlikely.   In fact,
     loading due to slime placement in a mined-out settling area
     ordinarily involves stresses less than those associated
     with the original matrix.


2.40      "...new soils will develop that may be better suited."

          The "new" soils with increased clays enhance restoration
     of forested and marsh wetlands and mesic hammocks.  Sand
     tailings enhance the potential for restoring scrub and
     sandhill communities.  Evidence of dramatic improvement in
     growth of pines relative to growth on nearby undisturbed
     land is presented by Devall (1950) .

                             -22-
                              3-

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2.40      "Topographical effects will be caused primarily by
          excavations to remove phosphate ore ...  however,
          reclamation will restore these lands to nearly their
          original contours."

          Optimum natural system habitat restoration should
     not return lands to "nearly their original contours".
     This is one of the clear dichotomies between reclaiming for
     intensive human use or restoring for wildlife habitat with  (jj
     dense cover and sanctuary.  The irregular slopes of un-
     reclaimed land that limit access are an important factor in
     setting wildlife value.


2.42      "Certain existing plant communities are permanently
          displaced."

          No. plant community need be displaced on the long-
     term if restoring that plant community is a fully-funded
     objective of the site-specific restoration plant.
     "Permanently" is a human concept as applied here.  Given
     adequate time and no restoration, weathering, erosion, and
     vegetative succession, virtually every plant community    uj
     present on a site prior to mining is likely to return
     eventually after mining.  The extent and locations of the
     communities will change as a result, but permanent extirpation
     of a community type over a large area is extremely remote.


2.42      "As much as 30 percent of the mined uplands/wetlands
          habitat becomes aquatic habitat."

          The percent of wetlands depends heavily  on the site-
     specific restoration plan and easily can be greater in    £»/- (&
     acreage than the aquatic habitat.  The created aquatic
     habitats are high in natural system values in their own right.
     They are also of great value and utility to man, especially
     in the counties with a very small lake inventory.


2.42      "Habitat quality of unmined as well as mined
          land is degraded."

          Realistically, the preponderance of land projected for
     mining in this area has been severely degraded already as   (^)"
     wildlife habitat, an observation made in the DEIS.  Manage-
     ment methods exist to offset many mining impacts on adjacent
     unmined habitats if they are needed.  The fact remains that
     among the very best natural habitats existing in the area,
     especially from a fish and wildlife perspective, is the
     unreclaimed lands mined before 1950.

                             -23-

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2.42      "Diversity is diminished."

          While obviously true of lands recently mined, there
     are no quantified data comparing diversity values for mined
     vs. unmined mesic hammock (as at the Christima site)  or
     a mined, forested wetland (scrub stage)  with an unmined one
     or, even a mined reclaimed pasture to an unmined one.  These
     are the types of studies that would be required for an
     accurate evaluation of impacts.                                  ,
          Unreclaimed lands mined between 1900-1920 that have  (J "  f /
     had 50 or more years to mature appear at least to have
     equal species diversity when compared to unmined habitats
     in the area.  This opinion is based on naturalistic expertise
     and 30 years of field ecology, both of which are inferior to
     data.  However, the alleged reduction in biological diversity
     is central to the validity of the impact assessment conclusions
     and until quantified studies are available, the question
     cannot.be reconciled.
          Biological productivity can be of equal or greater
     importance than diversity, yet this is never mentioned.  Net
     productivity appears to increase after mining, probably
     because of soil and water changes, increased fertility,
     increased edge between habitats and increased miles of
     aquatic shorelines.  Restoration is limited only by technology
     and funding.  As both increase, if emphasis is given to
     natural system restoration,  diversity will increase rapidly
     as more niches are created and filled.


2.42      "Local populations of many important species are
          reduced."

          All species are important.  Most lands to be mined
     are understocked, poor habitat.  Mining at any one time  k/— 7 c^
     takes only a small portion of a particular species
     habitat within either the mine site or region.  Reasonable
     rates of postmining restoration should provide increased
     acreages and productivity of critical natural habitats.
     Wildlife are resilient and will withstand a local
     perturbation if there are adequate habitat inventories
     ahead of, adjacent to, or behind the mining.


2.42      "Estimates of evergreen forests are considered
          reliable, but it is impossible to estimate present
          or future areawide extents of either mixed or
          deciduous forests because of the paucity of data
          of appropriate detail."

                             -24-

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          It is a significant shortcoming of the document that it
     does not contain an accurate vegetative cover map' and a
     corresponding table of acreage and percent cover by plant  (A/""73
     association.  The information can be compiled from aerial
     photography, ground^truthing site surveys, available literary
     references and existing DRI's.  Such information is
     essential for assessment of the scope and scale of potential
     impacts.  The land area figures used in the DEIS are based
     on land use categories and total ecosystem extent rather
     than a more interpretively useful breakdown by individual
     plant communities.


2.42      "None of the forest types can be restored to their
          native condition on mined lands."

          This statement is refuted by several thousand acres .»_ -7 ^_
     of native forests growing on previously mined land..


2.42      "The deep sand soils necessary for mixed forests
          are irreversibly altered."

          Most of the true sandhill and scrub forests in the area
     seem to be outside of the lands projected for mining.  At
     most, a couple of hundred acres may be at issue.  These soils
     are, by nature, relatively sterile and lacking in a complex  soil
     horizon profile and, therefore, are among the easiest of the
     specific plant community soil types to restructure after
     mining.  Sand tailings should make excellent sites for xeric
     hammocks and mixed forests.  Tailings usually have gone to
     dry pasture.  However, there are several examples of high
     survival, good vigor, and growth of slash pine plantations
     on tailings.  Restoration of sand tailings to create xeric
     hammocks and mixed forests could greatly increase the overall
     inventory of these habitats in the area.
          Mixed forest species are relatively shallowly rooted
     and more dependent upon moisture conditions than on the
     presence of deep sand soils.  The pine flatwoods is the most
     common forest type in Florida.  Its failure to become
     identically reestablished on the reclaimed soils is neither
     particularly significant nor should it be taken as an
     indication that a functionally similar or improved system
     would not result.

                             -25-

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2.42      "...  the loss of underlying organic hardpan precludes
          the re-establishment of typical pine flatwoods."

          It is difficult to conceive why any land manager would
     recommend restoration funds be committed to creating pine
     flatwoods, with hardpan, when the regional inventory already
     is so high.  The DEIS states, "By far the greatest amount of
     remaining forest in the study area is typical pine flatwoods"
     (p.1.21).


2.42      "...  and the configuration as well as the species
          composition of hammocks is destroyed."

          This is not a true statement, as evidenced by mesic
     hammocks on mined lands, such as that at the Christina site.
     No effort, thus far, has been made to deliberately restore     __ -
     mesic hammock.   All those reoccurring can be attributable  **' "~
     to a naturally favorable site environment.  If appropriate
     species are selected for planting and if soil and topographic
     factors are accomodated in the site-specific restoration
     plan, then establishment of a mesic hammock would be expected.


2.42      "Less important but still unreclaimable in its native
          condition is mined rangeland."

          "Rangeland" throughout the area largely is a disclimax
     created by man and does not have a "native condition."
     Pine flatwoods are the "native condition" which has been
     converted into range by cutting, frequent burning, disking,
     use of herbicides, and often eventually moving into an     Lj—~?&
     "improved pasture" use.  The low value as natural habitat
     of the 2+ million acres of range and agricultural lands
     which will dominate every projected mining site provides a
     compromise that may lead sensible environmentalists to
     support mining if the restoration emphasis is placed on
     creating natural habitats.  On the other hand, as part of
     site-specific restoration plans, rangeland can be and has
     been reestablished.


2.43      "This is a small (3 percent) but important portion
          of areawide wetlands extent."

          Three percent of the area inventory is indeed small    .  _ Q
     and should be easily doubled or even tripled through       **/~ • "
     restoration.  It is difficult, in any case, to evaluate the
     importance of this 3% without some qualitative review of the
     actual habitats.

                             -26-

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2.43      "There is no indication that wetlands of any kind can
          be restored on mined land.  Not only are the low-
          relief topography and attendant drainage patterns of
          wetlands difficult to restore, but the deep, water-
          logged soils of many wetlands can be neither
          restructured nor feasibility conserved."

          This conclusion is totally erroneous.  Numerous
     wetland habitats occur on currently and previously mined
     lands.   Existing postmining wetlands vary greatly in
     quality.  They exist by accident rather than design and  UJ —
     intent.  Deliberate, planned restoration could produce
     nonforested wetlands of greater productivity and diversity
     than most of those occurring naturally prior to mining.
     Backfilling during the reclamation process provides control
     over ultimate topography.  Establishment of moisture and
     drainage conditions through soil selection and final
     contouring provides the starting point for wetland formation.
     Hydric soils develop rapidly in productive wetlands with
     an adequate hydroperiod.


2.43      "That the quality of terrestrial habitat generally
          reclaimed in mined areas is inferior is readily apparent
          when comparing wildlife usage of managed systems with
          that of essentially natural systems."

          The poor natural system values of recently reclaimed
     mined land reflect the intent to reclaim to a man-dominated
     end product.  Even for purposeful restoration toward a
     natural system, it is unrealistic to compare an early
     succession post-reclamation system to a long established
     natural community.


2.43      "They can be maintained at no cost to man.  To
          maintain agricultural habitat types as such, it is
          necessary to use external controls..."

          It should be obvious that the early post-reclamation
     ecosystems which received a cost or energy subsidy from
     man is due in part to present reclamation requirements.
     Early reestablishment of some vegetation type which will / i_ 
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2.43      "Habitat fragmentation will have lasting effects,
          likely reducing the carrying capacity of the remaining
          habitat for wide-ranging herbivores (e.g., deer)  and
          carnivores (e.g.,  bobcat)."

          The present fragmented system of either premining
     pasture/range conditions or the postmining reclaimed and
     unreclaimed areas have  relatively high bobcat populations.
     The mixture of brushy,  early succession areas, which occur
     either in postmining areas or in range habitat and adjacent
     forested floodplain or  other wetland areas,  offers a
     relatively good to ideal habitat for bobcat.  In addition,
     deer are also recognized as being species preferring         Q "%
     relatively open young successional stages and are not     tv-o <3
     found in mature deeply  wooded areas at near the same
     population levels.  Therefore, this statement concerning
     bobcat and deer is incorrect.


2.44      "Mining is likely  to affect 12 threatened and
          endangered vertebrates and may affect six others
          (see Table 1.15)  although their presence in the
          mining areas is doubtful."

          Language suggesting that mining is "likely" to affect
     animals whose presence  is "doubtful" is unnecessarily
     vague and ambiguous. Further, the endangered species
     impact assessment for terrestrial and wetland animals
     consists of one paragraph of discussion sandwiched between
     the treatment of erosion and commercial and recreational
     animals, without even a topic heading.  If the reviewer   IA/
     refers, as directed to  Table 1.15 (p.1.44)  for a listing
     of the 18 "land and wetlands" protected species, he
     encounteres a list of 13 "Aquatic Species Designated
     Endangered, Threatened, Rare or Special Concern" virtually
     all of which are marine species.  In fact,  a table listing
     the 18 threatened and endangered terrestrial vertebrates
     does not exist.  Beyond this, the referenced 18 vertebrates
     are not even identified!
          Apart from all the technical reporting problems,  the only
     factual statement'of note is mention of the inconsequential
     impacts on the Osprey and Caracara.   It is evident from
     observation of mined lands that the Osprey is attracted to
     mined lands'  water bodies.  It is also quite likely that the
     Least Tern, Peregrine Falcon and Wood Stork will be attracted
     to the water bodies and uplands of reclaimed lands.

                             -28-

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2.44      "The recreational potential of hunting quail and
          squirrel ...  will be reduced.  Deer and wild hog
          habitat will be reduced."

          This is not expected to occur to any significant degree
     due to proposed mining and, in fact, quail and dove should   (^—6
     be benefited by mining.  Most game species are not creatures
     of the deep woods,  but are adapted to and managed for on
     relatively young succession lands.


2.45      "... but continued habitat loss eventually will
          eliminate certain species from the game list and
          degrade the quality of hunting."

          No evidence is available to support the conclusion  i.J—$((>
     that certain species will be eliminated from the area.


2.45      "Mining will adversely affect more than one-half
          of approximately 75 ecologically significant species
          in the 7 - county region."

          The trend throughout the DEIS is to make incredibly
     generalized assessments of mining's impact on the regional
     biota, without reference to magnitude, duration, specific
     species or restoration.  The vast majority of the
     "ecologically significant species" will experience only
     short-term perturbation, and many will incur negligible   {^J ~ & "7
     impacts on local populations.  None of these species are
     either threatened or endangered.  The long-term degree of
     assessment attempts to lump 30 to 40 vertebrates into an
     adversely affected category without any identification or
     quantification,  rendering a meaningful critique of this
     opinion impossible.
          The value of a species list for protection, conservation
     or consideration of species from impacts decreases as the
     number of species placed on the list increases.  When
     approximately half the species occurring in an area appear
     on one list or another, almost any action affecting the
     environment will affect some of the listed species.  Therefore,
     the value of such lists as guides for planning activities
     having an environmental effect is vastly decreased.


2.45      "Mining activities will increase the potential of
          several species to reach population levels of nuisance
          or pest proportions.  Mammal pests will proliferate
          around work areas and expanded urban areas.  Bird
          pests will become more abundant in similar areas as
          well as on reclaimed pastures and croplands.  Insect
          pests will proliferate around cattle, in areas devoted
          to monoculture, and in the nutrient-rich reclaimed lakes."

                             -29-

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          A listing of the several species potentially reaching
     pest proportions would be helpful in assessing the validity
     of this general statement.   There is no documentation in
     the text of a proliferation of nuisance animals on lands
     that have been mined during the past 70-80 years, and,
     therefore, no reason to believe this situation will occur
     in the future.  The fact that some mammal pests occur
     around work areas and urban areas is not unique to mining,
     and would occur no matter what the nature of cultural      \jJ~oiJ
     alteration.  There is absolutely no evidence for the
     statement that bird pests will become abundant on reclaimed
     pastures and cropland.  Again, a listing of these theoretical
     species would be necessary to further evaluate this opinion.
     Florida has many hundreds of thousands of acres occupied by
     cattle, crops and nutrient-rich lakes without any unusual
     proliferation of insect pests.  There is no apparent basis
     for applying this statement to mined lands.  There is
     considerable existing evidence to the contrary.
          The previously mined areas appear remarkably free of
     these projected effects.  Most of the identified potential
     pest problems are associated with intensive human use or
     occupation of reclaimed land.


2.50      "... and for the lower Floridan, 196 picocuries
          per liter."                                        ^_

          The correct value is 1.96.


2.50      "However, ground water has been and probably will
          continue to be locally contaminated.  Specific areas
          of concern include the large slime impoundments, the
          waste-gupsum stacks, and the large process-water cooling
          ponds."

          Evidence of radiochemical contamination of groundwater Lj
     due to phosphate industry activities does not exist.


2.52      "Combined loadings of chemical pollutional parameters
          (especially phosphates, fluorides, and total suspended
          solids) from discharges of nonprocess and process
          wastewaters to various stream segments."
                                                               U/ -
          Such loadings are governed by EPA effluent discharge
     standards.


2.52      "The creation of many water impoundments that will
          tend to deteriorate water quality by permitting
          over-enrichment."

          Impoundments will be created.  However, water quality Lj^
     degradation may not be assumed.

                             -30-

                                3-33

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2.52      "Local surface-water deterioration from clearing,
          burning, construction, reclamation, slime spills,
          and seepage from contaminated ponds.  Local water-
          table quality deterioration because of draining
          and dewatering, overburden, product storage, seepage
          from contaminated ponds, and reclamation of mining
          pits,"

          Surface water quality is protected by discharge
     standards.  Groundwater contamination due to phosphate i>J—^ "
     industry activity is not documented.


2.52      "Local Floridan aquifer water quality deterioration
          from wastewater injection."

          Wastewater injection has not been practiced within the
     phosphate industry and implementation of the practice is  ^-
     not contemplated.


2.53      "Of the 13 aquatic species endangered, threatened,
          rare or of special concern, only the American
          alligator, Suwannee cooter and manatee might
          potentially be affected by phosphate industry
          activities.

          Of these three species only the American alligator
     is likely to be affected.  However, given the alligator's
     recent and continuing population expansion in Florida, any
     concern in the mining area is unwarranted.  The creation
     of aquatic habitat will probably result in an increased
     areawide alligator population.  It is interesting to note   t*J
     that one begins with a species list including approximately
     half the vertebrates occurring in the study area, reduces
     that to 13 aquatic species, and then finds that only one of
     those could be expected to be significantly affected by
     mining.  This rather dramatically highlights the problem
     of a too-inclusive species list.  Note that with regard to
     all species, no case of extirpation nor serious population
     decline is projected.


2.53      "Slime placement poses a potential for the most
          significant adverse impact on rare and endangered
          aquatic species of the study area."

          A direct connection between slime placement and the  ujf- 3 (?
     safety of rare and endangered species is tenuous at best.

                             -31-

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2.54      "...  stream ecosystems generally recover in
          2 to 5 years."

          This should be compared with the approximately 4000
     years stated as being required for recovery of a wetland
     (p.2.35).  The comparison points to the fact that the
     wetland projection is seriously in error.   Every severe £*/-? r
     flood has similar effects and the stream habitats are
     adapted to benefit from them.


2.54      "...  present reclamation must be altered to
          include lakes and ponds with wide littoral zones
          and other areas (e.g.,  'marshy1  islands)  ..."

          This paragraph is of special interest because a
     change in reclamation technology is recommended.   Almost
     all  the impacts discussed thus far would differ with
     changes in restoration technology, but this is one of
     the  first times the authors  identify or recommend a change.


2.54      "The steep-sided,  relatively deep lakes now
          predominating are of little long term value;  they
          quickly become degraded and/or eutrophic."

          Most of the mined lakes with high phosphates are
     remarkably slow to degrade or eutrophy when compared to most
     Central Florida lakes.   This is precisely because of the
     deep open water and relatively narrow littoral zone.  While
     the  lakes can be improved in design,  they should continue to
     be deep with an increased but still small ratio of shallows
     to open water.


2.55      "Draining and dewatering low, wet areas,  thus
          eliminating breeding areas for midges and mosquitos,
          will have a positive effect but will be more than
          offset by the industry's creation of additional
          surface water."

          A quantitative projection of acreage to be drained
     in the 7 - county area compared to new water area created
     by mining activity is necessary to evaluate this impact.  M/~r
          The pest species are areawide problems independent of
     mining.  When mining increases aquatic and wetland systems,  it
     increases habitat for many of the pest species.  However, their
     "pest" status usually relates to an interface with man, which
     is reduced in wildland settings.  Midges and mosquitos are
     part of the food chain for many species.  Far more ecological
     damage has been done under the umbrella of mosquito control
     than by the mosquito or deliberate construction of wetlands
     with mosquito niches.

                             -32-

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          This discussion of aquatic nuisance and pest species
     seems to advocate the draining of generally viable and
     productive mining-created wetland, which runs counter to
     the desire for wetland replacement on mined lands.  Studies
     of mining's long-existing, surface-water impoundments
     indicate no unusual proliferation of nuisance biota, even
     after 50 or more years.  This adverse potential is equally
     as great in naturally occurring wetlands.


2.55      "The amount of standing water communities expected
          to directly be affected ... is relatively small and
          involves no major lakes, ponds, or impoundments ...
          Perhaps the most important consideration will be the
          creation of new standing-water habitat.   (28,400
          acres by year 2000)"

          While these statements support mining, the use of
     "standing water habitat" is interesting.  We suspect it
     refers to the idea that a lake is made by Nature, while
     man makes "standing-water habitat".


2.56      "... utilization of this potential fishery is
          expected to be relatively light since an outstanding
          marine fishery is also readily available to anglers."

          The notion that high quality freshwater sport fishing
     is deposed by an outstanding nearby marine fishery has
     very little merit.  Each type of fishing has its own    Uj-f®
     devotees and a substantial number do both.  All Florida
     fishing licenses sold in the area are for freshwater fishing
     since no license is needed in saltwater.  As at Saddle Creek
     Park, phosphate lakes often are heavily fished and with
     excellent yields.  The present interpretation is erroneous
     and misleading.
          This assessment represents an obvious positive benefit
     from the mining process.  The expectation that these
     newly-created lakes will experience light sport and commercial
     fishing utilization due to the available marine fishery is
     contrary to reality.  Freshwater and marine angling represent
     entirely different experiences in terms of location, economics
     and fishing preference.  Available mining lakes have been
     heavily utilized for recreation and fishing by the regional
     populace.  According to the study area's FGFWFC Fisheries
     Biologist, phosphate lakes provide the "best bass fishing
     anywhere, and the fishing quality doesn't taper off over time,
     as a lot of people believe".  Commercial rearing of catfish
     and other aquatic food resource species is also a reality.

                             -33-

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2.56      "... the effects of the relatively small changes
          of freshwater discharge patterns are expected to be
          minor and obscured in normal discharge variations."

          This has been repeatedly stated and has a quantitative
     base.  Yet, juxtaposed are such statements as:  "community-
     structure alterations accompanying local habitat degradation
     by siltation and turbidity will be manifested as reduced
     algal abundance, replacement of more desirable benthic     \jj
     forms with forms more tolerant of silty substrate, poorer
     condition of local fish populations because of food chain
     disruption and impairment of feeding activities, and reduced
     fish egg and larva survival" , presented with no quantitative
     basis.
2.57      "... this will represent an adverse effect, since
          flowing-water communities are of greater resource
          value to the study area."

          No basis for this contention has been presented and tiJ
     the statement may contradict others made concerning the
     value associated with lentic communities.


2.60      "Phosphate industry's ownership of land has probably
          been the major cause of the current crescent— shaped
          population distribution."

          This conclusion is not corroborated by any factual
     data.   Indeed, factual historical data contradicts this
     hypothesis.   Demographic data show that population growth i J
     has been a function of net migration.   A high proportion
     of this migration is retirees who create the economic base
     for the service and trade oriented economies which
     characterize Charlotte, Sarasota, and Manatee counties.
     Mining has certainly not precluded this.
          Retirees and population growth in Florida is oriented
     around the sea shore.  Internal development is generally
     sparse and occurs at special areas, i.e., Orlando, or at
     transport nodes.


2.60      "Since the service businesses catering to the needs
          of the retirement and tourist sectors are in direct
          conflict with the phosphate industry, however, there
          is good reason to believe that they could absorb surplus
          workers from the phosphate industry."

                             -34-

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          That growth of the phosphate industry has precluded
     growth of a tourist/retirement economy in Polk, Hardee,
     and DeSoto is unsupported.  A more reasonable and
     economically justifiable argument is that the inland
     counties possess few of the amenities that migrants to
     Florida desire.
          Even if expanded tourism filled the void left by a
     contracting phosphate industry, phosphate industry workers
     may not possess the skills needed for a service economy,
     and such workers may not be willing to accept the generally
     lower wages paid by service industries.


2.64      "Among possible secondary effects not implied in
          the discussion of primary effects are certain
          changes occurring in coastal areas as a result of
          mining."

          This is reaching out for completeness in identifying
     impacts, and the closing phrase, "the expected changes ...
     will have little effect," neutralizes the impact.  State
     and federal jurisdictions are responsible for permitting i/J^fO
     harbor development to safeguard the marine environment.
     Such port expansions are independent from the increase in
     in shipping, if any.
          This vague discussion should be materially expanded,
     or deleted.  It is difficult to envision potential impacts
     on the study area's terrestrial biota as a result of a possible
     future increase in harbor area.


2.67      "Development of Tampa Harbor and development of the
          phosphate industry are synergistic:"

          Clearly they are related.  That the relation is    fa/~(  &
     synergistic is somewhat remote.


2.69      "The primary effects on these features are
          expected to be collapse or high-volume drainage caused
          by excessive surface loading and increased hydrologic
          head created by abovegrade storage of clay slimes and
          waste gypsum."

          Evidence of sinkhole collapse due to waste loading is
     lacking.  Loading due to placement of waste clay in a mined
     area will be less than that associated with the original
     matrix.

                             -35-
                                J-Jfi

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2.72      "The loss of only several hundred acres of mixed
          and deciduous forest types (sandhills,  sand pine
          scrub,  and hammocks)  will severely deplete the
          unknown but undoubted limited extent of these
          important habitats."

          It is necessary to emphasize  that the extent of habitat
     types within the study area should not simply be dismissed
     as "unknown" in a document of this importance.   Complete
     aerial photography of the study area is available from
     several sources, as well as several general  vegetative cover
     maps and many site-specific environmental studies done with
     the region.
          A supplementary report utilized in large measure to
     prepare the  biological sections of the DEIS  is entitled
     "Fish .and Wildlife Inventory of the Seven-County Region" /./_//
     (Layne, et al., 1977) .  The authors chose to excerpt the *^
     appropriate  regional area of Davis' "General Vegetation
     Map of Natural Vegetation of Florida"  (Davis, 1967)  for the
     purpose of identifying and delineating the vegetation of
     the study area  (p.50).  Although this  cover  map is
     macroscopic  in scale,  it provides  a reasonably accurate
     portrayal of the original location and extent of the nine
     vegetation types identified within the seven-county region.
          The authors of this critique  generated  a vegetative
     impact composite graphic using Figure  III H.I (General
     vegetation map of the seven-county area)  and Figure III 1.2
     (Location of holdings of phosphate companies of the seven-
     county area) from the above-mentioned  wildlife supplement
     in order to  determine the generalized  extent of mining's
     total potential alteration of original natural vegetation
     types for this century-   Neither the DEIS nor the supplemental
     working papers offer a figure suitable for this type of
     impact interpretation.
          Throughout the text,  the greatest concern for continued
     habitat viability, other than generic  "wetlands," is given
     to the sandhill, xeric hammock and sand pine scrub vegetation
     types due to their relative abundance  of rare and endemic
     flora and fauna.  Based upon an interpretation of our natural
     vegetation/mining lands composite  graphic for the study area,
     only about 20 percent of the total sandhill  and xeric hammock
     habitat, and less than 10 percent  of the sand pine scrub
     association  will be altered by mining  by the year 2000.
     These figures include the habitat  altered prior to 1975.
     Since the majority of these forest types in  Florida exist
     outside of the study area, and the percentage lost or
     temporarly displaced within the region is so small,  the area-
     wide and statewide potential loss  is relatively small  (Davis,
     1967; Laessle, 1958 and 1967).  In addition, future reclamation
     efforts will seek to restore these habitat types through
     site-specific land preparation and plant species selection.

                             -36-
                               J-J?

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2.72      "...  62 percent of the projected 4 percent areawide
          loss of rangeland ..."

          The stated 4% does not correspond to the 7% loss
     indicated in Table 1.31 (page 1.63), so actual mined acreage
     cannot be determined.  In order for a reviewer to readily
     grasp the projected impact of mining versus other land-uses
     in the various habitat and land use categories, a proper    ^/.
     figure,should be generated listing the proportional areas
     and percentages.  Further, impacts on natural systems should
     be segregated by vegetation types, which would require an
     areawide comprehensive vegetation cover map as a prerequisite.


2.72      "As wildlife habitat, waterbodies created during
          reclamation are,  like terrestrial habitat, generally
          inferior to those that could develop naturally were
          the mining areas merely abandoned."

          It is not necessarily true that created water bodies
     are inferior.  However, this is one of the few statements
     reflecting author awareness that high quality natural    ^ -/ (
     habitats have resulted from reversion of mined lands.
          Given careful attention to design, construction and
     management, man-made aquatic systems can exceed natural
     ones in diversity and productivity-


2.73      "Since phosphate mining will account for most of the
          expected areawide change in land use by the year
          2000,  it will account also for most of the change
          in community structure."

          The projections of Table 1.31  (p.1.63) show an       {*/~' ' ~
     increase in urban area of 146 thousand acres.  This is by far
     the major change in land use through the year 2000.


2.73      "Particularly will the modified habitat types
          replacing forests and wetlands support a smaller
          variety of biota and be considerably less productive
          in terms of life support."

          It is almost inconveivable that earlier statments
     concerning the anticipated improvement in soil conditions
     and associated soil characteristics would result in conclusions
     about a lowered potential quality of the system reestablished
     on mined areas.  The DEIS continues to make the comparison
     between a natural system which is of a relatively mature age
     and a post mining ecosystem of a relatively young age.  No
     reasoned comparison can be made from such dissimilar bases.


                             -37-
                               3-40

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2.73      "The greatest impact on threatened and endangered
          species that likely will be affected by mining will
          come primarily from loss of uplands forested habitat.

          The DEIS generally lacks even a terse discussion of
     habitat, range, and relative abundance considerations for
     the species of concern in the various threatened and
     endangered species sections found throughout.  The reviewer
     has very little information, in terms of percent of specific
     habitat alteration or individual species ecology and
     abundance, that can be used to weight and evaluate the     ^—/
     assessments of potential impact.  More of the quantitative
     could be included, possibly with range maps for threatened
     and endangered species, including those for the relevant
     flora.   Also, the species range maps in Section 5 (TI 1977e)
     are often somewhat at variance with those in the Fish and
     Wildlife Inventory volumes, from which they were probably
     extrapolated.  The non-overlapping ranges in Section 5 for
     the Florida gopher frog (p.5.54) and Florida mouse (p.5.92)
     when compared with the Florida gopher tortoise (p.5.57)
     is a good example.  Many others seem inconsistently mapped
     and probably should be revised accordingly.


2.73      "There will be an increase in the proportion of
          managed systems that require expenditures of
          energy to natural systems that do not.  The regional
          carrying capacity, which is the ability of the
          regional environment to sustain particular levels of
          activity, may be stressed."

          Immediately following reclamation and in order to
     stabilize soils and provide for reestablishment of a natural
     succession, a managed system will usually be required.  It
     can be anticipated that these systems will revert to low    LJ~
     maintenance or self-maintaining natural systems, except
     where economics dictate otherwise.  Carrying capacity cannot
     be stressed, it can merely be increased or decreased.  It
     also has nothing to do with activity, but rather with the
     mass of organisms occupying an area.  Consideration is also
     normally given to the average well-being of the organisms'
     mass occupying an area.


2.74      "Loss of forests  (and in this case, particularly wetlands)
          will have the greatest impact on ecologically significant
          species."
                                                                 ij-
          This "loss of forests" statement differs substantially
     from that on page 2.45 which addresses natural ponds and
     lakes and wetlands.

                             -38-

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2.74      "The impact on the hunting and trapping potential
          of commercial and recreational species is
          considered minimal, as is the impact of increased
          abundances of nuisance and pest species."

          These minimal impact assessments on hunting, trapping,
     recreational, nuisance and pest species are substantially   . . ig
     different from the assessments on pages 2.44 and 2.45.    \S/~~


2.76      "Additional concern for the water quality of the
          Floridan aquifer is warranted because of the
          projected increased amount of injection of waste-
          waters as mines attempt to meet the New Source
          Performance Standards."

          No injection of wastewater is occurring nor is any  ijj—I ( 9
     proposed.


2.76      "Forests, agriculture, and open space will be areally
          displaced, resulting in negative impacts."

          This interpretation is inconsistent with the low
     wildlife habitat values previously assigned to the agricultural
     range, and most of the forest lands.  Suddenly they have a
     wildlife value as great as the crops they yield!
          The intensive, man-dominated aspect of most of the
     land to be mined does not seem to be remembered or incorporated
     in this land use section.


2.77      "The impact would be catastrophic, since irreplaceable
          historical resources would be lost."

          The provisions of the DRI and EIS structure require
     that an archeological assessment of known and potential
     archeological and historical sites be identified and "worked"
     prior to site disruption.  The intent is that irreplaceable  (J-
     historical resources will not be catastrophically lost.  The
     text language paints an unnecessarily grave picture of
     mining's impact on these resources.


2.77      "The conditions of this scenario would impact the
          area's economics and the demographic and cultural
          elements, as described for Scenario 2.15."

          It is simply not reasonable to assume that the economic
     impacts are qualitatively and quantitatively identical for
     all scenarios.                                         ,  .> v
                                                           bJ-lD-

                             -39-
                              3-4*-

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2.78      "Timber"

          Minute examination of this section is essential for the
     reader to be persuaded that the jumbled structure does in
     fact contain consistent numbers.   However, actual "timber"
     area has never been sorted from the total forest acreage, tj - ( i
     so the evaluation is not terribly meaningful . . .  notwith-
     standing the assessment of negligible impact.


2.83      "Continued holdings of large tracts of land by the
          phosphate industry on the north-south axis  from
          Lakeland to Port Charlotte will continue  to increase
          population density in the development crescent from
          Lakeland to Tampa and along the coast."

          The driving force for coastal development  is certainly not
     the ph9sphate industry.  This activity will continue whether
     the phosphate industry holds large tracts or releases large    .
     tracts.
2.83      "Accelerated phosphate mining under Scenario 2.11 could
          increase already inflated land values,  deplete non-
          renewable resources,  and further reduce the amount of
          land in agricultural  production."

          This curious paragraph is a lumping of  all the
     potential ills that easily come to mind, gratuitously provided,
     the author unfettered by the burden of  substantiation.  "There
     is every reason to believe ..." is a troublesome opening.
     If but one reason were committed to paper, the task of the
     reviewer would be ever so  much simpler.
          If planned restoration creates the  mix  of natural   fj - ^ 
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2-86      "Eliminating slime ponds through the sand/slime
          mix technique will result in a topographic surface
          approximating the original surface over one-half of
          the mine area;"

          Restoration of the original topographic surface may
     not be an overriding consideration.  In any case, the    /./_/
     feasibility of returning to original grade depends upon  v*'~*
     site-specific considerations.


2-86      "Eliminating dryers and dry grinders through the
          implementation of this process modification is
          expected to reduce airborne radionuclide concentrations
          in the immediate vicinity of the replaced process
          equipment.  The impact of such a change on exposure
          to phosphate workers and the general population is
          expected to be insignificant inasmuch as current    £*/— /T.8
          processes are also insignificant (unmeasurable);
          i.e., dose projections for phosphate workers have
          been shown to be small and well within guidelines."

          The first and second sentences in this paragraph
     are inconsistent.  Elimination of dryers cannot be
     expected to measurably decrease exposure.


2.88      "Concern regarding contamination of the water-table
          aquifer by directly exposing the water table to the
          slime material."

          The water table aquifer is presently exposed to    i/J- /Z
-------
          The south prong of the Alafia River has a considerably
     elevated conductivity,  nutrient content and sulfate burden
     in comparison to other  brown water streams in the state
     or drainages from typical perched wetland areas.   There  /./
     does not appear to be any appreciable difference  in      (A/
     vegetation composition  along this waterway or others with
     a lower content of dissolved solids.   It would seem that
     if an effect were going to occur, it  would have by now and
     it would be apparent in vegetation changes.
2.91      "...  it is  assumed  that  lost  production will  be
          made up through changes in  mining  plans
                                                   . , "
          For a limited period of  time,  that alternative is
     available.  In the long term,  of  course,  the resource is
     lost.   It should be evident that  mining can take place
     only where the resource exists,


2.91      "Although part of  the void will  be filled  by an
          expanded  volume of clay  slimes,  a  net  void is still
          expected. "

          The area  and volume utilized for mining waste
     disposal depend upon the nature of  the  ore  body,  selected
     dam heights, distribution of  tailings to  backfill and
     dam construction,  consolidation behavior  of waste clays,
     the shape and  size of the tract and numerous dynamic    t/J ~ 1 3 3
     characteristics of the  mining  operation.  The overly
     simplified statement reflects  little  understanding with
     regard  to the  mass and  volume  balance for materials involved
     in a Florida phosphate  mine.
                             -42-

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 3.1        "Reducing slime-pond extent will have a positive  effect  on
           the area's unique physical features because ,'of  the  signifi-"
           cantly reduced potential  for collapse of ka'rst  features..."

           If slime ponds are economically sound',; ecologically .beneficial/
     and  important to restoration of natural habitats,  their  elimina-
     tion could have'a negative  impact' greater than  the positive  . •
     effect described.                  '                         fc/-


.3.2        "Lining waste-gypsum stacks and cooling-water ponds at new
           chemical processing plants would reduce seepage into the
           underlying strata that has been suspected  6f  enlarging lines
           of parting.  However,  data are not sufficient to  quantify
           effectively the potential impacts due to seepage  and/or
           collapse."           s

           Even if the data are insufficient, it would assist  the   fcA-
     reviewer if ,the study suggesting a certain potential for collapse
     were referenced.  Similarly, if the data alluded, 'to  are  non-existent,
     it would be helpful if this item were labelled  as  wholly
     unsubstantiated speculation.


 3.2        "Since the effects of  emissions  (including"those  from rock-
           drying and chemical manufacturing) are largely  unknown  (or
           if known, are unmeasured), minimal impact  had been  assigned
           in this area."

           The basic limitations  of  ambient air levels'of  suspended iA
     particulates are well defined  by the EPA in both Standards for *^
     Protection of Human Health  and Protection of Human .Welfare.  .The
     impact of fluoride emissions is also well known, well  documented
     and  several years of data exists on ambient air levels.


 3.3        "In view of the fact that freshwater wetlands restoration
           has not been demonstrated and seems infeasible  on a large
           scale within a reasonable time, the only practical  approach
           to analyzing impacts of this part of the proposed action is
           to assume prohibition  of  minor development of facilities
           in waters of the U.S.  and wetlands as shown in  the  LUDA  maps."

           The notion that freshwater wetlands restoration has not  been
     demonstrated is completely  erroneous.  Wildlife biologists involved
     with waterfowl management recognize that high quality  wetlands
     can  be made by man over large  acreages and short times.   They are     __
     among the easiest natural habitats for man to establish  through fc/- / 3 r
     construction and management.
           Thus the approach taken to analyze impacts of this  part  of
     the  Proposed Action is incorrect.

                                  -43-
                                   3-41

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3.5     ,  "No projections are made on water quality effects for New
          Source Chemical Plants, because none are expected in the
          proposed action.  However, in the event development does
          not follow projections, and application <•is made for a •- *
          New Source^Chemical Plant, the proposed action requires
          more stringent limitations than EPA New,Source Performance
          Standards to protect water quality in the affected basins."

          Data do not exist to support the contention that more
     stringent water ,quality limitations are necessary.  Similarly,  .
     with regard to groundwater, data- do not support the proposed  \/J
     need for gypsum pond liners.


3.6       "Changes in background radiation levels could occur also
          in association with replacing dry-rock grinding with
          wet-rock grinding and eliminating dryers;"

          If changes occur, they will be too insignificant to measure
     (see pages 2.86, 2.87).


3.7       "Hbwever, since mining activities are expected to merely
          shift to lands not classified as U.S. waters or wetlands
          and.since sufficient reserves exist within the study area
          to accommodate the required shift in mining operations
          between now and the year 2000, such exclusions will not
          materially affect production tonnages previously estimated
          for the two.time periods under Scenario 2.11."

          This is a totally inadequate evaluation of the impact of \jJ
     prohibiting mining.
                                  -44-
                                  2-47

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4.3       "Return land to approximate original contour ..., etc."

          The administrative requirement to mention the Federal
     Surface Mining control and Reclamation Act of 1977 is recognized.
     However, the inclusion of specific provisions seems to be
     a tacit expression of applicability.  The listed recommendations
     cannot be assumed to be useful in the present situation, nor
     even pertinent, and they should therefore be deleted from/^^i^./
     the text.


4.3       "System monitoring should be complemented with once-
          per-shift manual sampling to ensure that the
          automated equipment is efficiently operating."

          Presently required monitoring and optional (but
     generally utilized) alarm systems are sufficient to properly
     protect the environment from spills.                     / — / 4. 7
                             -45-

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6.1       "Land-use changes caused by mining will narrow future
          land-use options, especially in reclaimed slime pond areas.

          Slime pond soils represent a new soil type for the area.
     Agricultural production of one sort or another will continue to
     be a major and important use in the area.   All pre-mining soil £
     types will continue to exist in the area.   Therefore,  it would
     appear that future land use options are not appreciably narrowed


6.1       "Time beyond the year 2000 would be needed to  reestablish
          the natural system of most of the habitat types."

          Reestablishment of the natural system is recognized as  a  b/
     realistic outcome within a reasonable period of time following
     mining.
                                 -46-
                                  3-4?

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                        BIBLIOGRAPHY
Council  on  International  Economic Policy,  Executive Office
    of the  President.  1974   Spe.ctat Re.poit, C/uttcat Imposed
Davis, J.  H.  1967.  General  map of natural  vegetation in
    Florida.   Agr. Exp.  Sta.,  Inst. Agr .  Sci.,  University
    of Florida.

DeVall, W.  B.  and C. L.  DeVane. 1950.   "A Field Survey of
    Florida's  Pebble Phosphate Striplands."  JouAnat o&
    FtotLida Academy o^ Scte.nceA  12(1) : 21-34.

Drury, W.  H.  and I.C.T.  Nisbet. 1973.   "Succession."  JouAnat
    ofi the Arnold  AfiboAetum 54 (3) : 331-368.

Edscorn,  J. B. 1977.   "Wildlife Values may  be Negated by
    Phosphate  Mine  'Reclamation'."  rn Layne, J.  N. , &t at.  1977.
    FxCifi and Wtldttfie. Inventory o^  the. Se.ve.n- County Reg-con Included Ln
    the. Ce.ntsiat Ytofuda Phosphate. InduAtny Atieautijde. Env4A.onme.ntat Impact
    Study.

Hurlbert,  S.  H.  1971.   "The  Non-concept of  Species Diversity:
    A Critique and Alternative Parameters."  Ec.ot.ogy 52: 577-586

Kuchler,  S. W.  1964.   Manual  to accompany  the map "Potential
    Natural Vegetation  of the  Coterminous United  States."
    AmeA.  Ge.ogA. Soc. Spec. Pub.  No. 36

Laessle,  A. M. 1958.   "The Origin and Successional Relationship
    of Sandhill  Vegetation and Sand-pine  Scrub."   Ec.otogtc.ai
    MonogAaphA  28(4): 361-387.

Layne, J.  N.,  &t at. 1977.  P-L&h and ^itdtl^e. lnve.ntoiy o& the.
    Szve.n-County Re.gton Included -in the. Ce.nttLat  Ttontda Phosphate. InduAtny
    EnviAome.ntat  Impact Study.

Olson, J.  S.   1958.  "Rates  of Succession and Soil Changes  on
    Southern Lake Michigan Dunes."  Rot. Gaz.  119:  125-170.

Texas Instruments Incorporated.  1977e.   "Water."  Ce.n&iat Ftolida
    Phosphate. InduA&iy Aieaw.de. Impact A-64e6-6men£ P/iog^am, Votume. I/.

U. S. Department of the Interior.   1956.  "Wetlands of the
    United States."  USDI Circular 39.

Whittaker,  R.  H. 1953.   "A Consideration  of Climax Theory:
    The Climax as a Population and Pattern."   Ecotogtcat
    Monogtiapht>  23(1):   41-78.
                            J-sro

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                  ATTACHMENT B
Contents:

U. S. Environmental Protection Agency letter dated
April 18, 1978 to Holland & Knight

Holland & Knight letter dated June 19, 1978 to
U. S. Environmental Protection Agency

-------
          UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

\   ,0<^                  WASHINGTON. D.C. 20460
 'ft   fc
                            APR 1 8 1978
  OFFICE 9F
GENERAL COUNSEL
 Mr. Roger Sims
 Holland & Knight
 P.O. Drawer B.W.
 92 Lake Wire Dr.
 Lakeland, Florida  33802

 Dear Mr. Sims:

      This is in response  to your  letter  of  March.23,
 1978, to Mr. Jeffrey Gaba, requesting  that  the  Office
 of General Counsel clarify EPA policy  on implementation
 of the Florida Phosphate  Area-Wide  Environmental  Impact
 Statement (Area-wide EIS).  Although the Agency has  not
 in the past prepared such a broad-based  impact  statement
 for new source development, the Area-wide EIS is  viewed
 as an important adjunct to the site specific  impact  state-
 ments (site specific EIS), prepared pursuant  to §102(2)(C)
 of the National Environmental Policy Act, 42  U.S.C.  §4332(2)(C)
 and §511(c)(l) of the Clean Water Act, 33 U.S.C.  §1371(c)(l),
 for new sources having significant  environmental  impacts.
 Through these site specific EISs, EPA  is able to  identify
 and minimize the adverse  environmental impacts  associated
 with the issuance of new  source permits,  and  it is the
 Agency's policy that EIS  recommendations be implemented
 whenever posslble-either  by their inclusion as  conditions
 in permits themselves or  by separate agreement.

      The Area-wide EIS prepared for the  Florida Phosphate
 Industry serves the same  basic function  as  the  site
 specific EIS; it identifies environmental consequences
 and allows the Agency an opportunity to  minimize  their
 effects.  However, the Area-wide EIS offers a range  of

-------
 means  for  achieving  this  goal.   As  the Council on Environ-
 mental  Quality  noted:

           [T]he  program statement has  a number of
           advantages.  It provides  an  occasion
           for a  more  exhaustive  consideration
           of effects  and  alternatives  than
           would  individual  action.   It ensures
           consideration of  cumulative  impacts
           that might  be slighted  in a  case-by-
           case analysis.   And  it  avoids dup-
           licative reconsideration  of  basic
           policy questions.

 CEQJMemorandum to Federal Agencies  on  Procedures for
 Improving  Environmental Impact Statements,  3 Env.  Rep.  82,
 87  (May~16, 1972).   See_also  40  C.F.R.  §1500.6(a)  and
 (d); Scientists' Institute  for Public  Information  v.
 AJ3C, 481 F.2d 1079 (D.C.  Cir .  1973); Mi_nnesot_aJPIRG v-
 Butz,  358  F.Supp. 584  (D.  Minn.  1973)7

     Since the Area-wide  EIS  deals  with a  variety  of  com-
 plex problems, both  cumulative and  site specific,  no  one
 scheme  for the implementation  of  its recommendations  may
 be  appropriate.  Consequently, the  Agency  plans  to implement
 those  recommendations  based upon  the nature of the pro-
 blems  identified.  Although any  new source  must  meet  all
 applicable existing  legal  requirements  identified  in  the
 Area-wide  EIS, additional  recommendations  will be  implemented
 in  the  following manner.

 Sjjie Specif ic Impacts;  Certain  of  the  recommendations
 In  the Area-wide EIS deal with problems which have only
 local,  site specific effects  but which  occur at  most  sites
 subject to phosphate development.   Analysis of these
 local problems in an Area-wide statement allows  for
 thorough consideration while  avoiding  duplicative  review
 of  similar problems  in a  series  of  site specific EISs.
 Where the Area-wide EIS has reviewed a  local problem  its
 recommendations will be presumptively  applicable at a
 new source.

     However,  since  these  recommendations  deal with site
 specific problems they are necessarily  subject to  analysis-
 and possible revision  by  a site  specific statement.   First,
 specific plans are -needed to  implement  general recom-
mendations, and thus,  the site specific EIS will  tailor
any recommendation to meet the localized Condition of a
particular area.  Second,  the recommendations themselves
may be modified where  the site specific EIS identifies
alternatives as effective as  those  proposed in the Area-wide
EIS, indicates that they  are  unnecessary due to  unique

-------
                              -3-

local factors, or  otherwise  indicates site specific factors
making modifications  appropriate.

     These site  specific  recommendations include:

Mining-

     1.   Elimination  of  conventional above ground slime
          disposal  areas.

     2.   Provision of  storage  that  allows recirculation.
          of water  recovered  from  slimes.

     3.   Use of  "connector wells"  for  mine dewatering.

Chemical Processing-

     1.   Lining  of gyp ponds.

     2.   Recirculation of contaminated  and non-contaminated
          water.

     3.   Recovery  of  fluorine  where  economically  pos-
          sible.

     4.   Recovery  of  uranium where  economically pos-
          sible.

Cumul£tj._ve_Imjaacts:  Analysis of cumulative effects  is
uniquely an aspect  of  an Area-wide statement,  and  such
analysis can not  be effectively replaced by site specific
studies.  Recommendations to minimize these cumulative
impacts associated  with development  of  the phosphate industry
will'be implemented where possible,  and, with  only limited
exceptions, such  recommendations may  not be modified on
the basis of a site specific EIS.

1.   Elimination  of rock drying.

     The Area-wide  EIS has identified  cumulative particulate,
radiation and energy problems associated with  the  drying
of mined phosphate  rock, and the EIS  has concluded that
elimination of rock dryers at new plants is an effective
and economically  reasonable method of  deal ing  with these
problems.  However, the Aroa-wi.de KIS  indicates that there
may be case-by-case modification of  this recommendation
where rocks are  to  be shipped outside  of Florida for chemical
processing.  If  the energy for  transporting the moisture •
is greater than  the energy saved by  elimination of drying,
consideration may be given in a site  specific  EIS  to dry-ing
at a benefication plant if air quality,  including  radiation,
can be adequately protected.

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                              -4-

 2.   Limitation  of  Wetlands Development.

     The  piecemeal  destruction  of  environmentally sign-
 ificant wetland  areas  is  one of the more  significant
 impacts identified  by  the Area-wide EIS.  To avoid such
 destruction  the  EIS has concluded  that  regulation of wet-
 lands development  is necessary,  and it  contains recom-
 mendations that  development be  precluded  in the most
 sensitive wetlands  (Category 1), be subject to strict
 reclamation  restrictions  in less sensitive  areas (Category
 2), and be unregulated with respect to  reclamation in
 certain isolated and intermittent  wetlands  (Category 3).
 It was impossible  in the  Area-wide EIS  to identify the
 classification of  all  areas covered by  the  EIS, and only
 a general description  of  the categories was.provided.
 It will be necessary to precisely  classify  proposed
 development  sites  on a case-by-case basis,  and the site
 specific  EIS  is  one method  by which such  localized
 analysis.may  be  performed.

     Although site  specific analysis  is an  essential part
 of implementation of this proposal,  the basic  recommenda-
 tions of  the  Area-wide EIS  may  not be modified.  Thus,
 while the site specific EIS may determine the  category
 of wetlands  into which an area  belongs, the consequences
 of that classification is determined  on the basis of the
 Area-wide EIS.

 Recomme ndations  for  futuie  government action;   Certain
 recommendations  contained In "the Ar"ea-wTde~EIS may not
 be directly  implemented,  and in  such  cases,  the analysis
 of the problem and  proposed solution  may  form  the basis
 for future government action.   These  recommendations
 include:

 1.   Modification of process controls and monitoring require-
     ments for existing sources.

 2.   More stringent  effluent limitations  in new source
     chemical plants.

     Although the Area-wide EIS  concluded that chemical
processing facilities are capable  of  achieving effluent
limitations  far  lower than  those contained  In  existing
new source standards of performance and that such lower
limits are necessary to preserve water  quality,  existing
law precludes directly implementing lower effluent limitations
based on  recommendations  contained  in the EIS.   These recom-
mendations can, however,  form the  basis of  future government
regulation's,  and they may be implemented  by modification
of current new source standards  of  performance or state
water quality standards,  or  by  establishing  stricter

-------
                             -5-

water quality based effluent limitations  under  §302  of
the Clean Water Act.  This conclusion does  not,  of course,
mean that new facilities will not be  required  to satisfy
existing Florida water quality standards, and  such standards
will be implemented on a permit-by-permit basis.

     I trust that this letter has clarified  EPA's position
on implementation of the Area-wide EIS, but  if  there  is
any further information that I can supply please feel
free to contact me or Mr. Gaba.
                         Yours truly.
                         Alan W. Eckert
                         Acting Associate General Counsel
                         Water Quality Division  (A-131)

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MAPY I *ria(.rGATE
MARINA W FlARNETT
VfRNA'TjA BARTON. JR
HO'iAfi R BAYLESS
CHARLES (I. BFNTLEY
WILLIAM r BEVIS
JULIAN CLARKSON
HUME F COLEMAN
MICH*' L B.COLGAN
F.ALAN CIJMMINGS
GREGORY R DEAL
ROY E DEAN
CHAHLCS w DODSON
flRlAN C F.LUS
rvonem R FEAOIN. Ill
DENNIS » FrnrausoN
JOHN W, FROST, n
JOHN GERMANY
ROBERT B GLCMM JR.
WARREN M GOODRICH
RICHARD A HAMPTON
PAUL D HARDY
WILLIAM O.E.HENRY
MAI.KA ISAAK
MICHAEL L.JAMICGON
JOHN ARTHUR JONES
.[}. BURKE KlBLER,Ul
HENRY M. KJTTLESON
P O. KNIGHT. JR.
EDWARD F. KOREN
D.BRIAN KUEHNER
JAMES V. LAU
JOHN R.LAwbON.Jo
PAUL E.LOGAN
WILLIAM H.McBRiDE. JR.
ANTHONY J. McNiCHOLAS.UJ
C PARKHILL MAYS. JR.
STEVEN D.MERRYOAY
RULON D.MUNNS
ROBERT P. MURRAY
JACK S.NEWSO'ME
JOHN R.PURCELL
JOHN RADCY
ROBERT C RASMUSSEN
JAMC3 M. Rr.ED
Roi3C«T L. RHODES, Jr».
BRUCC H.RoriERSOM
RONALD J.Russo
GERALD V. SARBO
HARRY M. SAWYER, JR.
ROGER W.SIMS
RICHARD B.SrEPHENS, JR.
W.DANIEL STEPHENS
WorrORD H.STIDHAM
BRUCE STONT
MARK K.STRALEY
HARF?Y O.THOMAS
HENRY TOLANO
EDWARD w. VOGEL.TJI
CHARLES C.WHITAKEH.TJ
TEOD N.WILLIAMS
CSTEVEN YERRID
                                                LAW OFFICES
                                         HOLLAND & KNIGHT
                                P. O. Box IO68
                             24S SOUTH CENTRAL AVENUE
                              BARTOW, FLORIDA 33020
                              TELEPHONE (813) 533 MSI
                                P. O. DRAWER B W
                               92 LANE WIRE DRIVE
                              LAKELAND. FLORIDA 33002
                              TELEPHONE (OI3) 6O2-H6I
                                P. O. Box 1268
                            EXCHANGE NATIONAL BANK BLDG.
                              TAMPA, FLORIDA 33501

                             TELEPHONE (813) 223-1621
    P 0 Box 1669
4O6 THIRTEENTH STREET WEST
 PRAOENTON. FLORIDA 335O6

 TELEPHONF (ni3) ?ir. 710?
 P. O Box 3O76

MOO TAMIAMI TRAIL
                 P O Box 2441
              2O75 WEST FIRST STREET
              FT. Mvrns, FLORIDA 33»oz
              TrLCPtipNr (nij) .n."1 ^it\-"
                   P. O. DRAWER eio
                  SARNCTF BANK BLDG.
                                             TELEPHONE fain) 365-3321  TCLCPHONC (90-1) ??i 7OOO
                   CABLE ADDRESS
                    HNO KNIGHT

                   TELEX s-seao
                                               I.SE REPLY TO   Lakeland
                                                June  19, 1978
Alan W. Eckert
Acting Associate  General Counsel
Water Quality Division
U.  S. Environmental Protection Agency
Washington, DC   20460

           RE:   Florida Phosphate Area-Wide
                 Environmental  Impact Statement
                 ("Area-Wide  EIS")

Dear Mr. Eckert:

           Thank you for your  letter dated  April 18,  1978, in
which you explained EPA's current posture  on implementation
of  the Area-Wide  EIS.  We agree with your  conclusion  that
existing law precludes implementation of lower effluent
limitations for chemical plants based on recommendations
contained in the  study (page  4)  and further wish to  acknowledge
EPA's consistent  position that it has "no  direct legal
authority to change requirements for existing sources"  on
the  basis of the  Area-Wide  EIS (page 1.74  of the draft  EIS).

           The Florida Phosphate Council and its member
companies,  however, wish to raise a few basic areas  of
concern in response to your letter.  In the first place, the
National Environmental Policy  Act of 1969  ("NEPA"), which
provides the authority for  preparation of  environmental
impact statements,•does not authorize promulgation of rcyulatory
provisions.  An  EIS  is a report,  to be used by decision-
makers in reaching  particular  conclusions.   It also provides
a record of decision making for the benefit of the public.
We  find no authority for the  proposition that bindinn restric-
tions or conditions on development may be  developed  throuqh
the  EIS process,  however.   Although such conditions  could

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Alan  W.  Eckert
June  19,  1978
Page  Two
perhaps be developed  through  rule  making proceedings authorized
by other statutes,  NEPA  is  primarily  a  "full  disclosure  law"
and  imposes a  requirement that  agencies  make  decisions with
an environmental conscience.

          Moreover, the  basic unit of EIS analysis  is the
site-specific  impact  statement.  Planning Level  and Program
Impact Statements under  the National  Environmental  Policy  Act:
A Definitional Approach, 23 U.C.L.A.  L.  Rev.  124, 147 (1975).
No area-wide or program  EIS should interfere  with the full
consideration  of alternatives available  to a  site-specific
proposal, since the consideration  of  such alternatives must
be accomplished "to the  fullest extent possible".   NEPA, §
102.

          I.   PRESUMPTIVE APPLICABILITY  OF CERTAIN
               RECOMMENDATIONS REGARDING  "LOCAL PROBLEMS"

          We understand  that the Area-Wide EIS will not be
the  only review of phosphate industry "new sources"  pursuant
to NEPA.  Presumably, all new sources that meet  the threshold
test of "major federal action" and  "significant  environmental
effect" will be subject  to additional site-specific NEPA
review before  issuance of necessary federal permits.

          On page 2 of your April  18, 1978  letter,  you note
that certain Area-Wide EIS recommendations  dealing  with
"local problems" will be subject to analysis  and possible
revision during site-specific studies.   This  concept  is
consistent with NEPA, in'that it provides  for tailoring of
area-wide recommendations and site-specific recommendations
to the particular facts  and detailed proposals regarding
each project,   allowing full consideration  o.f  alternatives.

          The  formulation of restrictions  on  an area-wide
basis, however, without  consideration of  site-specific
factors and development  plans, is not consistent with the
intent or goals of NEPA.  The Area-Wide  EIS should  be used
in the overall evaluation process directed  toward approving,
approving with conditions, or denying a  particular  permit  or
other major federal action.   In the landmark  Calvert  Cliffs'
decision, the court noted that

         NEPA  mandates a case-by-case balancing
         judgment . . .  particular economical
         and technical benefits of planned  action
         must  be assessed and then weighed  against

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 Alan  W.  Eckert
 June  19,  1978
 Page  Three


          the  environmental  costs;  alternatives
          must be  considered which  would affect
          the  balance  of  values;  .  .  .  the point of
          the  individualized balancing  analysis is to
          ensure that  the optimally beneficial
          action is'finally  taken.  Calvert Cliffs'
          Coordinating Committee, Inc.  v.  United
          Atomic Energy Commission,449 F.2d 1109,
          1123 (D.C. Cir., 1971) .

          We submit  that  site-specific  review may appropriately.
 incorporate data and consider recommendations from the Area-
 Wide  EIS, weigh them against site-specific economic and
 technical factors  and  site-specific impact analysis,  and
 reach a conclusion which  may support  specific action  regarding
 the proposed development.  Such  site-specific considerations
 would also apply to  the other category  of  recommendations
 listed in your letter  (cumulative impacts).

          However, it  is  our view that  the recommendations
 in the Area-Wide EIS cannot  and must  not assume the  status
 of inflexible  regulatory  requirements.

          II.   FINALITY OF RECOMMENDATIONS  REGARDING
                CUMULATIVE  (AREA-WIDE)  IMPACTS

          The  "cumulative  impacts"  category  addresses  the
 elimination of  rock drying (with certain very  limited  excep-
 tions) and limitations  on wetlands  development  (preclusion
 of mining in certain wetland  areas).  EPA  takes  the position
 that  these Area-Wide EIS  recommendations are  conclusive, and
 argues that no  site-specific  factors  may justify  modification
 or revision thereof.  We  submit that  this  is  inappropriate
 and that site-specific  flexibility must  be maintained  so as
 not to preempt  the fulfillment of NEPA during  site-specific
 reviews.

               A.   Rock Drying

          The  recommendation  of Lhu Area-Wide  KIS  rocjiirdlncj
 elimination of  rock drying does allow some  flexibility  on a
 "case-by-case basis" where rock would be shipped  outside of
Florida for chemical processing, and  also  recognizes that
rock to be utilized in  triple superphosphate, elemental
phosphorus,  defluorinated rock feed, or  other fertilizer

-------
Alan W. Eckert
June 19, 1978
Page Four


processes requiring dry rock would be dried at chemical
processing complexes or dryers permitted by the state prior
to publication of the draft Area-Wide EIS  ("DEIS").

          As existing facilities are closed down and new
facilities are phased in, however, restrictions on construc-
tion of new rock dryers would logically result in a diminishing
supply of dry rock.  A dozen phosphoric acid chemical plant
complexes in Florida currently require dry rock, and conversion
to wet rock (in order to accommodate the wet rock supply
coming from the new mines) would cost over 10 million dollars
per facility.

          Furthermore, the DEIS suggests that restrictions
on rock drying may not be necessary:

          .  .  .  eliminating dryers and dry grinders
          [and the resulting change in exposure to radio-
          nuclides] ... is expected to be insignificant
          inasmuch as current processes are also insigni-
          ficant (unmeasurable);  i.e., dose projections for
          phosphate workers have been shown to be small and
          well within guidelines.   [DEIS,  P.  2.87].

          Finally,  the DEIS makes  no reference to existing
regulations  for the prevention of  significant deterioration
of air quality ("PSD") administered by EPA (40 C.F.R.  §
52.21)  and by the state of Florida '[Rule 17-2.04,  Fla.
Admin.  Code].  Under these PSD rul.es, new rock dryers cannot
be permitted unless the projected  impact is within acceptable,
specifically described increments.   We submit that PSD is by
definition a program for controlling cumulative,  area-wide
impacts and  that any attempt to preempt these regulations
and eliminate rock drying through  an Area-Wide EIS is  arbitrary,
capricious and beyond delegated legislative authority.

               B.  Wetlands

          The DEIS poses certain restrictions that might
preclude phosphate mining in various wetlands or waters
under the jurisdiction of the Corps of Engineers pursuant to
Section 404, Federal Clean Water Act.   Again,  no consideration

-------
Alan W.  Eckert
June 19,  1978
Page Five
would be allowed  for  site-specific  economic  or technical
factors, or for developments  in wetlands  restoration techniques,
The  DEIS, on page  2.91,  notes  that  where  the Area-Wide EIS
would preclude mining in wetlands,  "potentially lost tonage
will be made up through  changes in  mining plans .  .  .".
This does not recognize  that  phosphate  rock  must be  mined
where it is found.  Thus,  rock located  in areas designated
for  restriction by  the EIS would be lost.

          Furthermore, existing regulations  fully  provide
for wetlands.review,  including cumulative impacts.   For
example, the Corps  of Engineers has promulgated guidelines
at 33 C.F.R. Parts  320-329, 42 Fed.  Reg.  37121 (July 19,
1977), which include  a "public interest review"  [33  C.F.R.  §
320.4 (a), 42 Fed. Reg. 37136  (July  19,  1977)]  and  a  "wetlands
review" [33 C.F.R.  §  320.4 (b), 42 Fed.  Reg.  37136  (July  19,
1977)].  These reviews would  take into  account cumulative or
area-wide impacts  [(See  §  320.4 (a) (2) (iv)  and  §  320.4(b) (3),
both found at 42 Fed. .Reg. 37136  (July  19, 1977).]

          EPA has also promulgated  detailed,  comprehensive
guidelines for evaluating  impacts from proposed  actions
under Section 404,  Federal Clean Water Act,  found  at 40
C.F.R.  Part 230.  These  guidelines  should  be  implemented  in
coordination with the Corps of Engineers  review  under  33
C.F.R.  Parts 320-329  at  the time a  specific  proposal is
made.  Thus, although Area-Wide EIS  recommendations  may be
considered by reviewing  agencies under  these  existing  wetlands
regulations, the Area-Wide EIS should not  preempt  such
regulations or restrict  the exploration of alternatives at
the site-specific level.

          As indicated in  technical  comments  submitted by
the Florida Phosphate Council to the record  of the DEIS
hearings,  there are many factors to  consider  in  evaluating
proposed activities in wetland areas.  Such  evaluation must
be conducted prior  to the  formulation of  specific  policies.
Current Corps of .Engineers and EPA  regulations should  be
applied in developing any  specific  controls  on phosphate
mining or construction activities in wetlands.   The  Area---
Wide EIS may serve  a valuable,.but  not controlling function
in this process.
                               3-
-------
Alan W. Eckert
June 19, 1978
Page Six
                           * * * *
          In conclusion, we reiterate our intention to raise
only a few basic concerns herein regarding proposed imple-
mentation of the Florida phosphate Area-Wide EIS.  We urge
that EPA affirm the need for maximum flexibility at the site-
specific EIS stage, where all relevant factors may be balanced
during consideration of practical, specific alternatives.  This
is not only consistent with applicable laws, but is in the
best interest of all parties.

                              Sincerely,

                              HOLLAND & KNIGHT
RWS:pm

cc:  Mr. Homer Hooks
                              Roger

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                  ATTACHMENT C
Contents:

Florida Phosphate Council letters dated November 15, 1977,
January 12, 1978, and February 9, 1978 to U.  S. Environ-
mental Protection Agency

-------
          phospkate
             feeds you
Homer Hooks
President
                                               Suite 24. executive Plo^o
                                               4406 S. Florida ftvenue • PO Sox 5530
                                               Lotelond, Ftorido 33803
                                               Telephone 813/646-8583


                                               November 15,  1977
           Mr.  R. E.  McNeill
           Project  Officer
           EPA  Region IV
           EIS  Branch,  Phosphate  Study Unit
           345  Courtland Street
           Atlanta,  Georgia  20208

           Dear Gene:

                       Subject:  Comments  on "Draft  Summary Outline
                                   Probably  Scenario to be  Recommended  By
                                   EPA Phosphate  Unit"

                       As you  requested, we submit herewith our comments on
           the  above document and urge that you and other members of the
           Steering Committee consider these  recommendations most carefully
           in  formulating the draft  scenario:

           "Page  1,  I. New Sources  — A.  Mining and Beneficiat'ion --  1.  Air Quality"
           Comment:
The elimination of rock drying at beneficiation plants would
effectively restrict  export of phosphate rock from new mines.
Also, no provision is made for the rock used by electric furnaces
or defluorinated  rock or triple superphosphate plants which must
have dry rock as  feed.
           "Bases:  -

           Comment:   Citing drying process emissions of approximately 10,000  tons  of
                      participates annually by the year 2000 is an error in calculation.
                      For a large phosphate dryer of about 400 tons an hour, the particu-
                      late allowance in the State of Florida is 44 lbs./hr., which  equates
                      to  about 55 tons/yr.  for a million tons per year drying  operation.
                      Using EPA's value of 10,000 tons per year of particulate would
                      result in the drying of 182 million tons of rock per year.  If 20
                      million tons a year of rock were dried in future mines,  the value
                      would be about 1100 tons per year of particulate emission.  Thus,
                      EPA is high by a factor of about 10 on this basis.

                      The statement that "A significant quantity of radionuclides would
                      also be emitted in these areas if the drying process were used" is
                      misleading and taken out of context from the EPA report,  "Population
                      Radiation Dose Estimates From Phosphate Industry Air Particulate
                      Emissions."  On page 12 of the Draft Report of May 1977,  the  state-
                      ment is made, "The results of this study show small, but measurable,
                      increases in tests for radioactivity surrounding the phosphate
                      industry operations."  It further states, "Dose projections provided
                      in  Tables 15 and 16 also show the small magnitude of airborne
                                     Cnoirman of theBoord UJm. H. f jn\ Gordimer. Inc
   Flgnco Chemical Company » Borden, Inc. — Chemical Divi5'on/Srmrh-Dougloss • Oreajster Phosphates (flmencan Cy-namid/Kerr-McGee) • Consssrv. Department c-' Pnil'pp
   firotne/s Division of €nglehcrd funerals 6 Chemicals Corp • Clectro-Phas Corporation • Farmland Industries. Inc • Frceport Chemical Company • Gardinie/ K: » UJ. R.
   Grace & Company, flgnculcurul Cbo.imcals • International Minerals & Chemical Corpororon • Mississippi Chemical Corporo^,on • Mobit Cncmicol Company • O;c.dental
   Chemical Company • Rou>ter Company • S'oufrer CherP'ia! Company » Siuift Rsyicultu'O' Chemicals Corporation • T/H Minerals Corporation • Ur»5 rXyi-Cne.-mcals

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Mr.  R. E.  McNeil1               -2-               November 15,  1977


          particulate radioactivity released from the phosphate  industry
          operation.   It appears that drying operations are the  most
          significant source  of airborne radioactive particles. "  The import
          of this statement is  that the magnitude is small,  and  that the
          dryers contribute most of it.  It is misleading to say that the
          dryers emit significant quantities of radionuclides.

"Bases -- i i"
Comment:  Net energy savings  cited as one barrel of oil per ton  of rock
          dried is in error.  This would require 42 gallons of oil to dry
          a ton of rock;  whereas a good industry value is 2.5  to 3.0 gallons/
          ton.  A 20% moisture value is used, which is high., since phosphate
          rock generally  averages about 12% moisture.

"Possible Exception on Case by Case Basis:"

Comment:  The cost of drying  a ton of rock using the current price of $12.00
          per barrel of oil,  is 71.3$ to 85.5$ per ton.   For 12% moisture
          rock, wet rock  shipments would contain 0.136 tons water/ton dry
          rock.  Thus, if the freight cost is over $6.29/ton,  it would be
          more than the cost  of drying, using current oil prices.

          Air quality protection using two-stage scrubbing or  bag filtration
          equipment is cited.  Two-stage scrubbing is not required to meet
          the Florida process weight table.  All the operations  in Florida
          that have wet scrubbers use one stage of scrubbing.  Bag filtration
          equipment is not used, since it is an impractical application for
          drying phosphate rock, due to severe equipment operating problems.

PROPOSAL  — We propose that  the industry be permitted  to
              develop the most  economical  methods of processing
              with adequate environmental  controls.  Particulates
              and any associated radiation are  controllable with
              present technology.

"Page 2, 2.  Surface Water Quality"

Comment:  All operations  will have to meet EPA effluent limitations and
          Florida water quality and EPA water quality standards, whatever
          they may be.

"3. Eliminate above natural ground slimes disposal areas, by a method such as
    pre-thickening of slimes, combining with tailings, and utilizing combined
    material for filling  mined-out cuts."

Comment:  The requirement to  eliminate above-ground waste clay disposal areas
          cannot be met for the following reasons:

          1.  Proven technology does not exist.

          2.  In order to achieve final grade at original ground level,
              the clay or sand-clay mixture will have to be stacked
              above ground to allow for consolidation and dewatering.

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Mr.  R. E.  McNeill               -3-               November 15,  1977


           3.  Variations in ground contours will necessitate  retaining
               dikes in some areas.

           4.  An initial above-ground clay disposal area must be  constructed
               prior to the start  of mining.  Only after some  time period has
               elapsed will sufficient mined-out area be available to begin
               waste disposal operations below ground.

PROPOSAL  — Utilize  developing technology to  minimize above-
              ground  slimes  disposal areas, recognizing the  need
              for an  initial slimes  storage facility,  and the
              desirability of a timely and balanced  land reclama-
              tion program.
"Bases"

Comment:  1.  The 1972 State of Florida dam regulations have been  effective
              in eliminating dam breaks.

          2.  A requirement that all waste clays be placed below ground will,
              in fact, eliminate several options for land reclamation:  lakes
              and rolling topography, for example.  Better land for both
              Mtildlife habitat and for economic development may be achieved
              by a balanced reclamation plan that will involve some above-
              ground disposal in order to avoid placing waste  materials
              over the entire mined area.

          3.  After self-weight consolidation, slimes typically retain 75
              to 80 percent water, not 92 to 96 percent, as stated.
              Approximately 1000 gallons of water per ton of rock  is tied
              up, not 200 gallons, as stated.

          4.  We have seen no data on plant-scale operations to show that
              new disposal methods will cost the same as conventional
              impoundment.

"Disadvantages"

Comment:  This lang-^age indicates  that if a process is developed to allow
          economical chemical processing of slimes, new source mines should
          adopt such a. process immediately.  This implies that mines should
          then enter into the chemical plant business.  We do  not  believe
          that this is the intent. The decision on whether or not to  enter
          into the chemical plant  business should be a company decision
          because of the large magnitude of capital investment and market
          considerations involved, and should not be a requirement for a
          permit.

"Page  3, k.   Groundwater Quantity  --  b."

Comment:  The draft states, "Basically, 100% of process water  should be
          recirculated on an annual basis."  This cannot be done,  since
          process water is not a separate circuit and mixes with the
          water going to the slimes pond, which retains a significant

-------
Mr.  R. E.  McNeill
-4-
November  15, 1977
          portion of the water.  In addition,  some  well water is required
          in one stage of  the flotation process.  This requirement is
          impossible to meet.  Current recirculation rates in the industry
          are about 85% to 90%.  If reoiraulation is required in the scenario*
          it should be defined in detail.

          The draft states,  "Maximum pumping from wells should approximate
          the losses to evaporation during periods  when evaporation exceeds
          rainfall over a  SO day period."  It is  impossible to determine
          accurately evaporation and rainfall values over an entire mining
          property.  This  was explored in great depth with EPA on the
          effluent guidelines for phosphate fertilizer plants, and EPA
          eventually eliminated this requirement  in the regulations.  It
          is impossible to determine accurately the areas of evaporation
          plus transpiration that occur, and it is  equally impossible to
          obtain accurate  rainfall values, since  scattered rainfall occurs
          in this area.  Within a 15 mile range in  this area, it has been
          found that annual rainfall may vary by  10 inches.

"Page k, 6.  Radiation"

Comment:  In our opinion,  air emissions from rock dryers are not a radiation
          problem.

"Page k, 7.  Reclamation"

Comment:  The concept of maintaining constant acreage of wildlife habitat
          needs to be explained in more detail.   If the goal is to maintain
          wildlife populations, constant acreage  is not the only way, and
          probably not the best way, to achieve- it.   The statement that
          area to be mined is a large percentage  of wildlife habitat
          currently available is not supported by DRI's already prepared
          nor by the working papers.

          TI's working paper, "Future Land Use",  p.  2.S, projects a decrease
          in existing wetlands of 1,1% between 1975 and 2000.  Furthermore,
          it may be desirable to alter existing wildlife populations in some
          areas for specific management purposes, e.g., fisheries, waterfowl,
          etc.

          Conflicting Federal, State and local requirements make this most
          difficult if not actually unworkable.   Different agencies cannot
          seem to agree on the best reclamation practices and objectives.

PROPOSAL  — Mining and reclamation  plans  will be  designed to
              maintain a wildlife population.  Proposed  alterations
              in wildlife habitat must demonstrate  specific desirable
              management goals.

"Page *t, ?• c."

PROPOSAL  — Wetlands which are under the  jurisdiction  of  the
              Corps of Engineers Section  404,  Federal Water

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Mr.  R. E.  McNeill                -5-              November  15,  1977


              Pollution Control  Act, will be protected or restored.
              Those wetlands for which permits are issued to mine
              will be  restored to provide a  physical basis for
              reestablishment of natural functions.

 "Page  5,  B.  Chemical Processing --  2.  Surface Water Quality"

 Comment:  The values given for the "old" EPA Standards of Performance For
          New Sources are -incorrect, -in that TSS criteria do not apply if
          the process wastewater (pond water) is treated  before discharge.
          These TSS values should be removed.

          The "new (area-wide EIS)" requirements for SO day average are
          less than one-third for phosphorus.,  and  only 40% for fluoride.
          They should not have any TSS requirements.  Laboratory work done
          by EPA itself3 in EPA's own laboratories,  on a  number of gypsum
          pond water samples from this area and other areas of the country,
          were used to establish the so-called "old (current)" EPA Standards
          of Performance For New Sources.   Technology does not exist to
          meet the "new  (area-wide EIS)" proposed  requirements, as shown
          by EPA 's own laboratory work for gypsum  pond water.

          In evaluating current effluent quality as reported to EPA on a
          quarterly basis, it is most likely that  the data represent non-
          process water discharges.,  since process  wastewater (pond water)
          is only discharged a few weeks per year  (after  liming and settling),
          or for some plants, not at all.   However,  when  water is discharged,
          EPA requires analyses on effluent leaving the treatment system
          before any dilution.

          The draft recommends that the non-process water system be designed
          for complete recirculation with the same design surge capacity
          as a contaminated process water system,  and the same standards
          for discharge are applicable.  The same  standards  (process waste-
          water) for discharge now apply to non-process water.  This
          proposal is not technically feasible, since a substantial amount
          of the non-process wastewater source is  from boiler blowdown to
          eliminate dissolved solids and from cooling towers to eliminate
          dissolved solids.  It is not possible to recirculate this water
          back to the boilers or cooling towers without treatment.  Such
          treatment would then again provide regenerated  waste streams
          which cor.not be put back either.   The best way  to use this water
          is to dispose of it in a mining operation, if the company has
          its own phosphate mine nearby, since it  would be suitable for
          this use in the mine circulation system.

          DER mining effluent guidelines effective October 1, 1977,
          regulate phosphorus in mining effluent.   Adding non-process
          water  to the mining circuit may increase phosphorus levels above
          allowable values.

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Mr.  R. E.  McNeill
                          -6-
November 15,  1977
"Page 6 -  Basis"

Comment:   It is stated that several chemical complexes have converted to
           complete recirculation of both systems; that is, including non-
           process water.  We do not know of any chemical plant that has a
           closed circulation system for non-process water.  The one plant
           referred to that does not have an NPDES permit does not recircu-
           late non-process water, but puts it into their mine water circuit,
           which is the best place for it.  The statement citing recirculation
           systems for non-process water should be removed.

"Page 7, 3.  Ground Water Quality"

Comment:   It may be that, at a specific site, it could be demonstrated that
           a lining is not necessary to protect groundwater from chemical
           and radiological contamination, if groundwater is defined in
           detail.  It certainly seems to be no problem with deep aquifer
           water, although there may be some problems in some local areas
           around the ponds in the upper surficial sand layers — which
           could probably be corrected.

"Page 7, 5-  By-product Recovery -- a."

Comment:   It is recommended to recover fluosilicic acid from phosphoric
           acid evaporators.  The market is limited for this material,  and
           if too much is recovered, it cannot be sold and will be dumped
           into the pond.  This should be a matter of economic evaluation
           for the company involved.  Plants recovering fluosilicic acid
           do not have noticeably lower fluoride concentrations in their
           gypsum pond water than plants that do not recover the material.

"Page 7. 5- " b."
 Comment:
This again should be a matter of economics for the individual
company.  Recovery of uranium from the phosphoric acid will have
little or no effect on the uranium in any of the waters or solid
waste disposal areas of the industry, since the phosphoric acid
containing uranium is either shipped from the area or used to
produce solid fertilizers, which contain all of the uranium
present in the acid.
 "Basis:"
Comment:  The  basis  that it is economical depends on the situation involved
          and  should not be presented as a fact.

"II.   Existing Sources  -- A.  Modifications, page 8, first paragraph"

Comment:  Since the  areawide  EIS can have no direct legal impact on existing
          sources, these recommendations should be excluded.  Federal guide-
          lines promulgated in November 1976 already require existing sources
          to comply  with new  source standards and only a compliance schedule
          is left to be worked out with the State DER.
                                 .7-67

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Mr. R.  E.  McNeill              -7-            November  15,  1977


         It is mentioned that a study to be completed in the next two
         years will determine the need or lack of need for lining existing
         gypsum ponds.  How existing gypsum ponds could be lined is  unknown
         and there would not appear to be any practical way that this could
         be done.  This statement implies that EPA plans to conduct  such
         a study.

"Page 8,  B.  Operation and Maintenance"

Comment:  We support this recommendation for in-plant inspections* source
         sampling, and ambient monitoring.  We oppose any proposal that
         the industry pay for this surveillance.  The costs should be
         borne by the DER and EPA.

          In summary, we  feel  that the elimination  of the rock
drying process at beneficiation plants is not based on techni-
cally accurate data, either as to particulate emissions or net
energy savings.  The latter may actually have a converse/effect,
with  concurrent serious  impacts on exports.

          We feel that the proposed elimination of  above ground
slimes disposal areas is an impossible requirement, and we have
a  specific language proposal  on this subject.

          The reclamation requirements in the draft scenario may
well  be counter-productive, and we have draft language proposed.

          The proposed new surface water discharge  requirements
are unattainable, and no evidence cited justifies  these values.

          We feel that the production of fluosilicic acid and/or
uranium are management determinations, based upon  economics.

          Finally, it is  our firm contention that the accumulated
evidence produced in the Texas Instruments working papers
demonstrates that phosphate mining should be allowed to expand
to meet the growing world demand for fertilizer and food,  that
it would be against the  best  interests of all the  people to deny
access to the known Florida deposits, and the Texas Instruments
papers further document  that  this mining can be accomplished
within reasonable environmental restrictions which are already
in force by various levels of jurisdiction.
 HHrjb                                Homer Hooks

 cc:   Steering Committee
      Advisory Committee

-------
                                                            Suite 24. Crecu'ive Plozo
                                                            4406 5. Florida flvenue • P.O. Box 5530
                                                             lokelond. Florido 33803
                                                             Telephone 813/646-8583
Homer Hooks
President
January  12, 1978
          Mr.  R.  E.  McNeill
          Project Officer
          EPA  Region IV
          EIS  Branch, Phosphate Study  Unit
          345  Courtland Street
          Atlanta, Georgia   20208

          Dear Gene:

                     Subject:   Comments on "Draft  Summary Outline
                                Scenario to be Recommended by  EPA
                                Phosphate Unit"
                                                                       I
                     We submit herewith our comments on the above document
          mailed by you on  December  30, 1977, and received by  us on
          January 4, 1978.

                     We are  struck by the absence  of any comment in the
          draft scenario on the documented and demonstrated  social and
          economic benefits of continued and expanded phosphate mining
          in Florida.  Any  options by  decision-makers as to  expansion
          or limitation of  phosphate mining in Florida must  obviously
          take into account the enormous economic benefits of  this
          industry to Florida, the nation, and the world, and  most
          certainly must recognize the unique impact of this industry
          in providing fertilizer and  food production in the United
          States and the world.  We  see no inclusion of this basic con-
          sideration in the draft scenario, and we strongly  urge that
          deserved recognition be given to these  fundamental factors in
          the  draft environmental impact statement.

                     Also, we question  the legality of prescribing, in
          the  draft scenario and presumably in the EIS, what are, in
          effect, new surface water  quality standards for chemical
          plants without having gone through the  established and
          required procedures for rule-making and promulgation of
          standards.

                     Further,  it is our firm contention that  the accumu-
          lated evidence produced in the Texas Instruments working papers
          demonstrates that phosphate  mining should be allowed to expand
          in Florida to meet the growing world demand for fertilizer and
          food, that it would be against the best interests  of all the
          people to deny access to the known Florida deposits, and the
          Texas Instruments papers further document that this  mining can
          be accomplished within reasonable environmental restrictions
          which are already in force by various  levels of jurisdiction.

                                Chairman of theBcxyd: UJm. H FunK Gordmier, Inc.
  flgrico Chemkol Compony * Sorden. Inc. — Chemical  Division/Smith-Douglass • Brewster Phosphates (flmerican Cyonamid/Kerr-McGee) • Consent Department of Philipp
  Brothers Division of €ngl«hord Minerals & Chemicals Corp. • €lectro-Phos Corporation • Farmland Industries. Inc. • Preeporc Chemical Company • Gordmier. Int. • UJ. ft
  Grace & Company, ncjricultural Chemicals • International Minerals & Chemical Corporation • Mississippi Chsmical Corporation • Mobil Chemical Company • Occidental
  Chemical Company • Royster Company • Stouffer  Chemical Company • Suiift Rgrlculturol Chemicals Corporation • T/fl Minerals Corporation • USS Hgri-Chamicals

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Mr.  R. E.  McNeil1
-2-
January  12, 1978
            Following are specific  comments on  sections of the
draft scenario:

"Page 1,  I.  New Sources — A.  Mining and Beneficial:ion —  Air Quality"

Comment:  Eliminate first sentence and substitute therefor:   "Reduce use
          of the rock drying process whenever technically possible  or
          technically practical."  The uses for dry rock specified  are
          too limited.  Vie suggest the following language be added:
          "or other fertilizer processes requiring dry phosphate rock."
          For instance, singlesuperphosphate, still a  large  tonnage product,
          is omitted.

          The requirement that rock is to be dried at  the chemical
          processing complex, or at existing dryers in Polk  County, is
          unfair to future miners and chemical plant operators  and  to
          Polk County, and should be eliminated.  The  present Clean Air
          Act requirements and Florida 17-2 rules are  very strict and
          are designed to protect the public and the environment.  'Any
          new installation will have to meet these criteria.

"Page 1,  Bases: —  i"

Comment:  The 2, 000 tons of particulate annually, from dryer stacks,  would
          be about 1,100 tons a year, provided that as much  as  20 million
          tons a year of rock were dried by future mines.  Later in the
          paragraph, 2,000 tons is used as a dryer estimate,  which  is in
          error, because this 2,000 tons includes transfer and  trans-
          portation estimates, and we do not know the  basis  for this
          number.

          It is general practice when discussing radioactivity  on an
          annual basis, to present this in terms of curies,  which would
          be 0.042 curies per year for 1,100 tons per  year particulate
          out of stacks.  To put this in perspective,  this is equivalent
          to 0.042 grams/yr. of radium-226, a very small quantity.

"Page 2,  2.  Surface Water Quality"

Comment:  All operations will have to meet EPA effluent limitations and
          Florida water quality and EPA water quality  standards, whatever
          they may be.

"Page 2,  3.  Slimes  Ponds"

Comment:  Complete elimination of conventional above-ground  slimes  disposal
          areas cannot be accomplished with current, proven  technology.

          We propose the following wording:  Minimize  above-ground slimes
          disposal by utilizing new technology for slimes dewatering.  The
          mining and reclamation plan for New Source Mines should establish
          a method whereby  the slimes  (or slimes-tailings mixture)  is used
          for reclamation or some other purpose.  The  need for  an  initial
          above-ground storage area is recognized, as  is the need for
          temporary  retaining dikes around disposal areas prior to  reclama-
          tion.

-------
Mr.  R. E.  McNeill
-3-
January  12,  1978
          Also, paragraph (Hi) is not clear.   Suggest following wording:
          "Should allow a higher degree of water recirculation than the
          85-90% now achievable by releasing additional water normally
          retained in the slimes."  Slimes in conventional settling areas
          can retain up to 1,000 gallons of water per ton of rock pro-
          duced.  With regard to paragraph (iv),  costs of alternative
          methods of slime disposal can not be forecast with certainty
          at this time.

"Page *t, 5-  Ground Water Quality (i)"

Comment:  This paragraph should be changed to read "The mining plan
          should allow for maximum utilization of water obtained from
          dewatering."  Incorporating requirements for use of this water
          in transportation and beneficiation processes in a discussion
          of connector wells is out of place,  since the tao are not
          necessarily related.

"Page A, 6.  Radiation -- Paragraph 2:"

Comment:  Requires that recommendations published by EPA on March 1 and
          June 1, 1978, be included in the final EIS.   It is our under-
          standing that these will be proposed regulations.   A period of
          time will be allowed for comment, and the final regulations may
          indeed be different.  Other research, data to become available
          may further modify proposed regulations.

"Page 4, 6.  Radiation — Paragraph 3:"

Comment:  Change to read "Mining and reclamation plans for New Source
          Mines shall meet future State of Florida and EPA requirements
          with regard to radiation levels of future reclaimed land. "
          It is premature to specify how this will be accomplished until
          the final reports of studies now being done are completed and
          final regulations are promulgated.

"Page 5> 7.  Reclamation (c.)"

Comment:  In this latest draft, your tentative classification of wetlands
          into four categories has been reduced to three categories.

          Our main objection to this section is that it appears to limit
          the range of options for wetlands mining and reclamation to a
          simple set of conditions.  The enclosed memo by Mr. Tom Oxford,
          of Bromwell Engineering, Lakeland,  Florida,  expounds on this
          point in some detail.

          We are willing to accept the proposed categories as a broad
          statement of policy.  Some wetlands are so valuable that they
          should not be disturbed; others have such little value that
          neither preservation nor restoration is required.   Between

-------
Mr.  R.  E. McNeill               -4-                January 12,  1978


           these two end cases, a variety of situations exist that must be
           considered on an individual, site-specific basis.

           It should also be recognized that natural reclamation, in some
           cases assisted by man 's efforts, can restore wetland functions
           and result in high quality habitat for wildlife.  Provision for
           this should be made in any effort to establish criteria for
           restoring wetlands.

           Further study is needed to establish both the value  of existing
           wetlands and the value of various possible types of  wetlands
           reclamation.  Ongoing studies, including work for the Florida
           Phosphate Land Reclamation Study Commission, U, S. Fish and
           Wildlife Service, and various EIS's for new mining operations
           will help to provide the needed data.

           Until such studies are made, we oppose any effort to establish
           inflexible criteria for wetlands preservation or reclamation.

"Page  5,  B.  Chemical Processing -- 1.  Air Quality"

Comment:   The first sentence should be changed to read "Hew source
           performance standards are adeqv&te to protect air quality."
           Inclusion of the language "if emission limitations are con-
           tinuously met" is an unwarranted implication of non-compliance
           in the phosphate industry and has no place in the scenario.

"Page  6,  B.  Chemical. Processing -- 2.  Surface Water Quality"

Comment:   We reject the concept that the EIS can by-pass the normal rule-
           making procedures of EPA by proposing to implement the proposed
           "New  (areawide EIS)" effluent limitations.  These proposed "New
           (areawide EIS)" effluent limitations should be removed from
           the scenario.

           There is no scientific basis for the values proposed under the
           "New  (areawide EIS)" values, and this appears to be  an attempt
           at rule-making by fiat.  Since existing chemical plants only
           neutralize and discharge process wastewater a few weeks a year
           at the most, the improvement in the environment in reducing
           these values from the current performance standards  to the new
           proposed standards would be negligible.  In our opinion,
           technology does not exist to meet the "New  (areawide EIS)"
           proposed guidelines.

           The  "New  (areawide EIS)" requirements for 30 day averages are
           less  than one-third for phosphorus, and only 40% for fluorides,
           of existing EPA new source performance standards.  Laboratory
           work  done by EPA, in EPA's laboratory in Cincinnati, Ohio, on
           a number of gypsum pond water samples from this area and other
           areas of the country, were used to establish the  "current
           (EPA  standards of performance for new sources)."  Three tables

-------
Mr..  R. E.  McNeUl               -5-                January  12,  1978


          of laboratory data obtained by EPA in these tests are enclosed.
          These tables do not show EPA fs name, and to the best of our
          knowledge a formal report was never issued.  However, EPA can
          check with Mr. Elwood Martin of the EPA Guidelines Division
          in Washington, D. C., to verify that these are,  indeed, EPA
          data.  In reviewing the averages of the EPA data, there is
          a wide variability among the different pond waters, not only
          w-lbh respect to initial analysis, but with respect to final
          fluoride, phosphorus, and total suspended solids obtained by
          double liming treatment.  None of the averages met the proposed
          "New (areawide EIS)" requirements for fluoride,  phosphorus, or
          TSS, except for one sample which met it on phosphorus but which
          is a high chloride sample and not typical of inland chemical
          plants.

          The draft recommends that "the non-process water system is to
          be designed for re-circulation with the same design surge
          capacity as the contaminated process water system," and the
          same standards for discharge are applicable.  The same standards
          (process wastewater) for discharge now apply to non-process
          water.  This proposal may allow possible discharge of cooling
          tower and boiler blowdown in cases where this water cannot be
          discharged to a mining circuit.  This requirement may "be too
          restrictive.  There are other water sources which need to be
          discharged that cannot be circulated, such as regeneration
          streams from water softeners.   Data and experience are not
          available to know whether or not some of this non-process
          water can be recirculated and re-used without excessive scaling
          of equipment.

          As pointed out before, the State of Florida DER mining effluent
          guidelines effective October 1, 1977, regulate phosphorus in
          mining effluent.  Adding non-process water to the mining cir-
          cuit may increase phosphorus levels above the allowable value,
          in which case this cannot be done.

"Page 7. Basis"

Comment:  It is stated that several chemical complexes converted to
          complete recirculation of both systems, and that the one new
          chemical complex constructed since that time does not even
          have an NPDES permit, because it is designed for complete
          recirculation of process and non-process water,  with a portion
          of the non-process water blended with the mining circuit.
          This statement is not correct.  The plant that does not have
          an NPDES permit discharges their non-process water to the
          mine circuit.  A few other plants in the area which were
          believed by EPA to have complete circulation of non-process
          water, have in fact continuous discharges of non-process
          water.  Therefore, there are no chemical complexes in Florida
          that have complete recirculation of non-process water.  This
          will involve a new technology, and experience is not available
          at this time to determine how it will work.  We do not know

-------
     R. E,  McNeill
-6-
January  12, 1978
          of any information that shows that these proposed recirculation
          systems would result in a net reduction of costs, because of
          savings of product and the reduced need for pumping water from
          the aquifer.  Product savings would not result and the cost of
          the extra equipment and power required for pumping to recir-
          culate this water would increase costs.

          The last paragraph at the bottom of page 7 relating to the EPA
          Development Document in July 1971, is out of date and was
          superseded by the attached laboratory tests conducted by EPA.

 Page 3, 3.  Ground Water Quality"
Comment:  This entire section should be removed from the scenario.

          Existing data do not support the necessity to line gypsum ponds
          with an impervious material.  Additional studies are being made
          in cooperation with the Florida DER and, until these are completed,
          there is no basis for this requirement.

          It may be, at a specific site, that it could be demonstrated that
          a lining is necessary to protect groundwater; however,  this is
          not the case at the present time.

"Page 8. 5.  By-Product Recovery— a."

Comment:  This entire section requiring fluosilicic acid recovery should be
          removed from the scenario.  It is unrealistic to require a company
          to increase its operating costs to recover a product for which
          there is a limited market.  If this material cannot be  sold,  it
          will be dumped into the gypsum pond, thereby wasting valuable
          economic resources — capital and operating costs.

"Page 8, 5-  By-Product Recovery — b"

Comment:  This entire section requiring uranium recovery from phosphoric
          acid should be removed from the scenario.  It is unrealistic to
          require a company to invest substantial capital and incur
          increased operating costs unless it is assured of a reasonable
          return on investment.  This should be a management decision and
          has no place in the scenario.

"Page 8, 5.  By-Product Recovery — Basis"

Comment:  Plants recovering fluosilicic acid do not have noticeably lower
          fluoride concentrations in their gypsum pond water than plants
          that do not recover the material.  Phosphoric acid containing
          uranium is either shipped from the area or used to produce fer-
          tilizers, which contain all th& uranium present in the  acid.

"Page 8,  II.  Existing Sources, A.  Modification"

Comment:  Since the area-wide EIS can have no direct legal impact on
          existing sources, these recommendations should be excluded.

-------
Mr.  R. E.  McNeill              -7-               January 12, 1978
          The Federal Guidelines promulgated in November 1976,  already
          require existing sources to comply with new source standards,
          and only a compliance schedule is left to be worked out with
          the State DER.

          It is mentioned that a study to be completed within the next
          two years will  determine the need or lack of need for lining
          existing gypsum ponds.  How existing gypsum ponds could be
          lined is unknown and there would not appear to be any practical
          way that this could be done.  This statement implies  that EPA
          plans to conduct such a study.

"Page 9> B.  Operation &  Maintenance"

Comment:  We support this recommendation for in-plant inspections, source
          sampling, and ambient monitoring.  We oppose any proposal that
          industry pay for this surveillance.  The cost should be borne
          by the Florida  DER and EPA.

          We would like to point out that chemical plants have  been
          performing maintenance on scrubbing equipment since they have
          been installed, and that this did not start just because of
          inspections by  the 'DER in October-November 1977.  This language
          should'-'be re-written since it is very misleading.
                                          Homer Hooks

HH: jb

Enclosures

cc:   Steering  Committee
      Advisory  Committee
                             3- 77

-------
                         ^MEMORANDUM


TO:          EPA/EIS File

PREPARED BY: T. P. Oxford

REVISED:     L. G. Bromwell

SUBJECT:     Proposed Categories for Wetlands Classification
     The four wetland categories proposed by the EPA are
inadequate to describe the situations encountered in phosphate
mining and land reclamation.  The four categories are a subset
of a more comprehensive set of circumstances, as described in
some detail below.

     Note that each of the EPA's categories, with a. certain degree
of imprecision, follows a particular format; viz., present land
use, future land use.  The present use of lands in categories
1 and 2 is to "serve important functions", tacitly assumed to be
those functions that are commonly ascribed to wetlands.  The future
use in category 1 is precisely the same as the present use since
lands in this category are not permitted to change.  The future
use in category 2 is "similar" to the present use and disruption
is permitted.

     An example of circumstances that would distinguish between
categories 1 and 2 would be, on the one hand, the very specific
case of a wetland parcel performing the particular identifiable
function of purification of agricultural runoff water in which
case removal of the vegetation would cause immediate and relatively
long-term detrimental effects on downstream waters; on the other
hand, a like area of similar size and quality might be so located
as to possess importance only as a member of the regional pool of
wetland acreage.  This suggests that location, at least insofar
as it relates to function, is deserving of consideration.

     Categories 3 and 4 have similar present uses, namely, "less
important".  The matter of "importance" is at once crucial and
nebulous.  In this instance it is not clear whether lands in these
categories are less important because they perform important
functions less well  (than category 1 and 2 lands) or because they
perform only less important functions, or perhaps a narrower range
of functions.  The distinction may bear significance.  A clue  is
provided  (unconsciously it seems) in the comparative wording of
the category 2 and 3 descriptions.  The less important wetlands of

-------
Memorandum EPA/EIS File
January 5, 1978
Page 2


category 3 may be replaced with land of completely different
wetland type, suggesting a link between importance and type and
implying that no such approach is valid for category 2 lands.
Thus, where a particular important function is served, restoration
of similar function requires restoration of similar type.   Possibly
this notion is only inadvertantly expressed.  It is, in any case,
a debatable idea.

     Finally, the category 4 wetlands are less important to the
extent that they may presumably have zero value...unless,  of
course, some non-zero worth is assigned to all wetlands by definition.
This category is but one of the many that appear in figure 1.

     The figure illustrates the most reasonable pairings of present
uses and future actions as well as indicating some pairings that are
only marginally likely.  Present uses in terms of wetland function
are graded as (A) important, but with value deriving largely from
location, (B) important, in the sense of being vigorous and
contributory, but not necessarily irreplaceable, and (C,D,E) less
important or unimportant.  Action options include (1)  no disruption;
(2,3), restoration of site to same or alternative type wetland;
(4,5) site restoration not considered and equivalent acreage
elsewhere may or may not be considered.

     In figure 1, blank squares are those that are not logically
consistent or, even if so, must be excluded as a practical matter.
Pairs indicated by "X" are those that are possible, but not
highly likely circumstances.  Pairs indicated by "*" are the
categories that it is entirely reasonable to expect.  Numbered
entries refer to the corresponding EPA categories.

     EPA,category 1 seems to correspond to case Al.  Cases Bl
and Cl are less likely to occur, but the situation can be imagined
in which very localized function, even if small ("less important",
case Cl), dictates that consideration be given to preservation.
The unlikely case Bl might occur where the extent of land involved
was so great that temporary disturbance would disrupt even the
general contributory function.

     Case B2 may be that which EPA had in mind for category 2.
Here the suggestion that important function can be restored only
by like-type wetland is implicit.  If that is so, then the indicated
case B3 is unlikely, if not impossible.  However, if function is
not site-specific, then case B4 in which equivalent wetland acreage
is created elsewhere is, in fact, a circumstance that is very
reasonable.

     The supposed connection between function and wetland type
pervades cases A2, B2, C2, and D2 making them very  likely, while
making cases A3, B3, and C3 less so.  Case C4, however, appears

-------
WETLAND FUNCTION PERFORMED IS




















ACTION TAKEN IS
(1) Disruption represents
unacceptable adverse impact
NO COMPROMISE
(2) Restoration of like-
type W/L at site
(3) Restoration of alternative
type W/L at site
(4) Restoration to other land-
use but with equivalent W/L
acreage created elsewhere
(5) Restoration to other
land-use
0)
-p
-H
in


•o
c
a

4J
G
(0

^|
a-3

H -H
0
0)
--. a
A «


*!




X











•d
§

4J
C
m
-P

L
E ^
M M
0)
C
^. Q)
W U>


X




X

*







•.
4J
s
^
o
04 0
e -M

•H
W O
CO CU
0) O4
h3 M

+J

O 43


X




X










4J
S
M
O
04
E r-t
•H nJ
^1
0} (U
CO C
a) cu
^) C71

•O
-> d
S 
-------
Memorandum EPA/EIS File
January 5, 1978
Page 3


to be identical to EPA category 3.   Thus where function is less
important and not specific to the site,  an alternative wetland
type would be acceptable.   Similarly,  though not recognized in
the EPA proposal, an alternative site  would be acceptable, the
situation represented by case D4.  Further, depending upon degree
of importance, a non-wetland land use  might be contemplated as in
case D5.

     Case D5 or E5 is EPA category 4 in  which wetland value is
insufficient to warrant restoration as wetland.   However, even
when no present wetland function exists, there may be a need to
create wetlands at a particular site of  disturbance.   A common
example would be an area that previously was marshland and was
drained long before mining for agricultural use.   Such a situation
would be included in case E3.

     The position frequently taken by  environmentalists is that if
an area is declared a wetland, it then must perform certain vital
functions, and in consequence it must  not be disturbed.  The only
rational counter-proposal is to require  that wetland areas be
evaluated on an individual basis.  The EPA proposal,  modified to
be suitably comprehensive, provides the  grounds for site-specific
evaluation.  By comparison, any approach using acreages and water
flow criteria appears to be inflexible and therefore counter-
productive.
se
                             -8 I

-------
TA'DU: i
IIESULTS 07 TllHATADILm JAR TESTS
PHOSPHATE FEKTILISin LYDUSTOY V/ASTC'.i'ATEn SAMPLES
'.oapany i pH
Jane raw
Farmland 2.3
•2.4
•2.4
•2.4
2.3
2.3
«'2;3'
"2.3
•*2.3
.V.U.3
"M.ff
Harden 2.3
•1.7
/ *1.7
V '1.7
2.3
2.3
••2.2
"2.2
"2.2
.Mil. 8
•••2.0 '
Gardinicr 2.1
•1.6
•l.G
•1.6
2.1
••2.0
••2.0
"2,0
«ii.'i'S
•••1.9
pi! 1st
i •
stasc
start end
1
3.3
3.6
3.G
3.6
3.3
3.3
3.5
3.3
3.5
5.2
7.1
3.8
3.6
3.G
. . 3.6
. 3.3
3.3
3.3
3.3.
3.3
5.1
7.2
3.3
3.5.
3.5
3.5
3.3
3.5
3.5
3.5
4.8
7.0
3.2
3.7
3.6
3.7
3.2
3.2
3.0
3,0
3.0
5.1 •
G.O
3,4.
3.5
3.5
S.C
3.4
' 3.4
3.3
3.3
3.3''
5.1
7.0
3.3
3.4
3.4
3.4
3.3
3.1
3.1
. 3.1
4.0
?;? '
'pi! 2nd Et.M»o ml/1 10$ line
slurrv Settling timo - hrs Fluoride
start end 1st stago .'2nd stage 1st "etajjo.
(mix timo - min)
6.7
8.5
.0,8
8.G
8.6
ais
8.3
.
*

,t
6.0
8.1
a. s
• 8.5
8.5
8.3
8.6

' ,


• 6.2
8i3
8.5
1 8.5
8.5
• Br9
6,7
8,5
8.2
8,2'
8,3 ...




•

7.3 •':
0,2
8.0 "
8.9
0.2
-
.
.
i • '
1
1
6.3 '
0.4 ' •
0.5
0,4


60 (6)
' 60 (6)
60 (0) ..
23 (1)'
23 (1)
23 (1)
• 60 (6)
..." 00 (7).

133 (7)
133 (7)
.133 (7)

90 (10)
.. ' 00 (10)'
00 (10)
. 120 (8) •
170 .(9) '.'

75 (5)'
75 (5)
75 (5) •

' 40 (2)
40 (2)
40 (2)'
loo (a)
150 (4)
•
60 (0)
GO (9)
•GO (9)
20 (<1)
2 (<1).




,
•110 (11)
110 (11) ;
110 (U)
30' (3) '.
4 (6)





00 (6) ..
00 (6)
90 (6)
35 (3).
•0,5(*
39 '
50
50
DO'
50
so r
rQ.5 50 "
GJ«Q'5 50 ^V
'0 WT
C-Cy '
50 /)V
50'
1 of 3
6/27/75
o;/l Sulfa'to-mii/l
final raw /inul
•12
300
GO




\ 00
80
30
20
£3
.2,7UO
'1,020
330


.
GO
35
• .20

ajjjr'u
CO'

1,710 ''
•a Qf-
3,700
3,700
3,700
3,700
'3,700
3,700
3,700
3,700
3,700
3,700
3,700
0,400
G.'IOO
G,400
• 0,100
0,400
• 0,400
G.400
(
0,400
0,400

G,400
3,'IOO
3, IOO
3,400
3, 400
3,100
") 3,400
/ 3,400
3 ,400
3,400
3,400
KOTEi  Circled nunbors donota concentrations oqual to or loss, than limits promulgated 4/8/74.

-------
TA;>L:: i (cont.)
HESULTS OF THEATADILITY ^AH TESTS
PHOSPHATE FERTILIZER INDUSTOY WASTE!* ATT.R SAOTLKS '
ipany pll
ic raw
v fy«, 2.4
/w i "**7
O*N »1.7
•1.7
2.4
2.4
••2.2 .
•'2.2
"2.2
iili.B
•••2.0 _
gonserv 2.2
•1.5
•1.3
• *1.5
( 2.2
* «z!o
K/ ••2!o
4A*1.7
till. 9 '
/4rrieo 2.0
	 -1.4
•1.4
•1.4
2.0
•2.0
•2.0
•2.0
"•"•"1.7 "
ill 1st Ktil.TQ.
start end
3.4 3.4 •
3.5 3.4
• 3.5 3.5
3.5 3.5.
3.4 3.4
3.4 ' 3.4
3.5 3,4
3.5 3.4
3.5 3,4
4.8 4.7
7.1 6.3 •
3.2 . 3.3
3.5 3.4.'
3.G 3.5
*3.6 3.G
3.2 3.3
: 3.2 3.3
3.5 -3.3
3.5 3,5
4.8 4.7
7.2 ' 6.5-
3.3 • 3.2 .
3.5 3.4
3.5 3.5
3.5 3.6- '
3.3 3.2
3.5 3.2
3.5 3.2
3.5 3.2
4.9 4.6 '
7.6 6.9 •
Jill 2nd staso
start end

•


8.4 7.1
7,3 9.1
8.6 8.2
8.6 8.2
8,6 8.4
8.3 .
. 8i6 "'. r-
. •
'•
.
,
:' 6.7 6.7
;- 8,4 8.3
8.5 8.2
'. B'.S 8.6'
8.5 •
' 8.5. ;..
T ' "'
;
.1

5.1 6.7
8.5 8.7
8.5 • 8.9
8.5 9,2
8.4
'8.6 '
2 of 3
0/27/75
ml/1 103 line slurry Settlin-r tiiao - hrs Fluoride - meA Phosphorus '- mr/l S. Solids - up/1 Sulfato-n-/l
.1st stage 2nd. stajre 1st stajo 2nd stage raw
(mix tine - min) • ' •
. • •
' 05 (4)
• ' ' 95 (4)
• 05 (4)


CO (8).
60 (8)
CO (8).
•• 100 (15)
'• 160 (6)

115 (4),
. 113 (4)
113 (4) .
. t
•' 90 (8)
, . 90 (0)
' . 110 (9)
• ' 1C5 (4)

230 (0)
• 230 (6)
• 230 (C)
•
150 (10)
150 (10)
-: 150 (10)
; 200 (13)
2GO (11)
'



: ' .

• 100 (8)
• .-'lOO-(B)-'
. ' 100 (8)
..35 (8)
i '.'• 3 (5).-
i ' •

.

.
:' ' 60 (6)
60. (6)
' 34 (5) '
3 (4) .
V ' -
'. • •
•


120 (?)•
.120 (7)
• 120 (7) •
• 41 (a)
3 (4) '
1 •
6
12 . .
24
1
1
24
24 •'•
24
24 ' •
24 .
1
6 ••
. 12
24
1
!• ' "
24 •
24 .
24
24 . '
1 .
6
12 '
24
1 .
24 " •
24 -
24 . ' '•
24
24


.

• 2
- 2
. 12
24
• 48
. , 96
72




-. 2
2
12
24
96
72


•

2
12
24
48 .
06
72
' 4J700
4,700
4.700
4J700
4,700
4,700
4,700
4,700
final raw .
400
76
: 76
70
26

-/so:
\40
. 4,700£'.^3J5
' 4,700 /
. 4,700
7J400
7,400
7,400
7, -100
' 7.400
. • 7J400
• •7,400
7,400
7,400
7,400
. 10,200 '
10,200
10,200'
10,200
10,200
10,200
10, 200 -j
ioIbooA
10,200
Ov/("g
• Lsa
100
40
36
37

JQ
8 0?
•4O
29 ?
ho
55
50
'• 53
©

•

6,000
6,900 .
0,000
. 6,000
'.0,000
. • 0,000
. 6,900 3
6,900
0,900.
6,900-
6,000
0,700
5,700
5,700
5,700
, . 5,700
i 5,700
.,;•/ 5,700
//It's, 700
^5,700
5,700
lojooq
10,000
10,000
10,000
' 10,000
10,000
10,000 tqc
10,000 'i.1
lolooo "v
10,000
final
•
.4J650
5,025
5,100
37B
C^
^ _1 2U5~1
. 189 {
120?
126'
. ^jM
3i300
4,400
3,000
2,700
2JO-
'Off©
30 ©i


-------
TAUUi 1 (cunt.)
HESULTS 01' T'rtEATADILJTY
PHOSPHATE FEHTIU'iSR INDUSTRY WA
jwyany nit nil 1st stniro . pll 2ml
lino row
/HHed 1.9
•1.8
•1.8
•1.8
l.D
•*1.7
"1.7
"1.7
JLlil. 2
•••1,3
JP£eC£OTt ' '2.3
•2.3
Ui >'2'3
7 "2.5
OR "2'5
06 "2.3.
"^ *"2.3
•"2.2
Olln -2.2
•2.2
•2.2
"2.3
"2.3
"2.3
.1142.1.
•"2.1
start end
3.3
3,5
3.5
•3,5
3.3
3.5
3.5
3.5
4.9
. 7.3
3.S
3.3
3,0
3,5
.3.5
3.5
5.2
7.1'
3.5
3,3
3.5
3.5
3,5.
3.5
5.0
7.1
3.2
3.2
3.4
3.4
3.2
3.2
3.2
3,2
4,7
7.1
3.0
3.2
3.2
3.2
3.2'
3.2
5.3'
7.5
'3.2
3.4
3.4
3.5
3,5
3.5
4.7
7,8
start

0.2
8.G
8.S
8,6
8.4
. 0.7 •.



8.5
,8.3
8.5
8.4
a.9

. ..
/•
8.5
8.5
8.5
0.5
8.6
stnso' rtl/1 10'' lime slurry Settling time -
end

'6.8
9,1
: 3.5'
9,3


.


8.9
0.0
;.0,4





8.3
8.5-
8.4

'
JAN TESTS
STE'.i'ATKn SAMPLES
hrs Fluoride - mp/1 Phosphorus - m
'1st .stage . 2nd ctarc 1st staco 2nd stajjo rai/
(mix time » mini
-.- 200 (5)
200 (3)
200, (5)

: -100 (8)
•• 190 (8)
100 (8)
/' 270 (11)
300 (3)
•' 40* (5)
40 (3)
40 (5)
• 30 (7)
30 (7)
: . .30 (7)
•'•' 40 (5) '
'. 110 (0)'
•'" 30 (5)
,. • 30 (5)'
30 (5)-
23 (3) '
25 (3)
23- (3)
GO (4)
| 120 (7)
•

140 (12)
140 (12)
140 (12)
37 (G)
' 1 (2)
(


30 (4)
30 (4)
30 (4)-.
12 (3)
2 (4) .



" 00 (7)
00 (7)
. 00 (7)
41 (0)
3 (3)
1
'. 0
12
24 ,
1
24
24
24
24
24
G .
12
24
24
24
24
24*
, 24
.5 '
12
. 24
24
24
24
24
24

: 2
12
24
48
00
72
.


12
21
48
06
.72



12
24
48
OG
72
11,000
11,000
11,000
11,000
11,000
11,000
11,000
11,000
11,000
11,000
3,100
3,100
3,100
3,100
3,100
3,100
3,100
". 3,100
lj?00
1,700 .
1,700
1,700
1,700
1,700
1,700
1,700
final raw
110
100
:100
102
•10
58"
401
31 (
6©1
aa-
100.
177
102
105 N
105 (
105
. 18
54J
234
'103
210
30
'33'
30.)
C ("G)
61
8,400
B,400
8,400
8,400
0,400
!B,400
;0 0,400
->u 8,400]
AV- 0,400'
8,400'
1,3UO
1,300
1,300
I 1,330
-.yl.SGO
' /'/ 1,330
/V- 1,380
1,300
ejono
•"* 0,000"
G,000
0,000
33 0,000
' 3-f 0 , ooo
'ff' 0,000
• 6,000
3 of 3
0/27/73
7/1 S, Solids - ms/1 ' Sulfatc-n^/1
final raw
3,600
4,200
4,350
C,000
000
r 155
<--} '1'1'1
l^ejm
/v-/.\ 0
^ 3L!4
1J200
1,000
1,200
100
nil 1S4
A-/ 103
v| 09
, w \JJ
_ 5,400.
5,100
4,050
(300
•»•?/ ;313
J-Vy < 200
"^ /3SO

4
4
4
.4 •
4
4
4
4 > -,
30 4 °/
..4 *
< i
< i
< i

1 IU
<'l ^
} <'l .
	 121..
121-
121
121
121
121 " ./
121 "'' i
• 121 :'
final
137
43
4,150
("1.020
,1,540
•i 5EO
.?! no
/l''- 40
36 '


,--100
r 110
;)' '132

(_'l20
_. 72.. — •
12
JLT@
.^i/m)
l/i©
/.frCD
' \ i32
'L @
ra\' ' i inii
10,785
131735
15,735
15,785
15,78.0
15,7G5
12,785
15,735
15,765
2,400
2,450
2,400
2,400
2,400
2,100
2,450
2,450.
"3,340
3,540
3,5-10
3,340
3,040
3,010
3,540
' 3,540
 KOTEi  Circled numbers denote concentrations equal to .or lose than, limits promulgated 4/8/74.
 •    1st etajo analyses on top 33 era in 2000 ml graduata.
*•    lat ttago lining of 2000 el raw viatcwatcr; 2nd stage liming of top 33 cm of 1st staeo;  2jid stago ^ql'ysea on top 0 cm of nlxturo.
"    lut ttoga liming of 2000 al rnv wastotfatar; 2nd atago liming of top 1000 ml of 1st ctaco;  2nd ttagQ qjialysoa on top half of mixture.

-------
                                                             Suite 24. Cxcr,;:. rf, Pi'.vo
                                                             4406 S Florida Rvgnuo • ?.O :;rL551
                                                             Lokelond. Florida 35BOS
                                                             Telephone 81S/C45-853:
                                   February  9,  1978
Homer Hooks

President
          Mr.  R. E. McNeill
          Project Officer
          EPA,  Region  IV
          EIS  Branch,  Phosphate  Study Unit
          345  Courtland Street
          Atlanta, Georgia  20208

          Dear Gene:

                     Subject:  Central Florida Phosphate EIS  -  Your
                                Memorandum  of February  2, 1978 and
                                Attached Recommended  Scenario

                     On Tuesday,  January 31, 1978, the Florida  Phosphate
          Council, Inc., participated in  a meeting  held by EPA in Tampa
          for  purposes of discussing the  Recommended  Scenario  with the
          Advisory and Steering  Committees.  In addition to  the dis-
          cussion during the meeting, we  submitted  written comments
          for  the record.  A copy of these comments is attached hereto
          as Exhibit A for your  convenience.

                     The Recommended Scenario attached to your  February 2,
          1978 memorandum reflects some modifications, but does not
          recognize the basic objections  submitted  by the Florida Phosphate
          Council, Inc. on January 31, 1978.  Thus, we hereby  reaffirm
          the  comments contained in Exhibit A and resubmit them for your
          consideration.  In addition, we have the  following comments
          on the areas modified  after the Advisory/Steering  Committee
          meeting  (as  outlined  in your February 2,  1978 memorandum):

                     1.  Wetlands Description

                     As noted on  January 31, we object to the preclusion of
          mining on any categorical basis  (i.e., in "category  one" wet-
          lands) .  Although the  areawide  EIS may discuss policies or
          general findings, restrictions  on site-specific activities
          should not be proposed until EPA, the Corps, the Fish and
          Wildlife Service and  other agencies have  been consulted
          regarding detailed plans for development  and restoration sub-
          mitted by the applicant.  Until such information is  available,
          the  review contemplated by applicable Corps of Engineers
          regulations   (33 CFR §302.4) and EPA regulations  (40  CFR part
          230) cannot  be properly completed.
                                 Chairman o'thsBoo/d UJn H Fu^k Gordmier. Inc.
   flgrico Chemical Company • Garden. !nc — Chemical Division/5mith-Douglar.s * 6reujsf.sr Pnosphotes (firrsncan Cyano * Con^en/. Depcr''Te.-..- c-s PR ;'^p
   Brothers Division of €ng!ehord M'nerols & Chem«cots Corp. • Gleccro-Pnos Corporaf-on • For.^'Dnd Indjstncji. Inc • rrzcport Chus.-n.coi Con-.pony • Gcrc'--''"e.' l*-c • ll' ~R
   Grace fj Compony. RynculLural Chemicals • International Minerals & Chr.micol Corporct-on * .V.-5Sissippi Cr.ern'cal Curpo'j^.on • W.ob.l Ch^micct Cofma-C'*• 6cc'-7-vo:
   Chcmica' Company • flov'-Ur Corrpo-ny • S:ouffef Chemicof Company • Sm.fc flgric-jlwol Chc.Tiicols Corporation • T/fl Minerals Corporation • USS rt".-Cie.-".:;o!s

                                               ^-S'i"

-------
Mr. R. E. McNeill            -2-          February 9, 1978


          2.  Surface Water Quality

          A second area discussed on January 31 and summarized
in your February 2, 1978 memorandum is the proposed set of
effluent limitations for new source chemical plants.  These
concentrations do not reflect technology available in 1978,
and there is no scientific basis given for the specific values
proposed or for the necessity of more stringent limitations
in the Tampa Bay and Peace River Basins.  Furthermore, as
discussed on January 31, we consider the proposal of more
stringent effluent limitations in the scenario to be in conflict
with Section 511 (c) (2) of the Federal Water Pollution Control
Act Amendments of 1972.

          3.  Above Ground Slimes Disposal Areas

          We suggest the following wording on page 3 of 'the
scenario under Bases, iv):  Current research, and one full
scale operation, indicate that two of the new technology
methods may result in costs approximately the same as conven-
tional slimes disposal.  However, there is no firm evidence
or data from full-scale plant operations that would confirm
any reduction in costs to be anticipated by the use of new
technology.

          4.  Ground Water Quality

          The third area discussed on January 31 is the lining
of gyp ponds.  Your memorandum indicates that no changes in
the scenario will be made, however.  Thus, we have no further
comment at this time, but reconfirm the objections stated in
Exhibit A hereto.

          5.  By Product Recovery

          This area was discussed in detail on January 31 and
new scenario wording is proposed in your memorandum.  This
entire section should be eliminated, however.  By-product
recovery requires substantial investment of capital, and
whether recovery is economically viable or not, such a decision
should be left to the Industry, and not be made by EPA.

          The alternate requirement that "estimated fluorine
emissions from new source gyp ponds should not exceed the
total allowable point source fluorine emissions within the
plant complex if a permit is to be issued" is arbitrary and
capricious.  No scientific basis is given for this fluoride
emission requirement, which is a welfare pollutant and not a
primary health pollutant.  Further, there is no known scienti-
fically correct method available for predicting fluoride
emissions from gyp ponds.  This alternative should be removed

-------
Mr. R. E. McNeill            -3-            February 9, 1978


from the scenario because it makes recovery of fluoride compounds
from phosphoric acid evaporators mandatory.

          The other areas mentioned in your memorandum of
February 2, 1978 should be viewed in light of the objections
and comments submitted by the Florida Phosphate Council on
January 31, 1978 (Exhibit A hereto).  The comments outlined
above are supplemental to comments previously submitted by
the Council and we strongly encourage EPA to make appropriate
revisions in the scenario before the draft EIS is prepared.
                                   Homer Hooks

HHrjb

Enclosure

cc:  Steering Committee
     Advisory Committee
                            2-87

-------
pHospKc&z
   feeds you
                                                                  EXHIBIT A

                                                             Suite 24. Executive Plozo
                                                             4406 S Flondo Rvenue • P.O. Box 5550
                                                             lokelond. f lorido 33803
                                                             Telephone 813/646-8583
Homer Hooks

President
                                                    January 30,  1978
        Mr.  R.  E. McNeill
        Project Officer
        EPA Region  IV
        EIS Branch,  Phosphate Study Unit
        345 Courtland Street
        Atlanta, Georgia  20208

        Dear Gene:

                   Subject:  Comments  on "Draft  Summary Outline
                              Scenario,  dated January 24, 1978,
                              to be Recommended by EPA Phosphate
                              Unit:

                   We submit herewith  our comments on the  above document,
        received by us on January 26,  1978.

                   We reiterate the comments made on the first page  of our
        letter of January 12, 1978, dealing with (1) absence of any comment
        on the social and economic benefits of  continued  and expanded
        phosphate mining in Florida,  (2) the question of  whether  the EIS
        can legally promulgate standards in the absence of prescribed rule
        making procedure, and  (3) our firm contention that accumulated
        evidence of all work  done by  the contractor, Texas Instruments,
        demonstrates that phosphate mining should be allowing to  expand
        in Florida  in order to meet growing U.  S. and world demand  for
        agriculture products  produced by phosphate fertilizer.

         "Page 1,   1.   New  Sources —A.  Mining and Beneficiation -- 1. Air
                         Quality

        Comment:   Eliminate first sentence and  substitute therefor:  "Reduce
                    use of the  rock drying process whenever technically
                    possible  or technically practical."

                    The requirement that rock "is to be dried at the  chemical
                    processing  complex, or at dryers permitted by DER priot
                    to publication of the Draft EIS" is unfair to future
                    miners and  chemical plant operators and to Polk County,
                    since that  is where all the present dryers are  located.
                    This requirement should be removed from the scenario.

                    The present Clean Air Act requirements  and Florida 17-2
                    rules are very strict and are designed  to protect the
                                 Choirmon of the Boord: UJm. H. Funk Gordinier. Inc
   figfico Chemicol Compony • Borden. Inc — Chemicol Division/Smlth-Dougloss • Breujster Phosphates (flmericon Cyanamid/Kerr-McGee) • Conserv. Deportment of Philipp
   Brothers Division of C-nglehord Minerals G Chemicals Corp. • eiectro-Phos Corporation • Formlond Industries. Inc • Freeport Chemicol Company • Gordinier. Inc. • U). R.
   Grace & Comoony Rgnculturol Chemicals • International Minerals Si Chemicol Corporation • Mississippi Chemicol Corporation • Mobil Chemical Componv • Occidental
   Chemicol Company • Royster Compony • Stouffer Chemical Compony • Sujift agricultural Chemicals Corporation • T/fl Minerals Corporation • USS flgn-Chemicats

-------
Mr. R. E. McNeill
                 -2-
January 30, 1978
          the public and the environment.   Any new installation
          will have to meet these criteria.  This statement
          should be included in the scenario to correctly inform
          the public.

"Page 1,  Bases: — 1"

Comment:  Since you have brought up the radioactivity of power
          plants which emit krypton-85 and iodine-131, why have you
          neglected to inform the public about the radium-226 and
          radium-228 emitted from the stacks of coal burning power
          plants, especially since these are in the Central Florida
          area?  It has been estimated that a 1,000 Mw(E) coal
          burning power plant will discharge into the atmosphere
          between 28 millicuries and one (1) curie per year of
          radium-226 and radium-228.  This is 2.8 x lO1^ to
          1 x 10   picocuries, or more than the phosphate rock
          dryers cited.  (Ref.:  Guimond,  R. J., "The Radiological
          Implications of Increased Coal Utilization")

          It is general practice when discussing radioactivity on
          an annual basis, to present this in terms of curies, which
          would be 0.042 curies per year for 1,100 tons per year
          particulate out of stacks.  To put this in perspective,
          this is equivalent to 0.042 grams/yr. of radium-226, a
          very small quantity and is probably less than a 1,000 Mw(E).
          power plant burning coal.

          The statement "Additional particulate, with a proportionate
          quantity of radionuclide emissions, would also be prevented
          due to transfer and transportation of wet unground rock
          instead of dry rock" is a non-quantitative statement and
          presumably refers to fugitive dust which would mostly fall
          in the plant area."  Unless this can be quantified and put
          into proper perspective, this statement should be removed
          from the scenario.

      2,  2.   Surface Water Quality"
Comment:  This statement should be added in order to inform the
          general public:  "All operations will have to meet EPA
          effluent limitations and Florida water quality and EPA
          water quality standards, whatever they may be."
 "Page 3,  3.
Eliminate conventional above ground slimes —
Bases:  (IV) "                           ~~~
          The costs for alternative methods of slimes disposal are
          not known at the present, and will not be known until
          further full-scale testing is conducted.  The available
          cost data are insufficient to conclude that the alternative
          methods will be lower or even approximately the same as
          conventional slimes disposal.

-------
Mr. R. E.

"Page 4,
McNeill
-3-
January 30, 1978
6.   Radiation —Paragraph 2"
Comment:  The statement  "Proposed regulations regarding radiation
          levels in structures 	" is incorrect.  EPA intends to
          offer proposed recommendations which have no legal
          authority and  cannot be enforced by EPA.  These must be
          adopted by state, county, or other regulatory authorities
          before they become regulations and legally binding.  This
          was told to representatives of the Florida Phosphate
          Council by Dr. William Mills of the Office of Radiation
          Guidelines in  a Washington, D. C. meeting on January 24,
          1978.

          The language should be changed to eliminate the word
          regulations and substitute the word recommendations.

"Page  5.  6.   Radiation — Paragraph 3"

Comment:  Change to read "Mining and reclamation plans for New
          Source Mines shall meet future State of Florida and/or
          local regulatory body requirements with regard to radiation
          levels of future reclaimed land."  It is premature to
          specify how this will be accomplished until the final
          reports of studies now being done are completed and final
          regulations are promulgated.

"Page  5.  7(c) Reclamation — Wetlands"

Comment:  The program EIS should serve as a statement of policy and
          priorities for various types of wetland protection.  The
          balancing of costs and benefits should be conducted during
          the site specific EIS so that a program most beneficial
          to the overall public interest may be developed.

"Page  6.  B. Chemical Processing — 1.  Air Quality"

Comment:  The first sentence should be changed to read "New source
          performance standards are adequate to protect air quality."
          Inclusion of the language "if emission limitations are
          continuously met" is an unwarranted implication of non-
          compliance by  the phosphate industry, reflects on the
          credibility of the scenario, and has no place in the
          scenario.

"Page  6.  B. Chemical Processing — 2.  Surface Water Quality"

Comment:  We reject the  concept that the EIS can by-pass the normal
          rulemaking procedures of EPA by proposing to implement the
          proposed  "Areawide EIS" effluent limitations.  These
          proposed  "Areawide EIS" effluent limitations should be
          removed  from the scenario.

          There  is no  scientific basis for the values proposed under
          the  "Areawide  EIS" values, and this is an attempt at
                                3-

-------
Mr. R. E. McNeill                -4-            January 30,  1978

          rule-making by fiat.

          Since existing chemical plants only neutralize and
          discharge process wastewater a few weeks a year at the
          most, the improvement in the environment in reducing
          these values from the current performance standards to
          the new proposed standards would be negligible.  In our
          opinion, technology does not exist to meet the "Areawide
          EIS" proposed guidelines.

          The "Areawide EIS" requirements for 30 day averages are
          less than one-third for phosphorus, and only 40% for
          fluorides, of existing EPA new source performance
          standards.  Laboratory work done by EPA, in EPA's labora-
          tory in Cincinnati, Ohio, on a number of gypsum pond water
          samples from this area and other areas of the country,
          were used to establish the current "EPA Standards of
          Performance for New Sources."

          Three tables of laboratory data obtained by EPA in these
          tests were sent to you previously.  These tables do not
          show EPA's name, and to the best of our knowledge a formal
          report was never issued.  However,- EPA can check with
          Mr. Elwood Martin of the EPA Guidelines Division in
          Washington, D. C., to verify that these are, indeed, EPA
          data.  In reviewing the averages of the EPA data, there is
          a wide variability among the different pond waters, not
          only with respect to initial analysis, but with respect to
          final fluoride, phosphorus, and total suspended solids
          obtained by double liming treatment.  None of the averages
          met the proposed "Areawide EIS" requirements for fluoride,
          phosphorus, or TSS, except for one sample which met it on
          phosphorus but which is a high chloride sample and not
          typical of inland chemical plants.

          The draft recommends that "the non-process water system is
          to be designed for recirculation with the same design surge
          capacity as the contaminated process water system," and the
          same standards for discharge are applicable.  The same
          standards  (process wastewater) for discharge now apply to
          non-process water.  This proposal may allow possible
          discharge of cooling tower and boiler blowdown in cases
          where this water cannot be discharged to a mining circuit.
          This requirement may be too restrictive.  There are other
          water sources which need to be discharged that cannot be
          circulated, such as regeneration streams from water
          softeners.  Data and experience are not available to know
          whether or not some of this non-process water can be
          recirculated and re-used without excessive scaling of
          equipment.

          As pointed out before, the State of Florida DER mining
          effluent guidelines effective October 1, 1977, regulate

-------
Mr. R. E. McNeill
— 5—
January 30, 1978
          phosphorus in mining effluent.  Adding non-process water
          to the mining circuit may increase phosphorus levels above
          the allowable value, in which case this cannot be done.

          The statement "The above limitations do not preempt EPA
          National Effluent Guidelines, but are based on protection
          of water quality in the Tampa Bay and Peace Basins" is
          erroneous since the limitations do pre-empt EPA National
          Effluent Guidelines.  No facts are given for the basis
          and it is purely an unsubstantiated opinion.  This sentence
           (in quotes above) should be removed from the scenario since
          it is not credible.

 "Page  7,  8   Basis"

 Comment:  It is stated that several chemical complexes converted to
          complete recirculation of both systems, and that the one
          new chemical complex constructed since that time does not
          even have an NPDES permit, because it is designed for
          complete recirculation of process and non-process water,
          with a portion of the non-process water blended with the
          mining circuit.  This statement is not true.

          The plant that does not have an NPDES permit discharges
          their non-process water to the mine circuit.  A few other
          plants in the area which were believed by EPA to have
          complete circulation of non-process water, have in fact
          continuous discharges of non-process water.  Therefore,
          there are no chemical complexes in Florida that have
          complete recirculation of non-process water.  This will
          involve a new technology, and experience is not available
          at this time to determine how it will work.  We do not
          know of any information that shows that these proposed
          recirculation systems would result in a net reduction of
          costs, because of savings of product and the reduced need
           for pumping water from the aquifer.  Product savings would
          not result and the cost of the extra equipment and power
           required for pumping to recirculate this water would
           increase costs.

          The last paragraph at the bottom of page 8 relating to the
          EPA Development Document of July 1971, is out of date and
          was superseded by the laboratory tests conducted by EPA.
          We do not know of any system designed in the last 10 years
           that would meet the proposed  "Areawide EIS" values.

 "Page  8,   3.   Ground Water Quality"

 Comment:   This entire .section should be removed from the scenario.

           Existing data do not support the necessity to line gypsum
           ponds with an impervious material.  This requirement
           assumes  that  this is the only solution to any potential
           problems.  Additional studies are being made in cooperation

-------
Mr, R. E. McNeill
-6-
January 30, 1978
          with the Florida DER and, until these are completed,
          there is no basis for this requirement.

          It may be, at a specific site, that it could be demon-
          strated that a lining is necessary to protect groundx^ater;
          however, this is not the case at the present time.

"Page 9,  5.   By-Product Recovery —- a."

Comment;  This entire section requiring fluorine compounds recovery
          Should be removed from the scenario.  It is unrealistic to
          require a company to increase its operating costs to
          recover a product for which there is a limited market.  If
          this material cannot be sold, it will be dumped into the
          gypsum pond, thereby wasting valuable economic resources
          — capital and operating costs.  This should be a manage-
          ment decision and has no place in the scenario.

"Page 9.  5.   By-Product Recovery •— b."

Comment:  This entire section requiring uranium recovery from
          phosphoric acid should be removed from the scenario.  It
          is unrealistic to require a company to invest substantial
          capital and incur increased operating costs unless it is
          assured of a reasonable return on investment.  This should
          be a management decision and has no place in the scenario.

"Page 9,  5.   By-Product Recovery — Basis"

Comment:  There is no evidence that recovery of fluorine compounds
          would reduce emissions, and this statement should be
          removed from the scenario.  It is arbitrary and non-
          factual.

"Page 9,  II.   Existing Sources,  A.  Modification"

Comment:  Since the areawide EIS can have no direct legal impact on
          existing sources, these recommendations should be excluded.
          The Federal Guidelines promulgated in November 1976,
          already require existing sources to comply with new source
          standards, and only a compliance schedule is left to be
          worked out with the State DER.

          It is mentioned that a study to be completed within the
          next two years will determine the need or lack of need for
          lining existing gypsum ponds.  How existing gypsum ponds
          could be lined is unknown and there would not appear to
          be any practical way that this could be done.  This state-
          ment implies that EPA plans to conduct such a study.

-------
Mr. R. E. McNeill               -7-

"Page 9,  B.   Operation S Maintenance"
January 30, 1978
Comment;  We support this recommendation for in-plant inspections,
          source sampling, and ambient monitoring.  We oppose any
          proposal that industry pay for this surveillance.  The
          cost should be borne by the Florida DER and EPA.
HH/lh

cc:  Steering Committee
     Advisory Committee

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                                               Post Office Box 1480
                                               Bartow, Florida 33830
                                               Telephone: 813/533-3181
                                             June 7, 1978
Mr. R. E. McNeill
Environmental Protection Agency
Region IV
EIS Branch
.Phosphate Study Unit
3U5 Courtland Street, N.E.
Atlanta, Georgia 30308
                              SUBJECT:  Draft Areawide
                                        Environmental Impact
                                        Statement  - Central
                                        Florida Phosphate
                                        Industry
Dear Mr. McNeill:

As a supplement to my May 16, 1978, letter on the  captioned subject,
there is another area in the DEIS that requires some correction.
This area is the correct identification of -CF Industries and  its
Florida facilities in the DEIS.

Throughout the DEIS, CF Industries' three manufacturing locations—
CF Chemicals, Central Phosphates, and CF Mining—are confused.  The
narrative in the first paragraph defines the activity at each loca-
tion.  Phosphate fertilizers are produced by both  CF Chemicals  and Lj
Central Phosphates.  Phosphate rock mining is contemplated to com- t*/
mence November 1978 by CF Mining.  The DEIS applies incorrect titles
to CF Industries' operations on Plate 1 and Pages  1.9, 2.8, and
2.35.

The DEIS does not recognize CF Mining as an existing source whose
immediate activities include construction of a phosphate mining
facility in Hardee County (Page 2.39).  Figure 2.2 (Page 2.8)  pro-
jects an incorrect production startup date and rate for CF Mining.
Present projections are for 1.0-1.5 million tons/year starting  in
November 1978, with a possible increase to 4.0 million tons/year
in Fiscal 1985.

CF Industries' plans for a fertilizer complex in Hardee County are
undetermined at this time.  The DEIS' statement on Page 2.35  that
the plans are cancelled is inaccurate.  A more accurate statement  \t
would be that no engineering of that phase is 'currently being done,
and that specific plans will be made only as a function of member
requirements.

                                                    Continued . .  .
                             3-

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Mr. R.  E.  McNeill            -2-                    June 7,  1978
Under separate cover, CF Industries will present a more formal
comment on the content and issues of the DEIS.

                              Sincerely,
                              William A.  ScAamming
                              Director, Environmental Affairs
WASrslh

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PLEASE R£?LY TO: Senator Richard (Dick; Stone
                 Suite 200B-2639 North Monroe
                 Tallahassee, Florida  32303
                  June 13,  1978
    Respectfully referred to:

        Environmental Protection Agency
        345 Courtland Street, NE
        Atlanta,  Georgia   30308
    Because of the desire of this office to be
    responsive to all inquiries and communications,
    your consideration of the attached is
    requested.  Your findings and views,  in
    duplicate form, along with return of the
    enclosure, will be appreciated by
                       Richard  (Dick)  Stone
                       United States Senator
                                              TLH-7
                                          3-97

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                                                        Un ell
 A acker Induces Corp. Subsid,ary                                   <:».„.„,  t
 Suite 51                                                  Sector Stone MRSfdi-jj ;hi.-
920 Manatee Avenue West, Bradenton, Florida 33505                   „.m3tt9r; Pj«S8 wfer to
Telephone: 813/74V-1727                                      "9 if -
                                               June 6, 1978
   Senator Richard  Stone
   1327 Dirksen Senate  Office Building
   Washington,  B.C.  20510
  Dear  Senator  Stone:
  The attached letter  to Mr.  John. E. Hagan,  III,  Chief of EIS Branch,
  EPA, outlines some of  the particular points that need clarification
  in the Draft Areawide  Environmental Impact Statement for the Central'
  Florida Phosphate Industry.

  The study was initiated by  the President's Council on Environmental
 ..Quality following a  request by President Ford to look into the matter.
  President Ford's request was in turn primarily  prompted, during the
  last presidential election  campaign, by a  request from the publisher
  of the Sarasota areas  only  major newspapers,  which shortly thereafter
  endorsed President Ford for reelection.

  It has frequently-been stated that the study  was prompted by the major
  interest exhibited by  the people of the region.  The attendance at the
  workshops and at the recent public hearings belies that statement.
  The hearing at Manatee Junior College was  primarily attended by in-
  dustry representatives, the media, students or  staff of Manatee Junior
  College and possibly a dozen Sarasota County  or  beach residents (over
  35 miles from the nearest proposed phosphate  activity) mo3t of whom
  are retired and-are  veteran meeting attendees. Professional represent-
  ation was also provided by  the Audubon Society.  It was noteworthy
  that both Sarasota County and City political  body members and rep-
  resentatives, except for the county environmental control director,
  were absent including  their delegate to  the advisory committee for
  this EIS. In fact, only one of the advisory committee members (other
  than the phosphate representative) was identified as present.

  I believe that the message  is clear.  The study was prompted by the
  desire of a few, for whatever motives that they  might have. The result
  has the potential for  ladening an already  over-regulated industry
  with more rules, higher costs, lost reserves  and its inevitable ef-
  fect on our inflation  prone economy.

  I do not feel that as  a result of this study  that any new action is
  adviseable or needed,  but recognizing the  inevitability of some form
  of final statement I have included alternative wording that should
  be substituted for the EPA's in the final  statement.  My suggestions
  are in the letter to Mr.  Hagan.  I urge you to help by (in the words
  of.The.Polk County Democrat)  "— not  demanding the impossible from  this
               essential industry" and conveying that thought to CEQ  and EPA.
 "LGB/mg

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 A Boker Industries Corp Subsidiary
 Suite 51
920 Manatee Avenue West. Bradenton. Florida 33505
Telephone: 813/748-1727
                                                June  6,  1978

     Mr. John E. Hagan,  III,  Chief EIS Branch'
     Environmental Protection Agency
     Region IV
     345 Courtland Street,  N.E.
     Atlanta, Georgia  30308

     Dear Mr. Hagan:

     Z have reviewed the Draft Areawide Environmental Impact Statement
     for the Central Florida  Phosphate Industry dated 3/14/78 and offer
     the comments contained on the following pages for your  review and
     inclusion in  the final  statement.

     We appreciate this  opportunity to make our views heard  and sincerely
     trust that due consideration will be given these comments in the
     ultimate utilization of  the Impact Statement.
     Very truly yours,
     Lewis G. Bartow
     President
     LGB/mg
 /••;

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                              - 2 -
On page 1.20 reference is made to the natural dry prairie or palmetto
prairie. No differentiation is made between secondary, palmetto prairie
development and natural development. It should be noted that many areas
that are identified as natural prairie are in truth palmetto growth   U~
established on previously cleared forested lands. In many areas,  pasture
lands that are not maintained will almost certainly revert to palmetto
scrub.

On page 1.27 the reclamation regulations for mining are reflected upon.
The statement is made that-the.regulations produce a landscape of managed
systems, primarily improved pasture. Acknowledgement is not given to the
areas developmental progress, other than with respect to phosphate
mining activities. Improved pasture lands are developed because a need w
exists. The same applies to farmland. Either this acreage (the reclaimed
area) or some as yet undisturbed acreage will be converted by the agric-
ultural community, if the need exists. Not reclaiming for agriculture
does not preclude the addition of acreage for that purpose (with no
clearing permit required by the farmer).

On page 1.28 surface water quality characteristics are shown. Levels of-
phosphate and fluoride in the study area streams are attributed to
phosphate mining and processing. Beker has monitored the Manatee and
Myakka Rivers for quality (without-mining or processing activity) and
finds the following, indicating the natural presence of these items:
                                                       Beker
                                  EIS           Manatee     Myakka

Tot. dissolved solids           61-409 mg/1     61-354      78-302
Hardness                        34-264  "
Sulfate                          6-198  "       2.8-42      .6- 64
Chloride                         3-23   "        14-23      15-25
pH                                5-8           6.2-7.3    6.0- 7.35
Color                            0-280 Pt-Co     50-300     35-350
Phosphate                        .4-3.9 mg/1    .81-2.5    .06-1.9
Turbidity                        0-350 J.T.D.'s 2.8-27 NTU'S 1.1-16NTU'S

On page 1.28 it is stated that in the 1960's discharges of P & N degraded
water quality in the Peace and Tampa Bay Basins. It should also be noted
that other studies have shown that additions of P from stream flow dis-
charges have had no additional effect on Tampa Bay due to natural ex- l*J~
cesses that are already present.

On page 1.41 the projected water demand in Manatee County and/or its
major implied cause is incorrectly.stated. Only two mines could possibly
contribute to the suggested 53 million gallon change during the 1976-1985
period and their total demand is 21 million gallons per day (Swift - 13
mm, Beker - 8mm). Other mines will have their wells in Hillsborough or
DeSoto Counties. It should also be noted that the 21 million gallons re-
ferred to above is not all increased demand since over 9 million gallons
                          S'/oo

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                           - 3 -
of agricultural water use will be discontinued when Beker initiates
mine water useage.

On page 2.16 it is stated that the estimated water demand per ton of
phosphate rock produced is 1,500 gallons. Similarly, Table 2.3 on page
2.12 indicates water requirements of up to 310.84 m.g.d.  for mining/
beneficiation. Data obtained from SWFWMD and others shows that the   I I — I £" I
overall phosphate industry water use in 1969 was 351 m.g.d., 1970 -
271 m.g.d., 1971 - 250 m.g.d., 1973 - 167 m.g.d., and 1974 - 244 m.g.d.
These numbers include other than mining water use as well as for mining.
Utilizing the same data sources, mining operations themselves are
estimated to require approximately 215 m.g.d. in 1977-  It is projected
that phosphate mine water useage will peak around 1983  -  1984 at about
245 M.G.D. Thereafter, water withdrawals will fall to about 220 m.g.d.
In 1985 and 155 m.g.d. in 1990. The recently published  Four Rivers
Basin Study offers confirmation with it's industrial water demands by
counties for 1975 showing Polk with 264, Hillsborough - 15, Hardee - 1,
DeSoto - .3, and Manatee - 3.1. Folk's use declines 60  m.g.d. by 1985
and 233 m.g.d. by the year 2035. Manatee's use increases  to 32 m.g.d.
in 1985 and then declines to 6.3 in 2035. Hillsborough, Hardee and
DeSoto Counties show similar changes.
SWFWMD records for recent permit actions indicate a decrease in the
phosphate mining industries water withdrawal demands. Beker's use is
equal to 973 gallons per ton -of phosphate rock produced.  This compares
with an average of 2400 gallons per ton for mines permitted prior to
1975 and 1390 gallons per ton since 1975. Each operation  must be assessed
separately (as is now the case) to determine water needs, but a downward
trend seems apparent.

On page 2.18 there ensues a discussion relative to the  elimination of
slime ponds. There is no question that this is the direction and the
result that the industry would like to achieve, but as  yet there is  k/~/5 2.
no evidence that this is achieveable at all mine sites. The result is
in part dependent on the nature of the partic • Lar deposit and the
minerology of-that site as well as on improving technology and achievement.
Again, it would appear that a case by case consideration, must'be..given
rather than a blanket dictum that slime ponds must be eliminated. It
should also be noted that while the report takes note of  Mr. Timber lake's
remark, that "The lands reclaimed have potentially higher resale value
	." It should also be noted that the cost per acre  for reclamation
of this type could range from $7,000 to §10,000 an acre while the value
of agricultural acreage is less than $800 per acre.

On page 2.21 a dry conveyor at an existing mine for the transport of
matrix from mine to beneficiation plant is discussed and  in other parts
of the report is recommended for inclusion at other mines. The inform-   •  i <--7
ation presented on page 2.23, representing the initial  cost and the           "^
operational cost, was based on projections and not on lengthy operational
experience, and as such is inconclusive. It is premature  for EPA or
others to positively recommend to industry a new technology that has
not been sufficiently tested or time proven. The mining company that
placed the conveyor in service should be commended for  its efforts to
improve upon existing practice, but until operational experience has
                             3-101

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proven the practicality of the theory, there is no reason for others to
duplicate the system.  The EPA by seizing upon the still unproven efforts
of some, as best available technology, at best, will discourage others
from trying new techniques for fear that their efforts will be mis-
interpreted and adopted by the agency as proven technology.
It will be necessary to develop specifics with the company that is dev-
eloping the use of the conveyor, but it is thought that phosphate rock
recovery losses have been encountered as well as operational difficulties
on the belt and with the total system 'design concept. This does not say
that the problems won't be worked out, but it does call for confirmation
of the result before making a blanket recommendation.
The comment on page 2.27 that says that the conveyor belt will result in
a decrease in water use is inaccurate and does not apply, based on in-
formation available at this time.

On page 2.27 reference is made to containment of 10 year and 25 year 24
hour storms. It is not clear if this "containment" envisions, above ground
storage, which in other parts of the report would be considered dis-     ,
advantageous, or below ground storage, which in areas of sandy soils   lv
and high water tables is impractical. Again, it would appear that a case
by case review must be undertaken in place of implementing broad rules-
or regulations that will require exceptions in many instances.

On page 2.31 a discussion on mining in wetlands begins. The statement
is made that the first part of the scenario would prohibit_ mining or dev-
elopment- --- -—wetlands as defined by the regulations-— - by the U.S.
Corps of Engineers of Section 404 ----- . The regulations do not prohibit,
but do require permitting prior to preceding. Permit applications can
either be approved or denied, but there is no automatic prohibition, as
it is a case by case decision, following the proper procedures for both
satisfying environmental concerns and protecting' the property owners
rights .                                                                 v£

On page 2.33 the restoration on previously mined wet lands of an equiv-
alent habitat for certain species should relate to the presence, .number
and the value of those species versus mans alternative use of the land
for other purposes. Similarly, it would seem to serve no purpose to re-
claim a flat pond and then see it or an adjacent pond drained for the
needed agricultural activity. Again, the philosophy that all wetlands
are important or conversely none are important must be replaced with
a closer look rather than with a blanket policy such as has been advanced.

On pages 4.2 and 4.3 a statement is made that specifications required by
PL 95-87 .(Surface Mining Control & Reclamation Act of 1977) should be
adopted as measures to apply to phosphate mining in west central Florida. /J. ?
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                             - 5 -

 1.   Returning  the land  to  the approximate original ccfntour is the age old
 and  often disproven adage  that what was here first was best. Reshaping
 the  land can be useful  and beneficial. Annual review of reclamation plans
 by State and County officials, as presently called for by law, will pro-
 vide ample  control over this reclamation activity.
 2.   Returning  the land  to  its prior use is meaningless unless that prior
 use  was the highest and best use of that land. This is the true meaning
 of conservation.
 3.   Stockpiling topsoil in west central Florida is, in many areas, tant-
 amount to stockpiling sand for replacement on top of more sand. It is
 evident that "reconstructed soil" can often be preferable and more valuable
 than the so called topsoil.
 4.   Commencing reclamation within one year of initial disturbance is
 applicable  to  coal, but not to phosphate rock since the disturbed areas
 often become water holding ponds or part of the water recirculation system.
 5.   The same comments given in response to 1. & 2. above apply relative
 to replanting  vegetation that existed prior to mining.
 6.   Reestablishment of  surface and groundwater hydrology systems that ex-
 isted prior.to mining ignores the beneficial enhancement of aquifer recharge
 that can occur with mining. It also ignores the continued use of recharge
 wells after .mining as well as the addition of lakes on the land surface.
 7.   Designating areas as critical wildlife habitat and prohibiting mining
 in those areas is again equivalent to condemnation of the land with a dis-
 regard for  the property owner's rights. Presently, none of the lands in •
 the  study area carry the label, of critical wildlife habitat and so to
 wait to apply  such a label, at the time when a proposed raining venture is
 being reviewed is ill-conceived.

 The  foregoing  has touched  upon some of the points that were considered in
 the  preparation of the  following comments relative to recommended changes
 to the Proposed Action, Section 1. E.

 The  elimination of rock drying at beneficiation plants assumes that the
 rock production at the  new mine is solely for captive use, since the miner,
 can  not dictate to the  ultimate user the plant modification that is needed
when using  undried phosphate rock. In short, it places the new miner at a
 competitive disadvantage for if he is to compete with dry rock he must   *J- "384-
 first go to one of his  competitors for that service, a distinctly inequ-
 itable situation. Further, a restriction of this type in effect says that
we should continue with and encourage the use of the older drying plants
while foregoing the technological developments that make newer plants more
 efficient and  cleaner.  It  appears to be self-defeating in purpose. Alternate
wording is  suggested-as follows:
   Rock drying at beneficiation plants must employ emission control devices
   capable  of complying with the prevalent regulations that are designed
   to protect air quality. The elimination of drying is encouraged and
   should be pursued whenever practical.
Florida's effluent limitations for discharges have not as yet stood the test
of practical compliance. Beker has previously submitted to Florida DER and

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                            - 6 -
also to EPA statistical findings that show that the new regulations
were based on an improper analysis of the permormance of existing mines.
Alternate wording would be:
   Florida effluent limitations for discharges vs.  actual discharges
   from existing operations will be monitored and the limitations will
   be established for all mew sources, providing the data demonstrates i^_ 28(o
   that the limits can be met using the best available technology.
Eliminating conventional above ground slime-disposal areas is dependent
upon the nature of the deposit and .the amount and types of clays in
the matrix. Suggested wording would be:
   Reduce the area and number of above ground- slime-disposal areas to
   the Tn-in-tmiim that is compatible with the nature of the deposit.
The recovery.of water from the clay slimes has always been an objective
of the phosphate mining industry. However, a limit  for effective reuse     te
can be reached. Under those circumstances some recovered water must   4*/~-So
be released. An example, the proposed Beker mine, will employ well water
only for the flotation section requirement where it is necessary. A
portion of the recovered water must then be discharged or used in ir-
rigation or land disposal. Suggested alternative wording is:
   Water recovered from slimes shall be stored and  reused to the max-
   imum extent possible.
Use connector wells should be modified to read:
   Use connector wells where feasible and with the approval of the  ii_ 288
   water management district and the DER.
The protection and restoration of habitat for important species of
vildlife is too broad a requirement in that important species lacks
definition and accordingly could be conceived by anti-mining factions .1 _ •? g 
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                     IIORIDA  ClIAITI-K
                                  oi;
                 TIIH  WIUUIFIi  SOCII'TY

                                  June 20,  1978
 .John E. Hagan,  III
 fhlof, HS Branch
 f rwlrnnmental  Protection Agency
 'V'j(on IV
 W Courtland  St., N.E.
 Atlanta, GA   30308

 Dear Dr. Hagan:

     The Florida Chapter of The Wildlife Society Is a group of professional
 wildlife biologists concerned about the welfare of fish and wildlife and
 their habitats  1n Florida.  .We have always  been interested in wild!and
 areas and we are particularly concerned about  landscape alterations  and
 reclamation associated with phosphate mining in this state. ' We have
 reviewed the report entitled "Draft Areawide Environmental Impact Statement:
 Central Florida Phosphate Industry" and hereby submit our comments.

     Our major  criticism of the report is that 1t lacks a thorough discussion
 of the Impacts  of phosphate mining on fish  and wildlife habitats.  Through-
 out the report, there are references to the relative value of various
 habitat types without substantial  reference to the source of the evaluation
 or methods used in determining the relative values reported.  With the
 exception of the criteria that high habitat diversity supports a diversity
 of wildlife, It is very misleading and inappropriate to indicate that a   faj
 particular habitat type has high or low wildlife habitat value.  Habitat
 Is desirable or undesirable solely from a standpoint of the ecosystem's
 ability to satisfy life requirements of particular species.  For example,
 a wetland which supports an abundance of waterfowl, shore and wading birds,
 frogs, snakes and a highly productive fish  population, would likely provide
 very poor habitat conditions for scrub jays and red-cockaded woodpeckers.
Assignment of relative values for wildlife  habitats must, therefore, be
more specific in the species or groups of species for which comparisons
are being made.

     Another related point is that above ground slime ponds do have value
as wildlife habitats and they add to landscape diversity, but discussion  •j
of these benefits are minimal in the draft  EIS.  As professional wildlife ^
biologists,we support the concept that above ground slime ponds are

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John C. Hagan, III
Juno 20, 1978
Pago 2


beneficial  to wildlife (particularly wetland species)  and we discourage
the total_ elimination of these areas.  In addition, we would like to see
changeTTn the current state regulations (we have expressed this  in
writing to the Department of Natural Resources)  which  allow shallower
slopes along pond or lake edges resulting in wider littoral  zones.   Our
qroup has offered (with no success) our assistance to  the D.N.R.  in
development of standards for the reclamation of  wildlife  habitat  values
on mined lands .

     Reference is made to your species "lists" throughout the report,
.iml although we recognize the importance of identifying a number  of those
-.pnHrs to be affected, we feel that your selection criteria for  "special-
LonLorn" and "species of ecological importance"  are too arbitrary.   For
example, on page 2.34 a list of species which would potentially be  affected
by phosphate mining in wetland areas is presented.  Although we can only
speculate on the criteria for including many of  the species  listed, it    lrJ~IS~c(
Is difficult to determine why species such  as the Florida duck, wood'
stork, white ibis, roseate spoonbill, osprey, bald eagle, and all common
migratory waterfowl  are excluded from the list,  while  the wood duck,
black-crowned night heron, Virginia rail, sharp-shinned hawk, and  the
wild (feral) hog are included.

     We believe that the report fails to provide a comprehensive, objective,
full disclosure assessment of the impact of phosphate  industry activities
on fish and wildlife habitats.  Also, we would like to  see more consider-
ation given to fish and wildlife in your criteria for  wetlands restoration.
We agree with your statement (pages 2.34 and 3.3 of the report) that  good
wetlands restoration has yet to be determined, but knowing this,  we then  U~l(e>O
find it difficult to understand statements  about irreversible habitat
alteration (pg. 1.26), regulation of restoration (pg.  1 .72) ,  wetlands
restoration (pg. 2.5, 2.43)  and required wetlands restoration (pg.  2.31).
We strongly support the need for further research into  restoration  of
fish and wildlife habitats on phosphate mined lands.

     If we may be of any assistance to you, please feel free to contact
me.

                                   Sincerely,
                                   Nicholas  Holler,  President
                                   Florida  Chapter of  The Wildlife  Society
NH/sls

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THE  /ZAAK  WALTON LEAGUE OF AMERICA
                            INCORPORATED
                 DEFENDERS OF SOIL, WOODS, WATER, AIR AND WILDLIFE
                                                   MANATEE CHAPTER
                                           1619 Palraa Sola Boulevard
                                           Bradenton, Florida  33505

                                           June 21, 1978

  Mr* John E.  Hagan, III
  Chief, EIS Branch
  Environmental Protection Agency
  Region IV
  3^5 Courtland St., N. E.
  Atlanta, QA  30308

  Dear Mr. Hagan:

  We wish to make  the following comments on  the Draft Areawide  Environ-
  mental Impact Statement, Central Florida Phosphate Industry,  and request
  that they be made a part of the May 22 hearing record:

  1.  'We commend the federal government, in  particular the EPA, for under-
  taking this  study, since site-specific mining EISs can not deal with
  cumulative,  over-all impacts.  .We observe  with regret, however, that (jJ-
  the manner in which the report is organized makes it rather difficult
  to understand.  Inclusion of a summary with material organized by subject
  would be helpful.

  2.  We concur with many of the criticisms  and comments made at the hearing
  in Bradenton, in particular the following:
                                                                     Kt
  a*  Mr. Ernie Estevez on inadequacy of regulatory agency monitoring and
  control;
  b.  Mrs. Gloria  Rains on radiation hazards, wetlands protection, pollution
  of air and water, and water resource depletion;
  c.  Mr* Archie Carr on phosphate industry  use of energy and depletion of
  a national resource;
  o*  Dr. Jeffrey  Lincer on air inversions in the Tampa Bay area.

  3»  We regret that the study did not reflect original research and that
  where data were  inadequate, an element was frequently excluded from con-
  sideration.   Examples are:
a.  Page  1.32 - "Hydrogeologio conditions favor entrance of contaminants
to at least the water-table and upper Floridan aquifers.  However, con-
tamination is generally poorly documented due at least in part  to
monitoring deficiencies.
                                                                      . . •
                                                                    — » w 5
  b.  Page 1.50 -  "Long-term effects of low radiation doses are not fully
  known."
                              3-10 7

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    Page 2 -

c.  Page 2.2? - "Because of the lack of data on the extent, if any, of
surface and subsurface seepage and the feasibility and adequacy of imper-
vious linings to control this potential source of pollution, effects
assessment did not include an objective and quantitative evaluation of
this process modification."

d.  Page 2.40 - "No data exist, however, to support quantification of the
potential for collapse of a slime impoundment or gypsum stack."

e.  Page 2.63 - "no secondary impacts could be determined. . .because of
the lack of any quantitative model with which to assess the effects of
leeching."

f.  Page 2.6*f - "Quantifying impacts on the general population by exposure
associated with the pathways just listed was considered beyond the scope
of this program."

kt  The Draft EIS presents ample evidence of overwhelming, widespread and
serious adverse impacts of phosphate mining and processing, of which some
are: alteration of land surface; removal of soils and vegetation; reduction
of wildlife habitat and populations; potential effects on air and water
quality; reduction of livestock forage during raining;  reduced productivity
of mined area even after reclamation; reduced recreational resources;
potential destruction of archeologic values; redistribution of radionuclids
resulting in an increase in human -exposure (page 1.50 states "Long-term
effects of low radiation exposure is considered harmful, with adverse effects
to be proportional to dose."  In other words, there is no known "safe" thresh
old of radiation exposure for humans); reduction in quantity of available
ground water; irrevocable commitment of resources including phosphorus and
fossil fuel.

We call attention to major adverse effects which are given little importance
in the conclusions of the report:
                                                                       U/
a.  Page 5.2, first paragraph, reads ". . . continued extraction of phosphate
from westcentral Florida will shorten the time when future resources will
need to come from other locations in Florida, the U. S., or the world. . ."
On page 1.2, we read ". .Central Florida . .accounted for approximately 80
per cent of U. S. production and 33 percent of world production in 1976. . .
the U. S. could be a net exporter of phosphate rock through the year 2000,
but that the demand would likely exceed the domestic supply before the year
2010, requiring that phosphate rock be imported to satisfy all requirements."

This is probably the most important observation in the report, yet it appears
to have been given exactly zero weight in the proposed action.  Pursuing a
policy which risks placing our nation in the position of hostage to foreign
countries for needed fertilizer within the next few decades is sheer folly.
                                                                         U/-/63"
b.  Page 6.1, second paragraph cites as an irretrievable resource the fossil
fuel necessary to generate electricity needs of the industry.  Does this
include fossil fuel necessary to transport phosphate?  If not, we request an
estimate of the cost in fossil fuel to ship Florida phosphate to foreign
destinations from now to 2000, and the cost thereafter of shipping foreign
phosphate to the U. S. for processing (and further shipment abroad?)  Is
this ecenario in the national interest?
                                 3-toe

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Page 3 -
5.  We find that some aspects presented as "advantages" require further
 analysis.  Illustrations are cited:
a.  Page 5.1, paragraph one states that undesirable impacts will be "offset
in the long term as public knowledge of phosphate operations and regulatory
agency activities increases (sic) and broadens (sic) and as the requirements
of the proposed action are matched by the performance of the phosphate
industry."  Is there evidence to substantiate this rather sweeping statement?

We find it  wholly unacceptable to "trade" ,  for example,  potential damage
to the health of people in Manatee County or other areas for presumed benefits
to the Port of Tampa with spin-off benefits to Disney World.
                                                                        A/-/67
b.  Page 5.1, first paragraph, states "The  tradeoffs are low-priced fertilizer
for enhanced agricultural production. . ."   In fact, phosphate frequently
feeds the v/rong people.  A recent U. N. Food and Agricultural Organization
report indicates that the "rich are getting fatter and the poor hungrier."
In the 32 poorest countries, calorie consumption is on the decline, with the
percentage  of malnourished on the rise in the developing countries of Africa
and Asia.  Furthermore, phosphate frequently feeds us the wrong foods.  In
rich industrialized nations, excessive food intake or improper diets contribute
to steadily rising prevalence of such diseases as obesity and artery failure,
according to medical authorities.

It appears, also, that there is a law of diminishing returns operating with
regard to world grain production and fertilizer use.  In 19^9-52,  each million
tons of fertilizer resulted in about 15 million tons of  additional grain
supplies.  In the past few years, the ratio has dropped  to less than six to
one ("The Global Economic Prospect: New Sources of Economic Stress", Lester
Brown).

If low-priced fertilizer is to be considered in the balance as an advantage
for the phosphate industry, more serious research is needed, with facts more
objectively examined.
                                                                         V-
c.  Page 5.1, first paragraph cites "reduction in U. S.  trade deficits" as
an advantage.  The unfavorable U. S. trade  balance is due entirely to our
 extravagant use of imported oil.  "Trading" the health  of Florida residents
for wasteful use of energy is wholly unacceptable.

d.  While employment appears to be rated an "advantage"  of the industry, UJ~
we find the following on page 2.60: "Since  the service businesses catering
to the needs of the retirement and tourist  sectors are in direct conflict
with the phosphate industry, however, there is good reason to believe that
they could  absorb surplus workers from the  phosphate industry."  Thus, there
is no need  to tolerate the disadvantages in exchange for "jobs".

6.  In view of the above comments, we believe there is ample justification
for requesting the following actions:                                   vJ"

a.  No authorization of new mines until major problems such as radiation in
reclaimed areas are better understood, leading to their resolution.
                                   - /of

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Page k -
b.  Use of all available governmental authority to phase out export of
U. S. phosphate within a reasonable period of time, for example, five to
ten years.

c.  Application to existing sources of the improved techniques proposed
for new sources, on a reasonable phase-in schedule.  For example, companies
which might conduct scavenger operations to recover high-grade phosphate
rock from old tailings (page 2.7) would be expected to operate without
creating slime ponds.  We acknowledge the limitations cited on page 1.7^
but call attention to the fact that administrative and legislative remedies
are available when needed for public health and safety.

d.  Since companies do not plan to open new processing plants, suggestions
of new processes such as lining of gypsum ponds are largely academic unless
applied to existing sources.  Existing plants should therefore be required
to line areas to be used for gypsum waste stacks, while awaiting phase-out
and while developing means of disposing of those stacks and ponds already
accumulated.

Continued processing in the U. S. of imported phosphate after U. S. supplies
run out imposes a wholly unacceptable health risk to people in the vicinity
of processing plants.  Disposal of processing plant waste is recognized as
one of the most difficult problems. facing the industry (page 5.1).  Perhaps
a ceiling could be set on the percentage of Florida surface which may be
covered with gypsum stacks and ponds.

                                              Sincerely,
                                              Hilda Quy, Vice President
                                              Manatee Chapter, I\

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CITIZENS
                           P.O.BOX 1574
              RIVERVIEW,  FLORIDA 33569
                                               June  19,  1978
Mr. John C. White
Regional Administrator
U.S. Environmental Protection Agency
Region IV
345 Court land St.. NE
Atlanta, Georgia 30308
                             Re: Central  Florida  Phosphate  Industry
Dear Mr. White,                  Draft EIS

     Our previous public statement was incomplete,  having just  received
the working papers on the Monday mrrriing  of the  EPA Bradenton hearing.  We
ask that you consider the following in the final  EIS.
     It is not, in our opinion, reasonable to assume that the flood plain
areas and wetlands will be mined in the future.   Wetlands reclamation              .
technology is not adequately developed on signif icant^'to pr-eceed with    l\f —' I  I I
this assumption.  We request requirements for reclamation be included
with specific amounts of acreage to be determined successful by 2PA standards.
The term "acceptable recla.nation" or "successful" reclamation needs to be
clearly defined.  The following example will demonstrate the need  for this
requirement:  On January 3, 1976, U.R. Grace requested  a variance  from the
Hillsborough County Mining Ordinance to mine the  wetlands and headwaters of
the Little Manatee River.  This variance  is contingent  on the successful
reclamation of two acres of wetland to be destroyed (not mined) and restored.
W.R. Grace is proceeding with submitted plans to  the Hillsborough  County
Engineering Department and hopes to prove'successful1 reclamation  in the near
future.  There is no agency or party designated  to determine the success of
this project - to what degree or what time frame  is not discussed.  This
request is in direct violation of EPC rules and  regulations and also the
Conservation Element of Horizon 2000, Hillsborough County Land  Use Plan.  The
need for Federal guidelines should be evident.

     We do not agree that restricting mining of  the wetlands forces more
extensive upland mining.  Rather, we feel maximum restrictions  should be
required for the protection of the fish and wildlife and the preservation of
a  resource necessary for life itself - water. The adverse  effects on the
quality of this vital resource are well documented in regard to mining.

     We request specific on-going mechanisms to  provide immediate  action
when adverse impacts of mining have been  demonstrated.  For example: a. Decline
in the Floridian awuafier of three or more feet  will prompt a moratorium       .
in the area until sufficient recovery has been substantiated, b. Similiar   fa/~ I • *i

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CITIZENS  AGAS;\!ST  RIVER  PQLLUTEQFJ
                          P.O. BOX 1574
              RIVERVIEW,  FLORIDA 33569
 Page 2


 measures indicated by a significant decrease in cfs  flow based on data
 recorded prior to mining in adjacent areas.

     We request that the Dept. of Interior,  National Wetlands Inventory
 Office in St. Petersburg be consulted regarding the  destruction of the    . . _  . —. -?
 three wetlands categories and the effect that action will have on the
 surrounding areas plus the effect on the quality of  water and increased
 possibilities of .flooding in downstream areas.

     We are also sending under separate cover the Hillsborough County well
 field map which clearly shows the extent of  land affected by wetlands mining
 and tributaries on the Alafia and Little Manatee rivers.  To assume that  these
 two rivers will not be severely affected is  not a feasible assumption.

     It was noted at the Bradenton hearing that the  Archibald Research Station
 studies listed numerous endangered species in the study area and that this
 document will be included in the final EIS.   It has  banobserved by a Fish and
 Wildlife officer and is in the process of verification by U.S. Fish and       U/~l~74
 Wildlife that a Florida panther exists in the Keysville area and uses these
 wetlands as travel roads.  Two nesting bald  eagles and a rookery of Sand
 Hill Cranes are also being verified.

     Comments regarding Uranium Recovery and radiation are being sent from
 the Hillsborough County Environmental Coalition.   We urge more specific
 and thorough recommendations in the final regarding  this process.  The
 statement that there is not sufficient data  regarding gypsum pond damage
 is questionable.  Please refer to the recent study by USF geologist, Dr.
 Upchurch regarding Gardinier.   We would also request a specific time table
 for radiation monitoring of the Floridian aquafier.

     We request consideration be given to the systematic study of the phosphate
 resources by the U.S. Fish and Wildlife Service,  L.A. Mehrhoff.   It is of           ^
 grave concern to members of our organization that such a valuable program    l*s — (  ' J
 has in no way been incorporated in the Draft EIS.

     In conclusion, we support the recommendations of the Tampa  Bay Regional
 Planning Council that the Bone Valley area be designated as an "Area of
 Critical State Concern".   We intend to kpursue  this  recommendation through
 all levels of government.  It is our opinion that  existing laws  lack strong
 guidelines and adequate enforcement.  We are also of the opinion that the
 new source guidelines should be applied to existing mines.  IMC  has stated
 in their annual report to the Hillsborough County Commissioners  that they
 intend to mine an additional 918\purchased recently without filing a DRI
 to cover this area.  Thank you for consideration of  these comments in the
 final EIS.
                                                   ^incerely,   sj\  . i .

                                                           AL^^L-h-h.^'
                                                    Robert Cribbs, President

                                 J-//2

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   SINCE NINETEEN HUNDRED   f         ,, A      3   "THE VOICE OF CONSERVATION"
                                               May 19,  1978
     John C. White
     K'~rional Administrator,  Region IV
     Lnvironmental Protection Agency                        i    )   j
     3'*b Courtland Street,  NE                           \jj ~"  '
     Atlanta, GA 30308                                  ^

     Dear Mr. White:

     Thank you for the opportunity to comment on behalf of  the Florida Audubon
     Society on the Draft Area Wide Environmental Impact Statement, Central
     Florida Phosphate .Industry.

     First, I find the Area-wide approach that EPA has  taken with the EIS process
     in Central Florida to  be an interesting one and one I  think will efficiently
     lead to equitable environmental protection.  I hope history will bear out my
     optimism.

     I .v-ould also like to compliment you and your staff for the admirable job of
     condensing the volumes of information developed by Texas Instruments and
     subsequent proceedings into a very readable volume.

     I have several comments  regarding the content of the EIS that are presented
     in no particular hierarchy of importance:

     1)  Fluorides:  a) It  is stated under Environmental Impact of Proposed Action
     (Section 3, p.3.1) that  "no new chemical plants are projected under the pro-
     posed action, and consequently, fluorine emissions will not increase."

     itus^I understand is possible largely because existing processing plants will
     continue to be used for  the rendering of phosphate rock from new sources.

     It hju^become abundantly clear to us that old plants retrofitted with fluoride
     pollution control equipment are far less efficient at  controlling fluoride
     e."i;->ions than new plants in which pollution control equipment is designed
     into the plant from the  beginning.

     ll'1' ,: ;s.w°uld be improved by inclusion of the fluoride pollution control
     ^.i; ,'.,•: 11 ties of the plants which are intended to process phosphate from new



FLORIDA   AUDUBON   SOCIETY

             921 Lake Sybelia Drive  •  P. 0. Drawer 7  •  Maitland, Florida 32751
                                   (305) 547-2615

-------
John C. White
May 19, 1978
Pace 2

b)  I appreciate that EPA is recommending biological monitoring of fluorides
(Section 4, p.4.1 - Ambient vegetative-fluoride sampling program).

I believe it should be expanded, and I submit for your consideration a
research plan (enclosed) authorized by EPA to monitor fluorides potentially
emitted by the Occidental Chemical Company operation in the vicinity of the
Suwannee River, north Florida.

The results of the north Florida research and the techniques developed there
might be very useful to a more complete monitoring program in central Florida.

I will not attempt to outline a specific monitoring program for central
Florida, but I do ask that you study the north Florida research plan with an
eye for its relevance to the central Florida area.

2)  Wetlands:  I approve heartily of the intent and justification to protect
wetlands expressed in the EIS.  I notice that many (36 of 39) archeological
sites are located within them, adding to the basic ecological and hydrological
good sense of protecting them.

However, I am very disturbed by the concept of cutting the hydrologic throats
of the wetlands expressed under "Effects of Controlling Activities in Waters
of U.S. and Wetlands," (p.2.90).

If leaving wetlands on   desiccating "pedestals"spells their doom, then avoid-
ing them to begin with becomes nonsensical:  The Environmental objective is
lost and the sacrifice by the phosphate industry is wasted.

I agree with the conclusion that "mining effects on remaining or 'undisturbed'
wetlands should be addressed in greater detail..." p.2.91).

I recommend that the principle receive thorough attention in the final EIS
and that it be stressed that the danger of wetland garroting should be care-
fully addressed in site specific EIS proceedings.

3)  Energy and Phosphate Conservation:  It is apparent that the huge energy
requirement for phosphate mining and processing (p.2.7.) is met only because
the industry receives a subsidy (lower rates) from TECO and Florida Power.

Just as it is said that the industry competes with the public for aquifer
water, so it can be argued that the industry competes with the public for
energy.

From data presented on phosphate supplies and demands (p.2.8-2.11) it is
apparent that more energy will be required to extract a given unit of rock in
the very near future.  Sub-economic resources are expected to become economically
recoverable when the market value of phosphate increases.

-------
John C.  White
May 19,  1978
Page 3

The fallacy and danger of this argument is that not only more money but more
energy will be required to produce what are currently sub-economic resources.
Energy,  unlike the market, will not inflate.   It will only deplete.  Thus
there will be two interdependent and non-renewable resources following
extinction curves, and the cost of phosphate,  energy and food will be log-
rithmically increasing.

I cannot help but envision a crisis emerging from these divergent curves.
I believe the history of fossil fuels is. a sufficient model to lead to this
conclusion, but I have every confidence that a complete evaluation of current
phosphate resource management practices would prove the point.

In view of the above, I look with great concern on the industry's enthusiastic
search for new and larger phosphate markets abroad.  It is argued that the
national balance of trade is served by phosphate export.   What fossil import
is required to subsidize that export?  I would be more content if in the
final EIS the U.  S. Department of Energy commented on this point  and on the
cbmpliance of phosphate mining expansion with national energy policies.

I am inclined to believe that American agriculture and the American consumer
are being "set up" for a food-cost crunch in the near future, perhaps before
2000.  This crunch'could be at least postponed by domestic resource conserva-
tion commensurate with incentives to Morocco to bring her massive resources
on line  rapidly.

In summary, I believe EPA will succeed in providing for a clean industry in
west central Florida if the Area-Wide EIS is adhered to.   But I am worried
that EPA is becoming innocently involved in gross resource mismanagement.  If
I am correct, then the cleanliness will be a trivial accomplishment.
                                            Archie Carr,  III
                                            Special Assistant  to the
                                            President  for Science
sh

enclosures

-------
  SINCE NINETEEN-HUNDKED  .''                 V'THE VOICE OF CONSERVATION"
May 24, 1978

                                                       \/J-  l"7"7
John C. White
Regional Administrator, Region IV
Environmental Protection Agency
3^5 Courtland St.,  NE
Atlanta, GA   30308

Dear Mr. White:

Please consider this an addendum to my May 19, 1978 critique of the Draft
Area Wide Environmental Impact Statement, Central Florida Phosphate Industry.

A close scrutiny of the EIS's treatment of endangered species, finds it to be
frighteningly casual and superficial. 'There is a blase mood surrounding
the fate of these organisms in the statement.  On pages 1.22 - 1.27, threatened
and endangered plants and animals in the seven-county area are identified,
and the general conclusion is drawn that phosphate mining will heavily impact
upon them.  Later in the document under Section 6, Irreversible and Irretrievable
Commitments of Resources, it is stated that 45,000 acres of endangered species
habitat will be lost.

That is the sum  total of the discussion.  From the standpoint of biological
management and probably from the standpoint of law, it is an inadequate
discussion.

EPA has the responsibility under the National Environmental Policy Act and
possibly under the  Endangered Species Act to seek to protect endangered species
and their critical habitats.  In the Draft Area Wide Impact Statement, there
is no mention of how EPA intends to achieve this protection.

Measures to provide for both mining and endangered species protection have
been presented during the past year by the Fish and Wildlife Service.  These
include phased mining schemes whereby habitat from one mine is restored prior
to opening of the next mine in a sequence; establishment of refugia and
corridors to preserve pathways for gamete exchange and other behavioral needs.

Neither of these ideas nor any other mitigating procedure is advanced in the
Draft EIS.
                il\o Sybolin Drive  •  P 0. Di.rArr 7  •  M;iill.md, Florida 3f751'
                                 (SOW 6'1/-:T.L5

-------
John C.  White
May 24,  1978
Page 2
The omission is intolerable to the Florida Audubon Society.

I have a specific concern for the proposed mining impacts on the Florida
Panther.  Members of the Florida Panther Recovery Team and the Florida
Game and Fresh Water Fish Commission are of the opinion that the Myakka
State Park is an important habitat for the panther, possibly second in
importance only to the Fakahatchee Strand in the Everglades.  I note that
mining is proposed within the Myakka River drainage basin and in very close
proximity to the Park.  The obvious question arises: will the mining damage
the recovery potential for the Florida Panther?

No answer is given in the Draft EIS.

In summary, the Final Impact Statement must address the management of endan-
gered species in the seven-county area far more thoroughly if it is to do
justice to law and common sense.
Sincerely,
Archie Carr, III
Special Assistant to the President for Science

dp

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                                     STATE OF FLORIDA
                      Department of ^ministration
                              Division of State Planning               *«ubln °'D A8kew
                                                           f                    GOVERNOR
                                Room  530   Carlton Building
R, G. Whittle, Jr.
STATE PUNNING DIRECTOR                             32304                           """"' " W""""™T"'H
                              TALLAHASSEE                       Wallace W. Henderson
                                   32304
                                 (904)488-1115


                                     June 22, 1978


Mr. John E.  Hagan,  III
Chief, EIS Branch                                                ••••••
U. S.  Environmental  Protection                                   ,      ,, R
   Agency, Region  IV                                            J"N  - °
345 Courtland Street,  N.  E.
Atlanta, Georgia   30308

Dear Mr. Hagan:

       Functioning  as  the state  planning and development clearinghouse
contemplated in  the U.  S. Office of Management and Budget Circular A-95,
we have reviewed the following Draft Areawide Environmental  Impact State-
ment:   Central Florida Phosphate Industry, SAI 78-1763E.

       During our review  we  referred the environmental impact statement to
the following agencies, which we identified as interested:   Department of
Agriculture and  Consumer  Services, Department of Community Affairs, Depart-
ment of Commerce,  Department of  Legal 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, Department of Administration's Bureau of
Land and Water Management, Southwest Florida Regional Planning Council,
Southwest Florida Water Management District, and South Florida Water Manage-
ment District.  Agencies  were requested to review the statement and comment
on possible effects that  actions contemplated could have on  matters of their
concern.  Letters  of comment on  the statement are enclosed from: Department
of Agriculture and Consumer  Services, Department of Commerce, Department of
Community Affairs,  Department of Health and Rehabilitative  Services, Depart-
ment of Legal Affairs, Department of Natural Resources, Department of
Administration's Bureau of Land  and Water Management, South  Florida Water
Management District, Southwest Florida Regional Planning Council, and
Sarasota County.

       Our review of the  agency  comments finds that the Environmental Protection
Agency must be commended  for its efforts in addressing the complex issues
surrounding phosphate  mining in  central Florida.  However, we must also note
that many of the agency reviews  have cited deficiencies in this draft impact
statement.

-------
Letter to John E.  Hagan,  III
Page 2
June 22, 1978
       Generally, Environmental  Impact Statements  address  site specific
issues.  This draft document is  unlike the typical  statement as it addresses
concerns of a broad regional nature.   The final  statement  on this program
will be used as a basic source document for future detailed site or project
impact statements.   Therefore, this  document is  of major importance to us
and will assume greater importance in the future.   As  this statement will
achieve major significance and as we  have found  deficiencies in this draft
document, we suggest that it be  revised to reflect our concerns.  We further
suggest that the revised statement propose a mechanism which would establish
a continuous updating process in order to provide  a current basis for the
site specific impact statements  that will follow.

       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 rsquest that you forward us copies of  the final  environmental
Impact statement prepared on this project.
RGWjr:Kb
Enclosures
cc:    Mr. John Bethea
       Mr. Charles Blair
       Mr. Martin Freidman
       Mr. Joseph W.  Landers, Jr.
       Mr. W.  N.  Lofroos
       Mr. Loring Lovell
       Mr. William Partington
       Mr. William J.  Page,  Jr.
       Mr. William Ravenell
                                       .  G.  Whittle,  Jr.
                                      Director
Mr. Harmon Shields
Mr, Phil Ashler
Mr. H.  E. Wallace
Mr. L.  Ross Morrell
Mr. Helge Swanson
Mr. Walter 0. Kolb
Mr. John Maloy
Mr. Donald Feaster
Mr. Roland Eastwood

-------
                                STATE or FLORIDA
            ,
-------
                                                May 9, 1978


                              State  of Florida
                      Department  of  Natural Resources
                               'Comments  on
                              SAI:   78 -  1763


Staff concludes that this statement  is a  very well written document.  Adequate
alternatives to the proposed action  were  sufficient for summary type evaluation.

A subject not adequately discussed in. the draft  was the present extent and
quality of restoration/reclaimation  projects.   If mining is indeed, to con-  kJ~~'  '&
tinue in west-central Florida, restoration/reclaimation should be continuing
at a rate equal to or greater than the rate of mining.

The subsequent-use of the—land-after__it has been restored/reclaimed is of
great interest to  the Division of Recreation and Parks.   Another subject
which was discussed sufficiently  in  the draft  statement was the level of
radionuclides and  floro-compoundj which may be assimilated by plants and     (»/—/'
-animals .as part of the restoration project.  The aesthetic quality and types
of uses .in which the reclaimed land  might be involved are not quite clear.
Some ..discussion was g'iven to human,  agricultural, and wildlife uses of these
lands, but a thorough evaluation  was not  included.

Mining as described in 'the "Primary  Effects of 'Permit Existing and New
Sources' Alternative" section depletes the extent of Florida's sandhill,
sandpine scrub,  and haiomock:habitats.--'Each of these habitat associations      W-I&
are.considered by "the Department  of  Natural Resources to be highly endangered.
The Department advises against destroying or altering these associations
whenever possible.

As understood bv the Division of  Recreation and  Parks,  site specific envir-
onmental assessments or" impact statements for  each new source will be dis-    VJ~\B\
tributed for review.

Staff appreciate  the opportunity to.review this fine draft statement.  In
closing, the Division of Recreation  and Parks  strongly supports the follow-
ing quotation from page 2.83 of the  draft statement:

     "There is every.reason to believe that increased mining activity
     could impact  unfavorably on  the multimillion dollar tourist/
     recreation industry by reducing or altering the scenic attraction
     of the area."

-------
   j;»" - -T>i,
  X. V'l t'l, '^
 /.->-- r-X-A
AV^V  'V-A
 -.•••: U'ro ;
     STATIC orm J'J,OKIIIA


     ut   nf   Afcmhusi'raitJDin

Division  of State  Planning

 • 660 Apolachec  Parkway •  IBM Building

       TALLAHASSEE
             32304
       (904)  488-2371
                                                                 //'.-•'!/N> Rcubln  O'D. Aokow
                                                                              COVdNOI
                                                                **•*! ''—'••  ' 'ft\.
                                                                 •:.   '' '.'l  >>


                                                                      ,. Gov.'j. K.^JIm" Wllllnmt
                                                                            «.«™.«,


                                                                              ,:. ,'M
           TO: __Mr.  Phyl  Ashler
                           of Comm
                            Building
                           ;, Florida 32304

         FROM:  Bureau of Intergovernmental

      SUBJECT:  SAI: ^7^/7^ 3
                  		          		;:tp _a pp.1 y Joj^jfedetpa.1
      ^^.sjt.ance.JS_belnglrefe.r.r.ed_t.o_yoyr_age.Dcy, for"reyiew'and comments.  Your
      .reviev/and comments should  a.dd_reis_themselyes tp_j;he_extenJ;._tpj:/h_i_ch_'Uie_
      Br_QJect_ij_cpn.sistent with  or contributes to the fuTfillnienf o^yo'ur agency's
      plans or the-achievement of your  projects,  programs, and objective's.

                If further information  is  required,- you are urged to telephone the
      contact person named on the notification  form.  If a conference seems necessary,
      or if you wish to review the entire  application, contact this office by tele-
      phone as soon'as possible.   If you have no  adverse comments, you may wish to
      report such by telephone.  Please check the appropriate box, attach any comments
      on your agency's stationery, and  return to  BIGR cr telephone by the above due
      date.  If we do not receive a response by the due date, we will assume your
      agency has no adverse comments.   In  both  telephone coversation and written
      correspondence, please refer to the  SAI.

                                            Sincerely***'   ^
                                            Lorfng Lovell, Chief
                                            Bureau of Intergovernmental Relations

      Enclosure
      **-***********************************************^

           TO:  Bureau of Intergovernmental  Relations
         FROM:  Department of Conferee
      SUBJECT:  Project..Review and Comments, SAI:   78-1763	
                  LJi'Io Comments
                  UZ1 Comments-Attached
      Reviewing Agenc^:,^
                                                            Data    May  15, 1978
          Titled Chipf,  Bureau  of  Economic Analysis,
              '~~T                         *-*

-------
                 Division of State  Planning1    RECEIVED
                       _  '                        i
                   CCO Apteclce Parkway •  IBM  Building  '•

                        TALXAIIASSKE
                                                    DEPT OF CW<''^C<^'"^'^^"'1" wm
                                                    DIV. OF TECHNICAt'X&Witfr1''"'!4*1
                                                                       Heubln O"i~>., AtJtpv-'
                                                                       1Q7R. co»u-.«J
                                                                       13I°
                                      4BG-2371
          •lc. v;ill\a.7i 15.  RaveRsl3, Secretary
                     of  Cc—.-.unity Affairs

                   ee,  Florida 32501

          Bureau of Intergovernmental Ralatioiis

SU3JECT:   SM;    /fif   7k
                                                                            tf.
                                                 BUS
                                                                            " '6
          The  attached "Ailva.icc 'lotificetion"  of intent to c?ply for federal
nssi.Ptance is  being referred to your egency  for review .an;! cc"i'.erits.  Your
review and co.T.T.ents sho-jlc!! address themselves  to the- ext.ent  to v}uch plhe
project is consistent, with or contributes  to the fulfiJh.isr.t of your ayency's
jOnns or-the r.chicvc.-crit of your projects, .programs, ani'Objectives.

          If further information is required,  you are urcjccJ  to tcOcphonc  the
contact person named on the notification forir.'.   If a cor./!crc.T.cc .€;ee:i'.r; necessary
or.if you \:it.}\ to revicv; UIG entire application, contact tliis office by telepho
AS soon i\s i^oosiblc.  If you have no adverse cG'.vr.onts, you r.ay wisli to report
r.uch by telephone.   Plcacc check Lhe appropriate ksy., sittnch ar.y co:r.:.'.cr.t^ on
your agency1 o  stationery, ar.d return to this office or telephone: by the above
due date.   If  \;o do not receive a response by  the due elate.,  v:c will acuunc
your agency Iins no adverse co-tncnts.   In both  telephone conversation and
vrittcn correspondence, please refer to the  S/M niraber.
                                      Sincerely
                                        wing Level 1, Chief
                                      Bureau of intergovernmental Delations
1-nclosure
                                     ttt*ttttlttttt*t «.-«.«;
                                                                     <;<.<. t/Ttittiiit
';o:i:
   Bureau of  Intergovernmental Relations
   Departrvsnt of  Con-.-aunity Affairs
fs  Project  Review ar.d  Corr.v.onts, SM:

-------
                       DEPARTMENT OE COMMUNITY  AFFAIRS
     REUBIN OU ASKEW. GOVERNOR

     WILLIAM H. RAVENELL, SECRETARY
                                          DIVISION OF TECHNICAL
                                              ASSISTANCE
                              MEMORANDUM
          DATE:  May  31,  1978

          TO   :  Loring Lovell,  Division of State Planning
          FROM:
John Sidor, Jr
t.
          SUBJ:  Draft Areawide Environmental Impact Statement
                 Central Florida Phosphate Industry (SAI #78-1763)
          This Environmental Impact Statement is. very well written
          and covers.some  key points.

          However,  from  the  angle of local government we would  like  to
          have more  information on the -impact the future mining and
          population growth  will have  on the provision of services
          such as water, sewer,  schools and recreation facilities.    I/
          The phosphate  industry has been helpful in other-areas in
          providing  certain  facilities, sometimes open to the public,
          sometimes  for  employees and families only.  Some indication
          of future  plans  would be helpful in evaluating the proposal.
           JS/mu
Diioctor.,. Local Government... Housing Assistance ... Planning & Research ... Community Development
•U'G-^G "    488-7??$           480-1536           488-235G              488-1536
                C571 Evecutivo Center Circle, East, Tallahassee,

-------
                         STATE  OF  FLORIDA

      ^DEPARTMkNT OF  HEALTH AND  REHABILITATIVE SERVICES

              PR\LOR NO •»>"""•••• ^  AND  REVIEW SYSTEM


                                      Date:    l/77?
MEMORANDUM

REF. NO: DHRS 	 SPDC  (SAI)      78-1763E

TITLE    Central Florida  Phosphate  Industry	;	

APPLICANT 	U.  S.  Environmental  Protection Agency	


TO:  Lt. Governor  J. H. Williams

     Attn:  Loring Lovell, Chief
            Bureau of Intergovernmental Relations


FROM:  William J.  Page, Jr.
       Department  of Health and Rehabilitative Services

       BY:  Office of Pu^iam Planning and Development

SUBJ:  NOTIFICATION OF INTENT TO APPLY FOR FEDERAL FUNDS

J   _lx-  The project is consistent with the goals and objectives of
1 >i    the Department of  Health and Rehabilitative Services.
       Favorable  action is recommended.

n       Substantive comments have been received and are summarized
      *in the attached.

       Conference  with applicant is requested.

       The project is not consistent with the goals and objectives
       of the Department  of Health and Rehabilitative Services.
       Approval  is not recommended for reasons described in  the
       attached.
D
Attachment (s)
                                    3 - f 2

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                            STATE or  FI,OHIJ>A

                                 of   Aftmhuisiratiott
              ro-1'"    ^Division of  State  Planning
                        660  Apalachco Parkway  • IBM Building
TO:
                              TALLAHASSEE
                                    32304
                              (904)  488-2371
                                         c
                                                                   Roubln O'D. Askew
                                                                        tOYU-Ol
                                                              M. Gov. J. H.-Jim' WillUmi
                                                                  ItCUtUT Or MWINIITIMIM
                                           R  E C
                                                           DATE
                                                               .  5- /-
         ^^^^                /  D .  •       MAY 2   1978
FROM:     Bureau of Intergovernmental Relations

SUBJECT:   SAI:   /O  / / V 5                 AHQRNEY GENERAL'S
                                                    CEEIQE

       The attached notification of intent to apply for federal assistance  is
being referred to your agency for review and comments.   Your review and comments
should address themselves to the extent to which the project is consistent  with
or contributes to the fulfillment of your agency's  plans or  the achievement of
yytf projects, programs and objectives.

       If further information is required, you are  urged to  telephone  the contact
person named on the notification.form.  If a conference seems necessary, or if
you wish  to review the entire application, contact  this office  by  telephone as
noon as possible.  If you have no adverse comments, you may  wish to report  such
by telephone.  Please check the appropriate box, attach any  comments on your
agency's  stationery, and return to 13IGR or telephone by the  above  date.  If we'
do not receive a response by the due date, we will  assume your  agency  has no
adverse comments.  In both telephone conversation and written correspondence,
please refer to the SAI number.

                                        Sincerely,
                                        Loring Love11,  Chief
                                        Bureau of Intergovernmental  Relations
 Enclosure
701       Bureau of Intergovernmental  Relations
»'ROM:
SUDOECT:  Project Review and Comments,  SAI:

          [yj No Comments

Signature:

    "•        i i fji* i i.i /L*\   t i f i si sft.'  ft  vi  i. \.f\_ i .
                    uV    wJl- 1 ^t
                                                {~"'~j Comments  Attached

-------
     STATE Of FLOHIDA

Srparlmrnr uf £tutr
       TUG CAPITOL
     TALUHASSEt 32304
   May 16,  1978
                                               ' L. ROSS MORRELL, ACTING DIRECTOR
                                                 DIVISION OF ARCHIVES, HISTORY. AND
                                                   • RECORDS MANAGEMENT

                                                      (904) 488-1480
                       IN REPLY REFER TO:
                                            Mr.  Louis D. Tesar
                                            Historic Sites Specialist
                                            (904) 487-2333

Mr. Loring Lovell, Chief
Bureau of Intergovernmental
  Relations
Division of State Planning
Room 530, Carlton Building
Tallahassee, Florida   32304

Re:  Clearing House Meeting
     SAI 78-1763
     Draft Areawide Environmental  Impact  Statement
     Central Florida Phosphate  Industry
     Charlotte, DeSoto, Hardee,  Hillsborough',
     Manatee, Polk and Sarasota Counties,  Florida

Dear Mr. Lovell:

     On May 11, 1978,  this agency's  representative, 'Mr. Louis
Tesar, attended a Clearinghouse Meeting  to review the Draft
Environment Impact Statement  on the  Central Florida Phosphate
Industry.  At that meeting Mr.  Tesar once again stated this
agency's concern that  archaeological and  historical site
remains, as non-renewable resources,  be  directly addressed
in any goals and requirements recommended by the United
States Environmental Protection Agency in the forthcoming
final EIS of the Central Florida Phosphate Industry.  To this
end, as requested at that meeting, we have prepared this
written response.

     We recognize, as  was repeatedly stated by the Environ-
mental Protection Agency's representative, Mr.  James MacNeill,
that this document is  being offered  only  as a working paper
with suggested guidelines, and  is  not considered as a final
                                            -183

-------
Mr. Loring Lovell,  Chief
May 16, 1978
Page Two


procedural document.   However, as was  stressed by several
other state agencies,  it is our concern  that this document,
promulgated under the auspices of the  United States Environmental
Protection Agency,  will take on the  aura of an official govern-
ment report and  repeatedly be returned to us as a base docu-
ment in the preparation of the by-project environmental impact
statements which it presumably is not  intended to supercede.

     We recognize and concur with the  statement on page 2.59
of the draft  under review:

          "Most Archeological sites are considered by archeolo-
     gists as  fragile and,  as such, wou*ld  be permanently altered
     or destroyed  if minded.  Florida's Division of Archives,
     History,  and  Records Management (1976) has expressed con-
     cern that valuable sites within the study area may be lost
     or may suffer irreversible damage; this agency maintains
     that the  effects will  occur on a regional  level and may
     result in the permanent loss of a sizable portion of Florida's
     archeological record.  Unless measures to collect and pre-
     serve the artifacts are taken before  mining,  the state
     office's  concerns will be valid."

However, we believe that these concerns  should also be
explicity presented in the "Goals and  Requirements" section
of the final  draft  of this EIS.

     As currently presented (see page  3.6 of Draft EIS),
it is assumed tha.t  most archaeological and historical sites
would be protected  through the indirect  method of protecting
water quality by recommending against  the use of Category I
waters.  While it is  true that most  of the presently known
archaeological and  historical sites  occur within Category I
areas,  it is  stressed that they are  by no means restricted
to su.ch areas.   For instance, on page  2.3 the W. R.  Grace
tract is used as an example.  We might point out that of
the five sites located in that tract the two considered
significant and  recommended for preservation or mitigation
through archaeological salvage excavation are both located
outside of Category I  wetlands.   One was located overlooking
the head of a small seepspring,  while  the other was located
on the edge of an upland ridge surrounding the lower prairie
wetlands.

-------
Mr. Loring Lovell, Chief
May 16, 1978
page Three


     It is for this reason we would suggest that, on page
1.72, following the discussion on the three categories of
wetlands,  a direct commitment for the need to conduct arch-
aeological and historical site assessment surveys, as well
as to avoid or mitigate significant site remains identified
as a result of such surveys should be presented.  The suggested
wording for this commitment might include the concepts embodied
in the following:

     It is recommended that the impact to archaeological
     and historical site resources be addressed in the
     project review procedure.  Early in the planning
     stage the Florida Division of Archives, History
     and Records Management should be contacted to
     determine whether or not proj'ect activities might
     impact any known or presently unknown archaeo-
     logical or historical site remains.  If necessary
     an archaeological or historical site assessment.
     survey should be conducted of the project area        Ut ~ /84-
     to locate and identify significant site remains.
     The resulting report should be submitted to the
     Florida Division of Archives, History and Records
     Management for review.  Efforts should be made
     to preserve through avoidance or mitigate through
     archaeological salvage excavation by a professionally
     competent agency any sites deemed significant.  If
     mitigation is chosen, the resulting report should
     be submitted to the Florida Division of Archives,
     Hisotry and Records Management for review and com-
     ment.  In this manner our nation will be assured
     that  its culturally valuable archaeological and
     historical resources are being properly managed
     and the information recorded for future generations.

     The opportunity to comment is appreciated.   If you have
any questions, please feel free to contact us.

     Your  interest and cooperation in protecting Florida's
irreplaceable historic resources are appreciated.
                               Sincerely,
                                         _ _
                               L. Ross"v7lbrrell
                               Deputy State Historic
                               Preservation Officer
LRMrTjw

cc:   Walt Kolb

-------
                                of
Whlllla.Jf.
 PIAKNIHO DIRECTOR
                    Division of State Planning

                      Room 530  Carlton Building

                          TALLAHASSEE
                               32304
                            (904)488-4925

                          May  22,  1978
Reubln O'D. Aik*w
GOVERNOR

Wallace W. Horxl*r«on
SECRETARY Of ADMINISTRATION
  MEMORANDUM
TO:
            Walt
  THROUGH:  James Ma-y^

  FROM      Jim McNeal
  SUBJECT:  SAI &78-1698E, Draft Areawide  Environmental Impact
            Statement, Central Florida  Phosphate .Industry
       The Bureau of Land and Water Management has reviewed the
  Draft Areawide EIS and submits  the  following observations.

       The mining of phosphate rock in  central Florida is a very
  energy intensive activity.. Even so,  this  document does not incor- (/J
  porate energy consumption  into  the  evaluation of the various de-
  velopment scenarios.

       Elimination of the rock drying process  would reduce the demand
  for electricity by the industry.  This  reduction should be con-           .
  trasted to the increased, energy use to  transport the wet rock to   \/J~lo(*r
  chemical plants.  Mining operations which  ship rock outside Florida
  for chemical processing may be  excused  from  this requirement but
  will be 'afforded an energy evaluation.

       Since this process modification  is the  only proposal which will
  affect air quality, exceptions  should be limited to environmental   Lj-/8~7
  or climatic factors; not to include whether  a plant is capable of
  receiving wet rock.

       Recovery of fluoride  from  recirculated  process water should be
  encouraged by recognizing  fluoride  as a pollutant and not singularly
  by the economics of the process.  Reported costs of fluoride re-
  covery operations exceed prices by  25 to 36  percent but fluoride
  emissions remain an important air pollutant.  Fluoride escapes from
  9VP ponds and should be included in calculating fluoride emissions
  from the complex.  Such emissions are reduced by the recovery of
  fluoride from recirculated process  water,  including scrubber water.

-------
          Kolb
flay 22,  1973
page 2
Thus, such recovery could be viewed to accomplish some functions of
a pollution control device.

     At the time of this draft,  the groundwater model could only
project water level effects to the Floridan Aquifer from the phos-
phate industry.   Presently the model can incorporate the effects
from other industrial,  agricultural and municipal uses.  Incor-   ^J
porating these demands  in concsrt with those of the phosphate in-
dustry would present a  more realistic evaluation of the cumulative
stresses on the groundwater aquifer, which does not discriminate
water pumpage by use.   The final EIS should utilize this advance-
ment of the model in evaluating the proposed action.  We would also
like to know if EPA intends to develop guidelines for water with-
drawals for phosphate mines in central Florida.

     From discussion in the report, placing top soil dressing over
mined areas appears to  be a significant act of reclamation relative
to achieving low final  background radiation levels.  However, in   \^
discussion this idea was not considered significantly effective.
Does the lead agency consider this action worthwhile to pursue in
reclamation efforts?

     A major conclusion in the report that technology does not pro-
vide for restoring freshwater wetlands or forest types'to their native
condition on mined land neads to be more specifically addressed.  A-
greed the deep sand soils necessary for mixed forests, and the hy-   Id-
drology and drainage patterns in wetlands are difficult to re-create.
Howevor, restoration of these lands to support similar communities and
perform the essential  functions of these environments is possible,
and certainly should be encouraged.

     The steep-sided,  relatively deep lakes now predominating in re-
claimed land were stated to be of little long-term value.  This Bureau
would like to be appraised of any recommended alternative designs and
limiting, depths to consider, in view of the climate in west-central iJ-1
Florida, to promote improved water quality.

     Industry sponsored' research at test sites has developed some im-
proved methods for' slime disposal and subsequent reclamation of these
areas.  While we have  seen few determined field efforts toward the.
near future elimination of slime ponds, we fully support efforts to
modify the conventional slime disposal method and maintain above-
ground storage to an absolute minimum.  These efforts will become f^J~ I
more important in daily operations as the richer deposits in Polk
County are depleted and the industry extends into Hardee, DeSoto,
and Manatee Counties.   Here, the matrix is a much lower grade and
when mined will send a  higher percentage of the matrix to flotation
nulls and generate increased amounts of slime waste.

-------
MKMO-Walt Kolb
May 22, 1978
Page 3
     Our final comment is that a display projecting anticipated
events, maybe in 5 year increments, would assist visualizing the
cumulative impact to the region; i.e., Floridan Aquifer potentio-
metric surface maps, wetlands coverage, etc.  We could then follow
the progressive changes by comparing such maps from the past to the
present.  Perhaps we could also recognize-undesirable events progress-
ing into the future as well and establish limits for the alteration
of present conditions.

     We recognize the monumental and complex issues inherent to the
Central Florida Phosphate District and congratulate the EPA on this
effort in defining the environmental issues.


JM/lw

-------
                    South  Florida
                                                                 JOHN R, MALOY, Cxocutivo Director
                              Water Mancasment District
JKEPLYREFER TO:   9-109-A
                       POST OFFICE BOX V, WEST PALM BEACH. FLORIDA, 33402


                                               TELEPHONE 305-686-8800


                                            3A
        Mr.  Loring Lovell, Chief
        Bureau of Intergovernmental Relations
        Division of State Planning
        Department of Administration
        660  Apalachee Parkway-IBM Building
        Tallahassee, Florida  32304
                                                                 DIVISION OF'STATE PANNING.
                                                                        Bureau Of
                                                                             il Relations
                                                 MAY 23 1878

                                                   RECEIVED
                                             SW NO.
        Rt:  SAI: 78-1763
        Dear  Loring:
     Draft Areawide Environmental. Impact Statement
     Central Florida Phosphate Industry
        We have completed our review of the above referenced draft and offer the
        following comments,

        -  Planned v/ater conservation practices as described in the document, which
          essentially consist of recirculation and reuse of water, will  very substan-
          tially reduce the demands for v/ater as compared to existing and especially
          as compared to past practices.  Thus, impact on potentiometric heads in
          the Floridan aquifer is'expected to be reduced.

        -  Potentiometric heads referred to above  will be the only impact that may
          affect the SFWMD.  Pumpage from the Floridan aquifer for use in phosphate
          mining and benefaction may create declines in potentiometric heads extend-
          ing into the SFWMD.  These impacts are in addition to head declines
          occasioned by citrus industries' use.  It is suggested that because these
          declines are anticipated to be minimal, no substantive changes are
          anticipated.

        -  In overall content, the EIS was put together very well, detailed and
          rather thoroughly documented.
   M f «t liudeidftl*.


   J n Si«,,tl
    U H.ll,
  Dr. John M. DoGrove

Vic* Chairman • Boca Raton
   R. Hardy Mathoton
       Miami
                      C. A. Thomaj
                       Lake Harbor
Robert W. Padrick

   Fort Piorce
                       Ben Shopard         Stanley Holo

                        Hinloali   ?-/_?_?  Naplot

Fornuvly Central ;mcl Southern FlotUl.i riooc! Control Distrirt
W. J. Scaiborough
  Lake Placid


Maurice L. Plummer
   r-t.Myorj

-------
9-109-A
Mr.  Loring Lovell
May 18, 1978
Page -2-


We appreciate this opportunity to review the draft and do hereby  request
that v/e be sent a copy of the final  EIS.

                                   Sincerely,


                                             <  ft.ft/fatstjflj,

                                   SUSAN M. McCORMICK, Director           ^
                                   Land Resources Division
                                   Resource Planning Department

SMMsbhm

-------
                i Southwest Florida Regional  Pi'ffvuunf* .Council
               2121 West First Street, Fort Myers, Florid\3GJ01  of\  >•
                                                             \~  (813) 334-7332
Mr. Loring Lovell,  Chief
Bureau of Intergovernmental Relations
Division of State Planning
Department of Administration
530 Carlton Building
Tallahassee,  Florida 32304

RE:  OMB A-95 Clearinghouse Review of the "Draft EIS for Central Florida.
     Phosphate Industry," SAI 78-1698E (RFC #78-143).
Dear Mr.  Lovell:
                                         June 16, 1978
At the June 15,  1978, meeting of the SWFRPC, the Council officially
endorsed the enclosed staff review and recommendations on the above-
referenced draft EIS.  In addition to this enclosure, please find the
official comments of Sarasota County; a local government impacted by
the Central Florida Phosphate Industry.  The receipt of any additional
comments from other affected local governments or interested parties
will be forwarded immediately.  If you have any questions concerning
the attached material, please do not hesitate to contact us.

Sincerely,
SOUTHWEST FLORID? REGIONAL PLANNING COUNCIL
Plan
E. Daltry
ng Director
WED/RSC/naf

cc:  V7alter Kolb, Comprehensive Planning
     Mr. James Duane, Executive Director, Central Florida RPC
     Mr. Scott Wilson, Executive Director, Tampa Bay RPC

Enclosures

-------
                        Southv/cr.t  Florida Region A I  Planning Council
                        *.. ^^^^^^r^^r—-7--,--r-,-^                        *^/^T?^^'"'%^7rcwi^j^yr»v'»'nr*^^rr'^'**-
'->   _         I <\Y    2121 Wnst First Street, Fort Myers, Florida 33901                       (813)3^1-7382
XA
       Mr.  Loring Lovell, Chief
       Bureau of Intergovernmental Relations
       Division of State Planning
       Department of Administration
       .530  Carlton Building
       Tallahassee,  Florida 32304
       RE:   OMB A-95 Clearinghouse Review of the  "Draft  EIS  for Central Florida
            Phosphate Industry," SAI 78-1698E  (RFC  #78-143).
       Dear Mr.  Lovell:
June 16, 1978
       At the June 15, 1978, meeting of the SWFRPC, the Council  officially
       endorsed the enclosed staff review and recommendations  on the above-
       referenced draft EIS.  In addition to this enclosure, please find the
       official comments of Sarasota County; a  local government  impacted by
       the Central Florida Phosphate Industry.  The receipt of any additional
       comments from other affected local governments or  interested parties
       will be forwarded immediately.  If you have any questions concerning
       the attached material, please do not hesitate to contact  us.

       Sincerely,
       SOUTHWEST FLORIDA REGIONAL PLANNING COUNCIL
       *ayne/E.  Daltry
       Planning Director

       WED/RSC/naf
       cc: v^VJalter Kolb, Comprehensive Planning
            Mr.  James Duane, Executive Director,  Central  Florida RPC
            Mr.  Scott Wilson, Executive Director,  Tampa Bay RPC
       Enclosures

-------
                      COUNTY  OF   SARASOTA
                               F  I  O R I  0 A
                 BOAR n   OF    COMMISSIONERS
                 BEVERLY CLAV • Of.miCT ?

                 JAME5 f> HfViLLF ' DISTRICT 3


                 LAMRY RHODES ' 111 STRICT 5
p o. BOX n
SXWA&OTA. fLA 3357H
PHONE 013/3-55 IOOO
June 14, 1978
Mr. Roland H. Eastwood
Southwest Florida Regional Planning Council
2121 West First Street
Ft. Myers, Florida 33901

Re:  Draft Environmental Impact Statement,
     Central Florida Phosphate Industry

Dear Mr.  Eastwood:

This letter is being submitted in response to  your  May 16,  1978,
request for comments in accordance with OMB  Circular  A-95.   Our anal-
ysis of the above cited environmental  impact statement and,  in par-
ticular,  its Proposed Action component, has  occurred  primarily within
the context of existing and evolving plans,  programs, policies and
objectives of Sarasota County.

The comments which follow have not been confined, however,  to simply
the direct impacts that the Central Florida  phosphate industry has
solely on Sarasota County-  A number of broader  based comments are
included within our analysis due to two highly interrelated factors.
First, the magnitude of the geographic, environmental, economic,
political and social impacts of the Central  Florida phosphate industry
or any industry which mines non-renewable natural resources (e.g. oil,
Ras, coal, bauxite, phosphate and iron) cannot be confined to the
locality within which the physical mining actually  occurs.   Second,
Sarasota County is affected by the policies  and  actions  embraced by
those outside of its area of legislative authority.  West Central
Florida watersheds and airsheds, for example,  recognize  only air-
pressure and land gradients rather than county line markers when trans-
porting the acids, flourides, and radioactive  contaminants produced
by the Central Florida phosphate industry.

1.   SINCE THE EXIST ING ECONOMIC FIBl-R _ 0 F_ SA RASOTj\_ COUNTY IS BAS ED
     PRIMARILY UPON! MAINTAIN' 1 N'GjnjH ENV'lROXMliNTAT. QUALITY j3F_THlT
     AREA, Till- LliC: n^.XjJVT^lTfAllJillSirn'  01-' j(Aj(ASOT7v__c:.0_U_NT\'_iIAS BH_i:"N
     TOTALLY COMMI'TTIil.) TO I'lTl: "rRHSLRVATlON AN'h CONSF.RVAT ION 01-' THAT
     liiN!VJROi\'Ml!\T.  This-commitment is  documented, in  part,  by the

-------
June 14, iy/8
 following ordinances,  resolutions,  and  research  which  have  been  or
 uill soon he  enacted  by  the  Board  of  County  Commissioners:

     Ord intincc  No.  72- 3_7_ addresses  the  control and  regulation  of
     air and  water  po.lJut.ion throughout Sarasota County  providing
     for stricter,  more  extensive,  and  more  stringent  regulation
     of pollution  than provided  Tor by  the State of  l-'lorida.
     (Adopted 9/L9/72).

     Ordinance  No.  72-83 determines that  the unregulated mining
     of phosphate  and other  similar and related  minerals has a
     detrimental  effect  on the health,  welfare and property
     rights of  the  citizen of Sarasota  County, and providing
     for regulation of phosphate and  similar mining  processes
     and the  reclamation of  lands  used  in mining.  (Adopted  10/17/72).

     Ordinance  No.  75-18 relates to the conservation of  water  during
     emergency  drought conditions  and authorizes the Board  of  County
     Commissioners  to limit  water  use in  case of emergency.
      (Adopted 6/26/73) .

     Ordinance  No.  75-38 establishes  zoning  regulations  for unincor-
     porated  Sarasota County replacing  earlier zoning  regulations
     and provides  for open use conservation  districts  and marine
     park  districts.   (Adopted 10/7/75).

     Ordinance  No.  75-47 authorizes the expenditure  of public  funds
     Tor  the  protection  of the natural  resources and scenic beauty
     of Sarasota  County  and  for  the abatement of air and water pollution
     which may result from existing,  pending and proposed phosphate
     mining projects.  (Adopted  1/6/76).

     Ordinance No.  76-40 amends  Ordinance No. 74-33  and  provides
      subdivision  regulations for unincorporated  Sarasota County.
      (Adopted 6/22/76).

     Ordinance No.  78-13 determines the environmental  importance
     of trees and prohibits  the  removal of protected trees  without
      a permit.  (Adopted  5/23/7S).

      Ordinance No.  78-18 expresses doubt as  to adequacies of  available
      water supplies to support  existing and  proposed growth in the
      Sarasota County area and the  surrounding region,  provides for  a
      six-month deferral  of all  rezoning applications which  would
      increase water supply  demands, and authorizes  an  intensive  study
      of water supplies.   (Adopted  3/7/78).

      Ordinance No.	7S_-_5_3 regulates borrow pits and  other excavations
      "fn~ unincorporated Sarasota  County.  (Adopted  6/6/78).

      Ordinance No.  78-55 relates to endangered lands,  provides for
      tTTc c!Tt~riTiTs"hiiicnt of an Hndangcred Lands Advisory Hoard  to  make
      recommendations to  the  Hoard  of  County  Commissioners concerning
      the identification, protection,  preservation,  enhancement a.nd
      management of_endangered lands.  (Adopted 6/13/78).

-------
Ho land II.  llastwood
.him: .14,  li)78
I'ii'.c 3 -
     3959j-^.t !-°I? 72-I-P. <
-------
Roland II. lias Lwood
June 14, 1978
I1 a go 3


     Rc.s_oljJ_t_ip_n_ 7_2_-_9 authorizes the Sarasota County Attorney to take
     a]l necessary action to participate, join, or intervene in the
     State of Florida's    iyation against Cities Service Company in
     reference  to phosphate  pollution of the Peace River.  (Adopted
     1/18/72).

     Resolution No. 75-58 pledges support to the Red Flag Charrctte's
     Plan to identify, inventory, and evaluate the existing natural
     and human,  resources of Sarasota County.  (Adopted 2/15/73).

     Resolution 75-171 determines the importance of the Gulf of
     Mexico to marine life, tourism, and conservation and requests
     the U.  S.  Department of the Interior not to grant leases for
     offshore oil drilling.  (Adopted 10/14/73).

     Resolution 75-255 endorses the Tampa Bay Regional Planning
     Council's  Water-Qr.r."!:ty Management Plan.  (Adopted 11/8/73).

     Resolution 74-67 adopts amendments to the Sarasota County Compre-
     hensive Plan including Environmental Limitations I.  (Adopted
     4/2/74).

     Resolution 74-.S5 prohibits the use.of water for out-of-door
     residential use during emergency drought conditions.
     (Adopted 5/2/74).

     Resolution 74-84 requests  the cooperation of the municipalities
     within Sarasota County as  well as surrounding counties in in-
     stituting  water conservation measures.  (Adopted 5/2/74).

     •Resolution 74-86 determines that an emergency drought condition
     exists,declares Sarasota  County an emergency drought area,
     and restricts the use of water.  (Adopted 5/7/74).

     Resolution 74-255 indicates intent to join with other units
     o~f government in Southwest Florida to develop a "208" plan
     pursuant to the  Federal Water Pollution Control Act Amendment of
     1972.   (Adopted  12/10/74).

     Resolution 75-44 adopts the Sarasota County Land Use Plan as
     an amendment to  the Sarasota County Comprehensive Plan including
     the following policies:

            Policy 10  - Full consideration should he given environ-
            mental factors within Sarasota County as they pertain
            to land use.

                 C.   Land and waters determined by the Environ-
                      mental F.lement to be of general environ-
                      mental value should be conserved, while
                      those  lands and waters determined to be
                      specific critical value should be preserved.

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June 14,  1978
Page 4
           Policy 11.   Recognizing  Agriculture  as  an  important and
           necessary  activity  within  Florida  and Sarasota County,
           adequate and appropriate land  should be reserved for its
           continuance.   (Adopted  3/13/75).

     Resolution  75-2.11  endorses  the Charlotte Harbor  Ecosystem Complex
     "alT an Area  of~ Critical  State  Concern under Chapter  380 Florida
     Statutes.   (Adopted 10/14/75).

     Resolution  75-223  requests  all federal,  state, and  local agencies
     and departments  to adopt  a  moratorium on all  actions which would
     facilitate  the initiation of  new phosphate projects until a study
     of the environmental,economic, and public  health hazards can be
     completed and analyzed.   (Adopted 10/14/75).

     Resolution  75-274  recommends  that Congressman L.  A.  "Skip" Bafalis
     introduce legislation in  the  United  States Congress to designate
     the Myakka  Riveras aV.'ild and  Scenic River.   (Adopted 12/16/75).

     Resolution  77-51 accepts  the  concepts and  recommendations contained
     in a 201 Facilities Plan  prepared for Sarasota County.  (Adopted
     2/8/77).

     Resolution  77-155  requests  the Region IV,  EPA Administrator to
     3e'terininc that the Bcker  Phosphate mining  project in Manatee
     County be processed as  a  new  pollution source requiring an EIS.
     (Adopted 8/9/77).

     Resolution  77-165  urges the U. S. Environmental  Protection Agency
     to adopt new source standards  as applicable to phosphate rock
     mining in accordance  with Section 306(b) of the  Federal Water
    •Pollution Control  Act.   (Adopted 9/16/77).

     Resolution  77-198  urges the Manatee  County Commission not to
     approve the IV. R.  Grace "Four  Corners" phosphate mining project,
     and to approve no  more  phosphate mining projects until completion
     of:

           1) The United  States Enviornmental  Protection Agency
              Environmental Impact Study (EIS) and the  adoption of
              any regulations called for in the EIS;

           2) All EIS's required  under the National  Environmental
              Policy Act  for  approved phosphate mining  projects in
              Manatee  County; and

           3) All approved  permitting of at least, one approved
              phosphate mine  in Manatee  County together with a com-
              plete  assessment  of the mining experience of such
              a project.   (Adopted 10/4/77).

-------
Koiaiui II.  lia stwotnl
June 14,  1978
Pa (jo 5 -
     Resolut i on _7^7_-_2n_S_ establishes a joint citizens linergy Advisory
     Hoard to" do "torn i nc the implementation of the National Energy
     Conservation Program and State Energy Laws.  (Adopted 10/11/77).

     Resolution 77-JAG' Determines tlic need for protection against
     significant degradation of air quality and urges the Florida
     Environmental. Regulation Commission to adopt the proposed
     revisions of the Significant Deterioration Rule, Section 17-2.02
     and 17-2.05(1)), Florida Administrative Code with certain modifi-
     cation including:
           1)
           2)
Class I designation be applied to the
State of Florida; or
entire
As a minimum Class.I designation be applied
to Sarasota County.
      (Adopted 11/29/77).

     Resolution 78-10 requests the Southwest Florida Water Managc-
     mcnt District to complete a study identifying dependable long-
     term sources of water for public, agricultural, and industrial
     use.   (Adopted 1/24/78).

     Resolution 78-59 establishes an energy policy for Sarasota
     County.  (Aclopted 3/21/78).

     Resolution 78-73 adopts the Overall Economic Development
     Program for Sarasota County including the following objective:

           Objective 1 - Ensure the conservation of those
           natural resources which are non-renewable and
           which represent the foundation of the County's
           retirement and recreation oriented economy.

     (Adopted 4/11/78).

     Resolution 78-100 authorizes a cost/benefit analysis be per-
     formed by the University of Florida as recommended by the
     Department of Planning's report, The Growth Management Con-
     cept and a Description of Specif icTTccimiques. (Aclopted 5/23/78) .

     December 9, 1975, Sarasota County Department of Planning authorized
     to draft an ordinance relating to stream protection and related
     regulations with regard to the water quality of the Myakka River.

     October 25, 1977, Sarasota County Department of Planning authorized
     to draft a flood plain protection ordinance.

     January 17, 1978, Funding authorized for joint University of
     Florida - Sarasota County Special 'Issues Project to study energy
     flow and growth management.

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UoJand II.  Hastwood
June 14, 1978
Page 6 -
                   I^MnSTni.'NTni;i)  iY Till- P.TR ART! .NOT AOiiQUATl'LY
                          _
                    -"-    "''  ^-TTo.\'' Ai\ I) ACCORD I NCT.Y c:T).\'l:'L L'CT
     A.   Land surface will be altered by surface mining and reclama-
         tion;  soils and vegetation removed from the mining and      ^/~
         associated areas; wildlife habitat and populations reduced;
         and there \vi\\- ,u?. notential adverse impacts on air and water
         quality.      * "  '

     B.   Recreational resources will be reduced, archeologic values
         may be destroyed and esthetic aspects will change.
            w
     C.   Redistribution of radionuclides , which result in an increase
         of human exposure, will occur.

     D.   The quant it"' •*;-,•' > •".• •• nble groundwatcr will be reduced.
                    "*'•'                                         1*/
     The primary shortcoming of the environmental modifications proposed
     by the HIS is their limited application to only new source phosphate
     operations.

     Alterations cause ' / : ..mining, .to the land surface are not mitigated
     in any manner by the Proposed Action because it assumes the con-
     tinued permitting of all new mines as proposed by the industry's
     Scenario (2. 11').  The modifications proposed to mitigate the
     environmental 'impact,, of, slime ponds may have some effect on the
     reduction of reclctwaVl'6n time, however, it is only applied to  k
     new sources,  thus allowing existing operations to persist in
     the use of above surface slime ponds.. Allowing 'the creation''
     of new slime ponds increases the potential threat to surface water
     systems.

     Specific reference is made to mitigating effects of phosphate
     operations on wetlands  (Scenario 2.14).  However, even if mining  i's
     prohibited in wetlands because of their identified value as        .,
     wildlife habits as well as their general aesthetic and ecological **/~
     importance to the region, increased mining permitted in the vicinity
     of protected wetlands is bound to have a negative impact upon  their'
     existence.

     An important limitation relating to the mitigating effects of
     the Proposed Action^as related to air and water quality and  the ij
     increase of human^' V"-.
-------
i'olnncl II. I'.astKood
June 14, 1978
I\MJC 7 -
     Proposed Action on  future grouiuluatcr  supplies  in  the  region
     Therefore, t!>e failure of the proposed action  to adequately
     mitigate these adverse environmental impacts conflicts  with
     many of the previously cited goals, nolicjcs,  plans  and
     programs of Sarasota  County  included in the  ColJowing:
Ordinance
Ordinance
Ordinance
Ordinance
Ordinance
Ordinance
Ordinance
No.
No.
No.
No.
No.
No.
No.
72-37
72-83
75-18
75-47
•78-13
78-18
78-55
Resolution
Resolution
Resolution
Resolution
Resolution
Resolution
Resolution
Resolution
Resolution
Resolution
Resolution
Resolution
No.
No.
No.
No.
No.
No.
No.
No.
No.
No.
No.
No.
72
74
74
74
75
75
75
77
77
77
77
78
-9
-83
-84
-86
-44
-233
-274
-155
-165
-198
-236
-10
                        Resolution  No.  78-73

 3.   THE  IMPACT  OF  PHOSPHATE  MINING  ON Till- MYAKKA  RIVI-n  IS NOT
     Al)'DRl-SSlil) BY Till'  DRAFT KIS:  INDHED,  IT  IS  HARDLY  M1-NTION1-D.

     The  failure of the Draft F,IS  to address  the potential impact of
     phosphate mining  upon  the Myakka River  and its  flood plain is of
     special  concern.   Roth the adopted Sarasota County  Land Use  Plan
     and  Environmental Limitation  I  have~~idcnti f ied~Thc  Myakka River
     System  as a conservation and  preservation  area.   Numerous reports
     have indicated that the  Myakka  River System serves  as a habitat
     for  endangered species and is a potential  source  of potable  water,
     The  national,  as  veil  as regional, significance  of  the Myakka
     has  been recognized by United States House of Representatives,
     Committee on  Interior  and Insular Affairs  which  is  considering
     • including the  river for  study as a potential  part of the Federal
     Wild and Scenic River  Program.

     Since several  of the phosphate  mines included in  Scenario 2.11
     and  the Proposed  Action  of the  Draft HIS plan to  mine within
     the  Myakka's watershed,  the failure of  the Draft  HIS to address
     the  impact  of  mining upon the Myakka River is a  severe oversight.

-------
.June 14,  1978
     S
     T|iiMMAFT_r-is SHOULD Aj)mu;_ss Tin- i.ow; ;niRMJlc_oNOM[(:  ''-'"ACT oi:
     :|'iiRll"l):''r|"i               ^''^           "
     TjTf "recent history should not bo ignored.  The petroleum  crises
     of 1974 and the continuing OI'I-C man i [>ulat ions on tlic price  of
     oil imported h>" the United States should alert us to the danger
     of becoming dependent, upon a foreign cartel for as vital a  resource
     as phosphate.   In 1976, the activities of the Central  Florida
     phosphate area accounted for thirty- three percent of v.orld
     production.  However, current Florida phosphate reserves arc  less
     than six percent of the measured economically recoverable world
     reserves and the estimated sub -economic phosphate resources  in
     Florida arc only two percent of the world total.                     .

     The implications of the above statistics are ominous.  As stated
     in the Draft CIS, the United States demand for phosphate "would
     likely exceed domestic supply before the year 2010. 1"  The rapid
     depletion of the Central Florida phosphate supplies resulting
     in dependence upon foreign supplies of phosphate to sustain
     agricultural production could have profound, adverse economic and
     environmental impacts upon not only this region, but the  entire
     nation.  The failure of the Draft EIS to address these long-term
     impacts of expanded mining activity is in conflict with  the  devel
     opmcnt policy of Sarasota County (Policy 11 of the Land  Use  Plan)
     and should be addressed as a major national policy question,
     as well .  Proper attention to the economic impact of the rapid
     depletion of domestic phosphate supplies might well support  a
     limitation on the expansion of mining activity and the development
     of a national policy regulating the export of this strategically
     valuable and finite -natural resource.


     T I IE DRAFT i:IS Q ITS PROPOSED ACTION 0? IIT PROPOSED MINING
     ACT I V I T 1 1 j S W M ICH WIU/XD   QJl'MJ^ .^J'MM '-' L AT I V 13 IMPACT OF THE  INDUS-
     T_KY. The Proposed Action assesses the ctr.'ects of only  those  phosphate
     mining and processing activities permitted prior to August  1,  1976
     (Scenario 2.19) and those mines for which DRI applications  had
     been made prior to August 1, 1976 (Scenario 2.11).  There  arc  at
     least thirteen additional mine proposals identified by the  phosphate
     industry's view (2.11') but these mines are not incorporated into
     Scenario 2.11, except, apparently, only to assess  the  effects
     that future mining will have on water quantity.  The  impact,  of
     such expected expansion by the phosphate industry  (i.e.,  "the  (sJ~2-0
     industry's view", 2.11') is not fully assessed.  Although- the
     Proposed Action suggests a.number of process modifications  for
     new sources, the mitigating effects of such measures  cannot  be
     adequately assessed unless all potentially new  sources arc  included.
     The findings of the HIS arc incomplete regarding the  long term
     effect of phosphate activities on the region.


    I
     U.S. 1-nvi ronmcntnl Protection Agency, D r a f t A r en j^'uk:  F. n v_i_r_o \\rno jitjU,
     Jjn p a c t: jS t a t e HUM i t_ - C c_nj_r_a 1_ n_q r i da PJ 10 .^ nji a t" e__ _Tnj3u_s t/r_y" (1\ t L a "n't "a ,  (la. :
     H.sT'linvir'onmcMUa'l'T'rotec't Ion Agency, Region  IV,  1978) p.ii.

-------
kolaiul II. Ha^twood
Juno 1-1, L97S
I'a/'.e <>
     Tiin(:ii;!Min,ATTvr._T_MP,\CT_p!-  m-GRADA/noN  or  WATI;ROUAUTY
                                     '
     Tin: ni;.\7: i'_T; Cs jU'D_ niT_ £fn;i rsiTn  u i'\j'N_jj'Y''~A>: y " s'mi's noli HN;r"s~i TH
     Sl'lfC [1:J_CT H_I_S.  The effects  of  the  phospha to "i ud~ulftry on water
     quality  is almost ignored  in  the KIS  as  dra(. ted.   Suggested
     improvements arc  limited  to a modification  of  slime disposal
     procedures and recommended  reductions in  effluent concentrations
     for new  source chemical plants.  It  is the  contention of the
     authors  of the Draft HIS  that  EPA  "has no direct  legal  authority
     to change requirements  for  existing  sources".   Even if  it were
     •assumed  that this statement were correct, the  Draft EIS should
     address  the communitative  impact of  the  industry  on radiation
     exposure and water quality  in  order  to enable  the appropriate
     federal, state and local  governmental authorities to determine
     whether  additional legal  authority should be  granted over
     existing sources.

     The HIS  lists four potential  pathways for secondary impacts
     of radiation exposures:

         Air  contamination by  radionuclides associated with
         dust created  when dry  phosphate  rock  and  phosphate
         products are  transferred.

         Possible contamination  of ground  waters by seepage
         of process waters at  the  chemical plants  and  slime-
         pond waters in the  mine areas

         Radon- 222 daughter-product  contamination  of air in
         structures built on land  previously  mined  by  the
         industry

         Consumption of foods  (crop  foods  or  beef)  produced
         on reclaimed
     However,  on  page  2.64  of  the  Draft 1ZIS,  it is stated that

         Quantifying  impacts on the general population by      \AJ.~  *
         exposure associated with  the pathways just listed
         was considered  beyond the scope of this program.

     In  light  of  the  failure of the Draft HIS to quantify the impacts
     of  increased radiation exposure, the Draft I/. IS. should clearly
     stress  the need  to  quantify radiation impacts in any subsequent
     si te- spec i fie HIS.
      21 Mil. ,  p.2.(«.v.

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Koland II.  Hastwood
June I'!, 15)78
I'IIP.C- Id-
Ill siiPiiiia i1)',,  accclcrntcd phosph.'ito mining under  the  Proposed Action
will Increase already inflated land values, deplete  non-renewable
resources, and further reduce the amount of land  in  agricultural
production.   Adverse environmental damage  including  despoiled
landscape; or incompatible land usage would unfavorably  impact
our mill timillion dollar tourist/recreation  industry.   It is obvious
that such impacts whicl'. are not adequately mitigated  by  the Draft
1:1 S Proposed Action are not in compliance with  even  the  broadest
goals, objectives, programs and plans, of our community.
Sincerely,
Douglas/James r Director
Sarasota County Department of Planning
20S6 Main Street
Sarasota, Florida  33577

l)J:DW:RD/ms

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c\ A/
OVV
                                                      IT p D p' e  pen r i A
                                                    V i  I \i  Vv o  \.n  i  ;.,-!)• i.
                                                      % AGENDA  ITEM 6     •;'
                                                      '\Jiivli'viiLl» Mi_/ri i iwi
                        CENTRAL FLORIDA  PHOSPHATE  EIS
                               (Staff Review)
The U.S.  Environmental Protection  Agency (EPA)'  has prepared and  submitted a
Draft Areav.'ide Environmental Impact Statement on  the Central Flordia  Phosphate
Industry  (EIS)  for state and areawide  OMB  A-95  Clearinghouse review.   The Draft
EIS analyzed the impacts associated with the Central Florida Phosphate industry
under several different Scenarios  or alternatives.  These  alternatives included
the permitting of existing mining  activities only (Scenario 2.15) ,  the permitting
of existing as well as New Sources_(Scenario 2.11), process modifications
(Scenario 2.12), required Reduced  Water  Usage  (Scenario  2.13), and  controlling
activities in U.S. waters and wetlands (Scenario  2.14).  The final  Proposed
Action alternative identified in the EIS results  from  the  combination of Scenarios
2.11, 2.12, 2.13, and"2.14.  The Proposed  Action  will  only affect New Source
operations, while allowing existing mine activities to continue  in  their present
manner.  The Council staff's review of the draft  EIS Action leads to  the con-
clusion that the selected Proposed Action  will  do little towards  minimizing  the
many negative impacts associated with  the  phosphate industry in  Central
Florida.   Further, the staff review finds  that  the proposed action  does not
encourage the wisa management of phosphate reserves and  resources of  the State
of Florida.

                            STAFF  RECOMMENDATION

1)  The selected Proposed Action,  if adopted, should be  made applicable to
     existing, as well as any proposed New Source, mining  operations.       I/J ~

In order to finalize the draft EIS and prior to adoption of any  particular  Proposed
Action, the EPA should develop a new scenario based on recognition  of the following
criteria:

(A)  The phosphate resources should be analyzed as a finite resource  of national
      importance.  As such, a new  alternative should be  developed on  the premise
      that this resource should be wisely  managed to insure the  longest term
      benefit that can be provided in  the  following four categories:
                                                                             LJ-2
      1)   Stabilizing fertilizer prices;                                     *~^
      2)   Ensuring stable employment and constant levels of tax  revenues;
      3)   Stabilizing local and regional economic activity;
      4)   Preventing the need to import  phosphate in order to  protect the
           nation's balance of payments.

(b)  The EIS should also address the short- and long-term  environmental impacts
      associated with this scenario.                                          .
                                                                            k/

RECOMMENDED ACTION:  Endorse staff review; recommend and authorize  Executive
                     Director to forward these  recommendations to  the appropriate
                     agencies.

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                           Introduction
On March 17,  1978,  the United States Environmental Protection Agency
(EPA) submitted a Draft Areawide Environmental Impact Statement  (EIS)
on the Central Florida Phosphate Industry to State and areawide OMB
A-95 Clearinghouse  review.  The purpose of the Areawide EIS is to
assess the areawide and cumulative effects of the phosphate industry
and to provide the  basis for developing site specific EIS's for
"New Source"  NPDES* mining activities (those not permitted to date) .

According to  the draft EIS,,there are currently seventeen potential
New Source mines in Polk, Hillsborough,  Manatee, Hardee and Desoto
Counties.  The study area identified in the EIS includes those
counties indicated  above, as well as Sarasota and Charlotte Counties.
Although no mining  activities are identified or proposed in Sarasota
and Charlotte Counties, these counties were modeled because phosphate
recovery practices  will have an impact on their water quantity and
quality.

According to  the EIS,  there are approximately 2500 million metric
(short)  tons  of economically recoverable phosphate ore in the U.S.
or approximately 14% of the world reserve supply-  In the Central
Florida Phosphate District, economically recoverable reserves are
estimated at  1,037-million metric (short)  tons or approximately 41%
of the U.S. supply  and 6% of the world supply.  The document also
notes that in 1976, U.S. phosphate production accounted for 41%
of the world's production.  The Central  Florida district by itself.
produced 80%  of the United State's production and 33% of the world
production.  The EIS indicates that National levels of production
are expected  to increase with the Central Florida Phosphate District
represented as a major contributor to this production.

The major impacts resulting from existing and continued phosphate
mining in Central Florida are:

     (a)  Land surface will be altered by surface mining and
          reclamation;  soils and vegetation will be removed
          from the  mining and associated areas;  wildlife habitat
          and populations will be reduced; and there will be
          potential adverse impacts on air and water quality.

     (b)  Livestock forage will be reduced during mining operations,
          and productivity of the mining area will be reduced
          even after reclamation.

     (c)  Population and employment in the Region will increase,
          but the socioeconomic infrastructure will receive
          stress.

     (d)  Recreational  resources will be reduced, archeologic
          sites may be  destroyed, and esthetic aspects will change.


 National Pollution Discharge Elimination System (NPDES)

-------
       (e)  Redistribution of radionuclides, which result  in  an
            increase of human exposure, will occur.

       (f)  The quantity of available groundwater will be  reduced.

       (g)  There will be an irrevocable commitement of resources,
            including phosphorus and fossil fuel.*

  Given the potential for 17 New Source mines and the observed effect
  of existing mining activities, the draft EIS considered  the impact of
  the phosphate mining industry under various scenarios.   These  included:
  limiting mining to those operations currently permitted  (Scenario
  2.15), continuing the operation of existing mines as well as future
  "New Source" operations  (Scenario 2.11), requiring process  modifica-
  tion for "New Sources"  (Scenario 2.12), requiring reduced water
  usage  (Scenario 2.13), and controlling activities in the waters of
  the U.S. and in the wetlands of Central Florida  (Scenario 2.14).
  In the following portions of this review, two different  scenarios
  are discussed.  These are the "no growth" scenario based on no new
  permits, and the "recommended" scenario, which is a combination of
  several alternatives.


  Scenario ,2.15  (Existing Source Permits Only) Alternative

  In the draft Areawide EIS, impacts of the Central Florida Phosphate
  industry under Scenario 2.15  (continued operations of mines permitted
  as of August 1, 1976) was discussed first.  In this scenario,  18
  mines and 15 processing plants would continue to operate, mining
  approximately  80.6 thousand acres between 1977 and 2000.**  During
  this period, approximately 593 million metric  (short) tons  of
  phosphate ore would be mined, which is approximately 57% of the. esti-
  mated economically recoverable reserves of the district.*** This
  mining activity also represents the consumption of 34% of the  area's
  known phosphate ore resources.

  Water demands upon the Floridan Aquifer generated by the industry
  under Scenario 2.15 are estimated to total 355.2 mgd in  1985 and
  195.77 mgd  in  the year 2000.****  Based on the assumptions  that
  the phosphate  industry's water demands would rise and fall  during
  the 1977-2000  production period and that municipal and agricultural
  demands would  remain at 1975 levels, the EIS indicated that the
  aquifer's pressure gradients will increase in a south and Southwest-
  erly direction.  As a result of this increase, the freshwater  head
  near the coastal sections would also increase, thereby reducing
   "Draft Areawide  EIA,  p.ii.
  **Ibid.,  p.  2.40
 ***Ibid.,  Table  2.15, p.  2.79
****Ibid.,  Table  2.3, p.  2.12

-------
 the  potential  for  saltwater  intrusion  and  restoring  coastal well
 capacities.*   These  conclusions  contained  on  pages  2.65  and 2.66
 of the EIS should  bo considered  somewhat misleading,  primarily
 due  to the assumption of  the municipal and agricultural  v.'ater
 demands~"will remain  equivalent to  the  1975 demands.   The EIS
 recognizes this  fact, as  noted on  page 2.46,  but  continues  to
 describe the positive and negative impacts on the Aquifer in its
 analysis of Scenario 2.11 (the continued operation of existing
 mines and the  permitting  of  New  Source mines).

 Scenario 2.15  also indicates that  13,700 acres of wetlands  will be
 destroyed between  the years  1977 and 2000  and the overall disturbance
 of approximately 80,600 acres will impact  surface and sub-terranium
 flows to the river basins in the district  area.   For  example,  the
 EIS  indicates,that between the .years 1977  to  2000, approximately
 48,300 acres,  3,500  acres, and 24,800  acres will  be  altered in
 the  Upper Peace  River, Little Manatee  and  Alfia River Basins,
 respectively-**  The document notes that the  impact  will be of
 sufficient magnitude to cause notable  community shift for organisms
 preferring flowing water  to  those  preferring  standing water.   This
 represents a significant  negative  impact since flowing-water communi-
 ties ' are of greater  resource value to  the  study area.*** Additionally,
 the  altered flow regimes  resulting from mining and reduced  surface
 runoff will cause  changes in freshwater discharges to principally
 the  Peace and  Alfia  Rivers.  Reduced freshwater discharges  to these
 rivers and their receiving coastal estuaries, will alter salinity
 regimes, causing modifications to  the  estuarine organism distribution,
 food cycles, etc.

 Finally, under Scenario 2.15, the  EIS  notes that  both surface and
 groundwater quality  will  be  negatively impacted.  Although  radio-
 activity concentrations are  not  expected to increase  significantly,
 the  following  effects are expected:

      (a)  There  will be combined loadings  of  chemical pollutional
          parameters (especially phosphates,  flourides,  and total
          suspended  solids)  from discharges of nonprocessed and
          processed  wastewaters  to various stream segments,

      (b)  The  creation of many water impoundments that will tend
          to deteriorate  water quality by  permitting  over enrich-
          ment,

      (c)  Local  surface-water deterioration from  clearing,  burning,
          construction, reclamation, slime spills, and seepage
          from contaminated  ponds  will occur,

      (d)  There  will be local water-table  quality deterioration
          because  of draining and  dewatering,  overburden,
          product  storage, seepage from contaminated ponds, and
          reclamation of  mining  pits,  and
 *  Ibid., p.  2.56
**  Ibid., p.  2.56
**  Ibid.

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     (e)   There will be local Floridan Aquifer water-quality
          deterioration from wastewater injection.*

Since Scenario 2.15 involves only the continued operation of those
mining activities which are currently permitted, it was not adopted
as the proposed course of action.  There has been considerable
demand by phosphate interests for additional mines for future
activities.  Consequently, the draft EIS seeks to find a compromise
between the industry demands (known as Scenario 2.11) and environ-
mental impacts through process modifications (Scenario 2.12), reducing
water usage (Scenario 2.13) and controlling activities in U.S. waters
and wetlands  (Scenario 2.14).  So in essence, the proposed action
identified in the EIS involves the continued operations of existing
phosphate operations and the permitting of New Sources as modified
by Scenarios 2.12, 2.13, and 2,14.


The Proposed Action  (Scenario 2.11, 2.12, 2.13, 2.14)

Scenario 2.11  (Permit Existing and New Sources)

Scenario 2.11 is based on the operation of existing and the per-
mitting of New Sources.  Under this alternative, not only will 18
mines and 15 processing plants continue to operate but 7 additional
mines are anticipated to commence operation within the time frame
examined in the EIS.  However, most of the impacts addressed in
this scenario are analyzed from an additional Scenario 2.11* stand-
point (the industry view) which requests that 12 new mines would
be permitted.

According to Scenario 2.11, an additional 58,500 acres of land would
be disturbed between 1977,and 2000.  This represents a 72.6% increase
over land disturbance created by mining operations currently author-
ized under Scenario 2.15.   (This differs from the industry's Scenario
2.11 which would result in an additional 103,700 acres mined or a
129% increase over Scenario 2.15 conditions.)** An additional 29,300
acres would be committed for slime ponds under Scenario 2.11  (as
compared to 51,600 acres for Scenario 2. II1),  Over 26,800 acres of
wetlands would be altered under Scenario 2.11***, while the loss
of forest  (timber) resources would amount to an additional 18,300
acres by the year 2000, representing an increase over Scenario 2.15
losses by 53%.****  (Scenario 2. II1 would result in a 67% increase
in forest acreage disturbance.)

Phosphate consumption would increase by 72% over Scenario 2.15
levels, totalling approximately 1,020 million metric  (short) tons
by the year 2000.*****  This volume of production represents 98%
of the economical recoverable reserves and 59.2% of the known
areawide resources.   (In comparison, Scenario 2.11 would result in
phosphate production of 1,350 million metric (short) tons by
2000 or a 126% increase over anticipated existing permitted mine
production.  In relation to area reserves and resources, scenario

     - Ibid., p. 2.70
   ** Ibid., p. 2.69
   *** Ibid., p. 2/72
  **** Ibid., p. 2.78
***** Ibid., p. 2.79                   _     ^

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2.111 will utilize  over 130% of the district's economically recoverable
reserves  and 78.5% of the known resources.)   The production discussed
under Scenario 2.11 will result in the mining of 40.8% of the U.S.
reserves  and 14.5% of the countries estimated resources.

In assessing the water demands of the phosphate industry on the
Floridan  Aquifer,  the EIS assumed worst case conditions, that of
the industry view  (Scenario 2. II1).  Based on the results of the model
which assumed municipal and agricultural demands would maintain 1975
demand levels, the phosphate industry will impact the potentiometric
levels in the Floridan Aquifer, particularly the coastal areas of
Manatee,  Sarasota  and Charlotte Counties.  However,  by the year 2000,
the EIS notes that "no adverse effects except the small increase
in pumping costs and the increased potential for saltwater incroach-
ment are  expected  from future pumping of the Floridan Aquifer by
the phosphate industry."*  This statement demonstrates a rather
narrow scope of impact evaluation; particularly since the Municipal/
agricultural demands were held constant and that the increased
potential for saltwater intrusion could be expected  to represent
a major negative impact on populations residing in coastal areas.

Water quality implications are significant.   According to the
EIS, under the conditions of Scenario 2.11,  the potential for
pollution loads from failures of slime-pond dikes will increase
and would threaten Class I waters.  It should also be restated
that phosphate operations under Scenario 2.11 (and 2. II1) would
increase  slime pond acreage 72.6% and 129% over currently permitted
conditions.   This  projected expansion of slime pond  areas will
significantly increase the likelihood of slime pond  dike failure.

Within the context of Scenario 2.11, Scenario 2.12 (Require
Process Modifications for New Sources), 2.13 (Required Reduced
Water Usage), and  Scenario 2.14 (Control Activities  in Waters of
U.S. and  Wetlands) were considered and constitute those remaining
elements  comprising the Proposed Action.


Scenario  2.12 (Require Process Modification for New  Sources)

There are six major modifications discussed for the  permitting
of New Sources

(A)  Elimination of Slime Ponds

     Under this consideration, elimination of slime  ponds was
     analyzed from two major approaches.  The first  approach
     discussed involved the changing of the mining process from
     a wet to dry  procedure.  The discussion contained in the
     draft EIS concluded that technical problems would make a
     dry  mining process infeasible within the 1977-2000 study
     period.**  The second approach towards eliminating slime


~*ibid.,  p.  2.83
**lbid.,  p.  2.80

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      ponds  dealt  mainly  with procedures to speed up the  dewatering
      and  settling process  in these slime pits.   Flocculation  of
      the  slime  areas  and/or combining sand tailings and  slimes to
      fill" mine  cuts were the basic procedures addressed.*   This
      could  reduce reclamation time for such pits.   This  modification
      is the recommended  use, which would allow pond usage  to  con-
      tinue  along  with the  potential for disasterous spills.
      Flocculation is  only  proposed for New Sources', enabling
      existing sources to continue  current methods  of operation.

 (B)   Chemical Processing of Wet Rock (Eliminating  drying process)

      Under  this consideration,  the dry-rock processing method
      would  be eliminated,  thereby  reducing released dust and
      air  pollution.** Wet  rock'grinding during beneficiation  arid
      chemical processing is already in use at several plants.
      Furthermore, this process  modification only applies to
      New  Source activities.  Consequently, existing dry  rock
      processing will  be  permitted  to continue,  thereby sustaining
      current dust and air  pollution.

 (C)   Dry  Conveyor for Matrix from  Mine to Benefication Plant

      The  process  described in the  EIS entails the  use of a mined
      rock transportation system comprised of an overland conveyor
      belt.***   According to this document, the system utilizes
      less water and energy to take the mined ore to -beneficiation
      sites. Most existing operations utilized slurry pipes to
      transport  the ore and will be permitted to continue this
      procedure.  Consequently,  energy and water demands  would
      appear to  remain constant  within the foreseeable future.

 (D)   Recovery of  Fluoride  from  Recirculated Process Water, Including
      Scrubber Water

      The  EIS describes a Fluoride  recovery system  utilized by
      USS  Agri-Chemical and W.R. Grace phosphate companies. Numerous
      problems were sited in the description and report costs  of
      Fluoride recovery operations  exceed prices by 25 to 36
      percent.**** In  addition,  this requirement would only be
      applied to New Sources and only if market conditions  offset
      the  .cost of  recovery.  Meanwhile, existing source fluoride
      emissions  will continue.

 (E)   Uranium Recovery from All  Phosphoric Acid

      This consideration  basically  involves the process of  extracting
      Uranium (U308) during initial digesting of phosphate  rock,
      using  sulfuric acid at chemical processing plants.  The
      digesting  process creates  phosphoric acid and gypsum, the
      gypsum being a  radioactive waste product separated  during the
      process.
   "Ibid.,  2.19
  **Ibid.f  2.11
 ***Ibid.,  2.11  - 2.13
****Ibid.,  2.23  - 2.25

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      Currently, uranium extraction  from phosphoric acid is
      being conducted by several  Central Florida Chemical processing
      plants  (W. R. Grace,  Bartow complex,  Uranium Recovery Corpora-
      tion, and  IMC's complex  at  Mulberry,  Florida).   According
      to the  EIS,  if .,*.'  "'" .   ^traction  was conducted at 90 to
      95% efficiency f .,       ...phosphoric acid chemical treatment
      plants  in  Central "Florida,  approximately 4,570,000 pounds
      of uranium could be produced a year.*  However, this process
      modification would only  be  encouraged for New Source activities.

  (F)  Impervious Lining for Recirculated Process-Water Ponds at
      Chemical Plants  , .
      — — - ' - ,V. •'.  .''I'
      This consideration involves the lining of gyp-ponds at chemical
      processing plants with an impervious  material in order to
      reduce  ground water quality degradation.  According to the
      EIS, operational and  cost data are not available for this
      consideration, since  it  has never  been tried.   Furthermore,
      little  data  was available to determine the impacts of seepage
      from these gyp-£.. >•/"!•- • ,• ,-d therefore,  the net benefit from
      installing impei-^.i-..-. - •„' ,-nings  was  not ascertained.**  This
      process modification  lb  only directed to New .Source activities
      and since  no new chemical processing  plants were considered
      in the  EIS,  this modification  is of little use.


  Scenario 2.13  (Requirt ••".  'uced Water Usage)

  This scenario basically describes the reduction of water usage
  through the  requirement that  stormwater drainage systems accommodate
  a 25 year-24 hour rain fp.^.l, storm event.   This requirement would
  only be imposed on New "Sour ce activities.***  Existing mining
  operations will be permitted  to  maintain their 10-year storm event
  drainage systems.  The water  volumes contained in the enlarged
  drainage system (storage ponds)  could be utilized in the mining and
  processing of the phosphate ore,  resulting in reduced groundwater
  withdrawals.  However, it  must be noted that the scenario would
  further reduce  surface water  flows  towards wetlands, streams, and
  river  basins, ultimately reducing river flows.   This process
  modification would appear  to  magnify one of the major negative
  impacts associated with the phosphate industry.


  Scenario 2.14  (Control Activities in Waters of U.S.  and Wetlands)

  Under  this scenario, prohibition of mining in U.S. waters and wetlands
  was considered.   Also considered was authorizing mining activities    '.
  in wetland areas, but o^ly if restoration  was a requirement after
  mining.

  Some major points were established  in this scenario.  First, the
  Army Corps of Engineers and the  Florida Department of Environmental
        , p.  2.25  -  2.26
 **Ibid., p.  2.27
***lbid.

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Regulation (D.E.R.)  were recognized as having purview in permitting
powers over U.S. waters and wetlands.  Secondly, the EIS notes
that even if mining in U.S. waters and wetlands were prohibited,
industry actions either adjacent to or up stream of these sensitive
systems would cause negative impacts by reducing surface/groundwater
flows.  In addition, assuming that the wetland was left undisturbed,
reclamation of surrounding mined areas usually results in the
lowering of original land surfaces.  Consequently, the wetland
becomes higher in elevation resulting in its eventual draining
and destruction.  The third point established was that no feasible
means for restoration of a mined wetland has been demonstrated.
Ever if the wetland could be restored, there appears little
doubt that its original characteristics,  productivity and habitat
features could ever be duplicated.

                              Conclusions


Based on the foregoing analyses of the Proposed Action comprised of
Scenario 2.11, 2.12, 2.13, and 2.14, it is apparent that the phosphate
industry will be required to do little toward minimizing impacts
associated with existing operations or New Source activities.  This fact
is emphasized since the draft EIS  is based upon issuing all requested
permits with only a few modifications in technology or site design":

Elimination of above ground slime-ponds is considered in the report to
be technologically  infeasible within the study period 1977-2000.
Although requiring  New Sources to  speed up the slime-pond reclamation
through flocculation and/or combining tailings with slimes would prove
useful, the reclaimed lands would  still be relegated to limited
agricultural uses.  Further, the threat of slime-pond dike failure will
increase in proportion to the new  ponds created; thereby magnifying
potential disasters to natural water bodies and river basins.

Elimination of dry  rock processing methods at beneficiation sites and
chemical processing plants is a modification only applicable to New
Source activities.  While this modification should serve to improve
air quality around  New Sources, areas adjacent to existing activities
will  continue to be impacted.

The dry conveyor transporting of phosphate ore from mines and beneficiati
plants would only be required for  New Sources.  As a result, the water
and energy demands  for permitted activities using slurry pipe transpor-
tation will remain  constant, within the foreseeable future.

Recovery of fluorides  from recirculated process water, including scrubber
water, has been  identified as very costly.  Additionally, according to
the EIS, enforcement of  this process modification for New Sources could
be v/aived if market conditions do  not support the cost.  It seems likely
the New  Source  applicants could demonstrate excessive costs for many
years to come resulting  in no enforcement of the modification.  Further-
more,  fluorine  and  fluoride emissions will continue from existing
sources.  Together, these  two factors would seem to negate the piausa-
bility of  improving environmental  conditions under this modification.

-------
,,r,.r.imn n.rovr.ry from all pho.sphor J c acid is a desirable activity.
AHhouqh so,,,,. conu>,mic>s aro currently undertaking this activity,  the
-,c-l oil applicability of the modification is directed towards New
Sources; and only to the extent of encouragement.

The lining of gyp-ponds with impervious materials appears to be a desirable
m-orc'durc for reducing ground and surface water contamination._ However,
tho'lilS 'notes the operational and cost data is not available since  it
ha- not been tried.  In addition, since it has not been tried, no net
benefit data is available.  Furthermore, this process modification  is  _
only applicable to New Source chemical plants, none of which are  envisioned
in the draft EIS.


Reduced water usage through expanding drainage capacities for a 25-year-
24-hour storm event and utilizing the 'contained water for ore processing
would appear reasonable.   However, l.his modification would only apply
to New Sources.   Furthermore, through increased detention times and
capacities,  surface water flows to streams and river basins will be
reduced.  Consequently, the modification would serve to compound the
flow regime  impacts already associated with the phosphate industry.

Proposals identified in the draft EIS to control activities in U.S.
waters, and wetlands appear to lead to one central conclusion; phosphate
industry activities will create significant negative impacts on these
aquatic environments.   Even if mining in U.S.  waters and/or wetlands
is prohibited,  mining operations within the vicinity of these environ-
ments will reduce surface water flows and deplete groundwater systems,
thus changing,  if not destroying, the waters and wetlands.   If mining
was authorized in wetlands on the basis of requiring Restoration,  a pilot
project in restoration would be necessary in order to adequately assess
its feasibility since it has never before been undertaken.

Finally, it  is important to discuss  that the justifications of the
Proposed Action are the positive benefits as identified in Section 5
of the draft Areawide EIS.  According to the EIS, the positive
benefits of  the Proposed Action include:

        (1)   low priced, fertilizer
        (2)   employment and tax revenues
        (3)   local and regional economic activity
        (4)   reduction in U.S. trade deficits                     U) ~~ "2-&8

However, none of the scenarios were  designed around these benefits,
but these benefits are used to justify the Proposed Action alternative.
It is recommended that an additional alternative should be developed
that would be based on maximizing these benefits from a long-term view-
point .   Environmental Impacts associated with this new alternative should
then be discussed" and explored"!   It  should be emphaiszed that the Proposed
Action alternative indicated in the  EIS is totally deficient in identi-
tying the long-term economic benefits by the parameters above.  This
fact is demonstrated in the following discussion.

(1)   Low priced fertilizer:  It may  be assumed that fertilizer
     produced in this part of Florida is competitive with the cost of
     developing phosphate resources  elsewhere.  The selected Proposed
     Action  would result in increased production and, thereby, more
     rapidly decrease reserves.   This would, perhaps, increase the

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    amount, of ,iv,ii ! able  low-priced  fertilizer  Cor  a  short  period  of
    time;.  However, a.-; local  reserves  are  exhausted,  higher, priced
    reserves cilije.whure will need  to  be developed.  Consequently,  rapid
    exhaustion of  1.oc«il  reserves  will  only lead  to increased fertilizer
    prices.  An  additional alternative maintining  current  level of
    production should be  . '.""ined for  its  ability  to  keep  local low
    priced fertilizers o  ,  j market for a longer  period of time.

(2)  Employment and  Tax Revenues:   The  selected Proposed Action encourages
    increased employment  for  a short period of time,  to be followed
    by an increasing number of layoffs in'the  labor  force. .This  cannot
    be considered  a long-term economic benefit.  An  additional alter-
    native should  be developed that  examines (as in  the case of ferti-
    lizer) the feasibility of maintaining  current  levels of employment
    for a longer period.  Similarly,  tax revenues, under the EIS
    selected alternative, can be  expected  to initially increase  (which
    is necessary for the  additional  governmental facilities needed
    by the phosphate industry), and  thereafter decline as  workers  are
    laid off.  This' decline in revenues will occur during  the period
    when governmental social  service expenditures  will need to increase
    in order to  accommoda '•;.;;.the newly-unemployed phosphate workers.
    The new alternative suggested  as  a  result of  this  review should
    examine a level of phosphate  production that would maintain current
    tax revenues as long  as possible.

(3)  Local and Regional Economic Activity:   As  discussed above, other
    business and governmental operations,  (ij.e., Port of Tampa) will
    need to gear up for  increased phosphate industry  operations;  and,
    therefore, can  be expected to decline  as the industry  declines.
    This cannot  be  considered a long-term  benefit.   A suggested
    alternative  would be  to examine  the feasibility  of maintaining "
    phosphate operation  levels within  the  current  framework of business
    in order to  postpone  and/or reduce future  adverse impacts as
    industry shuts  down.

(4)  Reduction in U.S. Trade Deficits:   This is a very temporary benefit
    that will be followed by  an increase in deficits  as the nation's
    reserves are used up.  The EIS  indicates that  U.S. demand will
    exceed Florida's production about  1990 and will  exceed U.S.
    production about the  year 2008.  After this  point, more expensive
    foreign resources will be needed to meet U.S.  demand.   The suggested
    alternative  would be  to examine  the benefits of  long-term
    self-sufficiency in  phosphates.  This  is particularly  important
    since the nation is  an exporter  of agricultural  goods.   It should
    be noted that  the EIS does not provide fiscal  data on  the sale of
    phosphate as an element of our trade balance.
                                 10
                                       J-/S-8

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REUBIN O'D. ASKEW
  GOVERNOR
                            STATE OF FLORIDA

          DEPARTMENT OF ENVIRONMENTAL REGULATION

                         SOUTH FLORIDA DISTRICT
                      BRANCH OFFICE AND LABORATORY
                       3201 GOLF COURSE BOULEVARD
                        PUNTA GORDA, FLORIDA 33950
                                  June  21,  1978
JOSEPH W. LANDERS, JR.
    SECRETARY

 PHILIP R. EDWARDS
 DISTRICT MANAGER
     Mr.  R. E. McNeill
     U.S.E.P.A., Region VI
     345  Courtland St., N.E,
     Atlanta, Georgia
     Dear Mr McNeill:
                                   Re:   Draft  Areawide EIS Central
                                        Florida Phosphate Industry
After reviewing the draft E.I.S., the technical working paper on
aquatic biota (Vol V, Section 2) , and attending the public hearing,
I am disappointed as to the lack of biological data which were       (/J-
presented for the. fresh water aquatic systems of the study area.   In
an attempt to improve both the quality and quanity of data available,
I am submitting species lists of - the macroinvertebrate fauna from
the P.N.S. samples of (1) the Peace River at Arcadia, Desoto County
(25.02.0004), (2) Horse Creek at S. R. 72, Desoto County  (25.02.0111)
and (3) the Myakka River at Border Drive, Sarasota County  (25.03.0403).

These lists have been edited to reflect most recent taxonomy and to
exclude erroneous identifications  (primarily from the older data).
All species listed were actually collected at the station location. tv~
Extensive museum specimens, water quality data and habitat preferences
are maintained and recorded for the majority of species.  Quantitative
data (d Shannon-Weaver)  from benthic grabs and artificial substrates
(Hester-Dendy, E.P.A. modification) are also available.  Collections
other than quantitative, stress those forms which are dependent upon
dissolved oxygen; thus most adult COLEOPTERA (excluding ELMIDAE) and
the HEMIPTERA are not represented except from quantitative collections;
in this one aspect the submitted lists are limited.

The Peace River at Arcadia is represented by 135 Taxa, dominated by
aquatic insects and is based upon 85 samples   (56 benthic grabs,  22
artificial substrates, 7 intersive qualitative samples). Of the     fcj -
aquatic insects which Lanquist  (1953) recorded from the Peace River
at Arcadia, four (4) ODONATA and two  (2) TRICHOPTERA have not occurred
in the P.N.S. sampling.
                                                                                I
                                   continued

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page 2
Draft Areawide EIS Central
Florida Phosphate Industry
June 21, 1978


ODONATA

  ANISOPTERA

    GOMPHIDAE

      DROMOGOMPHUS Spinosus

      PROGOMPHUS alachuensis

    CORDULIIDAE

      TETRAGONEURA sp.

  ZYGOPTERA

    COENAGRIONIDAE

      CALOPTERYX (Agrion) maculata

The two GOMPHIDAE & TETRAGONEURA sp. are regularly collected from
Horse Creek, a large tributary to the west, unaffected by historic
slime spills.  CALOPTERYX (Agrion)  maculata is a common inhabitant of
a small unnamed swamp stream tributary to the Peace River south of
Arcadia.  The GOMPHIDAE HAGENIUS brevistylus and the AESCHINIDAE
BOYERIA vinosa while not collected by Lanquist at Arcadia are reported
by him from upstream.  HAGENIUS brevistylus is a rare member of the
community at Horse Creek and BOYERIA vinosa is common in the same
stream frequented by CALOPTERYX mentioned above.

TRICHOPTERA

    PHILOPOTAMIDAE

      CHIMARRA sp.

    POLYCENTROPIDIDAE

      PSYCHOMYIID GENUS A (=NYCTIOPHYLAX sp)

CHIMARRA is a occasional member of the community at Horse Creek and
is also represented   by a single specimen from the Myakka River but
has not been recovered from the Arcadia Peace River Station to date.
Lanquist does not discuss the habitat from which CHIMARRA was taken;
however, collections of this organism at other south Florida sites
(DER monitoring data) indicate a distinct preference for substantial
velocity and a hard substrate (rocks or logs).  Large populations of
CHIMARRA exist to the south of the study area in the upper reaches of
the Orange River, Lee County, Florida and Alligator Creek, Charlotte
County Florida.  Probability for collection of CHIMARRA would likely
increase upstream in the Peace River.

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page 3
PYSCOMYIID GENUS A (Ross) has been placed in the genus NYCTIOPHYLAX
 (Flint 1964).   I have never seen this organism from the lower Peace
River Basin.   The nearest population which I have collected is from
a small rapid stream in Highlands County.

Horse Creek is one of the largest tributaries of the Peace River
drainage.  Arising as the accumulation of drainage from sloughs and
flatwood ponds in northeastern Manatee and northwestern Hardee Counties,
the stream flows in a well defined course the entire length of western
Hardee County and the majority of DeSoto County discharging to the   .  -5
Peace River in the vicinity of Fort Ogden.  Typical of southwest   W ~ £-
Florida streams, flow is influenced by the highly seasonal rainfall.
Inundation  of the hardwood flood plain normally occurs at least once
during the summer.  Base flows occur during the spring drought months
when the stream is totally dependent upon groundwater seepage.  In
severe droughts, segments of the stream bed dry for a short period.
This condition is more pronounced closer to the streams headwaters.
At this point I must caution that while there are times of no flow
 (spring droughts), Horse Creek cannot by anyone's imagination be called
an intermittent stream and use the correct definition of the term.
Even during the transient no flow period, pools along the stream bed
retain water.

The enclosed fauna listed for Horse Creek (S.R. 72)(152 Taxa)  is based
upon 157 samples  (101 artificial substrates,  47 benthic grabs and 9
intensive qualitative samples).   The richness of the Horse Creek
fauna is an excellent documentation of the historic water quality,
aquatic resources, and natural habitat diversity once common to the
entire Peace River Basin.  This stream represents the last large
drainage of the Bone Valley formation spared  the "progress" of modern
phosphate mining.  Serious consideration needs to be given to the
establishment of a State or Federal "endangered lands" designation
for a corridor encompassing the creek, contiguous wetlands, hardwood
flood plains and a small amount of uplands to preserve this state and
national heritage.

The Myakka River is a totally different environment from the Peace    •> i
River or Horse Creek.  Defined as a truly zero flow river during   w~*~i
portions of the seasonal cycle.   The Myakka River at the PNS site has
a strong tidal component during the winter and spring.  While the
125 Taxa approaches the number for the Peace  River,  Arcadia Station,
21 of these represent estuarine or brackish water forms not collected
at  the Peace  River Station.  The channel profile is similar to a box
cut canal, with a steep rapid slope and very  little shallows along the
edge.  The predominant substrate is bare limestone;  sand is present
only along the edges.  The faunal list was developed from 83 samples
(57 benthic grabs, 21 artificial sub'strates and 5 intensive qualitative
samplings).

Several inaccurate identifications and typographic errors are contained
in Tables 2.11 and 2.5 of the Aquatic Biota working paper  (Vol. V
Section 2) .                                                        U-

-------
page 4
TABLE 2.11

MOLLUSCA

  GASTROPODA

    CREPIDULA - This is a Marine and Estuarine organism.  No member of
                this genus belongs to the lotic freshwater community.
                Several of the other typical gastropoda genera are most
                likely also misidentifications.

  EPHEMEROPTERA

    NEOCLOEON (Traver) - Edmunds, Jensen and Berner  (1976) relegated
               NEOCLOEON to a synonym of CLOEON (Leach).  If this genus
               occures in the Little Manatee River or Alafia River, it
               represents a significant extension beyond the previously
               observed range.  BERNER  (1977) reports CLOEON in Florida
               only from the Tallahassee Area westward through the
               panhandle (BERNER, 1950, PETERS & JONES 1973, SCHNEIDER
               1967.)  Until confirmed I would assume that 'the record
               is-a misidentification of CENTROPTILUM  and delete it
               from the table.

    CHOROTERPES (EATON) - This Leptophlebiidae genus is represented in
                 south Florida by a single species C. hubbelli (BERNER).
                 Lanquist (1953) reports C_._ hubbelll~from Charlie Creek
                 in Hardee County but not from the Peace River.   I
                 have specimens from tributaries of the Peace River
                  (Horse Creek,DeSoto County and Shell Creek, Charlotte
                 County) and other small to moderate streams as far
                 south as Lee County but again not the Peace River proper.
                 I have no reason to assume exclusion of C. hubbelli
                 from the Peace but neither have I seen specimens or solid
                 published data to substantiate its occurrence.  C_._
                 hubbelli in my opinion probably does occupy some
                 segments of the Peace River.  COROTERPES as listed in
                 table 2.11 is a misspelling. (BERNER 1977, BERNER 1958,
                 PETERS  & JONES 1973, SCHNEIDER 1967.)

    EPHEMERELLA (WALSH) - Undoubtably this record represents E_._ trilineata
                  (BERNER).  Lanquist (1953)  records this species from
                 a small tributary north of Bartow, Polk County.   I have
                 been informed that this stream (Bear Branch) has, since
                 Lanquist's collection, been highly altered such that
                 it is presently little more than a drainage canal.
                 E. trilineata in all likelyhood does not presently
                 occupy this waterbody.  BERNER (1977)  gives a Manatee
                 County record but not a specific location; most likely
                 the upper Little Manatee or Manatee River Systems.
                 The closest existing population which I have sampled is
                 a small rapid stream in Highlands County.  EPHEMERELLA
                  could conceivably occur in some segment of the Peace
                  River or a tributary, however, its existence needs to
                  be confirmed.  Inclusion in table 2.11 until confirma-
                  tion  should carry a disclaimer. ^   , .
                                                3 - ' v> <-

-------
page 5
    HABROPHLEBIA (EATON) - Like CLOEON occurrence of this genus out-
                 side the panhandle would be a most exciting find.
                 However, I am inclined to be skeptical of this record
                 until verified.  The only Leptophelebiidae known to
                 occur in the Peace Basin or South Florida is the
                 previously discussed CHOROTERPES hubbelli.  Occurrence
                 of this organism is highly doubtful and it should be
                 excluded from table 2.11.  HABROPHEBIA as listed in
                 table 2.11 is a misspelling.

ODONATA

  ZYGOPTERA

      LESTES sp.  While this genus is a common inhabitant of pools and
                 wet weather ponds  I  have never observed it in a
                 truely lotic habitat in South Florida.

TRICHOPTERA

      LEPTOCELLA  Flint (1974) transferred all N.A.  species of LEPTOCELLA
                 -to the genus NECTOPSYCHE

      ATHRIPSODES MORSE (1975) removed all N.A.  species of ATHRIPSODES
                  to the genus CERACLEA.

TABLE 2.5

The following represent questionable records predominantly from
temporary pools and ponds.

EPHEMEROPTERA

      BAETIS

      BRACHYCERCUS

      TRICORYTHODES

These three mayfly  genera are common inhabitants of  the streams in the
study area; however, I know of no literature which documents their
occurrence in temporary waterbodies other than some  seasonal streams.

ODONATA

  ANISOPTERA

      MICRATHYRIA

To my knowledge this genus does not occur in Florida.

  ZYGOPTERA

      ARGIA

-------
page 6
This genus is a common STREAM FORM represented in the study area by
three species A. f umipennis , A_. moesta, A. sedula none of which have
been documented from temporary pools.  The genus LESTES is a common
inhabitant of these seasonal ponds and should be added to the list.

MEGALOPTERA  -  NEUROPTERA is outdated

      CORYDALUS

Again, a form requiring flowing water and high D.O. concentration.

DIPTERA

  TIPULIDAE

      CHAOBORUS

CHAOBORUS is not a member of the family TIPULIDAE

  CHIRONOMIDAE

      TELMATOSCOPUS

TELMATOSCOPUS is not a chironomid

  CHIRONOMIDAE

       MICROCRICOTOPUS

This genus while reported by COWELL, DYE, & ADAM in their Lake
Thonotosassa study was found only at station 10 located in Flint Creek,
a lotic habitat.

ODONATA

  ANISOPTERA

      GOMPHUS

      MACROMIA

      EPICORDULIA

None of these common genera are documented from ponds or pools by
PAULSON  (1966) in his extensive work on South Florida ODONATA.


                              Sincerely,
                              Richard W. Cantrell
                              Biologist
RWC/ck
cc:  Philip R. Edwards
     Louis M. Fendt
     Marvin Collins              ^ _ * r d
     Landon Ross                 -*

-------
REFERENCES;


Applied Biology 1977  Monitoring of Periphyton,  Benthic and Chemical
                      Parameters at the Manatee  Plant,  August 1975 -
                      May,  1977 - P.P.  & L.

Berner, L. 1950  The Mayflies of Florida -  U.  Fla.  Press

Berner, L. 1958  A list of  Mayflies from the Lower  Apalachicola River
                 Drainage.  Quart. Jour. Florida  Acad.  Sci.  21(1):25-31

Berner, L. 1975  The Mayfly Family Leptophlebiidae  in  the S.  E. United
                 States.  Fla.  Entomol. 58(3):137-156

Berner, L. 1977  Distributional Patterns of Southeastern Mayflies.
                 Bulletin of the Florida State Museum,  Biological Sciences
                 22(1):l-55

Conservation Consultant 1976  Studies on the Ecology of the Little
                              Manatee River. - F.P.  &  L.

Cowell,  B., Dye,  C. & Adam, R. 1975  A Synoptic Study  of the Limnology
                                      of Lake Thonotosassa, Florida.
                                      Part  I effects of Primary Treated
                                      Sewage and Citrus Wastes
                                      Hydrobiologia. Vol.  46,  2-3

Edmunds, G. , Jensen, S.  & Berner, L.  1976  The Mayflies of  North and
                                           Central  America. U. Minnesota

Flint,  0.  S. 1964  Notes on Some Nearctic Psychomyiidae with Special
                   reference to their larvae.  Pro.  U.S.  Nat.  Mos. 115
                   (3491):467-81

Flint,  0.  S. 1974  The Trichoptera of Surinam; Studies  of Neotropical
                   Caddisflies XV Stud. Fauna. Surinam  ,  55

Lanquist,  E. (1953)  A biological survey of  the Peace River.  Peace &
                    Alafia  Rivers Stream Sanitation Studies 1950-1953
                    Supplement to Vol.  II.  F.S.B.H.

Morse,  J.  C. 1975  A Phylogeny and revision of the  Caddisfly  genus
                   Ceraclea Contr. Am.  Ent.  Inst.   11(22)

Needham, J.  & Westfall,  M.  1955  Dragonflies of  North America.
                                 U. California

Paulson, D.  1966  The Dragonflies of Southern Florida,  phd  Dissertation
                  U. Miami

Peters, W. L. & Jones,  J. 1973  Historicl and Biological Aspects of the
                                Blackwater  River in N.  W.  Florida.
                                Proc. 1st Intern. Conf. on  Ephemeroptera.
                                E. J. Brill, Leiden pp241-253

-------
Schneider, R. F. 1967  Mayfly Nymphs from Northwestern Florida.
                       Quant. Jour. Fla. Acad. Sci. 29(3):202-206

Wiggins, F. 1977  Larvae of the North American Caddisfly Genera
                  (Trichoptera).,  U. Toronto

Westfall, M.  Personal communications  Odonata Taxonomy

-------
                  MACRO INVERTEBRATE LIST LEGEND








M - Marine species




* - Abundant  species




Alphabetical  species  (Sp.(A) ect.) designate identifications used at




          this  laboratory  to separate obviously different species of




          the same genus.  These do not represent published identifi-




          cations  unless designated by name following the species.
                                   3- !(*"?

-------
                      MACRO INVERTEBRATE  LIST



                     PEACE  RIVER  (DESOTO CO.)



INSECTA



  MEGALOPTERA



      Corydalidae



          Corydalus  cornutus*



  TRICHOPTERA



      Hydropsychidae



          Cheumatopsyche  sp.*



          Hydropsyche  sp.  (A)*



      Hydropti1idae



          Mayatrichia  ayama



          Orthotrichia sp.



          Oxyethlra  sp.*



      Leptoceridae



          Nectopsyche  sp.  (A)*



          Nectopsyche  pavida



          Oecetls sp.  (A)*



          Oecetls sp.  (D)*



      Polycent ropodIdae



          Cyrnel lus  fraternus*



          NeureclIpsls  sp.



          Polycentropus clnerus*



  EPHEMEROPTERA



      Baetidae



          Baetls Intercalaris*



          Baetls spiethi



          Baetis "splnosus"



          Call ibaetls  floridanus'1'




          CentroptIlum hobbs!



                                   J-/G6

-------
MACRO INVERTEBRATE LIST - PEACE RIVER - DESOTO COUNTY - PAGE TWO




          Centroptilum vi ridocularis-




          Pseudocleon alachua*




      Caenidae




          Brachycercus maculatus*




          Caen is diminuta*




      Ephemeridae




          Hexagenia  munda elegans




      Heptageni idae




          Stenacron  interpunctatum*




          Stenonema  exiguum*




      Tricorythidae



          Tricorythodes albi1ineatus*




  ODONATA




    Anisoptera




      Aeschnidae




          Naslaeschna  p'entacantha




      CordulIidae




          Epicordulla regina*




          Neurocordulia alabamensis




      Gomphidae




          Gomphus di iatatus




          Gomphus minutus*




          Gomphus piagiatus-''




      Libeliulidae




          Perithemis  tenera  seminole




      Macromi idae




          Macromia taeniolata*




    ZYGOPTERA

-------
MACRO INVERTEBRATE LIST - PEACE RIVER - DESOTO COUNTY - PAGE THREE




      Calopterygidae




          Hetaerina titia*




      Coenagrionidae




          Argia moesta




          Argia sedula*




          Enallagma cardenium*




          Enallagma pol1utum*




          Ischnura sp.



  COLEOPTERA




      Dryopidae



          (Pelonomus obscurus)* see notes on Horse Creek list




      Elmidae



          Dubi raphia  (quadrinotata)*




          Microcylloepus pusi1lus



          Stenelmis sp. * possibly several species




      Gyrlnidae



          Dineutus sp.*



          Gyrinus sp.




      Haliplidae



          Peltodytes sp.



      Hydrophi1idae




          Berosus sp.



  LEPIDOPTERA



      Pyralidae




  HEMIPTERA



      Belostromidae




      Nepidae



          Ranatra sp.*



      Naucoridae

-------
MACRO INVERTEBRATE LIST - PEACE RIVER - DESOTO COUNTY - PAGE FOUR



          Pelocorls sp.



  DIPTERA



      Chlronomidae



        Tanypodlnae



          Ablabesmyia



          Ablabesmyla ma 11och1



          Ablabesmyla ornata



          Ablabesmyla parajanta*



          Ablabesmyla tarella*



          C11 notanypus sp.



          Coelotanypus conclnnus



          Coelptanypus scapularls



          Coelotanypus tricolor



          Labrundinla floridana



          Lars la lurIda



          Pentaneura  Inculta*



          Procladlus  sp.*



        Ch!ronomlnae



          Chlronomin1 sp.  (A)   (Beck)



          Chironomus  sp.



          Cladotanytarsus  sp. (B)



          Cryptochi ronomus  blarina



          Cryptochi ronomus  fulvus



          Cryptotendlpes sp.



          Dlcrotendlpes modesj:us*



          Dlcrotendipes neomodestus*



          Glyptotendlpes sp.  (c)



          Goeldtchi ronomus  holoprasinus

-------
MACRO INVERTEBRATE LIST   PEACE RIVER - DESOTO COUNTY - PAGE FIVE

          Harnischia sp.

          Mlcrotendipes sp. (A)

          Microtendipes sp. (B)

          Paracladopelma sp.

          Paralauterborniella nigrohalteralis

          Ped ionomus beckae

          Polypedi lum convictum*

          Polypedi lum hal terale*

          Polypedilum !11inoense

          Pseudochi ronomus sp.<:

          Rheotanytarsus exiguus*

          Stenochi ronomus h i 1 a r i s

          Tanytarsus sp. (A)*

          Tanytarsus sp. (C)*

          Tribelos fuscicorn i s

          Unidentified near Omisus sp. (Beck)

        Orthocladi inae

          Corynoneura sp.*

          Cricotopus bicinctus*

          Psectroclad i us sp.
          Rheocricotopus robaki

          Thienemanniel 1 a sp.  (A)--

          Thienemanniella sp.  (B)*

      Simul!idae

          Simul ium sp.*

      Ceratopogonidae

          (Palpomyia sp. A)*

          (Palpomyia sp. B)*

          (Palpomyia sp. C)*

          Forcipomyia sp.
          	

-------
 MACRO INVERTEBRATE  LIST  -  PEACE  RIVER  -  DESOTO  COUNTY  -  PAGE  SIX




      Tabanidae



      Tipulidae




          Tipula sp.



      Culicidae



          Anopheles sp.



 CRUSTACEA




  AMPHIPODA




          Hyallela azteca*



  DECOPODA




          Palaemonetes  paludosus*



          Procambarus (alien!)*



 MOLLUSCA



  GASTROPODA




          Ancyl!dae



          Helisoma sp.  (A)*



          Helisoma (gyrauius) sp.  (b)*



          Hyalopyrgus aequicostatus



          Hydrobi idae



          Physa sp.*



          Pseudosuccinea sp.




  BIVALVIA



          Corbicula man!lens is*



          Eupera cubensi s




          Sphaeri idae*



          Unionidae



ANNELIDA




  OLIGOCHAETA




          Aulodrilus  piquet!




          Dero sp.



          Llmnodrilus sp.*             3~ I "73

-------
MACRO INVERTEBRATE LIST - PEACE RIVER - DESOTO COUNTY - PAGE SEVEN



          Lumbriculidae



          Monophlephorus lacteus



          Nals varlabills*



          Pristlna b!longata



          Prlstlna osbornl



          Slavlna appendiculata



          Stylarla fossularia



  HIRUDINEA



          Helobdella elongata



          Moorcobdella mlcrostoma



PLATYHELMINTHES



      PlanarlIdae



NEMATOMORPHA



      Gordi idae



CNIDARIA



  HYDROZOA



          Hydra



RHYNCHOCOELA



          Prostoma rub rum*

-------
                      MACRO INVERTEBRATE LIST




                     HORSE  CREEK (DESOTO CO.)




INSECTA




  MEGALOPTERA



      Corydalidae




          Corydalus  cornutus*



  TRICHOPTERA




      Hydrosychidae



          Cheumatopsyche  sp.*



          Hydropsyche sp.  (A)*



      Hydrotilidae



          Neotrichia  sp.



          Orthotrlchia  sp.



          Oxyethi ra  sp.*



      Leptoceridae



          Nectopsyche sp.  (A)*



          Nectopsyche pavida



          Oecetis sp.  (A)*



          Oecetis sp.  (B)



          Oecet i s sp.  (C)



          Oecetis sp.  (D)*



          Triaenodes  sp.



      Polycentropididae



          Cyrnellus  fraternus*




          Polycentropus cinereus*




      Philopotamidae



          Chimarra sp.




  EPHEMEROPTERA




      Baetidae

-------
MACRO INVERTEBRATE LIST - HORSE CREEK - DESOTO COUNTY - PAGE TWO

          Baetis intercalaris*

          Baetis spiethi

          Baetis "spinosus"-- possibly a complex of species very difficult to
                             separate as nymphs
          Cal1ibaetis floridanus*

          Centropt?lum vi ridocularis

          Pseudocloeon alachua*

      Caenidae

          Brachycercus maculatus*

          Caen is diminuta*

      Ephemeridae

          Hexagenia munda elegans

      Heptageni idae

          Stenacron Interpunctatum*

          Stenonema exiguum*

      Leptophlebiidae

          Choroterpes hubbel1i

      Trlcorythidae

          Trlcorythodes alb!1Ineatus*

  ODONATA

    Anisoptera

      Aeschnidae

          Nasiaesdma  pentacantha

      Corduli idae

          Epicordulla regina*

          Tetragoneuria sp.

      Gomphidae

          Dromogomphus spinosus

          Gomphus di latatus*

-------
MACRO INVERTEBRATE LIST - HORSE CREEK - DESOTO COUNTY - PAGE THREE

          Gomphus minutus*

          Gomphus plagiatus"

          Hagenius brevistylus

          Progomphus alachuensis

      Libellulidae

          Erythemis simplicicol1is*

          Orthemts ferrug!nea

          Pachydiplax longipennis

      Macromi idae

          Macromia taeniolata*

    Zygoptera

      Calopterygidae

          Hetaerlna titia*

      Coenagrionidae

          Aral a moesta
          Argla sedula*

          Enallagma cardenium*

          Enal lagma pol lutum*

          Ischnura sp.

  COLEOPTERA

      Dryopldae

          (Pelonomus obscurus) although  not  normally  considered  aquatic
                               several  specimens  of  larvae  apparently  of
                               this  species  have  been collected  live from
                               Horse Creek and  the Peace  River.

      Elmidae

          Dub!raphia (quadrinotata)*

          Mlcrocylloepus  pus ill us  ssp.

          Stenelmls sp.*  possibly  several  species

-------
MACRO INVERTEBRATE LIST - HORSE CREEK - DESOTO COUNTY - PAGE FOUR




      Gyrinidae




          Dineutus sp.*



      Haliplidae




          Pel todytes sp.*




      Hydrophi1idae




          Berosus sp.




  LEPIDOPTERA



      Pyralidae




  HEMIPTERA




          Ranatra sp.*




  DIPTERA



      Chi ronomidae



        Tanypodinae



          Ablabesmyia mal lochi*.




          Ablabesmyia parajanta*



          Ablabesmyia peleensis




          Ablabesmyia philosphagnos




          Ablabesmyia (ramphe)



          Ablabesmyia tarella*



          Clinotanypus sp.




          Labrundinia floridana*



          Labrundinia johansenni*




          Labrundinia neopllosella



          Labrundinia vi rescens



          Lars la lurida



          Monopelopia boliekae




          Pentaneura inculta*




          Procladlus sp.

-------
MACRO INVERTEBRATE LIST - HORSE CREEK - DESOTO COUNTY - PAGE FIVE



        OrthocladiIdae



          "Cordites" sp. (Beck)



          Corynoneura sp.''<



          Crlcotopus blclnctus*



          Crlcotopus sp. I  (Beck)



          Psectrocladius sp.*



          Smittla sp.



          Thlenemannlella sp. (A)*



          Thlenemannlella sp. (B)A



        Ch!ronominae



          Chironomlnl sp. A (Beck)



          Chi re-nonius sp.



          Cladotanytarsus sp. (B)



          Cryptochlronomus  fulvus



          Cryptotendlpes sp.



          Dlcrotendlpes  modestus*



          Dlcrotendlpes  neomodestus*



          Einfeldla  natch Itochea



          Glyptotendipes sp.



          Goeldlchlronomus  holoprasInus



          Klefferlus dux



          Lauterborniella sp.



          Mlcropsectra sp.  (B)*



          Mlcrotendlpes  sp.  (A)



          Nilothauma bicorn is



          Pagestiella sp.



          Parachi ronomus sp.



          Paralauterborniella nigrohalteralIs

-------
MACRO INVERTEBRATE LIST - HORSE CREEK -  DESOTO  COUNTY - PAGE SIX




          Polypedilum convictum*




          Polyped!lum fa 1 lax




          Polypedilum halterale*




          Polypedilum i11inoense




          Polypedi1 urn sp.



          Pseudochi ronomus  sp.*




          Rheotanytarsus exiguus*




          Stenochi ronomus hilaris



          Tanytarsus  sp. (A)*




          Tanytarsus  sp. (C)*




          Tribelos  fuscicorni s



      Simuli idae




          Simuli urn  s p.*




      Ceratopogonidae



          (Palpomyia  sp. A)*



          (Palpomyia  sp. B)*



          (Palpomyia  sp. C)*



          Atrichopogon sp.




          Forcipomyia sp.




      Tlpulidae



          Tipula sp.




      Culicidae



          Anopheles  sp.



          Culex  sp.




      Stratiomyidae



          Unidenti fled



      (DolIchopodidae)




          Unidentified





                                      3-180

-------
MACRO INVERTEBRATE LIST - HORSE CREEK - DESOTO COUNTY - PAGE SEVEN




CRUSTACEA




  AMPHIPODA




          Hyallela azteca*




  DECAPODA




          Palaemonetes paludosus*



          Procambarus (alleni)



MOLLUSCA



  GASTROPODA



          Amnicola dul1i Johnsoni*




          Ancylidae



          Helisoma sp. (A)*



          Helisoma (Gyraulus) sp.  B*




          Hydrobi idae



          Physa  sp.*



          Pseudosuccinea sp.




  BIVALVIA



          Corbicula man!lens is*



          Eupera cubensis
          Sphaeriidae*



          Unionidae*




ANNELIDA



  OLIGOCHAETA



          Allonais  sp.




          Dero digitata




          Limnodrilus*
          Lumbriculidae



          Nais  sp.*



          Pristina bilongata




          Pristina  lonqareata 1eidy i
                                         J>-f8 I

-------
MACRO INVERTEBRATE LIST - HORSE CREEK - DESOT COUNTY - PAGE EIGHT



          PrlstIna osbornl



          Slaulna append Iculata



          Stylarla foscular Is



  HIRUDINEA



          Helobdella triserlalls



          Mooreobdella mlcrostoma



          Placobdella mult 11Ineata



          Placobdella papllllfera



PLATYHELMINTHES



      PlanarlIdee



NEMATOMORPHA



      Gordlldae



CNIDARIA



  Hydrozoa.



          Hydra



RHYNCHOCOELA



          Prostoma rubrum*

-------
                      MACRO INVERTEBRATE LIST



                    MYAKKA RIVER (SARASOTA CO.)



INSECTA



  TRICHOPTERA



      Hydropsychldae



          Cheumatopsyche  sp.



      Hydroptilidae



          Hydroptl1ia  sp.



          Neotrichla sp.



          Orthotrlchia  sp.



          OxyethIra  sp.



      Leptocertdae



          Nectopsyche  pavida



          Oecet1s sp.  (B)



          Oecetls sp.  (C)



          Oecet1s sp.  (D)



      Polyceotropldidae



          Cyrnellus  fraternus*



          Polycentropus clnereus



      Ph!lopotamidae



          Chlmarra sp,



  EPHEMEROPTERA



      Baetldae



          BaetIs "splnosus"



          CallIbaetls florldanus



      CaenIdae



          Caenls diminuta
         Brachycercus maculatus



     HeptagenlIdae

-------
MACRO INVERTEBRATE LIST - MYAKKA RIVER - SARASOTA COUNTY - PAGE TWO




          Stenacron interpunctatum




          Stenonema exiguum




      Leptophlebi idae




          Choroterpes hubbel1i




  ODONATA




    Anisoptera




      Libellulidae



          Miathyria marcel la




      Macromi idae




          Macromia taeniolata*




    Zygoptera



      Coenagrionidae




          Argia sedula



          Enallagma cardenium*



          Enallagma pollutum




          Ischnura sp.



  COLEOPTERA




      Dryopidae




          (Pelonomus obscurus)




      Elmidae



          Dublraphia (quadrinotata)*




          Stenelmis sp.*




      Gyrinidae



          Dlneutus sp.




  HEMIPTERA




          Pelocorls sp.



          Ranatra sp.




  DIPTERA

-------
MACRO INVERTEBRATE LIST - MYAKKA RIVER - SARASOTA COUNTY - PAGE THREE




      Chi ronomidae



        Tanypodlnae



          Ablabesmyia ma 11ochi




          Ablabesmyia parajanta*



          Ablabesmyia (peleenis)




          Ablabesmyia tarella*



          Coelotanypus concjnnus




          Coelotanypus scapularis*




          Coelotanypus tricolor



          Labrundinia floridana



          Pentaneura  inculta



          Procladius  sp.




        Orthocladiinae



          Corynoneura sp.



          Cricotopus  bicinctus




          Crlcptopus  sp.  I   (Beck)



          Psectrocladius sp.



          Thienemanniella  sp. (A)




          Thienemanniella  sp. (B)




        Chlronominae



          Chi ronomus  carus



          Chlronomus  sp.




          Cladotanytarsus sp. (B)



          Cryptoch1ronomus blarina




          Cryptochi ronomus f u 1vus




          Cryptotendipes



          Dlcrotendipes modestus*




          Dicrotendipes neomodestus*




          Elnfeldia sp.

-------
MACRO INVERTEBRATE LIST - MYAKKA RIVER - SARASOTA COUNTY - PAGE FOUR



          Endochi ronomus nigricans



          Glyptotendipes sp.



          Goeldlchi ronomus holoprasinus



          Harnlschla sp.



          Micropsectra sp. (A)*



          Micropsectra sp. (B)



          Nilothauma blcornis



          Parachlronomus sp.



          Paralauterborniella nigrohalteralis



          Paratanytarsus sp.



          Pedionomus beckae



          Phaeoopsectra flavlpes



          Polypedllum convlctum*



          .Polypedilum halterale*



          Polypedllum 111Inoense



          Pseudochlronomus sp.



          Rheotanytarsus exiguus



          Stenochlronomus  hilarls



          Tanytarsus sp. (A)



          Tanytarsus sp. (C)



          Trlbelos  fusclcornls



          XenochIronomus xenolabls
      SlmulIIdae



          SImu11 urn sp.



      Ceratopogonldae



          (Palpomyia sp.  A)



          (Palpomyla sp.  B)



      Cultcldae

-------
MACRO INVERTEBRATE LIST - MYAKKA RIVER - SARASOTA COUNTY - PAGE  FIVE



          Anopheles sp.



      Tlpulldae



          Meglstocera longlpennls



CRUSTACEA



  AMPHIPODA



          Corophlum sp.  M



          Gammarus sp.*  M



          Grandldlerella bonnerl



          Hyallei a azteca



  ISOPODA



          Cassldlnldea lunlfrons  M



          Cyathura polIta  M



          Exosphaeroma sp.  M



          Munna sp. M



          Sphaeroma terebrans  M



  TANA I DACEA



          (TanaIs sp.) M



  MYSI DACEA



          Hysldopsls  bahla   M



          Mysls sp. M



          Taphromysis louIslanae



  DECAPODA



          Cal1Inectes sapidus  M



          Palaemonetes paludosus*



          Rhlthropanopeus harris!i M



MOLLUSCA



  GASTROPODA



          Amnicola dal1i  Johnson!

-------
MACRO INVERTEBRATE LIST - MYAKKA RIVER - SARASOTA COUNTY -  PAGE  SIX




          Ancylidae*




          Helisoma sp. A*




          Helisoma (Gyraulus)  sp.  B




          Hydrobi idae




          (Littoridinops monroensis)




          Physa  sp.



  BIVALVIA




          Corbicula  man!lens is*



          Eupera cubensis
          Mytilops is leucophaeata M




          Neritina reelivata M




          RangJa cuneata M



          Sphaeridae



ANNELIDA




  OLIGOCHAETA



          Aulodrilus piquet!




          Dero  sp.



          Limnodrilus*



          Pristina leidyi
          Pristina osborni
          Slavina appendiculata



          Stylaria fossularis



  POLYCHAETA



          Boccardia sp.  M



          Laeonereis culverl  M



          Nereis sp. M



  HIRUDINEA



          Helobdella sp.





                                          J-/8B

-------
MACRO INVERTEBRATE LIST - MYAKKA RIVER - SARASOTA COUNTY - PAGE  SEVEN




PLATYHELMINTHES




          Planar!idae



RHYNCAOCOELA




          Prostoma rubrum

-------
                                STATE OF FLORIDA

              DEPARTMENT OF ENVIRONMENTAL REGULATION

                              2600 BLAIR STONE ROAD
                           TWIN TOWERS OFFICE BUILDING
                            TALLAHASSEE, FLORIDA 32301
REUBIN O'D. ASKEW                                                 JOSEPH W. LANDERS, JR.
  GOVERNOR                                       .               SECRETARY
                                       June 19,  1978
           Mr.  Gene McNeill
           U.  S.  Environmental Protection
            Agency
           Region IV
           345 Courtland Street,  N.E.
           Atlanta, Georgia 30308

           Dear Gene:

           We  have completed our  review of the  Draft Areawide  Environ-
           mental Impact Statement on  the Central  Florida  Phosphate
           Industry.  Our comments are as follows:

             1. The impact of future activities of the phosphate  in-
                dustry on the availability of high quality groundwater
                remains largely unknown.   Groundwater modeling utilized   .
                in the study is preliminary and incorporates assump-    (*/-
                tions  regarding aquifer characteristics  and future non-
                industrial water  use that are likely to  be incorrect.
                The interrelationship  between ground and surface  waters
                needs  further investigation.

             2. The projected expansion of the  industry  is believed to
                be understated.  A long-term impact analysis should be  I^J^^I
                made based on the mining of known  resources or reserves.

             3. The economic and  social impacts of resource depletion
                are not addressed.  This is a major concern to the
                state  and should  be a  major concern to national security.
                The issue has been avoided both in the study and  in   LJ-1-I&
                response to questions  during public hearings.

             4. While  data on industry discharge to surface waters and
                surface water quality  are presented in the working
                papers, an assessment  should be made of  the quantita-  k/-
                tive impact of such discharge on water quality.   This
                might  be done using a  modeling  approach.

-------
Mr. Gene McNeill
Page Two
June 19, 1978


  5. Non-point source discharge due to industry operations
     needs to be addressed.  If all non-point source dis-   j^/—i
     charge has been converted to point source, this should
     be described in detail.

  6. Atmospheric conditions, such as temperature inversions,
     have a strong impact on air quality in the study area. lJ-
     This subject deserves further treatment.

  7. Quantitative estimates should be made of sinkhole
     occurrence in the study area.  This should be related
     to geological conditions, surficial dewatering, and    k/-
     piezometric differentials, such that projections can be
     made for future industry operations.

  8. The subject of airborne fluorides needs to be studied
     in greater depth.  The statement on page 1.12 that
     vegetative fluoride levels are inversely dependent on  k/-2.^5
     rainfall does not appear to be supported by the data
     given.  Low fluoride levels are noted in 1972 although
     rainfall was also low in that year.

  9. A discussion of the methods for implementing the pro-         -^
     visions of the proposed action should be included in  U^ -*.*•'
     the final Environmental Impact Statement.

Our comments on the working paper, "Presentation of Effects
Assessment and Impact Analysis Results" (Volume XI), as
expressed in my letter of January 24, 1978 to Mr. John
White, are largely applicable to the draft Environmental
Impact Statement.  A copy of this letter is attached and
should be included in the final Environmental Impact State-
ment along with the present letter.

While we basically agree that the "proposed action" will be
beneficial relative to current activities, it should be
stressed that requirements of the proposed action must
remain flexible to incorporate improved technologies for    ^/-
mining and processing.  It should also be clearly stated in
the final Environmental Impact Statement that the proposed
action in no way precludes the modification of these require-
ments by local, state or federal government should such be
indicated in the future.

-------
Mr. Gene McNeill
Page Three
June 19, 1978
Finally, the above comments are not intended to minimize the
excellent job that EPA and Texas Instruments, Inc. have done
in assimilating and interpreting a vast amount of important
data.  We also recognize that many of our comments pertain
to areas beyond the scope of the present study or that would
require new data beyond the resources of the study.  We
believe, however, that it is of primary importance at this
stage of the project to recognize those areas needing addi-
tional study.
                            Sincerely,
                            Jcusephl'W. Landers, Jr,
                            Secretary
JWL/bs

Attachment

cc:  Loring Lovell
                                  - / f

-------
                               STATE OF FLORIDA

             DEPARTMENT OF ENVIRONMENTAL REGULATION

                         2562 EXECUTIVE CENTER CIRCLE, EAST      . - "' '5\
                              MONTGOMERY BUILDING
                            TALLAHASSEE. FLORIDA 32301   ,,-•'•'

HEUBiNOD ASKEW                   Januarv  24   lB7Q<
-------
Mr. John White
January 24, 1978
Page Two
     3.   The study appears to conclude that consumptive
          groundwatcr use by the industry will not lead to
          significant water shortage or water quality de-   tv" *• *•
          gradation.  We feel that this conclusion is not
          justified due to:

          a.   the preliminary nature of the model analysis;
          b.   questionable assumptions used in the prelim-
               inary modeling (e.g., no increase in water
               use by agriculture and municipalities); and
          c.   a general lack of knowledge of the hydraulic
               characteristics of the aquifer.

     4.   Economic considerations have not been fully evalu-
          ated.  No significant changes in economic impact  k/
          are indicated for the various scenarios (aside
          from No. 2.15).  This is unlikely.

     5.   Environmental effects are averaged over the entire
          study area.  This often results in a conclusion of
          low impact when severe local impacts may result,  ij _ •} -*Q
          Also, cumulative effects are not adequately
          addressed.

     6.   The study does not present a true picture of the
          long term impact of the industry.  Scenario 2.11
          greatly underestimates the projected impact by
          considering only those additional activities for   i
          which permits have been applied or which are in
          the process of DRI preparation or review.  Scenario
          2.11 presents a more realistic picture but is
          considered in much less detail.  No analysis is
          given of potential activities based on phosphate
          deposits and/or company land holdings.  No impacts
          are projected beyond the year 2000.

     7.   The study does not adequately address nonpoint
          source impacts and their control.  .Area 208 plan-
          ning agencies were advised that no significant
          technical studies of phosphate-related topics     bJ-
          would be authorized as they would be covered in
          the EPA study.  This had not been done, thereby
          leaving a large gap in the 208 planning process.
                                    - if 4-

-------
Mr. John White
January 24,  197U
Page Three
     8.    fluorides are probably one of the major threats to
          air quality.   This problem is not addressed in any
          detail.   A recent EPA sponsored study of fluoride
          emissions from chemical process ponds (TRC Report)   .    ~ i
          should be included in the final EIS.   The current W -«-•*/
          sampling and  analysis techniques for  ambient air
          fluorides need to be reevaluated.

     9.    The report states that release of nutrients to
          estuaries will be beneficial.  This has not beenj^"^? <~
          demonstrated  and the converse would be expected
          as :
          a.    Florida estuaries are not phosphorous  limited;
               and                                            •>  7 ?
          b.    the estuaries are over-nutrified at  this    l^~ *-•*•*
               time.
    10.    The impact of flotation and coagulation reagents
          has not been addressed.  These reagents are  ulti-
          mately released to 'the environment.   Their effect
          is unknown and should be investigated.

    11.    The possible control of the rate  of  resource
          depletion has not been addressed.  This is an
          important area for consideration.


B.   The following additional comments are  addressed toward
     EPA staff draft scenario:

     While none of the scenarios considered present a  true
     areawide planning approach, which we feel to be essential,
     the EPA recommended scenario appears to be the most
     feasible and beneficial of the group.   Further comments
     are:

     1.    The information given does not demonstrate that
          the process modifications recommended will be
          feasible under all circumstances.  While process
          changes such as wet rock processing, the elimination
          of slime ponds, and the recovery  to  fluosilicic
          acid and uranium should be implemented, sufficient
          flexibility must be maintained to account fox-
          varying conditions and improved technology.   All
          such processes must be compatible with energy
          considerations and must consider  possible negative
          side effects such as changes in in-plant water
          management and possible toxic environmental  effects.

-------
Mr. John White
January 24, 1978
Page four


     2.   Elimination of above ground slime ponds may not
          completely eliminate the potential for surface and
          groundwater contamination.

     3.   The requirement for complete mining and reclamation
          plans prior to the initiation of mining has been
          dropped from the section on reclamation in the
          December 20, 1977 draft.  This requirement should
          be reinstated.  Plans should include all damming,
          diking, stream rerouting, etc.  Plans for revegeta-
          tion should be included in restoration plans.   A
          mechanism is needed to ensure the enforceability
          of such plans.

     4.   The section dealing with the reclamation of wetlands
          is ambiguous.  We feel that any attempt to categorize
          wetlands in terms of greater or lesser importances
          is, at this time, largely arbitrary.  In general,
          wetlands should be preserved.  Any further destruction
          or modification of those wetlands under federal or
          state regulatory jurisdiction should be done only
          under conditions-of extreme necessity for the
          public interest as determined on a specific case
          basis.

     5.   Effluent limitations should extend to nonpoint as
          well as point sources.

     6.   Water introduced into the Florida Aquifer via
          connector wells should conform to state drinking
          water or groundwater standards.

     7-   Monthly air pollution control inspections would be
          costly.  Semi-annual inspection, stack testing,
          and witnessing of the stack testing performed by
          the industry should be implemented.  Additional
          sampling personnel will be required.  What is
          needed is a cost effectiveness analysis of various
          monitoring alternatives.

     8.   The intensive operations and maintenance program
          existing prior to 1972 was initiated specifically
          to monitor the industry during a period of enforce-
          ment action.  Although a program of this scope is
          not required at this time, the present monitoring
          and field surveillance of the industry should be
          expanded to verify continued compliance.

-------
Mr. John White
Januaey 24,  1978
Page Five
     9.    A more extensive program is needed for the monitor-
          ing of earthen dams used for the impoundment of
          liquid wastes from mining and processing operations,

Also needed in all the scenarios is sound analysis of exist-
ing legal authority to regulate the phosphate industry and
recommendations for additional authority where there is a
need.

An important factor in the final scenario for the draft EIS
should be flexibility.  The EFA Environmental Impact Study
has attempted to provide an overview of the current knowledge
of the environmental impact of the phosphate industry.
There remain, however, vast areas of unknown impact.  These
should be identified to the extent practical.  The study and
final scenarios should serve as a basis for future studies
and a foundation for future planning for the development of
the industry.

My staff has been keeping in close contact with Mr. McNeill
of your staff, and will continue to do so.  We will be glad
to meet and discuss any of these items.  Also, I will be
glad to discuss this matter personally with you if you wish.
                              Josrfpfi W\J Landers, Jr,
                              Secretary
JWL/ns

cc:   James Brindell
     John Bottcher

-------
           3151 third cue. north /ulte 54O • /t. peter/burg, flo. 33713 • (813) 893-2635 tempo (813) 224-938O
June  13,  1978
Mr. John  C.  White
Regional  Administrator
Environmental Protection Agency
Region VI
345 Courtland Street Northeast
Atlanta,  Georgia 30308

Attention:   Mr. Gene McNeil

Subject:   TBRPC Clearinghouse Review No. 101-78;  Draft Areawide EIS
           Central Florida Phosphate Industry,  Tampa Bay Region

Gentlemen:
Please  be advised  that on June  12,  1978 the Tampa Bay Regional Planning
Council officially adopted the  attached report  on the above  referenced
draft Environmental Impact Statement.

In accordance with OMB Circular A-95 (revised)  this brings to a close
the regional clearinghouse review (#101-78) of  the draft EIS.  If you
have any questions regarding this procedure, please feel free to contact me.
Sincerely
tfilliam A.  Ockun?
Director of Pis
WAO/amr

cc:  Manatee County  Planning
     Hillsborough County Planning Commission
Chairman Ron Norman
Mayor, City of Sarasota

Biailonton   C
               Vlco-Chairmnn Jan Plall
               Councilwoman, Clly ol Tampa
                                   Socratary/Troasurot Michael Lodbelter
                                   Commissioner, Pasco County
                 Scott D. Wilson
               Executive Diroctor
Dunodin    Gullport    Largo
             HiiKlioroiHili
                                  Oklsmar   PalmiMto    Rinollns Park
                                 Wiilw   P.isoo  Pinollas  Cotintios
St, Petersburg     Sarasota   Tampa

-------
                                                 Agenda Item #11B
                                                 6/12/78
                  TBRPC CLEARINGHOUSE REVIEW #101-78
             DRAFT AREAWIDE ENVIRONMENTAL IMPACT STATEMENT
                  CENTRAL FLORIDA PHOSPHATE INDUSTRY
 PREPARED BY THE U. S. ENVIRONMENTAL PROTECTION AGENCY, MARCH, 1978
The following presents the comments and recommendations of the Tampa Bay
Regional Planning Council in accordance with OMB Circular A-95 (revised).
This raport is based upon information obtained during the review of six
phosphite related Developments of Regional Impact conducted by the Coun-
cil, the Council's comprehensive planning programs and Water Quality
Management Program and the Central Florida Phosphate Industry EIS.

The Council supports the efforts of the Environmental Protection Agency
in the preparation of the  (draft) Areawide EIS on the Central Florida
Phosphate Industry and finds that it is consistent v/ith the intent of
the Council ' s growth policy as expressed in Future of the Region adopted
in April, 1975, and amended in February, 1977.

The  (draft) Areawide EIS on The Central Florida Phor.phate Industry is
extremely valuable in that it represents the first time that all data
sources regarding the industry have been collected, organized and ana-
lyzed in a single work effort.  The EIS furnishes an important source of
data to supplement the Florida DRI -process and provides further justi-
fication for the designation of Bone Valley as an Area of Critical Con-
cern as provided for  in Chapter  380.05 Florida Statutes and suggested by
the Council in its adopted Regional Comprehensive Plan Guide and the
Rural Development Study, 1974.

In accordance with the requirements and purpose of the federal EIS sys-
tem, the recommendations in the Draft EIS are confined to those controls
that can be implemented through the federal permit system (NPDES, air
quality and dredge and fill) .  The study has analyzed the impacts upon
the industry and the social, physical and biological environment that
could result from permitting new mines and from various modifications or
requirements in these permits.

GENERAL COMMENTS

It has remained a' concern of the Council that the ongoing phosphate
study was based solely on existing data.  Unfortunately, the  (draft) EIS
shows no evidence that additional new data has yet been generated by
this areawide study of the phosphate industry.  As it is too late to
expect the study effort to initiate a new data collection effort, it is
recommended that the final EIS include specific recommendations identi-
fying needed new data collection efforts and identify how these efforts
should be conducted nnd by whom.

-------
The study represents the first effort to analyze water withdrawals of
the industry as a whole and will provide a valuable data base for future
water resource analyses and monitoring efforts.  Most importantly, the
study results support the Council's previously stated concerns over the
cumulative effect of phosphate drawdowns on the Floridan Aquifer.  While
it is recognized, that EPA has no statutory authority to directly control
water withdrawals, it is recommended that the final EIS include recom-
mendations concerning the aggregate drawdown of water withdrawals.

The study supports the Council's conclusions that the major negative
environmental impact of phosphate mining stems from the disturbance or
destruction of essential natural systems and environmental sources.  The
study also supports the Council's concerns over the severe long-term
negative environmental impacts associated with traditional land recla-             __
mation as identified by the Council through its DRI review process early  ** " *. 3 J
in 1976.  However, the study fails to acknowledge, recognize or utilize
the significant advancements that this Council, local governments of the
region, and several of the proposed new mines within the region have made
over the last two years in providing for the substantial mitigation of
these environmental impacts through natural systems reclamation.  It is
recommended that the results of these work efforts be incorporated into
the final EIS.

The study is limited in that it only deals with a 20-year planning hori-
zon; and it only assesses the impacts of existing and proposed mining
activities.  No study or analysis was conducted with respect to the         ._ - _ *
impacts of long-term mining of the extensive deposits of phosphate rock   **
not currently controlled by the mining industry.  As phosphate reserves
are estimated to last for 50 years, it is recommended that this issue be
addressed.

The comments on radiation lack the specificity necessary to guide local
governments in developing reasonable regulations to protect the public
welfare, especially in regard to reclaimed lands in residential or agri-
cultural use, and the quality of the water entering the deep aquifer      (J- \. 5 f
through connector wells.  It is recommended that the final EIS address
the problems of radiation and that a surveillance monitoring program of
radiation levels be considered.

Section 4 of the  (draft) EIS describes measures to mitigate unavoidable
adverse impacts resulting from the permitting of new mines, but does not
include cost estimates of expanded state air and water monitoring pro-
grams and/or land reclamation planning.  It is recommended that the final        _ Q
EIS include cost estimates of the suggested monitoring programs and       W- i. J 0
incorporate recognition of the existing responsibilities and efforts of
local governments in the review, permitting and monitoring of mining
activities.

There  is little reference to the DRI process throughout the Draft  EIS.
It appears that the study effort has failed to  recognize the DRI process
as an  effective tool for management and control of the industry; as well  • •  7_ 3 9
as the role that  the regional planning councils and the Division of
State  Planning can play in assessing and controlling areawide  impacts
                                          ~1 00

-------
from the industry.   Rather,  the Draft EIS recommends site-specific
environmental impact statementstof each new mine.   This would appear not
only to completely  bypass the DRI  process,  but will result in increased
costs to the developer through duplicating efforts, and increased costs
to the public for the development  of the site-specific  EIS.   It is rec-
ommended that the DRI process be recognized as a viable investigative
process and that the State of Florida and the EPA incorporate into the
DRI application appropriate  concerns, not currently addressed in the DRI
process.  This would eliminate the need for a separate  EIS on each new
mine, would result  in simultaneous review by EPA and the regional plan-
ning councils and would substantially reduce expenses to the  developer
and to the public.

While the EIS study effort represents an invaluable first-step in the
examination and assessment of areawide impacts resulting from phosphate
mining, the study has failed to provide guidance and recommendations for (
mechanisms to mitigate the aggregate impacts resulting  from expanded
phosphate mining activities  within the Tampa Bay Region beyond that
which can be implemented through the federal permit system.

•It is recommended that the phosphate mining areas of Central  Florida be
designated by the State as an "Area of Critical State Concern" in accor-
dance with the provision of  Chapter 380.05  Florida Statutes.   The
resulting impacts such as, water consumption, radiation and land recla-
mation are of such  magnitude that  comprehensive, integrated and uniform
management throughout the phosphate mining area is necessary.   The "Area
of Critical State Concern" designation would provide the vehicle whereby
the state, local governments, EPA  a'nd the industry together can develop
the necessary mechanisms and controls to mitigate the aggregate impacts
of mining.
                                  QfrvW^  'W  WMto*£*~.
                                                 Chairman
ATTEST;  / liC/Ml*   x|LAfl/At)rU	
            Secretary/Treasurer
These Comments and Recommendations
were approved by a majority vote of
the Tampa Bay Regional Planning
Council this j 3-tP-day of  ^Tl^f_- , 1978.

-------
                     C O U N T Y   OF  S A n A S O T A

                               riOt  I  !•  /.
                Jt O A U
                            OK   CO M M 1  S  S 1  O N E R S
                 • -t v. • »iiri ti m • r'M«iiit I

                 , ; ; > It HI • I1-f Tl ICf ;

                  ..,-.. > ••.',  r JT •  L « I -in 3

                  ,, . ! II. ^ ."I • I :•,.•(•! J

                 -.-IT i '-err i • r- ? • •• ci :»

                  .-. -Ml • 1C. Mir T"IS'»"- .'T.-K
                 t " lc« r

                 ! ..I •! f *«. I . • .-. • "I.

                 I I'T^.. M. '.'tl : ••!
     ?4.  1978
 Mr.  John  E. Hagan  III,  Chief
 l . I.S.  branch.  Region  IV
 U.S.  Invironmental  Protection Agency
 i-:(j  Courtland Street
 Atlanta,  Georgia   30308

 (var John:

 It was  a  pleasure-meeting  and talking with you briefly  at the
 recent  Phosphate Draft  E.I.S. Workshop at Manatee  Junior  College
 in Dradcnton on May 22,  1978.  As per my promise,  please  find
 enclosed  a transcript of my presentation.

 t know  you will seriously  consider the points brought up  and the
 recommendations which are  made in the presentation.  There are
 \evrral areas of concern ,to Sarasota County, such  as the  impact
 of radiation, economics  and air inversions (see attached  Sarasota
 ,'ournal article) which  we  are currently investigating.  You can
 fM'ect  a  detailed  analysis  of those parameters and others in the
 near  future.

 1 think EPA can be proud of the job which Gene and his  staff have
 done  to date on this very  complex and environmentally important
 Issue.  We very much look  forward to seeing your response to our
 cormcnts and to seeing  the  Environmental  Impact Study in  its final
 form.
Jeffrey r.  Uncer, Ph.D.
Invironmental  Specialist and
Acting Director, Pollution Control  Division

Jtlrrkt
fnc:
*c: E.  E.  Maroney w/enc.
    Cugene McNeill w/enc.
    Florida E.I.S. Phosphate
Advisory  Committee  w/enc.

-------
  PRESENTATION-TO U. S. ENVIRONMENTAL PROTECTION AGr.flCY
  ON THE DRAFT AREA-WIDE ENVIRONMENTAL IMPACT STATEMENT
  CENTRAL FLORIDA PHOSPHATE INDUSTRY, DATED MARCH,  1978

 PUBLIC HEARING, MANATEE JUNIOR COLLEGE,  DRADENTON,  FLORIDA
                       MAY 22, 1978
                         7:00 P.M.
 I am Jeffrey L. Lincer, Ph.D., of 4718 Dunn Drive,  Sarasota.
 I am an Environmental  Specialist for Sarasota County and  am
 appearing this evening at the request of Sarasota  County  to
 comment on the Draft Environmental  Impact Statement as  it
 relates to the phosphate industry in the seven county study
 area.

 We can appreciate the  amount of work and energies  that  went
 into the preparation of this draft  E.I.S.,  and compliment
 EPA's staff and their  consultants for bringing it  to its
 present stage.  There  are,  however,  some serious  concerns
 that Sarasota County has with respect to the draft  E.I.S.
 and these are as follows:

 1) AIR AND WATER POLLUTION

 On page 1.9, a statement is made that, "the industry's  air
 and water emissions are controlled  by collection  devices  or
 other treatment to meet State and Federal effluent  standards."
 This may very well be  the way the system is supposed to work,  .
 however, I think the question which  should  be raised is       U/"
 whether or not the system and equipment is  operating as en-
 visioned to ensure environmental quality.

 With respect to the natural environment and climatic conditions,
 the statement is made  on Page 1.10  that "because  of the area's
 flat terrain and steady winds, instances of extreme air pollution
 in West Central Florida are not common and  occur  primarily only
 in heavily populated or industrialized areas, sucn  as Tampa."
 This may very well be  generally true for West Central Florida, ij-
 but it is our understanding that Sarasota was to  be included
 in this seven county study  area. Discussions with  Meterologists
 at the National Weather Service Station in  Ruskin  indicate that
 inversions occur in this area on a  nightly  basis.   In this light,
and given the average  age of our retirement community,  we feel
 that additional investigation ought  to be made of  what  may be
 unique climatalogical  situations in  this area.

Data do exist in the files  of the National  Weather  Service in
Ruskin which deals with parameters,  such as wind  speed  and
direction, height  of mixing layer,  etc., that relate to  inversions
We would strongly  request that these and other pertinent data be
reviewed to determine  the importance of air inversions  in  and to
the County of Sarasota.

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                             -2-
 We  can  take  little comfort  in  some  of  the  twenty-four hour
 SOo  data as  reported on  Page 1.11.  Although these remain
 beiow critical- levels, analytical problems uncovered by   (J-
 EPA  indicate  that actual  levels could  have been two or
 three times  higher than  those  reported.

 The  1976 fluoride emissions by the  phosphate industry were
 reported at  315 metric (346 short)  tons.  Fluoride levels
 in  vegetation  according  to  the draft E.I.S. are dependent
 upon rainfall  frequency,  thereby explaining the high (60 ppm)
 levels  in 1974.  That would be acceptable to explain the 1974  (
 high fluoride  levels, but the data  presented in Figure 1.3
 indicate a trend of increasing fluoride levels starting in
 1972 with ever-increasing levels of fluoride.  We would like
 to  be sure that these data  are subjected to rigorous, statis-
 tical examination to insure that the conclusions are justified.

 2)  FLUORIDE AND URANIUM

 Recovery of these two compounds based solely on economic
 consideration, as implied on Page 1.72, is totally unacceptable
 in view of documented damage caused by these compounds.   They
 should  be removed from the waste water as a simple matter of
 health  protection.  If a profit results, so much the better for
 the  industry,  but placing such an emphasis on profit is  neither
 justifiable nor desirable from the public or environmental  health
 standpoint.  As a matter of precedent and historical  achievement
 of this action, U.S.S.  Agri -Chemi cal and W. R.  Grace are recov-
 ering fluoride from phosphoric  acid and the Uranium Recovery    u/-
 Corporation, Gardinier,  ? subsidiary of Westinghouse,  Agrico-
 Chemical and Freeport Minerals  are all  performing  a similar re-
 covery for uranium.   With respect  to uranium,  the  savings in
 terms of oil energy equivalence (and,  therefore foreign  depen-
 dence) would be considerable and  1s estimated  to be between 97
 129 million barrels  by  the draft E.I.S., itself.

 3) WATER USE

 With respect to the  recommended connector  wells as suggested on
 Page 1.71,  the utmost caution  1s  encouraged such that  existing  u-
 aquifer  water 1s not  degraded.   If the  use of  floating  dredges, **/~"
 which would  not necessitate de-watering of the  mining  site, can
 be shown to  result 1n less environmental impact than this approach,
 1t should  be encouraged.

 4) WATER QUALITY

A misconception that  has  been  perpetuated  by  the draft  E.I.S.,
as it stands  now,  1s  that EPA  "has  no  direct  legal authority to
change  requirements for  existing  sources".   This  is stated  on  u
 Page 1.74  and 1s virtually hogwash.   One has  but to turn to    *
Section  302  1n Public Law 92-500  to  find the  following  diametri-
cally-opposed statement  which relates  to specific  point  sources,
 "whenever,  1n the  judgment of the  Administrator,  discharges of
pollutants  from a  point  source  or  group of point  sources, with
 the  application of effluent  limitations required  under  Section

-------
1  i
                        -3-
        .  )  of  this  Act,  would J^ntcrfere with the attainment or.
           ,. of  iti.it  w,U(;r_jijJali_ty_ in  a  specific portion of the
        ;,•  h.itrrs  and  j_n_d u_s_trjjji Tu s c s ,  and  the protection of
        *.itiT  ;.uppl ies, agricultural  and industrial  uses, and  £*/
        tntion  and  propagation  of a  balanced population of
        •h,  fish and wildlife,  and allow recreational  activities
        on  (he  w.Uer,  effluent  limitations  (including  alternative
        i  ((,ntrol  strategies) for  such  point  source  or sources
        ,  r-.t.ihl ished.  which  can  reasonably  be expected to contri-
         thr attainment or maintenance  of such water quality."

   t  only  (foes  EPA have the  authority,  they have the legal.
  , ...  ••.ihility  to improve existing effluent  guidelines when
  !,.!ir%  I ike  tjrjj. support said  corrections.

  lii.i)  these lines, Sarasota and the State  of Florida  are
      !y on  record as  saying that  the application  of BPT would
      t  in substantially  more stringent  effluent limitations.

 ',)  HAIUTAT  LOSS AND UETLANDS

 'M' are encouraged to  see reference made (Page 1.21) to the
 I loMdj Department of Natural Resource's classification of
 nixrd forest communities, hammocks and  dry prairies as highly ^/.
 i •r.r_ed_  and "emphasis  being placed on  their importance to
 wildlife.

 Without a doubt, the area's wetlands (i.e. bayheads,  hardwood
 iwanps, cypress swamps,  mangroves, wet  prairies,  fresh water
 narshcs and salt water marshes) are the  area's  most important
 ecosystems  in terms of life support or  productivity.   Hardwood
 wanps and  cypress heads are, we  concur, No.  1  and  No.  2,  re-
 •.prctively, in  importance.  As pointed  out in  the E.I.S.,
 Darnell's 1976 study indicated that the  loss  of wetland habitat
 is the most Important Impact of construction  activity (Page 3.3).

 We also concur that, and  emphasize that, these  Florida  wetlands
 .ire of national significance because they, with some  of the
 sinilarliabi tat 1n Southeast Louisiana, are  the remaining  wetlands
 of significant extent and value 1n the  United  States.

 In speaking  of expanses of natural vegetation  in  "larger parks",
rention  was  made of  the Hlllsborough River State  Park on Page
 1.20,  but  no mention 1s made of the Myakka River  State  Park,
which  is  right  on  one  of  the rivers likely to  be  the  most  Impacted
by planned  phosphate mining  activities.

With  respect to projecting the  changes  1n  land  use  which will
occur  in  the future,  Table 1.31 on Page 1.63  1s misleading.   It
indicates  that  the wetlands  which  represent  178,268 hectares  as
of 1975, will  diminish very  slightly and,  in  fact,  decrease only
i.IS over  the  period  1975 to the year 2000.   In view  of the
Inter-relatedness  of phosphate  deposits and  wetlands, 1t would
seem  unwise  to project such  a minimal change  unless strong

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                             -4-
     !,•!•.MI  .in-  enacted  and  enforced  to  protect  these  critical
         jf  this  projected  decrease  1s based,  1n  any  way,  upon
 ,.,  '•'.,  [.lion  that  a  significant amount of  the  wetlands  can
 .,  Minified  to  their original  structure  and  function,  then,
       ,  thought  ought  to be  given to  the embryonic  state  of the
        M-clamination.   That 1s,  to our .knowledge,  no  one  has yet
 <   <•.<•  on'.irato  true  reclammatlon of a 'hardwood  swamp,  a  cypress
 >
-------
  i
                             -5-
      ,.  ,  of .in .innu.ll composite  sampling  of  all  dischargers
       .-'vrhip .1 picture of the additive  effects,  the frequ.ency
       r',1  year would not be acceptable since  far  too much
        (iuj|ot«nti.il for human health hazard  is great.   Because  much
 ,r  ;r.- d.ita  is still being developed,  with  this  E.I.S.  in mind,
 K-  *i)l reserve comment on this subject until concrete  figures ...
    r.jiiMirr, chronic effects over time, etc. are  available.
 v  no llie research has been done, human hazard has  been indicated.
 .r  will m.ikc additional comments on this subject  when additional
 •!.ii,i ore available, and analyzed.

 '*)  I CCNOMICS.

 Wr would like to point out that inadequate  consideration  has
 fnti yivon to th-e economic burdens which phosphate  mining opera-
 tions places on community services and infra-structure  (substantial
 runiiorjng costs were covered by other speakers).

 On  the National  scale, it seems utterly foolish  to  encourage
 importation of any finite and strategic resource, e.g.  oil  or  ,.
 1'iosphate, when, by doing so, we place ourselves  in  such  a  pre-
 i.irlous position with respect to dependence upon  other  countries.
 In view of the history on oil, we would strongly  recommend  that
 »o rorc phosphate be exported until a  sound National Policy on this
 (.in be established.

 Wr will  save any additional comments on this, radiation,  Inver-
 sions, etc., for our written comments, which will be submitted
 shortly.

 '0) DASIS  OF THE SCENARIO

 The State  of Florida has  already taken steps to  provide more
 stringent  protection against the adverse effects  of  phosphate
Mnlng,  which go beyond Federal requirements.

*•'«• encourage you to  strengthen the scenario 1n the  indicated   .1.
jrcas so  that the  EPA and  other Federal agencies  will be  able
 to nect  their responsibility in reinforcing the  environmental
protection  efforts  of State and Local  Governments.

JU:rkt

-------
    fUtdmg covin tht 24 hour porlod ending at 8 «.m. today


LATEST PSI: 87

Pollutant: Ozone
Health Implications:
Moderate danger to
public health indicated
in today's index.
                      PSI readings above 300 are hazardous to public health.
    The PSI  (Pollutant  Standards Index) count is taken by the Sarasota
Environmental Control Department at four different points around the county,
measuring  the  ozone, particulates. sulphur dioxide,  nitrogen dioxide,  and
carbon monoxide. The daily PSI  coqnt is derived  by taking  the  highest of
the four pollutant  readings. A  reading to 50 would be  well  within  the
"acceptable" range of modern living.
       Data courtesy of The Ssresota County Environmental Control
   ^•v ••    •  ^^^ w  «•«•••» ™ -^^^
   The graph describes a broad picture of the PSI count In  recent years.
Lines compare highest monthly readings for respective years.  Graph curves
do not reflect daily readings.

              1976********************************
              1S77
              1978
300
200
 25

  0

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•


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                      cc
                      CL
                            >
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                                                  01
                                                  V)
O
O
                                                             O
             11 A.M..READINGS

             Temperature g£  ',
                    *'        . ,*
             Dew Point fijj.     .
             Bflrometor
               (inches) 30.06.
             Vicilitlitw A mi1o«
                            X'v:
                                                                                     Over Area jf^
                                                                                          Air'
                                                                                        By PETE JJOBIiNS
                                                                                        Journal Staff \\rlicr
                                                                                     Caution  —  breathing  may
                                                                                   be h.v.arilous to your health.
                                                                                     If you found breathing
                                                                                   tough this morning, you can
                                                                                   expect  the  same trouble
                                                                                   Wednesday  as  moderate to
                                                                                   unhealthy levels of ozone air
                                                                                   pollution have descended, over
                                                                                   the local -rea.
                                                                                     Trapped by an Inversion at
                                                                                   6,000 to 7,000  feet, the  air
                                                                                   pollution  is  being  held in
                                                                                   place  by light and variable
                                                                                   winds.
                                                                                     Joe Plantc, mctcrolo|:M at
                                                                                   the U.S. Weather Service in
                                                                                   Ruskin, said this morning th.n
                                                                                   the inversion should break h>
                                                                                   midday and  allow for  fomo
                                                                                   mixing  of  the  atmospheir
                                                                                   But,  a second  inversion  .it
                                                                                   14,000 feet will   keep the .ur
                                                                                   within that two-mile plus atr.i
                                                                                     Citing  a  weather lui'.lc: •••
                                                                                   from  the  National  We.i!i^i
                                                                                   Sen-ice  office in WaOur-,-;.-
                                                                                   Plante said  parts of !'!.•:..la
                                                                                   are covered by stapn.nt .iir
                                                                                     With winds this nii'in n,: at
                                                                                   five miles an hour JI.MI Vt*
                                                                                   cast  .ind a  seal'ioi'.'i'   t!,.s
                                                                                   afternoon, the |v:;i;!:  . IN .'-X
                                                                                   swirling around the •"'•i  .i"J
                                                                                   not moving out.
                                                                                     Normally,  with  l;nr:Mon<,
                                                                                   winds push the rv'.V.;!!-Ti cut
                                                                                   of the area. Hut, r;..",i- <.,:J
                                                                                   the light winds »h;.-h wi'.l ho
                                                                                   shifting  will   not n\'\c  thc
                                                                                   air mass.
                                                                                     With only  a Mii.ill rJMn,t>
                                                                                 I  of  MinwiM'x  li>i i>.  v> j!N-r
                                                                                 I  OffK'l.llS  .Til' In't I'»JH . !] .,; ||.,.

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                    COUNTY  OF  SARASOTA

                              FLORIDA


                BOARD   OF   COMMISSIONERS
                ANDREW SANDECREN • DISTRICT 1              P.O. BOX 8

                BEVERLY CLAY • DISTRICT 2                8ARASOTA. FLA. 3357B

                JAMES D. NEVILLE • DISTRICT 3              PHONE: BI3/363-IOOO

                JOHN M. SABA, JR. • DISTRICT A

                LARRY RHODES • DISTRICT 5

                ED MARONEY • COUNTY ADMINISTRATOR
22 June 1978
Mr. John E. Hagan, III, Chief
E. I.S. Branch
U.S. Environmental Protection Agency
Region IV
345 Cortland Street, N.E.
Atlanta, Georgia  30308

RE:  Comments on Draft Areawide Environmental Impact Statement
     on the Central Florida Phosphate  Industry

Dear Mr. Hagan:

Please find enclosed additional detailed comments by Sarasota
County on the Draft Areawide Environmental  Impact Statement on
the Central Florida Phosphate Industry.   The comments are in-
tended to strengthen the Final Areawide  EIS and ensure adequate
guidance for subsequent site-specific  environmental impact
statements for particular phosphate mining  projects.

Should you have any questions concerning the enclosed comments,
please do not hesitate to call Dr. Jeffrey  L. Lincer, Environ-
mental Specialist for Sarasota County, telephone number 813-
371-3104.

Your consideration of Sarasota County's  comments is appreciated.

                                  /ery  tnuly youi
RLS:AS:
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COMMENTS ON DRAFT AREAWIDE  PHOSPHATE  EIS



                   BY



             SARASOTA COUNTY



             JUNE 21, 1978
                       3-2/0

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                          WETLANDS
On page 1.72, an Inference is made that category 1  wetlands
(which generally Includes cypress swamps, swamp forests, wet
prairies and certain freshwater marshes) should not be altered.
However, no specific statement to that effect is provided.
It Is our recommendation that such a statement be provided in
order that no misinterpretation of these guidelines is made.

There 1s also a real need to clarify the difference between    (/^— 2. 5TS"
categories 2 and 3 on page 1.72, if they exist.  For Instance,
reference 1s made to "certain isolated non-category wetlands"
1n category 2, which provides some ambiguity.  Under category
3, the statement ts made that "these ^wetlands] are Isolated
and normally intermittent in nature and have insignificant
hydrological functions and minimal life support value".   There
1s considerable value placed on these wetland depressions,
which by themselves may be singularly minor in their Hfe
support value, but in total  may be the major climatological
factor modifying Central Florida's weather.  In addition, the
total edge area or ecotone provided by literally tens  of thou-
sands of these small intermittent ponds contributes greatly to
the Hfe support system of the biological community.

Accordingly, the Draft EIS should be modified to specify that
the cumulative value of these intermittent shallow  depressions
be determined in site-specific efforts prior to automatically
classifying them in category 3.

A strong statement should also be made relative to  the mining
of lands juxtaposed to these wetlands.  That is, we cannot
afford ambiguous wording that would allow us to cut the  "hydro-
logical throats" of these wetlands by mining all around  them,
thereby leaving a pedestal community, which ultimately dries
up because of the neighboring drainage patterns.

It is Important, therefore,  that the Areawide EIS call for an
analysis of the relationship between juxtaposed hydrologic
systems 1n any site-specific EIS.  This comment should be added
to paragraph 4 on page 2.91  or paragraph 3 on page  3.4.

                        WATER QUALITY
There 1s a  temptation to assume that the water quality problem
1s not really a  regional one but a local one.   The Final  EIS
should recognize that even a localized impact  of lowered  water frj
quality on  a recreation-based economy could be devastating.
Recreational activities, such as fishing, swimming, boating
and other water-oriented activities, depend very greatly  on  the
maintenance of high quality water.  One has but to recall the
devastating effects of slime spills on the Peace River to realize
the potential impact of poor water quality on  a recreational-
based economy.

                            -1-

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A specific example of the value of a recreational  resource,
dependent on water quality and quantity, is that of the Myakka
River State Park.   Sarasota County has calculated  that nearly
a quarter of a million people visit this park per  year and
they contribute conservatively one-half million dollars to the
local economy.  As another example of the impact of, in part,
lowered water quality on the recreational economy, the Mote
Marine Laboratory completed an economic analysis of the impact
of the 1971 red tide outbreak on s^ven coastal counties, in-
cluding Sarasota.'  It was estimated that the impact of that
red tide outbreak on the tourist-oriented community was in
excess of twenty million dollars.  This estimate,  like the one
for Myakka State Park, was based on economic data  from the
early 1970's.  Impacts, based on more recent figures, would
undoubtedly be greater.

                         RECLAMATION
As pointed out in the Draft EIS (page 4.2), "mining disturbs
existing land cover, changes land use and redistributes soil
and radioactivity."  The subsequent statements made on pages
4.2 and 4.3, relative to reclamation, are significant steps
in the right direction; however, they seem almost editorial
in nature rather than establishing firm requirements for site-
specific EIS's.  The Final EIS should be modified to specifi-
cally recommend that the provisions of the Federal' Surface
Mining Control and Reclamation Act of 1977 be adopted by
Federal, State and Local agencies to regulate the reclamation
of phosphate strip mining.  This should be incorporated into
the last paragraph on page 4.2.

Although recognition is given to the fact that endangered
species will likely experience great losses (1.26), inadequate
attention is given to possible mitigating efforts (Section 4).
A significant omission, in the form of the U.S.  Fish and Wild-       ...
life Service's report on wildlife (prepared by the Archbold   l-J*"«-*  o
Biological Station), is glaringly obvious.  Recommendations
contained therein should be incorporated, especially with re-
spect to available reclamation and wildlife management tech-
niques.

In the above report, reference should be made to: Section VII,
which deals with existing fish and wildlife management programs
(pages 160-166); Section IX, which deals with the potential
impacts (both direct and indirect) of mining on  fish and wild-
life (pages 1267-1274), and; Section XC, which specifically
addresses reclamation recommendations (pages 1277-1279).
1
Habas,
of the
future
E.  J.  and C.
1971 Florida
occurrences.
K.  Gilbert,  1974.   The economic  effects
Red Tide and the damage it presages  for
 Envir.  Letters 6(2) = 139-147 .
                           -2-

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                         CLIMATOLOGY
Night-time  inversions  and  region-wide high  pressure zones,
which have  similar  effects,  are common occurrences  in this
area.  In addition,  summer cyclonic  weather  patterns  occur
regularly during  the day.   The generalized  concept  of
meteorology presented  in  the Draft  EIS does  not agree with
the existing  local  air modeling and  observations on clima-    U/
tology.   Sea  breezes,  in  fact, are  very complex in  their
meteorological  characteristics and  they do  not always cleanse
themselves  rapidly  of  pollutants as  one might expect.  Factors
which operate contrary to  this intuitive reason are:   1) the
back and  forth  movement of the winds which  make the air sub-
ject to  pollution emissions  more than once;  2) the  very fre-
quent inversions  associated  with coastlines;  and,  3)  a
multitude of  other  micro-meteorological  conditions  found
along this  coastline.

The micro-meteorological  conditions  along  the coastline are
indeed complicated  and should be of  primary  concern when doing
a site-specific EIS  or DRI.   We encourage  you to make a strong
statement in  the  Final EIS (for instance on  page 3.1) indicating
that these  kinds-  of  atmospheric conditions  should  be  attended to
in detail in  the  site-specific' EIS ' s .  Please note  that valuable
atmospheric data  are currently available at  both the  Ruskin
Weather  Station and  at Sarasota County's Pollution  Control  Divi-
sion.

                       AIR MONITORING
With reference  to  figure 1.3 on  page  1.12,  staff  research
since Dr.  Lincer's presentation  of  May 22,  1978,  indicates  that
the basis  for relating  vegetative  fluoride  primarily  to  rain-    /,j-2.6/
fall frequency  is  probably questionable.  Although  there is
an inverse relationship between  rainfall  and  vegetative  fluoride
for the years  1970 through 1974,  the  correlative  relationship
between those  parameters for the  years 1964 through 1970 is
more of a  direct  (or  positive)  relationship.   Vegetative fluoride
levels may be very good indicators  of fluoride emission  and it
would be a mistake to minimize  their  value  with this  Draft  EIS
such that  less  emphasis was placed  on continuing  vegetative
fluoride monitoring.   If a better  monitoring  program  can be
demonstrated, then that should,  of  course,  be used.  However,
we suggest that EPA not discourage  the monitoring of  this
poisonous  substance by  suggesting  that vegetational monitoring
is undesirable  unless an adequate  justification can be made for
such a move and a  better monitoring mechanism can be  recommended.
                          -3-

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                    RADIATION EXPOSURE
The lack of existing data on radiation exposure connected
with phosphate mining is reflected in the Draft EIS,  which
was essentially limited to compiling existing information.
The Final  EIS should clearly acknowledge this limitation
and call for the:  1) development of radiation exposure data
in subsequent site-specific impact statements, as well as,
2) enactment of adequate Federal and State monitoring require-
ments.

As 1t now stands,  the Draft EIS presents the meager existing
data in a manner which improperly suggests that the lack of
Information reduces the probability of radiation exposure
risks resulting from phosphate mining.  A glaring example of
this approach is provided in the Section of the Draft EIS     I
assessing the radiation environment (pages 1.48-1.54) as part
of the  background  and description of the proposed action.
The Draft EIS acknowledges that all radiation exposure is
considered harmful  and the long term effects of low radiation
doses are not fully known (page 1.50).  Nevertheless, the
summary of this Section (page 1.52) is entirely devoted to
statistics which are presented in the summary for the first
time to indicate that Polk County has a  lower lung cancer
mortality rate than other areas of the State.  This is a
correlative relationship and should not  be presented  as cause
and effect.

This arrangement of information is particularly inappropriate
because the body of the report states that radioactive concen-
trations have been  shown to be higher in homes and other
structures built on reclaimed land than  in structures located
on land outside the mineralized phosphate area (pages 1.51-
1.52).   No mention  is made of the estimated increased risks
of lung cancer from living in such homes although such esti-
mates have been calculated.

Although it is recognized that vegetables grown in the Bone
Valley  region have  higher radiation concentrations (page 1.52),
there is no mention anywhere in the Draft EIS of any  need for
information on radiation concentrations  in citrus or  cattle
raised  on reclaimed land or the risks which such products     b
impose  on humans.   This is particularly  disturbing since agri-
culture is one of  the major reclamation  alternatives  for mined
.land.  The Draft EIS states, "there has  been no proof to date
that any activity  of the industry causes a radiation  impact on
the general population" (page 2.63).   Then, after identifying
pathways for radiation impact by the industry, the Draft EIS
merely  observes (page 2.64):

            "Quantifying impacts on the  general
             population by exposure associated
             with  the pathways just listed was
             considered beyond the scope of this
             program."

                           -4-      -> * . sf

-------
In assessing the impact of radiation exposure resulting from
new mining, the Draft EIS asserts, "the impact on the general
population and on phosphate workers .  . .  resulting from the
forecasted increase in mining activity .  .  .  would be insigni-
ficant compared with that under Scenario  2.15" (the Without
Action Alternative).  This seems reassuring,  but it is diff1 -  .  % / ^
cult to understand how the impact of new  mining could be      **  *lp*r
compared to the impact of the Without  Action  Alternative when
there has been no quantification of the radiation exposure
impacts associated with reclaimed land associated with either
Scenario (cf.  pages 2.63-2.64).

Unlike the approach taken to the impacts  of mining upon water
quantity (page 2.74), the Draft EIS did not attempt to con-
sider a "worst-case" approach to radiation  on water quality
or land reclamation due to the lack of date (pages 2.63-2.75).
It is perhaps  natural to de-emphasize  invisible, emotion-arous-
ing dangers which are difficult and expensive to quantify.        5.67
Nevertheless,  the Final EIS should present, in a more forth-  l*/"
right manner,  the limited amount of disturbing information
which is currently available and clearly  call for the develop-
ment of quantified radiation exposure  data  in subsequent site-
specific impact statements as well as  a program of long-term
monitoring.

        SHORT-TERM USE VERSUS LONG-TERM PRODUCTIVITY
Section 5 of the Draft EIS should  provide a  well-ordered
analysis that relates the short-term effects of new phosphate jj. 2.C»6
mining in the study area  to the long-term impacts  that can be
expected from such mining.

The study area is the major domestic supplier of phosphate,  a
non-renewable resource of strategic importance to  the  security
and economy of the entire nation.   Accordingly, this Section
of the Draft EIS should attempt to clearly define  the  policy  ti-i,fc?
choices which must be considered by Federal, State and Local
government officials and  the public in determining what con-
trols should be placed upon phosphate mining in Florida.

The current disjointed juxtaposition of positive and adverse
impacts should be replaced with a  sequential analysis  of  the  . _
short-term and long-term  impacts of new mining in  the  study   ** "
area with respect to the  following:

          A.  Regional Environment

              1.  Soils
              2.  Water resources
              3.  Air resources
              4.  Vegetation
              5.  Wildlife and fisheries
              6.  Land use
              7.  Recreation resources
              8.  Aesthetic values

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          B.   Regional Employment, Economic Activity
              and Tax Revenues

          C.   Domestic Fertilizer Supplies and Prices

          D.   Importation of Phosphate and the National
              Balance of Payments

All of the above factors are currently addressed by Section 5
of the Draft  EIS in less than two double-spaced pages by
employing vague generalities and unstated assumptions.*       k/-
The Council  on Environmental Quality has recently called for
greater emphasis on analysis in the EIS process.  The need for
expanded, more vigorous analysis in this portion of the Draft
EIS is both  obvious and imperative.

* As an example, Section 5 begins by asserting that there is a
"tradeoff" between adverse environmental impacts versus "low-
priced fertilizer for enhanced agricultural production" as well
as "reduction in U.S. trade deficits."  In the context of
analyzing the short-term and long-term impacts of new mining, rj
this approach amounts to comparing environmental "apples" with
economic "oranges."  There appears to be no basis in the Draft
EIS for the  assumption that new mining will result in "low-
priced fertilizer" for either domestic or foreign agricultural
production,  nor is there any serious attempt to address short-
term versus  long-term effects of more rapid depletion of domestic
phosphate supplies upon the nation's trade deficit.

                        IMPLEMENTATION
The implementation of the recommendations of the Final  EIS is
of paramount concern.  Accordingly,  the EPA should  clearly
identify: 1) the specific agencies which will  be responsible  (^-
for implementing actions, and; 2} the specific actions  called
for by the Final EIS.

A particularly critical facet of the area-wide study was the
impacts predicted by the chosen scenario.  The predicted impact
on water quality assumes that the industry will  have to meet
Florida effluent guidelines.  Since  the Draft  EIS recognizes
the necessity of applying Florida guidelines,  which are more  U/~
stringent than the Federal  effluent  guidelines,  and in  order
that future impacts not exceed predicted impacts on water quality,
the Final EIS should recommend that  the Federal  government adopt
Florida standards.

Because of limitations in funding, scope of study and/or lack
of data, many areas of concern have  been left  up to the site-     i_"7iT
specific EIS's.   It is, therefore, recommended that a separate I*'"*'
Section be devoted to specifying critical matters which must be
addressed in the site-specific efforts.

                            -6-

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It would  not  be  the  intent  of  this  Section  to  cast  in  concrete
the scope nor  the  technical  approach  to  all  site-specific  EIS's,
for each  one  will  have  to address  some  problems  unique to  that
site,  but merely to  make  sure  that  important parameters,  which
are identified in  the Area-wide  EIS,  are not overlooked.   These
considerations are currently scattered  throughout  the  Draft EIS
text in a manner which  is helpful  to  neither the industry  nor
the regulating agencies.

The implementation of reclamation  is  of  particular  importance.
The Final  EIS  should  identify  means for  preserving  the benefits
of reclamation,  once  reclamation  has  been achieved.   It would
be disappointing for  instance  if,  after  large  sums  of  money had
been expended  by the  industry  and  by  the regulatory  and advisory
agencies  to restore  particularly  valuable habitat,  reclaimed
land were to  be  sold  for  some  land-use  which would,  once again,
result in habitat  devastation.  Therefore,  the Final  EIS should
recommend mechanisms, such  as  the  use of restrictive covenants,
to insure the maintenance and  protection of  ecologically signi-
ficant habitats, including  wetlands.
                            -7-

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 (DIPIOMATE OF AMERICAN BOARD OF ALLERGV AND IMMUNOLOGY)
MARY L. IELKS, M.D.
   PEDIATRICS
 1700 SOUTH OSPREY
SARASOTA, FLORIDA 3JS79

TELEPHONE {(13) 366-2002


 June 20, 1978
                                                          (OIPLOMATE OF AMERICAN BOARD OF PEDIATRICS)
Mr. John Hagan
U. S. EPA Region IV
345 Courtland St
Atlanta, Oa. 30308

Dear Mr. Hagan:

Re: Phosphate EIS

1*  The health effects of  radiation from the phosphate mining have not /-/-7"77
b een adequately investigated.   For instance, no castigation of the    **^
recent omission of reaulremanttfdEralkaiinizatlon of washings which would
decrease radiation hazards.  'Immediate economies' seems to dominate the
policy of your present administration without regard of healtji effects or
eventual costs.

2.  The impact of air pollution of power development for the activity of
mining has not been addressed.   The sulfur oxides which when exposed to U/
the high ozone will givd serious health hazards of sulfates to populations
who will not benefit from  the rewards of the profits of the activity.
Power sources have additional hazards since energy problems have shifted, to
oho fuels with higher sulfur  contents.  Florida is a delicate environment
whore, heat, humidity and  sunlight will increase the reactivity of this
combination of air pollutants to be more hazardous.

3*  The monitoring of florides  has been inadequate and there is little k'~ *  '  '
control of its emtsstonnfrom the gypsum ponds.

4,  The emotional appeal of fertilizer to feed the hungry world is full k) -
of fallacies.  The state of Florida has a very small percent of the available
phosphate of the world.  Phosphate fertilizer is not the only means of
increasing productivity of soill  There is poor distribution of the already
over productive materials  with  waste i n our fertilized farmlands.  The
uncontrolled mining activity taking place today, resulting in vast wasteland
areas, with removal of most of  our resources of phosphates to a depleted
state, with simultaneous health hazards, water depletion and destruction
of a naturally beautiful land,  to gain a few-short lived economic deals,
will reveal the lack of .concern we have for our cottntryJs futoUBte.

Please consider these omissions and recommend further appraisal of
the phosphate mining activity with some federal scrutiny of this industry
which has powerful lobbyists to tend to blind adequate state monitoring.
(In all fairness, only the federal level can access radiation problems,
since the state is lacking personnel in this field.).

                                 Sincerely,
                                 M. L. Jelks, M.D.

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General Development Utilities. Inc.
n
 V.	i

                                 June 22,  1978
      Mr. John Hagen  III
      Chief, EIS Branch
      Environmental Protection Agency
      Region IV
      345 Courtland St.,  N.E.
      Atlanta, GA  30308

      Dear Mr. Hagen:

      General Development Utilities,  Inc.  has under construction
      a regional water treatment plant on the Peace River in DeSoto
      County, Florida.  The plant-will be placed in operation in
      early 1979.

      A review of  the Draft Areawide  Environmental Impact State-
      ment on the  Central Florida Phosphate Industry causes us
      great concern.  Some of  these concerns were independently
      addressed by other  speakers at  the three public hearings.
      Comments follow on  two areas of vital interest to the
      Utility, water  quality and quantity in the Peace River.

      Section 3 of the Draft Areawide Environmental Impact State-
      ment refers  to  parts of  other scenarios that modify Sce-
      nario 2.11  (Permit  Existing and New Sources) as well as
      other mitigative measures.  Supplements of impacts are
      provided in  Section 3 for impacts described in Section 2.D.

      As a downstream user of  Myakkahatchee Creek (Big Slough)
      and a future user  (early 1979)  of the Peace River, General
      Development  Utilities, Inc. is  concerned about water
      quantity and quality. The impacts described in the draft
      about quantity  are  not considered to be adequately or
      clearly represented.  Since quantity and quality may be
      related, a similar  concern exists for quality.

      On page 3.4, 3a briefly  discusses quantity by informing
      the reader that decreased surface flow is expected, followed
      by an increase.  No time periods are mentioned.  No quanti-
      ties are estimated.   The reader must then refer to Sec-
      tion 2.D to  glean more information.
	J-2S?
1111 Soulli Biivshoti'Oiiw. MI.IIIII. FkMii1,i :i:ii:il, ti'li'tilumi' LWS XiO U
-------
Mr. John Hagen III
Page 2
June 22, 1978


On page 2.56, a statement was made concerning the net loss
of surface runoff due to evaporation in containments or
impoundments.  These losses were estimated to be 15 cubic
feet per second (c.f.s.) by 1985 and 21 c.f.s. by 2000 in
the Peace River.  Some questions arise from these estimates.

     1.  Are the estimates annual numbers?
     2.  Do these estimates vary seasonally?  How much?
     3.  What are the estimates for direct loss due to   ^J — i. (J /
         containment or impoundment?
     4.  How will reclaimation affect the quantity and
         quality of runoff?  How much more or less?

Similar questions exist for the required reduced water usage
scenario, particularly with regard to the impact on down-   ^ ^ > g
stream users about quantity that is retained and must be    **^
addressed in much more detail to assess impacts on downstream
users.

On pg.257 EPA suggests that the alteration of stream flow
through 1985 is minor, but by 2000 noticable.  The draft
also states that changes in freshwater discharge to estuaries
are relatively minor and obscured by variation in normal     .  5 * ?
discharge.  This statement of virtually no impact to the   ^/ "
estuary is puzzling.  Many agencies, state and federal, are
concerned with the impact of water loss to estuaries and some
have required extensive studies for losses of freshwater.
EPA should consider again their position about impact to
Charlotte Harbor and whether the topic deserves study as
part of the generic impact of the phosphate industry.

One secondary effect of the southward expansion of the phos-
phate industry is increased use of electricity.  The proposed
Florida Power and Light power plant in DeSoto County near
the Peace River would supply some of the new electrical demand.
At the same time,  large amounts of water would be diverted
from the Peace River to a man-made lake for cooling purposes.
This impact on water quantity in the Peace River caused by  ii-
power needs of the phosphate industry is not adequately
assessed either for downstream use or environmental changes
that may occur in Charlotte Harbor.

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Mr. John Hagen III
Page 3
June 22, 1978


General Development Utilities, Inc. has a potential service
area that would require it to serve approximately 300,000
persons from its Peace River Water Plant.  The interests
of these utility customers in obtaining a sufficient quantity
of safe potable water is directly tied to activities affect-
ing the Peace River and we request that the Draft Areawide
Environmental Impact Statement on the Central Florida Phos-
phate Industry adequately address protection of these interests,

                          Sincerely yours,
                          Harold E.  Schmidt
                          President
HES:1mb

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                                                                NtW&ANO PUeUlAfFAIM

                                                                H.T.'U SMITH
                                                                  l Q SMITH
                                                                  OaiAl KttlMt'.H
VOLUME  XZl>  NUMBER 39                             FEBRUARY 21, 1978


                 BREKSTER PHOSPHATE KEEPING  PROMISES?
You would have thought  that after the big  spill  which muddied  the
Alafia  River last August,  the Brewster phosphate company would have
leaned  over backward  to  prove that it was  a  freakish, one-tine ac-
cident,  not an indication  of the company's true  attitude toward  the
environment and other people's rights.  But  now  comes a report frort
the Hillsborough County  planning staff which claims that, to quote
directly,

      "The most recent instances of non-compliance,  rather than
      being isolated violations, are part of  a pattern which
      spans two years."

Among the recent instances referred to are the building of an  800-
foot  dam, the destruction  of 50 acres of trees,  and the excavation
of a  creekbed.  The planning staff report  claina the Brewster  firm
violated both the county mining ordinance  and the commitments  it
mads  to get a state permit as a "Development of  Regional Impact."
                                     It also seens to violate promises
              ART CARD               made to the public in this  booklet
                                     published at  the time, which  re-
             OF BOOKLET              peatedly  states  that flood  plains
                                     will not  bs altered or affected.

We understand that in any  project of this  mngz'.ituda. . .mining 50-mi.llion
tons  of ore from almost  Cen-r.housand acres of land... there are bound
to be occasional problems, even with the best of intent.  But  these
incidents seem to °o  beyond that.  We wore willing  to give Brewster
the benefit of the doubt after last sunnier's spill.  Now we suggest
it's  time that this company and all ot'rnrs  mining the land in this area,
be put  on notice tbat making promises is not enough.  They must  also
live  up to them.

-------
          United States Department of the Interior

                    OFFICE OF THE SECRETARY
                     WASHINGTON, D.C.  20240
 In Reply Refer To:
 ER-78/339
 Mr.  John  C. White
 Regional  Administrator
 U.S.  Environmental Protection Agency
 Region IV
 345  Court land  Street
.Atlanta,  Georgia  30308

 Dear Mr.  White:

 We have reviewed the draft statement for the Central Florida
 Phosphate Industry sent to us April 7, 1978.  We have exten-
 sive and  serious concerns as to the adequacy of the document
 from both our  jurisdictional responsibilities and our several
 areas of  expertise.  Interior reviewers were unanimous in
 their criticism that the organization and analysis in the
 statement were highly confusing.

 The  statement  should indicate that review and approval of
 any  New Source NPDES or Section 401 permits require consulta-
 tion with our  Fish and Wildlife Service.  The statement
 should also reflect recognition of EPA's responsibilities,
 and  indicate how they will be discharged, under the following
 laws or Executive Orders:

     Endangered Species Act of 1973

     E.G.  11593g "Protection and Enhancement of the
     Cultural Environment"

     E.O.  1190, "Protection of Wetlands"

.The  statement  does not present a clear, coherent identifica-
 tion and  analysis of impacts that may be reasonably expected
 to occur  on resources of the area.  This is particularly     lJ
 true in regard to archeological and historic values; recrea-
 tion values, including a possible scenic river, and projects
 established with the aid of Land and Water Conservation Funds;
 water resources, including both groundwater and surface water;

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and wildlife.  Discussion of the hazards and possible impacts
from radioactivity are especially confused and ambiguous.

The statement (pp. 1-70, U-3) that the Department of the
Interior intends to apply regulations under the Surface Min-
ing Control and Reclamation Act of 1977 to any surface mining
involving federally controlled lands is in error.  Section
709(a) of the Surface Mining Control and Reclamation Act of
1977 (30 USC 1201) directs the Chairman of CEQ to contract  j^-if
with the National Academy of Sciences-National Academy of
Engineering or other Government agencies or private groups
"for an in-depth study of current and developing technology
for surface and open pit mining and reclamation for minerals
other than coal designed to assist in the establishment of
effective and reasonable regulation of surface and open pit
mining and reclamation for minerals other than coal."  The
Department of the Interior is awaiting the results of this
study.

Finally, the presentation of the proposed action, on pages
1.70-1.72, is highly misleading.  The reader is led to
believe that rock-drying processing at beneficiation plants
and conventional aboveground slime-disposal areas will be
eliminated and that fluorine compounds and uranium oxide  (J - I 1 f
will be recovered.  However, in some cases, it may not be
possible for present purchasers of phosphate rock to use the
wet material.  Elimination of the aboveground slime-disposal
areas is dependent on the sand-spray dewatering system devel-
oped by Brewster Phosphate Company.  This method is dependent
on the sand/clay makeup of the matrix and cannot be
universally applied.  The impact analysis (pp. 3.8 and 3.9)
indicates that some of the uranium may be recovered, but no
recovery of the fluorine is expected.  Recovery of these is
entirely dependent on economics.

We are providing extensive comments and suggestions for your
consideration and use in preparing the final statement.  In
this regard, we strongly urge that EPA reconsider the decision,
as expressed in the transmittal letter of April 7, 1978, to
not reprint material contained in the draft statement.
Because of the ambiguities, disconnected analysis, and exten-
sive errors in the draft, it is doubtful that NEPA require-
ments can be satisfied in this case by limited revisions and
                                       8

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responses...  We will be glad to assist as necessary in the
areas where we have expressed concerns.

We appreciate the opportunity to review this statement.

                              Sincerely,



                              SECRETARY


Enclosures

-------
                 Review and Comments on DBS for
               Central Florida Phosphate Industry


The following comments elaborate on and provide specific
details as to the concerns identified in our letter.   The
order of discussion generally follows that in the letter-

Archeological and Historical Sites

The statement acknowledges some 701 known archeological and
historical sites in the survey area.  At a minimum, four
could be permanently altered or destroyed if mined.  However,
we find no mention of "systematic survey" which could sub-
stantially increase the number of archeological and histor-^»v,1 X.
leal sites impacted by the proposed action.  Consequently,
the concerns of the Florida Division of Archives, History and
Records Management appear valid in that discussion of mitiga-
tive measures to protect Florida's archeological and histor-
ical resources is almost non-existent and grossly insufficient.
We, therefore, recommend that the final environmental impact
statement contain in-depth discussion of alternatives to
include the avoidance of any impact on Florida's archeological
resources.  We suggest that the Environmental Protection
Agency consult with the State Historical Preservation Officer,
Advisory Council on Historic Preservation, and the Office of
Archeology and Historic Preservation to determine regulations
and guidelines for the protection of cultural resources.

In conclusion, the 7-county area described in this report is
sensitive as far as paleontological resources are concerned.
The final ES should have some reference to the presence of
these resources as well as suggested mitigating measures to
protect them.  Dr. Webb (Florida State Museum in Gainesville)
should be able to provide information on this subject.

Recreational Resources

With regard to impact on recreational opportunities, the exact
locations of the slime ponds are not identified.  However,
discussion in the statement indicates that slime placement
poses a potential for adverse impact on the water quality and
thereby the recreational potential of Peace River and Lake   fcX-
Myakka.  Please note that Peace River meets all requirements
for scenic river classification.  Further, Lake Myakka is con-
sidered to be of major recreational significance and is now
the site of recreational projects established with help of
the Land and Water Conservation Fund.  Consequently,,the pro-
posal's actual impact on recreation opportunities cannot be
determined without specific information; e.g. , maps depicting
recreational opportunities in relation to slime pond placement.

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jgater Resources

The changes in potentiometric head likely to result^from
various alternative scenarios are discussed in detail, but
potential impacts of these changes should be given more con-
sideration.  These are saltwater encroachment, upconing of   ^j
mineralized water, changes in lake levels in the Ridge area,
and reduction in available freshwater supply in coastal areas
through interception of ground-water flow before it reaches
these areas.  These are the real concerns in the area; the
lowered heads are of concern principally because they may
lead to one or more of those impacts.

Reference is made in several places to increasing the potential
for saltwater encroachment, and to "theoretical" saltwater
encroachment (e.g., p. 64 through 2.67, 2.74, 2.75),  but no
assessment is given as to the likely reality, magnitude, or
seriousness of this phenomenon.  Quite likely, data are not
available to assess quantitatively the times, distances, and
locations of possible encroachment, but we believe the
investigators have the responsibility of making some judgments
and of putting this possibility in perspective.  If no judg-
ment can be made, because of lack of data or understanding of
the system, this, too, should be stated, indicating that salt-
water encroachment remains a possibility that needs further
evaluation.

The analysis of effects on the ground-water resources of
Manatee and Sarasota Counties appears to be restricted to an
assessment of changes in the potentiometric surfaces of the
artesian or confined aquifers.  We suggest that it should
also include an evaluation of the possibility for interception
or "short circuiting" of unconfined ground-water flow toward
Manatee and Sarasota Counties as a result of pumping for
phosphate mines.

Another problem related to groundwater is contamination of
the aquifer.  This may result in two ways.  First, mineraliza-
tion of groundwater is a definite possibility.  This can occur
through depletion of the aquifer, as was alluded to above, or
by seepage from slime ponds and cooling-water ponds.   Secondly,
radiation contamination of the groundwater is a legitimate con-
cern.  The DES states that the efficiency of an "impervious
membrane lining" to be used in ponds cannot be projected,    tJ
because insufficient data exists.  Since this could have very
significant effects on the aquifer and the areas dependent on
its supply and purity (e.g., springs originating in the
aquifer discharge into the Hillsborough and Alafia Rivers
which, in turn, serve as supplies for the local population),
                             - 2 -

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the potential for radiation contamination should be examined
in much greater detail.  This is obviously not the sort of
problem one would want to deal with after the fact; conse-
quently, mineralization .and radiation impacts on groundwater
should be fully evaluated in upcoming environmental statements.

Surface water is also not dealt with as completely as it
might have been.  The natural waters of westcentral Florida
are already above "recommended" levels for phosphorous       ..
(p. 1.28), so additions from the new mines would speed the   &/-
eutrophication process.  Moreover, because several cities and
counties rely on surface flows for water supplies, their main-
tenance is critically important.  The DES indicates that
pollution control equipment will be employed to prevent dam-
age to surface flows, but there is no elaboration concerning
the exact nature of this equipment.  What it is, availability,
how it works, and how successful has it been in the past are
the type of questions that would provide the supporting
information necessary to fully evaluate this impact.

The DES also points out the potential for extremely damaging
pollution loading to surface water through failure of a slime-
pond dike (p. 183).  Since this might impact on Class I      LJ-
waters, preventing such an occurrence is vitally important.
The statement details the methods that will be used to control
this situation (p. 4.4), but more information about the actual
systems would be useful to assess their capabilities and to
suggest alternatives.

Wildlife Resources

Some of the habitat types (particularly those crucial to wild-
life and endangered species) should be mapped.  Much attention
is given to wetlands in the DES, but little definition is
given to important terrestrial habitat areas that may need 1.1-
protection.

We feel that Section 3 in the statement is most deficient in
the summarizing the impacts on fauna and flora outside of
wetlands and the man-made environment.  Plate 1 shows that only
a small percentage of the area is wetlands.  While it is true
that phosphate mining will have its greatest impacts on wet-
lands, the impacts on other communities need to be more
thoroughly addressed in the statement.

An extensive study for the FWS by the Archbold Biological
Station of Lake Placid, Florida, drew a number of important tj *. \O O
conclusions regarding the continuation of phosphate mining
into new portions of the study area and current reclamation
                              -  3  -

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practice on these mined lands.  The following is a summary
by the FWS of these conclusions:

1.  Most phosphate mining activities are adverse to wild-
    life.

2.  Present reclamation techniques favor a reduction of
    species diversity and establishment of a less valuable
    assemblage of generalized species.

3.  Mining effects on wildlife include some impacts far
    removed from the actual mining site.

4.  Those species having a restricted habitat (ecologically
    sensitive) are affected the most.

5.  Continued mining development, combined with other
    habitat losses, would result in a serious reduction in
    diversity and abundance of wildlife in the study area.

6.  Although recent reclamation proposals provide methods
    for greater variety of habitat, these remain largely
    unimplemented.

7.  Reclamation directed toward establishment of few adapt-
    able species would do little to minimize mining impacts
    in the area.

8.  Unless proper land use controls are implemented to pre-
    vent degradation of habitat after reclamation, any
    improved reclamation efforts would be useless.

Special actions on the local, county, regional, and State
level will be required in addition to any EPA regulatory
conditions imposed on new sources.  Changes in reclamation
practice are needed on currently disturbed mined lands
before additional habitat losses occur in new mining areas.

An extensive proposal by the FWS described in a recent paper
entitled, "Recommendations on Central Florida Phosphate," is
being circulated in the study area.  A cooperative develop-
ment and demonstration program on reclaiming phosphate mined
lands to wetlands and forest habitats is now underway in the
study area.  The Florida Game and Fresh Water Fish Commission
is the lead agency on this program.  Partial funding and
participation is also being provided by the FWS, the Florida
Phosphate Council, and some phosphate companies.  Other groups,
agencies, and phosphate companies may also join the effort
soon.

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Radioactivity Hazards                                  ij — £ O \

The treatment of radiation effects of the industry is confus-
ing.  This may be due to. the scattering of radiation data
throughout the statement and the peculiar use of the term,
"background radiation," as including the effects of the
industry.  There is no single section where all radiation
effects of the industry are evaluated together and where
they are compared to a background radiation not affected by
the industry.  Some quantitative data on radiation exposure
is presented here and there, but it is also stated that
quantifying population exposures "was considered beyond the
scope of this program" (p. 2.64, par. 1).  The reason why a
comprehensive quantitative analysis was not considered neces-
sary is not given.  Presumably the radiation effects of the
industry do not significantly raise population exposures and
presumably this can be adequately demonstrated by the avail-
able data.  However, this is not made explicit in the report.

Thus, discussion of exposure via the airpathway in Section 1
provides some quantitative data from two separate sources
but provides no measure by which these effects can be added,
nor does it assess their significance (p. 1.51, par. 1).  It
is also not clear whether the data in Table 1.18 (p. 1.51)
refers to total emissions from a typical plant or from the
whole industry.  In Section 3, radium-226 emissions from a
single dryer are given (p. 3.6, par. 1) that are more than
10 times greater than the total shown in Table 1.18 as
"associated with chemical processing."

The radiation effects at processing plants are not adequately
discussed.  Gyp-stacks or gyp-ponds at plants are variously
mentioned but their long-term effects are nowhere discussed.
Gypsum is indicated to contain elevated concentration of
radium-226 and the long-term management or reclamation of the
gyp-stacks and gyp-ponds therefore represents an effect in the
area that will persist long after the processing plants have
ceased operation.  Jurisdiction over the disposal of these
wastes should also be discussed.

Housing built on reclaimed minelands is indicated to potenti-
ally expose inhabitants to elevated levels of radon-222 and
its daughter products (p. 1.51).  Techniques to mitigate
this problem are mentioned (p. 2.86, par- 3) but the juris-
diction or regulatory authority to assure mitigation is not
discussed.

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Phosphate Data and Technology

The Bureau of Mines has recently updated phosphate reserve
and resource data.  Some of the tables shown in the study
should be replaced with updated tables currently available.
Several places such as Table 2.1, page 2.11, use 1975 data'
and pages 1.3 and 2.10 use 1977 data.  The attached Table 2,
dated May 1978, shows an increase in United States reserves
of about 1 billion metric tons compared with Table 2.1.    *».. 5 Q
Also attached are reserve data for Central Florida.  The
increase of more than 400 million metric tons should be
reflected in Table 1.1, page 1.3, and Figure 2.3, page 2.9,
of the study.

It is proposed on page 1.70 that new sources eliminate the
rock drying processing at benefication plants and transport
wet (6 to 20 percent moisture) rock to chemical plants.  This
could curtail our phosphate exports and have an adverse
impact on our balance of payments.

In 1977 the ,U.S. exported 13.2 million metric tons of phos-  bJ-i
phate rock.  All of this exported rock was dried except for
68,000 metric tons exported for use in electric furnaces in
Canada.  Ordinarily, overseas consumers do not have facilities
to wet grind or dry imported wet phosphate rock.  These con-
sumers would be faced with alternatives to construct terminals
for handling wet rock and drying facilities or turning to
other sources for dry rock.  Our export markets may then be
forced to choose between building facilities to handle and
dry the wet rock and buying from another source.

The statement on page 1.51, "Additional exposure is possible
due to dust generated by the drying of phosphate rock and by
chemical processing" is not supported by available data.     tJ-J
Emissions of particulate matter and any associated detectable
radiation are controlled with wet scrubbers.  The proposal to
eliminate drying plants at all new mines in Florida assumes
that systems exist to ship wet rock to export markets.
Although the benefits of wet rock grinding are clear if the
phosphoric acid plant is designed to digest wet rock, it is
also clear that restricting drying of phosphate rock may
exclude foreign markets for new mines in Florida and decrease
the competitive position of exporters of rock from Florida.
Also,  it is not clear how wet ground rock can be shipped to
port,  how it can be loaded on a vessel, and how, after the
vessel leaves Florida's temperate climate, frozen ground wet
rock can be unloaded and stored in subfreezing climates
either in the Orient or Western Europe.  It should be noted
that wet scrubbers or bag houses are available to control
emissions from rock grinding and drying plants.
                           - 6 -

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The proposal to use a "dry conveyor" for deslimed matrix from
mine to beneficiation plant cannot be supported by the recent
history of this conveyor at the Fort Lonesome mine.  The phos-
phate industry has stored waste clay slimes behind dams in
mined-out pits because it has been the most economical pro-
cedure to follow.  When, on occasion in the past, a dam failed
because of incorrect construction or .inadequate maintenance,
the impact was serious on surrounding waters.  With proper
construction techniques and adequate maintenance programs no if
significant dam failure has occurred in recent years.  The
technology to rapidly dewater the colloidal clays has been
elusive to both government and industry investigators.  Some
success has been achieved by Brewster's sand-spray system and
the Bureau of Mines' efforts to classify the slimes further
and recover a concentrate from the coarse fraction by flota-
tion.  Alternative systems to return waste clays to mined-
out areas will be developed, particularly if the economics
become more attractive.

The Bureau of Mines has concern for the lost P^S values ^n
the waste clays.  Depending on the dewatering system used,
these values could be lost forever.  At its Tuscaloosa
Metallurgy Research Center, the Bureau of Mines has current
research underway toward recovering Po^5 values from the
slimes.  State Legislation (H.B. 1370; also addresses this /^/-
important point "to establish methods for better and more
efficient phosphate recovery mining and processing in this
State as it may determine most beneficial to the economy,
environment, and way of life of the citizen of the State."
The categorical elimination of above ground slimes disposal
areas may not be in the best interest of the United States
until exhaustive research is conducted to determine if these
phosphate values can be recovered.

In 1978, the Governor of Florida created the "Phosphate
Land Reclamation Study Commission" to report March 1, 1978,
to the Governor and the Florida Legislature and to make
recommendations toward solving some of the environmental    l*J
problems associated with phosphate mining.  These recommenda-
tions were included in a revision (H.B. 1370) of the Florida
statutes,"The Severance Tax Act," signed into law on June 1,
1978.  This set up the Florida Institute of Phosphate Research
funded by a portion of the severance tax "to conduct or cause
to be conducted thorough and comprehensive study of phosphatic
clay disposal and utilization as a part of phosphate mining,
together with all environmental or land use related thereto."
We suggest that the final environmental impact statement
recommendation for this element correspond with subject legis-
lation.
                             - 7 -

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A USGS studyi/ concludes that phosphate mines in Central  (J-%00
Florida have not had an adverse effect on the supply of
water from the Floridan aquifer available to Sarasota County.

Finally, the expansion of the industry in Manatee, Hardee,
and DeSoto Counties that was opposed by Sarasota County, has
not occurred because of cost increases and a decline in     fJ-
prices in both domestic and international markets.  There   ^
is no question about the fact that there is an oversupply of
phosphate rocks in the world and it is a factor in restrict-
ing expansion in most producing countries.

General

We believe it would be most helpful to provide a brief back-
ground and status of reclamation practices and a discussion
of the county and State regulatory authorities and require- jj_
ments affecting phosphate mining.  More than 80 percent of
the mined or minable areas in Florida are on private lands.
The State of Florida has, until recently, played only a
limited role in developing regulations and stipulating mining
and reclamation standards.  The first State mandatory reclama-
tion requirements came as recently as 1975 and even with these
requirements the surface owner plays a very central role in
post mining land use choices.  Since most of the private lands
are owned by mining companies many critical reclamation deci-
sions are made by the mining companies.  However, both county
and State governments are becoming increasingly involved in
establishing regulations.  A review of this would be most
helpful for it may be desirable to interface some Federal
authorities with those of the State and counties.

While the measures taken to involve the public were docu-
mented, there was little discussion of the feedback that was
gathered.  The tabular scores of the steering and advisory   t^
committees in Table 2.8 do not, by themselves, do justice to
the views of the public.  We would like to see more narrative
discussion of the attitudes and expectations of the local
people in relation to phosphate mining.

The scope and purpose of the statement are given very briefly
only in the summary (p. i, last par.) and are not mentioned
in the body of the statement.  A full discussion at the begin-
ning of Section 1 of the scope of the statement and its
relation to the proposed action and to actions to be covered ^
by site-specific environmental statements would greatly  help
to clarify what follows.
17Simulated Changes in Ground-water Levels Resulting
    from Proposed Phosphate Mining, West Central Florida.
    Open file report 77-882
                             - 8 -

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The proposed Federal action which generated the need for this
statement is not well defined.  Specific pending permits
should be identified and such permits that may be anticipated
by EPA in the future should also be discussed.  The action is
given as a number of elements, described only in summarized  ..
format at the end of Section 1 (p. 1.70-1.74).  The descrip-^
tion of the effects due to these elements is then scattered in
Section 2 under different scenarios that presumably are alter-
natives to the proposed action.  When impacts for the proposed
action are summarized in the very abbreviated Section 3, it
is no longer clear whether all elements mentioned in Chapter 1
are still part of the proposed action.  A better description
of the proposed action, distinguishing aspects covered by
this programmatic statement from those to be dealt with in
site-specific statements, would clarify this matter.

The impacts of the proposed action are equally difficult to
follow.  Despite its heading, Section 3 only supplements     t
"the impacts described in Section 2D" (p. 3.1, par. 1).  Sec-
tion 2D, however, only gives the "primary effects" of the
without-action scenario; the term "effect" was specifically
defined to distinguish it from "impact" (p. 2.35, last par.).
Apparently, this distinction was not carried out in the text.
On the other hand, the distinction between "primary" and
"secondary" effects is not clearly defined.  Thus, there is
no clear picture in the statement itself of what the signifi-
cant impacts of the proposed action are considered to be.

The paragraphs (p. 1.69-1.70) relating to responsibilities
and authorities of the Department of the Interior with respect
to leasing and mining of federally-owned phosphate need
elaboration.  As written, the public may reasonably conclude
that present mining operations in central Florida involve    tJ
Federal minerals, and that the Geological Survey exercises
some degree of regulatory authority in the area.  These pass-
ages should reflect that no Federal leases exist in the study
area and thus neither the BLM or the Geological Survey has
present regulatory authority over mining and reclamation in
the area.  The EPA should also consult with BLM on the matter
of pending Federal lease applications in the study area, if
any, and include that information in the final statement.

Further, and in the same vein, this section of the statement
should fully identify the major State and local governmental .
regulatory authorities and responsibilities which do govern
present mining operations in the area, including the process-
ing plants and all related environmental monitoring and
surveillance.
                             - 9 -
                                        78

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The five alternative scenarios and their impacts are des-
cribed in a confusing manner, neither consistently pre-          __
sented nor identified throughout the report.   The impact  \jJ- J ' /
of the various scenarios on the man-made environment, and
specifically on the local phosphate industry, is only
examined in some detail for two scenarios (Table 2.1H on
p. 2.61).  The section on the environmental impacts of the
proposed action (p. 3.1) is actually a supplement to impacts
described for the primary scenarios in the previous chapter,
rather than a comprehensive statement of impacts of the pro-
posed action.  The true choices and their impacts are not
clear-
                            - 10 -

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                 Table 2.—Identified world phosphate resources
                                (Million metric tons)
                               Reserves I/
                Identified
                subeconomic
                 resources
                    Total
                  identified
                   resources
North America:
  United States—

3,530
    Total	     3,530
South America	•	       450

Europe:
  U.S.S.R.	     1,400
  Other	        15

    Total	     1,415

Africa:                        ~~
  Algeria	•	        50
  Egypt	       100
  Morocco	——	—    10,000
  Senegal	       130
  South Africa	       100
  Tunisia	•	•—       300
  Western Sahara	       400
  Other	       200

    Total	    11,280

Asia:
  China, People's Republic of      100
  Israel	        60
  Jordan	       100
  Syria	       200
  Vietnam	       100
  Other	       100

    Total	       660

Oceania:
  Australia	       100
  Pacific Islands	       100

    Total	       200

World total 2/	—    18,000
3,550
  100
                   3.650
                     500
                   2,000
                      30
                   2,030
                     500
                     900
                  30,000
                      70
                   4,000
                     400
                   1,300
                     200
                  37,370
                     100
                      40
                     200
                     200
                      50
                     100
                     690
                   1,900
                      30
                   1,930
                  46,000
7,080
  100
                     7,180
                       950
                     3,400
                        45
                     3,445
                       550
                     1,000
                    40.000
                       200
                     4,100
                       700
                     1,600
                       400
                    48,550
                       200
                       100
                       300
                       400
                       150
                       200
                     1,350
                     2,000
                       130
                     2,130
                     » ,000
I/  Estimated reserves at 1977 costs and prices.
2/  Data may not add to totals shown because of independent rounding.
                                                          Bureau  of Mines
                                                          May 1978

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                                                Identified
                                                fiubeconomic
  County                          Reserves       resources

De Soto	    103              92
Hardee	    426             433
Hillsborough	     76              20
Manatee	    263             217
Polk	    602             138
  Total	•	1,470             900
                                           Bureau of Mines
                                           May 1978

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                         SPECIFIC COMMENTS

Page 1.11: The S02 data is left in a cloud of confusion by the
     allusion to sampling problems.  The sampling methodology ^* 3 I 7
     and problems uncovered should be briefly described.

Page 1.31, fig. 1.10:  The reference should be to Shampine 1965.\J- 3tQ

Page 1.34, 1.35:  Data from gaging stations should be credited
     to the U.S. Geological Survey.                          i^-J/T

Page 1.36, sec. d:  The discussion of ground-water resources
     should include hydrogeologic parameters of the aquifer
     confining bed: transmissivity, storage, leakance coefficient,
     and thickness.  The lower confining bed of the Floridan
     aquifer should be mentioned.  The reference to Wilson
     1975 should be 1977a.

Page 1.37, fig. 1.12:  The Lake City Limestone is generally
     considered to be part of the lower confining bed, not t»^- Ja./
     part of the Floridan aquifer, in the study area,  The
     scale at the right of the section is wrong.

Page 1.38, last par-:  It should be explained why the phenomena tj- 3 1 "i.
     mentioned here are "important."

Page 1.39:  Declines of the potentiometric surface between
     September 1919 and September 1975 are not shown and thus
     the  "center" is not documented.  No evidence is given to
     support the claim that these declines are largely attributed      *
     to the phosphate industry-  The roles of drought and        fc/-i«*
     pumpages for irrigation, public supplies, and other industry
     should be discussed.  In the third line from the end of
     the  second paragraph, "principally" should be substituted
     for  "only."  The model shows, for example, that the effects
     of phosphate pumping in Polk County extend beyond the
     county boundaries.

Page 1.40: The potential for upconing of saltwater in inland areas
     due to lowering of potentiometric head should be discussed.
     No documentation is provided to establish that contamination
     from wells is a "much greater threat" (par. 2, line 1).     (J-3l4-
     While the initial paragraph on "water demand" identifies the
     many water users and Table 1.14 identifies on a county by
     county basis current and projected water consumption, this
     information would be much more valuable for developing a
     phosphate policy if it were broke out so that we would know
     how much is being used by the phosphate industry and how
     their projected activities might impact the fresh water
     supply.  We understand that as much water is used for

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                                                          2.
     agricultural irrigation as  for  mining  in  this  seven county
     study area.   What  part  of the increased water  usage will
     result from  increased levels of irrigation?  Also,  is
     there a sensitivity scale that  will  help  us  understand at
     what point in the  decline of the potentiometric  surface
     of the aquifer will the "increased potential for salt
     water encoachment" (page 282) or upconing become a  problem?

Page 1.41:  Water demands, as used in table 1.11, should be defined.
     It would be  useful in this  table to  give  annual  totals and 4^-j
     corresponding net  changes.

Page l."+8, par. 1:   It  is stated that "the  phosphate  industry
     currently mines slightly more total  uranium  than does the (J-
     uranium industry," but  it is not clear whether this applies
     to United States or worldwide production.  It  is stated later
     that "At a full-capacity operation of  4,570,000  ton per
     year . .  . the 12  phosphoric acid plants  in  operation in
     the 7-county study area would pass 4,570,000 pounds of
     U308 per year (approximately 19.U percent of 1975 U.S.
     uranium production" (p.  2.25-2.26).  Elsewhere it was
     stated that  the Central Florida Phosphate District  accounted
     for approximately  80 percent of U.S. production  and 33
     percent of world production in  1976  (p. 1.2, par. 2).
     While the foregoing statements  regarding  uranium are not
     necessarily  contradictory,  they appear to be,  and they
     should be clarified.

     The section  on radiation environment is written  in  such a
     way that the reader would assume that  if  U308  were  extracted
     from the phosphate ore,  radiation problems would be reduced.
     This conclusion is reinforced in the discussion  of  uranium
     extraction on page 2.25.  The report is correct  that      iJ-
     uranium exists in  Florida phosphate  deposits.  It is also
     correct that uranium is separated from waste products after
     the "initial digestion  of phosphate  rock  by  sulfuric acid."
     It is further correct that  extraction  will reduce the
     "radioactive materials  in phosphate  products," principally
     farm fertilizers.   But,  it  is misleading  and incorrect
     to suggest that the extraction  of uranium will reduce the
     level of uranium (radio active  materials)  in gypsum piles,
     slime ponds  or reclaimed areas.   Uranium  is  lost just as
     phosphate materials are left behind  in waste fractions.
     Uranium associated with any waste fraction will  remain
     even if U30a is commercially extracted in the  manufacturing
     of phosphoric acid.

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                                                        3.
Page 1.51: The abnormally high radium - 226 level in waters
     underlying Sarasota County are referred to here and     f/J - i 5. Q
     elsewhere in the report.  It should be made clear that
     this is unrelated to the phosphate occurence and the mining
     activities.  As the statement now stands, reference to this
     concentration is confusing.

Page 1.52, 1.53« The age-adjusted mortality comparisons are not      ~ a
     clear; 37.98 for white males (nationally) and 44.93 for   U - * * »
     Florida (does this include non-whites?)

Page 1.54, table 1.24: More recent employment and income informa-
     tion is available in such publications as "County Business
     Patterns" and the multipliers that were used to cite the  U/-*3<
     effects on employment, income and output (page 1.5) have
     been revised by the Regional Economic Analysis Division of
     the Bureau of Economic Analysis, Department of Commerce.

Page 1.65:  Any sites eligible or nominated for listing on the .j _ 3 7 /
     National Register?

Page 1.71 and 2.76:  The continued use of connector wells included
     in the proposed action should be more adequately discussed
     and evaluated, preferably with reference to successful
     experience.  The scope and impacts of the wastewater      \^f-23<—
     injections to which reference is made on page 2.76 should
     be more fully explained.  If connector wells are included
     here, it should be so stated.  The possibility of increased
     sinkhole or limestone-solutioning activity as a result
     of declining water levels in areas now having a high water
     table should be evaluated.  Increased exposure of walls
     of solution openings or rock joints to infiltrating water
     charged with carbon dioxide from soil and atmosphere will
     promote solutioning.  The greatest number of solution
     openings being formed should be near the water table.
     Thus, lowering the water table should make solutioning
     more effective at somewhat greater depths.  The statement
     should include the map of the potentiometric surface for
     1975, to which frequent reference is made, since all the
     simulated potentiometric surface maps intended to show
     effects are based upon the 1975 data plot.

Page 1.72: In addition to providing definitions for "3 categories"
     of wetlands we believe it would be most helpful to identify
     those areas whithin each category as soon as possible.
     We would assume mining would be restricted in those areas ^.33 7
     which "serve essential environmental functions" and all
     would be better served identifying those "critical areas"
     before mining plans are submitted in areas which will be
     classified as unsuitable for mining.
                                       .?- 2.44-

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     In sub (b) a recommendation is made to line "gyp ponds"
     with an imperious material unless it can be demonstrated tjj
     in the site-specific EIS that such lining is not needed. "*
     On page 2.87 the report states that the impact of such
     action can not be assessed because "insufficient data
     exists to quantify seepage from these already in existence."

     From our reading, that is the only statement in this report
     that even suggests that there is any seepage problem.
     Rather than imposing a requirement where neither the benefits
     nor costs (page 2.26) are known,it would seem more
     appropriate to recommend further study to better identify
     the problem.  If one exists, it would be of a generic
     nature and requirements on existing as well as new sources
     should be established on that basis.


Page 1.74:  It should be noted that the slight increase in total       ^
     fluoride emissions over the past several years parallels  U/-31S
     the increase in phosphate production and processing in the
     area.

Page 2.4: The use of dry conveying of matrix has not been proven
     as a satisfactory alternative to pumping slurries.  The  tJ-JSC
     matrix is deslimed before conveying.

Page 2.5:  Under 2.14 A, wetlands have^been defined in E.G.
     11990.  This definition should be "used for consistency, tj-* 3 7
     rather than EPA redefining the term.

Page 2.8:  The units used for production rates should be given.    >•*£
     The symbols in parentheses should be explained.           U/-*-**'

Page 2.12,  fig. 2.3:  The USGS pumpage total for phosphate
     chemical plants in the modeled area is 128 mgd for 1975   ti-iJ?
     (revised from 13.5 mgd in Wilson's report) compared to    "*^~    '
     93.04  mgd for 1976 reported by EPA.  The 1976 mines pumpage
     (259.29 mgd) is higher than the USGS value used in the
     model  (174 mgd).

Page 2.19:   The Bureau of Mines does not consider the flocculation^ \Ao
     method operational yet.                                        4

Page 2.40:   The reader would readily conclude from reviewing this
     discussion on physical environment that mining severely
     damages the soils and destroys much of its usefulness.  To t
     state that mining "destroys soil in terms of its original
     identification characteristics" is accurate but not neces-
     sarily useful.  We believe that an assessment of this soils
     change would be a most appropriate and useful tool for
     better understanding and solving of mining and reclamation
     problems.
                                        - i 4S-

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     "soil characteristics-"  Then, an assessment of the impact
     of this change should be made.  Furthermore, while it is
     useful to note that "high potential agricultural lands"
     will be disrupted, that statement is not sufficient in'
     itself.  We should also know how long it might be disrupted
     and if it can be returned to its previous productive
     capabilities.  We should also determine if all "high
     potential" lands are intensively managed.  These factors
     must all be considered in any loss assessment.

Page 2.42-2.43:  In the discussion of the impacts of mining on
     the biological environment there is simply a listing of
     all possible negative factors.  These conclusions are not      .
     consistent with the March 1978 Fish and Wildlife Service  CJ-J4 i.
     report on Osceola which stated clearly that there could
     be many beneficial effects from mining and reclamation.

Page 2.45, Sec. 3a:  The reference to Wilson should be changed     A .
     from 1977 to 1977b.                                       fc/-J-*/

Page 2.46, par. 1:  It is not clear how the "inability to com-      .
     pare effects is a distinct disadvantage."                «J-2 44-

Page 2.46, par. 2:  The reference to Wilson should be changed
     from 1977 to 1977b.                                      u/

Page 2.46, par. 3:  The range of "8x2 miles and 6x6 miles"
     should be changed to "7.5x2 miles and 5x5 miles."  It   uf-
     should be stated that a no-flow boundary is a special case
     of the constant-flow boundary.

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Page 2.46,  last par.  and page  2.47,  first par.:   This paragraph
     is confusing and should be  revised.   It seems unnecessary *v
     to introduce the terms  "time-dependent" and "time-independent,"
     "input and output parameters,"  and letter symbols which are
     not used again.   If sources and discharges  of water are to be
     discussed, upward leakage should be  included as a discharge.
     In the last sentence,  "amount"  should be changed to "rate,"
     and "coefficient" should  be inserted after  "leakance."

     Also,  pumpage and recharge  are  both  cited as inputs; this
     cannot be correct.

Page 2.47,  last par.:  Although  in calibration the intent is  fo/-j48
     to match the simulated heads with the observed heads, too
     much emphasis is often placed on the exactness—or inexactness—
     of the match; a  note should be  added that generally the difference
     between simulated and observed  heads can be accounted for
     by a reasonable  range  in  error  in one or more of the input
     parameters.   In  line 5, it  is not clear why or how the
     simulated heads  are "significantly"  lower.   The last sentence
     beginning on page 2.47 is not necessarily true; a highly
     unreliable parameter might  also be very insensitive and thus
     have little bearing on the  accuracy  of the  results.

Page 2.48,  par.3:   It is not clear why the distribution of
     transmissivity  was of  "major concern."  After trying various
     other transmissivity values for the  southwestern part of the
     area,  80,000 ft2/d was retained as the best for calibration«j_i4.^
     purposes.  Possible errors  in transmissivity in that area
     may be more related to errors in the observed potentiometric
     surface.  We know of no evidence to  indicate that transmis-
     sivity increases from north to  south and from east to west.
     The reference (Wilson, 1977) should  be changed to (Wilson, 1977b).

Page 2.49,  par. 1: The first  sentence is misleading.  The pumpages
     by agriculture and municipalities were held constant to assess
     the effects of the phosphate industry alone:.  It was not          Q
     assumed that they actually  would remain constant.  Similar *»/-•»*
     procedures are also being followed to assess the effects of
     agriculture and  of municipalities alone.

Page 2.49,  par. 2: The decline  predicted for an area near
     Ft. Lonesome was more than  2 feet.  To make it easier to
     follow descriptions and present a ready visual expression *^
     of declines and  rises  it  would  be helpful to include the
     potentiometric change maps  from Wilson's (1977b) report.

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                                                     7.
Page 2.19, par. 2:  The categorical statement that pumping will
     decrease streamflow, etc., is not substantiated.   The
     possible declines of lake levels as a result of mining   .
     activities is a subject of current concern in the Ridge b/~3
     area; thus, additional declines in the potentiometric
     surface could aggravate the situation.  An assessment
     should be made of the magnitude and importance of effects
     on these lakes and on the population of the Ridge area.
     It has been found that many of the lakes recharge the
     Floridan aquifer, particularly when surrounding ground-water
     levels are declining. I/ Thus, a "worst-case" analysis can
     logically be based on fluctation of lake levels paralleling
     computed changes in the potentiometric surface.

I/   a.  Kohout , F. A., and Meyer, F.W. 1959, Hydrologic features-
         of the Lake Istokpoga and Lake Placid areas ,  Highlands
         County, Florida:  Florida Geological Survey Report of
         Investigations no. 19, p. 65.

     b.  Stewart, H. G., Jr., 1966, Ground-water resources of
         Polk County Florida: Florida Geological Survey Report
         of Investigations no. 44, p. 1.

     c.  Stewart, J. W. , 1968, Hydrologic effects of pumping
         from the Floridan aquifer in northwest Hillsborough,
         northeast Pineallas and southwest Pasco Counties,
         Florida:  U.S. Geological Survey Open-File Report,
         p. 118.
     Upconing of poor-quality water from the lower part of
     Floridan aquifer through abandoned wells that have not been
     properly plugged is discussed here and on page 2.81.   The
     statement should include some assessment of the severity of
     this impact and, if possible, offer some suggestions  as
     to mitigation.  The impact analysis should also include
     at least a brief evaluation of the potential for impacts on
     the human environment from leakage of mineralized water
     because of the regional character of effects of the proposed
     phosphate industry activities.

     In the second sentence of this paragraph, delete   .  i  » ~-4
     "Unfortunately."                                   **

Page 2.50:  The value given for lower Floridan, 196 picocuries
     per liter does not jibe with values on Table 2.10.   (j. j «r«T

Page 2.61:  Impact analysis should include the costs of
     dislocation of the labor force and the social costs .• _
     involved in unemployment.
                                   J>- 248

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                                                        8.
Page 2.61, table 2.14:   Since the losses in induced payroll were
     based on 1967 dollars,  the total effect was underestimated  .
     by at least 50 percent.  Based on actual wage rates this  «*/-
     could amount to as much as $100 million in underestimatipn.

Page 2.65, fig. 2,10:  The boundary shown is that of the EPA
     study area, not that of the modeled area.  A scale should M
     be added.

Page 2.65, last par.:  Other changes are that more water will be
     discharged by upward leakage, and in Polk County less water**'"
     will be recharged  by downward leakage.

Page 2.66, fig. 2.11:  See comments for figure 2.10 (p. 2.65). uf

Page 2.69:  Sub (b)  on  soils should be revised in a manner
     consistent with the recommendations made for page 2.40.  fc/-

Page 2.72:  One can not be certain from reviewing the last
     paragraph if these statistics are based on previous Florida
     reclamation standards or on the best available techniques  *
     for reclaiming mined land.

     If the losses identified in the last paragraph of page 2.72
     result from the lakes or other wetlands that would be created,
     then it would be appropriate to discuss the benefit of these
     new areas, if there are benefits.  If these losses are
     based on existing  reclamation requirements or current reclama-
     tion trends, then  it should be noted that with appropriate
     regulations the local or State governments could prevent many
     of those losses if they deemed it appropriate.

Page 2.74, par. 3:  Another change is decreasing upward leakage
     in coastal areas.   Also, upconing, as predicted on page  «J
     2.64 (par. 3),  is  not mentioned here.

Page 2.74, par. 4:  It  would be helpful to include the potentiometric
     change map from Wilson's report.  In the first line, "1-foot"
     should be changed  to "2-foot".                      U-**4-

Page 2.75, par. 1, last line:  Change "1974" to "1975." t^-J^f

Page 2.75, par. 2:  In  describing the 1-foot decline, it should
     be noted that simulation of heads is less acurate near    fc/-
     boundary nodes than elsewhere in the modeled area (Wilson,
     1977, p. 25).  Thus, comparison of the position of the 1-foot
     contour line in 1985 and 2000 is meaningless, and the last
     sentence should be deleted.

Page 2.75, par. 4:  The word "western" should be changed to "eastern."

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Page 2.78:  While mining necessitates the total clearing of an
     area and the cutting of all timber, losses should be     «J
     measured in terms of reduced annual harvests.  Is timber
     commercially harvested in these seven counties?  If so, a
     table on existing and projected harvests would be helpful.
     It should also contain estimates of how this would be
     effected by mining and reclamation decisions.  While it is
     accurate to state that mining involves the "destruction of
     a resource", it is also appropriate to review efforts that
     have been made to reforested and revegetated mined land
     areas.  The principal reasons why more areas have not been
     reforested is that (1) reforestation is a long-term land
     use choice, (2) these counties are not a major timber pro-
     ducing area, and (3) most reclamation decisions are made
     by the surface owners.

     No mention is made of uranium loss or recovery here, yet  i
     earlier (p. 2.62), it was indicated to be of more signifi-
     cance than timber.


Page 2.80 and 2.82,  figs.  2.12 and 2.13:   The two figures are ^
     reversed.   Also,  on both figures the boundary shown is   w
     that of the EPA study area,  and not that of the modeled area;
     "Scale 1,500,000" is incorrect.

Page 2.80, last par.:   The question whether "a decrease in ground-     .
     water flow toward the Gulf of Mexico" will affect freshwater "-J n
     resources in Manatee and Sarasota Counties should be addressed.

Page 2.81, par. 2 and 3:  The increase for potential upconing    7-7 *
     through wells and theorectical landward movement of the  *»/-*'
     freshwater/saltwater interface are mentioned.   The likelihood,
     magnitude, and seriousness of these problems should be
     evaluated.  Also, upconing by upward leakage in inland areas
     should be discussed.

Page 2.81, last par.:   It is not clear whether the changes given
     for September 2000 are being compared to the September 1985
     or September 1975 maps.  The description of the 30-foot
     contour line does not correspond to that shown on the map
     in Wilson's report.  It would be helpful to include the
     change map for 1975 to 2000 from that report.

Page 2.82:  The significance of small decline relative to the
     thickness of the freshwater zone should be explained.  In the
     western part of the study area the freshwater zone is not  . \-f4~
     1,500 feet thick.  As above, the "increased potential for K'""i
     saltwater encroachment" should be evaluated.

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                                                      10,
Page 2.83,  par.  2:   The effects on water quality in the Floridan
     aquifer are not mentioned under secondary effects for
     Scenario 2.15  (p.  2.67,  par.  1) and should also be covered
     here for Scenario  2.11.

Page 2.84,  table 2.16:   Wage  losses were based on 1975 wages
     adjusted for 1967  purchasing  power.  To show the inaccurate
     picture that is represented by this method, the average   tj-
     per annum wage per worker was quoted as $7,742; while     v
     according to the Lakeland-Winter Haven Standard Metropolitan
     Statistical Area  (SMSA) report of employment, submitted
     to the U.S.  Department of Labor, the annualM-ricoine for
     phosphate industry workers was over $11,000 per annum in
     1975.   It is expected that current earnings are again
     substantially above 1975.  Wage loss was underestimated by
     at least 50 percent.   This type of analysis gives a completely
     inaccurate  picture of the alternative scenarios.

Page 2.91:   The  phosphate  (and uranium) resources preserved by
     restricting mining activities from water of the U.S.  and jj-j"
     wetlands will  be of value only if in units of size and
     character that may eventually be mined.
Page 3.U and 3.5,  Water Quantity and  Quality:   Impacts  on quantity
     and quality of water in -Floridan aquifer  should  be mentioned. .

Page 6.1:   The mineral commitment should  compare resource mined
     with the total resource.   Recovery of the balance  should (j- J "7
     be addressed.

Page 7.5:   Delete  reference "Wilson,  W. E., 1975." Change   ,  , e»/•
     reference from "Wilson, W.  R., 1977" to "Wilson, W. E.,l*'~
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                                                                  RECEIVED
                                                               EPA/REGION IV

                                                              NAY 31   IIK'H'IB

                                                                ENFORCEMENT
                                   5850 Gulf of Mexico Dr.          DIVISION
                                   Longboat Key, Florida 33548
                                   May 24,  1978


Mr. Paul Tralna
Director Enforcement Division
United States Environmental Protection Agency
1421 Peachtree St. N.E.
Atlanta, Ga. 30309

Dear Mr. Tralna,

For personal reasons I was unable to attend the hearing held at Manatee
Junior College on Monday  of this week, which hearing regarded the future
development of phosphate mining and industry. I have followed much about
phosphate and am particular^ Interested in  the  future regarding how Its
development is done or maybe is not done due to the fact that I was born
and reared in Polk County, Florida, where the scars of phosphate mining are
really making many problems for now and years to come. These problems are
regarding radiation, water draw-down and resulting sinkholes and disappearing
artesian springs (where I used to swim), air pollution and water pollution.

I am enclosing a letter that I wrote to Mr.  Richard J. Gulmond of the EPA
in Washington and would call your attention to  pages 15 through 22 In his
paper of the study entitled THE RADIOLOGICAL ASPECTS OF FERTILIZER UTILIS
2AIION , As you surely must agree the questions this study raises certainly
should be answered before much is done in new permits for mining and using   .
phosphate. I will also enclose a copy of his reply to me. It seems to me    l*J ~~
that controlled studies In fast growing lab animals eating controlled diets
of food raised both with and without phosphate  fertilizers could be per-
formed and the answers found within a reasonable amount of time* Also, I
have read of at least two companies now either actively extracting uranium
from the phosphate or planning to do this.  They are making money on It of
course. The end fertilizer should be safer  for  food growing, would It not?
Why not look Into this part of the study more thoroughly and make further
requirements.

In Manatee County, where I now live,  we are  faced with the spectre of Beker   « _ •>  
-------
                             3850 Gulf of  Mexico Dr.
                             Longboat Key, Florida 335A8
                             August 10, 1977
Mr* Richard J. Gulnond
Office of Radiation Programs
U.S. Environmental Protection Agency
Washington, D.C 20460
Dear Mr* Gu intend,

I have read your paper, "The Radiological Aspects of Fertilizer Utili-
sation", and vhereaa moat of it is over my head, the reason I looked it
up in the first place was my own curiosity regarding the absorption of
radioactivity by foods we eat*. I have asked physlolsta, physicians and
elected officials if anybody knew what the public nay be taking In through
foods fertilized with phosphates and nobody could give me an answer,

I recalled reading in the newspaper about certain grapefouit produced in
Polk County, Florida, that contained radiation. It was not explained whether
the radiation was due to fertilizers or perhaps that the roots had reached
down to natural radiation In either the soil or water.

I have wondered whether the higher Incidents of cancer has followed the
use-:of commercial fertiliser that got its large start in the 1840ls and
then with the superphosphates later on giving such possibilities a larger
boost.

Is there a society in this world that has not used commercial fertilisers
and from which studies regarding percentage of cancer development could
be compared? Perhaps we should not even be using phosphate fertilisers
unless the radiation can be removed before it is made into fertilizer.

Maybe ray thoughts are way off base but I just thought I would send thea
to you in case they are valid.

                                     Sincerely,
                                     Marty Ervln (Mrs,  E.K.  Ervln)

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    I    UNITED STATES  ENVIRONMENTAL PROTECTION AGENCY
                           WASHINGTON. D.C.  20460


                                      AUG 1  8 1977
Mrs. E. K. Ervin
5850 Gulf of Mexico Drive
Longboat Key, Florida  335H8

Dear Mrs. Ervin:

     I am writing in response to your letter of August 10, 1977, dis-
cussing radioactivity in foods that we eat.  Studies by the Environmental
Protection Agency and other investigators have shown that phosphate
based fertilizers contain concentrations of radioactive materials
which are higher than normally found in soil.  Our studies show that
different types of fertilizers contain varying concentrations of
these radioactive materials and, therefore, would be expected to have
differing potential for enhancing the radioactivity in the soil.
As you may know, radioactivity is ubiquitous throughout the world.
As a consequence, there are background levels to which we
exposed that cannot be reasonably avoided.  However, we believe
that it is prudent to minimize human exposure to radiation as much
as possible.  As a consequence, we try to provide technical -controls
to undiscriminate release of radioactivity to the environment to the
extent practicable.  At present we do not know if the radioactivity
present in the fertilizers is having any significant impact on the
uptake of radioactivity in foods.  In general, the uptake in most
cases is probably small, but we are attempting to learn more about
the situation and will be publishing the findings as our work progresses.

     Florida is unique in that 80% of phosphate mining in the United
States originates in Florida.  Consequently, there is, a considerable
amount of radioactive material naturally present in the subsoil
throughout central and northern Florida.  Prior to mining, this
generally does not interact with the biosphere; however, redistri-
bution of this radioactive material in mine products and wastes
can cause increased interaction with the biosphere and man.

     You referred in your letter to reading a newspaper account which
noted that certain citrus produced in Polk County contained radiation.
This citrus was grown on.reclaimed land or land containing considerable
phosphorous material. Because of the radioactivity associated with
the phosphate material in the ground we have been observing some
radioactivity uptake in certain crops.  This is probably more signif-

-------
leant for crops grown on lands which contain considerable concentrations
of the phosphate ore or related materials, than for land where
fertilizers have been added, because the phosphate land would contain
higher total concentrations and quantities of radionuclides than you
would normally find once a fertilizer was distributed throughout the
plowed layer of farm land.

     Unfortunately, it is very difficult to estimate whether increased
fertilizer use since the mid-1800 's has had any impact on national
cancer rates .   I believe that in determining whether we should or
should not use phosphate fertilizers we have to look at the benefits
obtained by the utilization of the fertilizers.  Clearly, these
fertilizers substantially increase crop yields and thus enable a
considerable amount of food to be grown on the land.  In times of
food scarcity, the fertilizers are quite beneficial in feeding the
world's population.  However, if it is possible to practically remove
radioactive materials from fertilizers , we must certainly evaluate
the reduction in health risk that could accompany the removal.
Where removal is determined to be practical it should be strongly
considered.

     Thank you for your interest in the protection of public health
from radioactive materials, and particularly with respect to the work
being done by the Environmental Protection Agency.  For your infor-
mation, I am enclosing several publications we have recently prepared
regarding the phosphate industry and 'its potential impact on public
health.  If you have any questions regarding these publications, please
do not hesitate to write me.
                                  /Sincerely ,ypurs
                                  "Richard Jt  Guiroond
                                Federal Guidance Branch
                          Criteria £ Standards Division (AW-460)
cc:  Dick Payne,  Region IV
     Ray Clark
     Charles Porter,  EERF

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USEPA, Region IV                                21 June 1978
Phosphate Unit
3i|5 Courtland Street
Atlanta, GA  30308

Gentlemen:

A close study of the pertinent working papers prepared for the
Central Florida Phosphate Industry Areawide Impact Assessment
Program leaves me with the conviction that a serious omission
exists concerning phosphate industry induced radiation impacts
on the Peace River and Charlotte Harbor.

The only report of the concentration of radioactive materials
in the surface waters of the Peace and Myakka Rivers and their
tributaries or of Charlotte Harbor appears on page l\..2l\. of
Section Ij., Volume VT and is for a point well up the Peace at  M
Saddle Creek.  It is of course well known that both the Peace
River and Charlotte Harbor are "high phosphate waters" due not
only to mining activities, but also to the natural pick-up due
to the normal erosive forces as the river makes its way through
phosphate rich soils.  It is also well known that radioactive
materials are common companions of the phosphate.  The question
in the minds of many has been whether the river and harbor had
levels of materials which could be considered to be potentially
harmful.  These papers do not address that question even though
many of us had thought that that was part of the plan.  The
question is particularly pertinent in light of the fact that
steps are underway to utilize the waters of the Peace as a
 source for Port Charlotte.  There must be figures available
somewhere to support the continuing planning for such use. An
evaluation of the surface waters from the public safety point
of viewe certainly seems warranted.

Of particular significance is the fact that roughly half of
the population of Charlotte County are over 60 years of age.
Such a group of people lived through the period when the med-
ical profession and industry didn't recognize the potential
future effects of exposures to X-rays and other forms of rad-
iation.  Many individuals may have a heavy burden from the
past and thus form a group which should not be exposed to
even rather low levels of radiation.

The preceding paragraphs are limited to possible hazards during
what might be called normal weather periods when the bottom
sediments of the river and harbor remain relatively undisturbed.
The massive slime spill of 1971 significantly altered the bottom
of the Peace and portions of the bottom of Charlotte Harbor.
Your papers report that "The flow of the river was increased by
a factor of 6, with a phosphorus concentration of more than
7,000 milligrams per liter.", and "Sediments were deposited more
than 6 feet deep in parts of the river channel, and a 3-inch
layer was left in Charlotte Harbor 70 miles downstream."  I
found no mention of measurements or estimates of the radiation

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USEPA, Region IV              2.                   21 June  1978
levels which certainly must have been increased above any "normal"
level.  If there are no measurements, then I believe that a  cal-
culation should be made using the same rationale as that  in  the
hypothetical case of a spill of approximately one-tenth the  size.
(See page I(..30 of Section if, Vol. VI)  I reco.-nize that the re-
sults of such a calculation could have strong emotional and pol-
itical impact, but I believe that it would be less than honest to
fail to do so.

The slime deposits on the river and harbor bottoms have been
subjected to actions of the river and harbor water for 6^- years
so it can be presumed that changes have occurred.  No data are
given concerning those deposits so one must proceed by using
assumptions.  I believe that it would be reasonable to assume
that a significant percent of those deposits remain and that  jj- J
little of the radioactivity has been lost thru solution but
remains in the particulate form.  If that be true, the river
and harbor now represent a reservoir for an unknown but measure-
able amount of radioactivity in fine particle form which can
become suspended along with the other bottom silts whenever
vigorous currents occur.  Once in suspension, these particles
are subject to the concentrating effects of surface tension and
bubble formation- due to wave action, much like the industrial
ore beneficiation process using froth flotation.  Once in the
bubble film, the fine particles can become airborne and produce
aerosols of particles in sizes which can penetrate to the alveoli
of the human lung and be retained there.  A recent paper (E. R.
Baylor, ejb al. , Science, 198, f??5, 1977) and referenced papers
describe a somewhat similar process with viruses and surf action.

The studies of the quality of the surface waters of the South-
west area of Florida conducted under the 208 Water Quality Man-
agement Program have been completed and did not  include meas-
urements of radioactivity because of the assumption that data
would become available from your program.  The absence of data
thus leaves a potentially important gap in that program.

The Environmental Impact Assessment Program will remain in-
complete and unsatisfactory until the actual past impacts and
the potential future impacts of the radioactive materials
loosed by .the activities of the mining industry into the Peace
River and Charlotte Harbor are evaluated in a thorough and
impartial manner.

Yours very truly,

,?*—*               ~-=;—
James R. E. Smith
101 Danforth Drive
Charlotte Harbor, PL  339!?0

cc:  208 Project Director, Ft. Myers, PL

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'RenionaJ. ttdminLttAOLtoA. U. S.  ffA Region 3V
ffiCpwtfJLand Street N. 6
Atlanta,  $0. 30308
Subject:   D/ia^t Aneaiuid.e faiviMonmentaJ. impact. Statement
                    FJiofiida.  Phosphate Ondmstnij. dated /'/o/z.c/1
 ean. /'k.  WkLte:
Bela/ie commerutLna on. £'ie Au.bJLe.c£ Dna.ljt /\9S,  0 /inieM. you
JLett&i dated /%' 1d,  1 /')*•  Qerie. filcfteJuLi,  vie ^ub^ncJ^ o£. w'nJich Jus
Jjte (jzn&iaJL FLo/dida. Pkodpruiie. fyivLnormcniaJ. impact Siudy*   Vou
wLLL  no£e £jw£ peci£Lc, £35 dh.)ul.d deve-top
a n.ecJLamation, ptan tnat  cvn^iden^ /ladicution oi. ApoiL mate/iiaL and.
reduced 04 muck 04 poAAibLe tlie amount oi siadio  nucMide- beaming,
mai.eAiaJ. J.ept witltin tJie 3 ~ ^ indie*  oj. tlie />iLn.jja.ce.   What
             wLLL be u^ed to evaluate juch data when *4ubmit£ed?  \*J~ ^    '
ALiOf  ude of. connecio/L weLLt is> mentioned 
-------
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  \\
   Ar^T^       DEPARTMENT  OF                       Reubin O'O Askew. Governor
      f' -1 £ "1
     :"; \\       Health  &  Rehabilitative  Services
       H
       (  h       DISTRICT SIX              MANATEE COUNTY HEALTH  DEPT
  i-J .'j-, N^X
                 2"2 SIXTH AVENUE.  EAST    BRADENTON.  FEOKIUA    33505


May 18, 1976
Mr. Gene HcNcill
U.S. Environmental Protection Agency
1421 Peachtree Street,  N.E.
Atlanta, Georgia  30309

Subject:  Draft Plan of Study - Areawide Phosphate EIS

Dear Gene:

This letter is primarily intended to  convey our thoughts engendered by our
perusal of the Subject  Draft Plan of  Study.

However, we feel that the validity of our  consents is predicated on a clear
understanding on our part of the material  presented in the subject draft and
preamble thereto and concurrence on your part that our understanding is correct.
Therefore, to this end  we present the following synopsis:

                                   PREAMBLE

1.  The IKS.E.P.A. will prepare an EIS specifically on the current and projected
development of the phosphate industry in Central Florida.

2.  An 18 month study to be conducted by the EPA's Atlanta Regional office will
provide the data necessary for the preparation of said EIS and will also provide
an economic and social  analysis of the impact of the industry on the region>
i.e. Central Florida.

3.  The EIS will be in  compliance with the requirements set forth in the Nation-
al Environmental Policy Act, the Federal Water Pollution Control Act and will.
also analyze environmental impacts resulting from all proposed Federal Permits
or actions of all phosphate mining or processing activities in the Region.

4.  The study will, be guided by a Steering Corrjnittee consisting of:

    (a)  ACEQ Chairman.
    (b)  Appropriate Department of Interior Representatives.
    (c)  Appropriate Department of Agriculture Representatives.
    (d)  EPA Representatives.
    (e)  Corps of Engineers Representatives.

    Advisors to the steering committee will be appointed by:

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fir. Cone McNeill                  ^^  2                   May IB, 1976
A. (Continued)
   (a)  The State.
   (b)  Local and County governments,  especially Mann tea  County.
   (c)  Appropriate environmental groups  or  organizations.
   (d)  The phosphate industry.

5. Preparation of the EIS will be administered by  the  EPA Regional Director.

                  DRAFT PLAN OF STUDY  - ARE/WIDE PHOSPHATE  EIS

1. Prepare a base line EIS.   The material contained therein' will  be derived
nainly from available data in various  fields relevant  to  the mining and pro-
cessing of phosphate e.g. hydrology, biology, geology  including 'soil types and
characteristics, socio-economy and topography.  This base line  EIS will be used
by the EPA in the preparation of ElS's applicable  to specific cases involving
the issuance of Federal permits.

2. The subject Plan of Study will be used to solicit bids from  qualified price
contractors possessing the capability  of  conducting end managing  the entire
study.  Contractors that have been employed  by the phosphate industry or
suppliers of the industry shall not be retained.

3.  The EPA will assign a full-time project  officer with  a  professional and
clerical staff under his direction to  assist the Contractor and review the
results of the contractor's work..

4. Duration of the Contract will not exceed  12 months  within which time interval
a final report in the format outlined  in  Federal Register Title. 40 - Protection.
of Environment - Chapter 1-EPA Part 6  Preparation  of Environmental Impact State-
ments will be prepared (parenthetically it is our  understanding that the National
Pollution Discharge Elimination Systein (>;PDES) will have  a  bearing on the EI.S
content) .  Supplementing this report will be bound sansnaries of each scenario
encompassed in the final report.

5. Elements #1 through and including ;'-:8 of the subject "Draft Plan of Study"
are outlines of the contents of the final report to be prepared by the prirce
contractor.

Assuming that the above synopsis indicates an accurate understanding on our
part of that which is presented in the subject "Draft  Plan  of Study" we now,
offer our comments which we hope will  clearly express  our beliefs regarding
that which our constituents will require  if  they are  to accept  the activities
of the phosphate industry in our County with a reasonable degree  of equanimity.

As you may know we presently have as part of our Zoning Ordinance a section
covering phosphate mining which is considered to be one of  the  best in the
State.  Land reclamation, protection of  the  natural ecosys'ten,  protection against
reduction of the quantity and quality  of  surface water sources  and protection
of the rater table aquifer are all covered by procedural  requirements.  There-
fore, the information to ba contained  in  Elements  #1  through #8 will he of

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Mr. Gene McKcill                Page 3                Hay 18, 1976


significant value to us even though in one very important area, i.e. the
hvclrological characteristics of the: Florida aquifer in thfij.r quantitative
aspects arc more directly related to SV.'FWMD r>im:o it controls the consumptive
use of v;ater drawn therefrom.

However, several questions have been raised; some at the 5 day public hearing
on the Phillips Petroleum proposal to nine phosphate in our County and some by
news releases eminating from the EPA and the SUat:e Department of Health.  These
questions have created public concern regarding the possible degradation effects
of phosphate mining and we believe strongly that they must be addressed by the
Steering Committee and the prime contractor.  We pose the questions; in an order
reflecting the degree of public concern and on each question offer our comments,

Question #1 - Will radioactive radiation and radon presence on reclaimed land
increase to a level above the existing natural background radiation and emission
levels to a. point where it constitutes a health hazard find will sliir,e ponds
created during the operations be a source of dangerous radiation and emissions?
As you may have noted our Boning Ordinance as it pertains to phosphate mining
is predominantly land use oriented and ve deem it essential first1, to determine
if a radiation hazard could be created and if so to obtain from a qualified
source a methodology to prevent it.

Question #2 - Will consumptive use of water by the phosphate industry particu-
larly from the Floridan aquifer reach such proportions that it would (a) restrict
farra land irrigation and beef cattle and dairy operations (b) adversely affect
the public drinking water supply as to the quantity and quality (c) contribute
to possible salt water intrusion or upwelling.   We recognize, of. course, that.
v?ater use and quality is a matter of concern to the appropriate state regulatory
agencies but it is also the concern of our County.

Question#3 - Is it practicable to use surface water in the beneficiation pro-
cess employed to recover phosphate fines?  UTe have been told that the use of
surface water in this process involves problems in obtaining water of a suitable
chemical composition but limiting parameters have not: been identified.  We
believe, however, that in every proposed operation surface water use should be
thoroughly investigated.

Question #4 - In the interest of saving water is it possible and practicable
to use dry beneficiation methods in recovering phosphate ore of the type found
in.Central Florida, i.e. in the Bone Valley formations?

Question #5 - Is it possible to improve the reclamation process delineated in
our current Zoning Ordinance?  A copy of the section pertaining to phosphate
mining is attached for your perusal.  We recognize the possibility that a nath-
oclolegy for preventing radiation and 'radon emission hazards will have to be
included.  However, there are other areas of concern such as the preservation
of wetlands which contribute to the maintenance of the natural ecosystem and to
the maintenance of stream flow and lake levels which should be exar.inecl.  Con-
cerning the tern "Wetlanda" it is essential, we believe, that it be concisely
defined.
                                    .?- It

-------
Mr. Gene McKeJll               Page 4                May 18, 1976


Qua st ion J!6 - Should the number of simultaneous mining operations in a region
be restricted by area topography and hydro-geological characteristics?  This
question has been raised in our County by the expressed desire of a number of
our citizens to the effect that if phosphate mining is permitted it should pro-
ceed on a "one-firra-at-a-time basis".  Thus reducing the strain on our water
supply and minimizing the disruption of the land area while the mining operation
is proceeding,

Credit for the foregoing should be given to Mr.  Gordon Bartle, a member of
the Manatee County Planning Commission.

                                               Very trul3r_y_o.urs,  *
                                               0,  E.  Ran de,  Jr
                                               Pollution  Control Director
OERjrrdk

Attachments :
     Zoning Ordinance
     Inventory of U.K.  Grace material
     Inventory of Phillips Petroleum material
     Inventory of Beker Industries material
     Manatee County Pollution Control material

-------
CF
                                                       SALEM LAKE DRIVE

        .InC.                                        LONG GROVE, ILLINOIS 60047

                                                          312/438-9500
                                June 21,  1978
Mr. John E. Hagan III
Chief, EIS Branch
Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia  30308

          SUBJECT:  Draft Areawide Environmental  Impact
                    Statement - Central Florida Phosphate
                    Industry

Dear Mr. Hagan:

CF Industries (~CF) appreciates this opportunity to provide
comment on the Draft Areawide Environmental Impact Statement
(DEIS) on the central Florida phosphate industry.  CF  Industries
is an inter-regional cooperative, consisting of nineteen
(19) farmer owned regional  farm supply cooperatives  in the
United States and Canada.   CF Industries' Florida operations
are composed of four separate facilities:  two phosphate
fertilizer manufacturing complexes -- CF Chemicals,  Inc.,
(Bartow) and Central Phosphate, Inc.  (Plant City); a phosphate
mining complex -- CF Mining Corporation (Hardee County), and
a distribution facility --  Tampa Phosphate Terminal.   Although
CF Industries is not a member of the  Florida Phosphate
Council, CF is a major manufacturer of phosphate  fertilizers.

Since CF does have a substantial investment in the central
Florida phosphate region, we also have a profound interest
in the DEIS.  One of our fundamental  concerns is how the     .   A
recommendations of the final EIS (FEIS) may be used  by     \tJ—*r
regulatory agencies in the  future.  It is our opinion  that
many recommendations which  are made on an industry-wide
basis in the DEIS would best be addressed in a site-specific
examination of particular regulatory  problems.  The  final
EIS should give recognition to this fact.

Additionally, there are six major areas about which  CF would
like to comment.  They are  as follows:
                                                          JUN 2 3
                                                             1C73

-------
Mr. John E.  Hagan III
Environmental Protection Agency
June 21, 1978
Page 2
          Chemical Processing of Dry Rock
          The DEIS proposes (Page 1.70)  that rock-drying
          processing be eliminated at new source mines.
          Certain exceptions are noted for existing,  DER-
          permitted dryers.  However, there is good reason
          to expand the list of exceptions to include a     (^-
          dryer at CF Mining's Hardee mine site.   Should
          other producers decline to supply dry rock to  the
          Bartow Complex at a competitive price,  CF Mining
          would be required to provide it.  There should be
          no prohibition in the FEIS which will prevent  CF
          Mining from having a dryer at  its Hardee site
          because such a prohibition would needlessly restrict
          competition.

          In addition to the required uses for dry rock  as
          delineated on Page 1.70, certain fertilizer plants
          -- among them, CF's Bartow Complex -- consume  only
          dry rock.  To change to wet rock would be an
          extremely difficult engineering assignment.
          Whereas the advantages of wet  rock grinding are
          prominently mentioned on Page  2.21, we recommend
          that the disadvantages be as prominently discussed
          in that same section.  They are as follows:

          a.   For a chemical plant converting from dry  rock
               to wet rock, there will be a substantial
               capital expense in the range of $10 million.

          b.   The switch from dry rock  to wet rock would
               have substantial negative environmental,  as
               well as economic impacts  on the management of
               pond waters.  For a chemical plant using  pond
               water for dilution of sulfuric acid in the
               phosphoric acid manufacturing process,  a
               detrimental pond (process) water balance
               would result.  The change could easily turn a
               pond water complete recirculation situation
               (on a yearly basis) into  one requiring treatment
               and discharge of treated  process waters.

-------
Mr. John E. Hagan III
Environmental Protection Agency
June 21, 1978
Page 3
          c.   At an existing location, there may not be
               space available for the required wet rock
               storage.  It is estimated that changing from
               dry rock to wet rock would increase land
               requirements from 0.4 acres to 7.7 acres, or
               more than 19 times the dry rock land requirements.

          Elimination of Slime Ponds
          Throughtout the DEIS, the phrase "elimination of
          slime ponds" is repeatedly used (see pages 1.70,
          2.85, 2.86, 2.87, 2.88, 3.2, 3.6, and 3.8).  CF
          requests that at a minimum the use of this phrase
          be changed to make clear that the recommendation
          proposes to substitute below grade storage of
          slimes for "aboveground slime -- disposal areas",
          not the total "elimination of slime ponds."  Even
          the new technologies that offer some promise still
          require slime disposal areas, although it is
          possible that the bulk of the disposal could be
          below natural grade.  It is important to understand
          that requiring below ground level slime disposal
          will increase the total acreage of land that has
          limited use for other than light agriculture.
          Water usage is primarily a function of the final
          per cent solids of the disposed clay fraction, and
          it will always be a desirable goal to seek methods
          that accelerate the release of water from this
          clay.

          Effluent Limitation - Phosphate Mining Subcategory
          As a part of the proposed action, new source
          phosphate mining (Page 1.70) -- the DEIS recommends
          that new sources "Meet Florida's effluent limitations
          for any discharges."  CF Industries has no data to
          indicate the achievability or non-achievability of
          the state's limitations.  CF did follow DER's      yj - 4"°3
          rule-making effort in the fall of 1976, during
          which time the state adopted the phosphate mining
          effluent limitations.  Throughout this DER rule-
          making process, both the data base used and the
          interpretation of that data for the development of
          the regulations were suspect and inadequate.

-------
Mr. John E.  Hagan III
Environmental Protection Agency
June 21, 1978
Page 4
          A more prudent recommendation of the DEIS would be
          to review EPA's phosphate mining subcategory
          effluent limitations through the traditional
          development document process to determine if the
          present limitations are technically sound or if
          technological advances allow a more stringent
          effluent limitation.  At this time, both rules are
          based on identical technology, the  settling pond,
          nevertheless they impose different  effluent limita-
          tions.  This technological anomaly  should be
          resolved by the FEIS or by appropriate  rule-making
          proceedings.

          Wetlands
          The DEIS discusses protection and restoration of
          wetlands at several points through  the  document.
          CF Industries recognizes that there are environ-
          mental concerns relating to wetlands.   However,  we
          are equally concerned that any blanket  prohibition
          of phosphate mining in wetlands would constitute
          arbitrary and capricious regulation.  In CF       •*
          Industries' case, a resource was purchased with
          the right to mine phosphate rock.   Prohibition of
          that action deprives our farmer-owners  of utilizing
          that resource, and unless justified by  a detailed
          site- specific study, could constitute  a taking of
          private property requiring compensation under
          recently enacted Florida law.   See  Chapter 78-85  -
          Laws of Florida.

          Wetlands considerations should be on a  case-by-
          case basis just as other environmentally related
          considerations; e.g., ambient air,  water quality,
          etc., are made.  Where restoration  plans are      ffJ
          proposed that satisfy realistic environmental
          concerns, mining should not be prohibited but
          should be allowed with adequate conditions.

          The discussion on Page 3.7 is not germane to the
          overall wetlands considerations.  To imply that
          "prohibiting development in wetlands" will "not
          materially affect production tonnages"  conceals
          the fact that wetlands phosphate reserves that are
                              3-167

-------
Mr. John E. Hagan III
Environmental Protection Agency
June 21, 1978
Page 5
          left unmined are no longer economically recoverable.
          The net result is a shorter lifetime of the deposit
          in question.

          Finally, the third paragraph on Page 5.1 of the
          DEIS is unclear.  This paragraph discusses "Holding
          wetlands from industrial development by the phosphate
          industry .  . . ."  The wording in that discussion
          is confusing and incomplete.  It can be construed    fa)
          to imply that wetlands whose development was
          restricted during phosphate mining may be developed
          at a later date for other purposes such as agriculture.
          The sentence does not explain why development of
          wetlands for agricultural or other uses is to be
          preferred over development of that same wetlands
          by the phosphate industry.

     5.   Lining of Gypsum Ponds
          As CF Industries understands this recommendation
          concerning gypsum pond lining (Page 1.72 of the
          DEIS) impervious lining would not be required if
          on a site specific basis it can be demonstrated
          that such lining would be unnecessary.   Such a
          demonstration can be made by developing a correla-
          tion between the geology of an existing site and
          the geology of a new site.

          The DEIS acknowledges that "insufficient data
          exist to quantify seepage" from existing gypsum
          ponds (Page 2.87).  Therefore, before concluding
          that an impervious liner is mandatory,  existing
          ponds should be studied to determine the extent,
          if any, of the seepage.  Therefore, any claims
          that seepage has contaminated any aquifer system
          is purely speculative and does not belong in a
          technical, scientific document such as the FEIS.

     6.   Recirculate Noncontaminated Water
          One proposed action called for by the DEIS is the
          "recirculation of noncontaminated water."  Most
          chemical plants presently recirculate these waters
          to the greatest extent feasible.  However, it

-------
Mr.  John E.  Hagan III
Environmental Protection Agency
June 21, 1978
Page 6
          appears that the DEIS is  proposing something more
          than the present practice.

          The DEIS is proposing that  waters  presently dis-
          charged under EPA's classification of "contaminated
          non-process wastewaters"  (as distinguished from
          process wastewaters) be contained  as  are the
          process (pond) waters.   It  must be pointed out
          that even the newest phosphate fertilizer plant in
          central Florida only accomplishes  that by virtue
          of disposing of its wastewaters to a  mining operation,
          While this might be a design consideration for a
          new chemical plant, the extension  of  this requirement
          to existing chemical plants (Page  1.74,  2.a) has
          not been demonstrated to  be practical from a
          cost/benefit determination  and indeed CF submits
          that the cost would make  such a requirement for
          existing chemical plants  uneconomical.

          Another concern is whether  the term "contaminated
          non-process wastewater" (a  particular EPA classifi-
          cation) is correctly understood as used in the
          DEIS.  "Contaiminated non-process  wastewaters"
          include the following waste streams:   cooling
          tower blowdown, boiler blowdown, regeneration
          waters, and waters contaminated by spills and
          leaks.   It can be readily seen that these waters
          are not entirely capable  of being  recirculated and
          reused.  Therefore, to imply as the DEIS does,
          that "noncontaminated water be recirculated" does
          not address the entire issue of reuse of contaminated
          non-process waters.

          It should be kept in mind that before contaminated
          non-process wastewaters can be reused within a
          plant a consumptive use must be found that is
          suitable for this quality water.   Since each
          stream has unique characteristics  (impurities), a
          detailed study must be undertaken  to  determine
          their reuse potential.   Until such time, the
          contaminated non-process  wastewaters  must be
          discharged as permitted by  present EPA regulations.

-------
Mr. John E. Hagan III
Environmental Protection Agency
June 21, 1978
Page 7
SUMMARY
          The DEIS process has attempted to thoroughly
          examine the central Florida phosphate industry.
          While CF Industries does not concur with all of
          the recommendations, we share EPA's concern that
          more information is needed to properly assess the
          present condition of the area's environment, the
          relationship of that environment to the phosphate
          industry, and the need for further regulations in  (
          selected areas.  When the final EIS is prepared we
          are very apprenhensive that the recommendations
          contained therein may be misconstrued by regulatory
          agencies as a mandate from EPA to adopt rules and
          regulations implementing these recommendations.
          For this reason we hope that the final EIS will
          specifically state that its contents include some
          recommendations that do not represent proven
          technology, and therefore should not be slavishly
          followed by rule-making bodies as they are applied,
          particularly to existing facilities.

                                Sincerely,
                                          T
                                T. H. Traylor
                                Vice President - Operations
THT/wpc:df
cc:  Malcolm S. Scott

-------
                   GARDINIER
INC.
                   U.S. Phosphoric Products
                    Post Oflicc Bo< 3269  •  r.iniid. Flnmld 33001  •   li!lc|ili(inc: 813 - 677 9111   •  1WX 810-B/fi DM'I

                                                              June  21,  1978


Mr.  John E. Hagan, III
Chief,  EIS Branch
U.S. EPA, Region IV
345  Courtland Street, N.E.
Atlanta, Georgia 30308


Dear Mr. Hagan:

     Gardinier, Inc. appreciates this  opportunity to present its comments on
"Proposed Action" of the "Draft  Areawide E.I.S. Central Florida  Phosphate
Industry":

     a.  Mining and Beneficiation  Requirements

        Eliminate Rock Drying (Page 1.70):

             While we agree that  any  mine which supplies rock to a new  phos-
phoric  acid plant should not dry that  portion of its production  unless the   fa) - 4f-/ /
energy  required for the transportation of the moisture exceeds that utilized
in drying, we strongly disagree  with the balance of this proposed action.  Need
will continue to exist to supply existing phosphoric acid plants with rock.   The
feasibility of converting existing phosphoric acid plants to wet rock feed would
have to be considered on a plant-to-plant basis.

             Drying of that portion of the mined rock which requires drying,
should  not necessarily be conducted at the point of consumption.  This clearly
increases energy consumption in  transporting  the moisture.  Additionally,
depending on the location of the mine  and the location of the  point of consumption,
the  least environmental impact could occur if drying were conducted at the mine.

        Effluent Limitations (Page 1.70);

             If the statement is  to be taken at its face value, that Florida  id ~~ 4 '
Law  shall apply, there are,  of course, no objections.  If, however, it indicates,
as it would appear from the working papers, that the limitations present  in Rule
17-3.04(2)(a)2a and 17-3.04(2)(a)2a(XXV) apply, there is strong  objection. These
rules are currently under litigation.   These  values were submitted to the Guide-
lines Division of EPA when the mining  effluent guidelines were under  review and
were rejected as unsupported.  The existing EPA Standards of Performance  are
sufficient to protect the environment.

-------
         Eliminate Above-Ground Slime Disposal Areas (Page 1.70);

              Under specific conditions of matrix composition, mixing of sand
tailings with phosphatic clays appears to be feasible, however, it is far from
a fully developed technology.  Another consideration which has been totally    t/v/-
overlooked is that slime ponds represent a potentially valuable national re-
source.  While at this time, no technology exists to recover the phosphate values
they contain, the possibilities are very high that such technology will develop
in the forseeable future.  Mining wastes of previous decades are now being re-
processed for recovery of their phosphate values.  The present method of disposal
permits ready recovery when new technology develops.

         Wetlands (Page 1.71):

              Unlike other activities of man which can disturb wetlands, mining
is unable to select alternate sites.  Minerals must be recovered where they exist.
To mine around an area is a waste of natural resources.  Category I Wetlands    LJ-
should be strictly limited to truly outstanding wetlands such as the Everglades.

     b.  Chemical Processing Requirements

         Provide for Recovery of Fluorine:

              It has not been demonstrated that recovery of fluorine lowers the
equilibrium fluorine concentration in recycled gypsum pond water.  As it has n°tk/_
been demonstrated that this action has an environmental effect, it should not be
required.

     r..  Additional Considerations (Page 1.73):

              The Guidelines Division of EPA conducted extensive testing in
arriving at the concentrations achieveable thru B.A.T.  No new technology has
been developed since that time, hence, there can be no justification for lower  iJ-
limits.

              There is no justification for surge capacity in non-process water.
Such a requirement would have an adverse environmental effect by creating
unnecessary surge ponds.

                                            Very truly yours,
GEW:rew
                                     -2-

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June 14, 1978
Mr. John E.  Hagan III                                     A , -7
Chief, EIS Branch                                     \jJ~ *t '  /
Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia  30308

Dear Mr. Hagan:

Swift Agricultural Chemicals Corporation desires to
submit its comments to the draft area-wide Environmental
Impact Statement (DEIS) on the central Florida phosphate
industry.  We request that our comments be incorporated
into the hearing record.-  Swift Agricultural Chemicals
Corporation has  been in the phosphate rock mining business
for many years.   Approximately 10 years ago we acquired
property in Manatee County for the purpose of recovering
the phosphate rock therefrom.   We own approximately 10,000
acres in this county.  We propose to mine this property
in 1982.  We presently have a mine located in Polk County,
Florida, at Silver City.   This mine will cease operations
in approximately 1982.   Your agency has determined that our
proposed Manatee mine is a new source and therfore an
impact statement must be filed.

In the DEIS,  under the heading "Proposed Action," for new
sources (Section 1.70), one of the items of proposed action
is to "eliminate the rock drying processing at beneficiation
plants and transport wet (6-2070 moisture) rock to chemical
plants."  Exceptions to this requirement are made for fer-
tilizer processes requiring dry rock, and also for shipments
where the energy for transporting the moisture are greater
than the energy  saved by eliminating drying at the beneficia-
tion plant.   We  feel that this item of proposed action is
objectionable on several grounds, including:

1.   The proposal mixes up energy considerations with environ-
     mental  considerations.  The exceptions bear this out.  We
     do not feel such considerations should control environ-
     mental impact statements.

-------
Page 2.


2.   In the summary sheet, the major environmental impacts are
     listed.  Requiring new phosphate mines to transport wet
     rock does not alleviate any of the listed major environ-
     mental impacts.

3.   We feel that if there is concern about air quality in the
     central Florida phosphate area, standards should be promul-
     gated to protect the air quality.  If a new phosphate mine
     can comply with these standards and still dry their rock,
     they should be permitted to do so.  The federal and state
     environmental laws are intended to protect the environment
     and not control the way products are produced and marketed
     if this can be done in compliance with the environmental
     requirements.

4.   New mines, of course, will be competing with old mines.
     To require new mines to transport wet rock at an increased
     cost in freight will place them at a competitive disad-
     vantage to old mines.  Many customers purchase small quanti-
     ties of phosphate rock, and therefore cannot economically
     justify the installation of a dryer.   Such competitive
     disadvantage should "be required only when environmental
     necessities require the same.   Requiring greater costs on
     new sources of pollution can only be justified where the
     new source will increase the pollutant load to an undesir-
     able or unhealthful level.  In Section 3.1 of the DEIS it
     is stated that the "proposed action will have little impact
     on the air quality in the study area."  On page 2.68 of  the
     report it is stated:  "Air emissions created by sources
     other than the phosphate industry will dominate the inven-
     tory in Hillsborough, Manatee and DeSoto Counties, so that
     any change in air quality will be difficult to associate
     with the phosphate industry...Sarasota and Charlotte Counties
     should not be materially affected by air emissions from the
     phosphate industry."  On this same page it is stated:  "Adding
     new mines to replace existing capacity will tend to keep constant
     the phosphate industry's area-wide pollutant load in the
     atmosphere after 1977."  As indicated by these quoted state-
     ments from the DEIS, this action is not necessary with regard
     to air quality.  All three of the Swift mines will not be
     operating simultaneously for any great length of time.  It
     is very possible that Swift will decide to move its dryer from
     the Silver City mine to the Manatee mine.  Thereby no increase
     in the pollutant load by Swift would be experienced.  In fact,
     dispersion of the phosphate mines from Polk County into an
     additional three counties should decrease the load.

5.   A standard which allows rock drying if it does not result in
     greater energy cost for transportation of moisture than energy

-------
Pag


     saved by eliminating drying is impossible to police.  As indicated
     above,  we feel there are sufficient regulations to protect air
     quality.   Additional regulations only fuel inflation by increasing
     the cost of doing  business.

Very truly yours,

SWIFT AGRICULTURAL CHEMICALS  CORPORATION
By.
. .                              President
nt
                                              o,
                                           J-27S"

-------
                                                               June 111,  1978
PRESIDENT
Charles R. Covert

VICE PRESIDENT
T. MabryCarltonJr.

SECRETARY
Dante Veuoli

TREASURER
John L Engels
           ASSOCIATION,INC. /RO.BOX 1333/SARASOTA,FLORIDA 33578
John "J. Has an   111
Chief, SIS Branch
Environmental Protection Ag ency
Region 17
314.5  Gourtland St.,  K.E.
Atlanta,   Ga. 30308
DIRECTORS
 Harry C Adley
'George R.Anner
 Samuel B. Applebaum
 Elmer G.Berkel
•Capt. Wm. B. Bernard
 George A. Bishopric, MD
 Ms. Tesse Brumgardt
•T. MabryCarlton.Jr.
 Jerome Chambers
•Charles R. Cover!
 M's. Agnes Cottap
 George Davis
 Joseph F. Defiinno
'Fred C. Duisberg
•John L Engels
 Stevun Floe.fie
 Dr. Larry S. Freeberg
 Gen. Arnold Funk
 HomerGreer
 Ansel E. Gridley
 J Randall Grobe
 James A. Haley
 Robert Hattersly
 Clinton Johnson
 Robert M.Johnson
 Ms. MaryKumpe
•Mrs. Wilfred A. Le Page
•Mrs. Jeanne McElmurray
•Robert Maas
•John Malpeui
'Lori Lee Mows
 Frank Oehlschlaegef
•Christy Payne, Jr.
 William E. Pensyl
 Edward Petrick
 Jonathan Pugh
 Joseph Roach
 John W Robinson
 Ms. Donald (Rita) Roehr
 Tony Saprito
 Thomas Savage
 Larry SpaIdmg
 Ted Sperling
 Ms. Anita Stuart
•Col Dante Veizoli
Dear Sir:

           Based on the adverse environmental impacts as
summarized on page Mi of  the Draft Areawide Environmental
Impact Statement   Central Florida Phosphate Industry.
March 1978 by your agency,  Save  Our Bays  Association  Inc.
wishes to be recorded as  requesting of U.S.3.P.A, that  no
further permits be granted for  the mining  and processing
of  phosphate in the area  covered by this  study until  such
time as this study is completed  and regulations  based on
its findings are  imposed.
           It is our sincere belief that the extension of
phosphate mining   and processing can only be detrimental
to  the best interests of  the people of this area and all
of  our nation.
           In the \>iords  of the Florida Phosphate  Council
" Phosphate Feeds You".   If we accept this as a  truth we
must also accept  our obligation  to protect this  invaluable
resource  and our  responsibility  to j?uijure generations.
           \"Je commend the U.S.E.P.A. for the work  they have
done on this study.   We believe  that more information is
required  before final conclusions can be  reached.
Especially in the areas of water quality  and quantity,
the effects  of res  ultant radiation and  air quality
deg radation on the  human population.  Existing   sources
must be defined as  only  those companies  physically
engaged in a mining  or processing operation at this time.
 For proper protection of "Wetlands" a geographic
deliniation as they  presently exist is required.
 •Indicates Executhr* Committee
                                                                1  9
                                             - 27

-------
              ASSOCIATION, INC. / RO. BOX 1333/SARASOTA, FLORIDA 33578
                                                                     Page 2
 PRESIDENT
 Charles R. Covert

 VICE PRESIDENT
 T. MabryCarltonJr.

 SECRETARY
 Dante Veuoli

 TREASURER
 John L. Engels

 DIRECTORS
  Harry C.Adley
 "George R.Anner
  Samuel B. Applebaum
  Elmer G.Berkel
 •Capt. Wm. B. Bernard
  George A. Bishopric, MD
  Ms. Tesse Brumgardt
 •T. MabryCarltonJr.
  Jerome Chambers
 •Charles R. Covert
  Mrs. Agnes Cowap
  George Davis
  Joseph f. DeNinno
 •Fred C. Duisberj
 •John L. Engels
  Stevei Fleet1*
  Dr. Larry S.Freeberg
 Gen. Arnold Funk
 Homer Greer
 Ansel E. Grldley
 J. Randall Grobe
 James A. Haley
 Robert Hattersly
 Clinton Johnson
 Robert M. Johnson
 Ms. Mary Kumpe
 •Mrs. Wilfred A. Le Page
 •Mrs. Jeanne McElmurray
 •Robert Maas
 •John Malpeai
 •Lori lee Mowe
 Frank Oehlschlaejef
 'Christy Payne, Jr.
 William E. Pensyl
 Edward Petrick
 Jonathan Pugh
 Joseph Roach
 John W. Robinson
 Ms. Donald (Rita) Roehr
 Tony Sapnto
 Thomas Savage
 Larry SpaIdmg
 Ted Sperling
 Ms. Anita Stuart
'Col. Dante Vezzoli
•Indicates Executive Committee
 In addition the consequence,  economically  and
 environmentally of a  rapid uncontrolled exhaustion
 of a  finite resource  vital to the needs of our nation
 must  be  eonsidered.   No phosphate should be exported
after  the expiration of any existing contracts.
      Processing   of phosphate  ore must be strictly
 regulated by the U.S.S.P.A.  to protect  the health and
 welfare  of  the  people of  the  U.S.A.
      With thanks for your  full consideration of our
 comments.
                                Sincerely,
                                             Cove'rt
                               President,  Savo  Our Bays Assoc.  Inc.
                                Pred.  C.  Duisberg
                                Natural  Resource Chairman
                                Save  Our Bays Assec.  Inc.

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^     The Fertilizer Institute
      1015 18th Street, N.W.
I      |  Washington, D.C, 20036
V. .....
      (202) 466-2700 • Telex 89-2699
      EDWIN M. WHEELER
      President
     June  21,  1978
     Mr. John E.  Hagan,  III
     Chief, EIS Branch
     Environmental  Protection Agency
     Region IV
     345 Courtland  Street,  N.E.
     Atlanta, Georgia   30308

     Dear Mr. Hagan:

          The Fertilizer Institute appreciates the opportunity
     to comment on  the draft Areawide Environmental Impact
     Statement, Central  Florida  Phosphate Industry, published
     in March, 1978, by  the U.S.  Environmental Protection
     Agency, Region IV.

          The Fertilizer Institute is an association for the
     U.S. fertilizer industry • representing over 90 percent of the
     domestic capacity of plant  nutrients used in fertilizers.
     With phosphates representing over one-fourth of the nutrients
     in fertilizer  it  is obvious  that an adequate supply on a
     continuing basis  is a  major  concern to not only Institute
     members, but the  total agriculture community as well.
     Without this vital  element  made available at reasonable
     prices, efficient production of food and fiber by the
     American farmer will no longer be possible.

          Two major points  of overriding importance form the
     basis for our  comments on the draft environmental impact
     statement  (EIS) .

          First,  we would stress  the critical importance of
     providing a  maximum degree  of flexibility for industry   tJ-4-
     operations in  the final EIS.   The EPA has stated in the
     public hearings that one areawide impact assessment will not
     adequately cover  the individual situations,  i.e., individual
     EIS will be  required for each new mining operation.  Likewise,
     it follows that each mining  site presents unique operational
     problems requiring  unique solutions.  Denying opportunity
     for individual solutions by  establishing a single rigid
     approach will  not provide for the most efficient recovery of
     this essential element.  One such example is the proposal

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Mr. John E. Hagan, III
June 21, 1978
Page 2
 that no new rock dryers be permitted.  Whereas processing  of
 wet rock is an emerging technology lending itself  to  certain
 of the phosphate chemicals, it is not universally  applicable
 for all products needed to efficiently and economically
 serve the agricultural community.

     The detailed study performed to gain background  for this
 EIS has made clear the advances in knowledge and technology
 to address and minimize the impact on the environment caused
 by mining and processing of phosphates.  We can expect this
 advancement to continue, as it must.  But, as it does we
 cannot entirely rule out today's technology for use in cases
 where the latest developments do not help.  To do  so  not
 only would serve to diminish utilization of our reserves,
 but additionally would penalize the nation's food  output.

     Secondly, in selecting requirements based on  technology
 we urge the EPA to use as _their major determinant  the
 testimony of the mining engineers, process engineers  and
 other specialists most qualified to cite the facts.   Without
 a sound basis, the final recommendations in the EIS will
 lead to faulty judgments by those who must rely on it in
 making future decisions.

     An example of our concern is the implication  received  W
 from reading the summary statement and the captions through-
 out the draft document that "elimination of slime  ponds"   is
 now possible.  There is nothing in the record to support
 this far-reaching conclusion.  Granted, considerable  progress
 has been made toward reduction in the size of slime ponds or
 the length of time to accomplish final reclamation, but
 elimination is nowhere on the horizon.  It is grossly mis-
 leading to suggest "elimination" as a viable possibility.

     Another example concerns lining of gypsum .ponds.  In
 the absence of information to demonstrate the need for such
 a general requirement it is proposed by EPA that gypsum
 ponds be lined with an impervious material.  To require such
 a lining, based only on speculative premise, would subject
 the operator to great expense with little assurance of
 success and without justification of the need.

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Mr. John E. Hagan, III
June 21, 1978
Page 3
      In closing,  it  is  urged  that  the  agency give    U/- 4 1. I
 serious consideration to  the  testimony of the scientists
 and  specialists most qualified  to  offer alternatives for
 phosphate ore  processing  in the light  of individual mine
 operations  and protection of  the environment.  Only with the
 recognition of the need for alternatives in the limitations
 imposed, will  the EIS represent an accurate assessment of
 the  continued  use of one  of Florida's  precious resources so
 essential to the  future supply  of  phosphate.
 Edwin  M.  Wheeler
 EMV7/pck
                               - 180

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           Mississippi
Post Off ice BOX 388 • Yazoo city, Mississippi 39194-Area Code (601) 746- 4131 -Telex 58-5449
      June 21, 1978
      Mr. Gene McNeill
      Environmental Protection Agency
      Region IV
      345 Courtland Street  NE
      Atlanta, Georgia    30308

      Dear Mr. McNeill:

      Re:  Central Florida  Phosphate Industry
           Draft Areawide Environmental Impact Statement

      Mississippi Chemical  Corporation respectfully submits the
      attached comments  on  the referenced document.

      If you have any questions or require any additional infor-
      mation, please contact me.

      Very truly yours,
      Carey Stark                                         K*
      Process Study Engineer                              Uu  '"   p~  ,
                                                             'rM.LtilOH IV
                                                             E I S BRA,\Xi)
      CS/fp                                                   *'w'™> «.

      Enclosure
                                                          ii 111
                                                              23

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      Mississippi Chemical Corporation





           Yazoo City, Mississippi
                 Comments On
United States Environmental Protection Agency





Draft Areawide Environmental Impact Statement





     Central Florida Phosphate Industry
                June  21, 1978



               Bartow, Florida

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Mississippi Chemical Corporation welcomes the opportunity to pre-
sent comments on the draft Environmental Impact Statement for the
Central Florida Phophsate Mining District.  We recognize that the
Environmental Protection Agency has been faced with a significant
task in preparing the draft Environmental Impact Statement for
such a broad area.  We generally commend the agency for its ef-
forts on this Environmental Impact Statement and support the goal
of protecting the environment in the Central Florida area.  We
would call your attention, however, to those sections of the draft
Environmental Impact Statement which, in our view, should be re-
vised or clarified;  namely the parts of the Proposed Action
dealing with Rock Drying, Wetlands and Clay Disposal.

  I.  Rock Drying

      The proposed action contains the recommendation that the
      rock drying process be eliminated at beneficiation plants.
      This action requires the use of wet rock in downstream        *
      processing facilities.  The only proposed exemption to    W ~ *
      this recommendation is based on a trade-off between fuel
      requirements for drying versus incremental fuel require-
      ments for transporting the rock to a processing site re-
      mote from the study area.

      The following factors were apparently not considered and/
      or were given insufficient weight in developing that re-
      commendation :

      A.  Wet rock grinding requires the input of fresh, uncon-
          taminated.water for the sole purpose of operating the
          grinding mill.  The impact of this water input on the
          overall plant water balance must be considered on a
          site specific basis.  In certain facilities and at cer-
          tain locations, this action will require the release of
          quantities of water in direct proportion to that used
          for wet grinding.  This requirement causes an adverse
          impact on water resources, will impact NPDES permit
          requirements for chemical processing facilities and
          jeopardizes the goal of total water recirculation in
          chemical processing facilities.

      B.  The trade-off on transportation to remote sites in-
          volves more factors than fuel consumption.  The im-
          pact on'total transportation cost should be considered.
          The proposed action will reduce by approximately 10%
          the effective use of vital transportation facilities,
          thereby increasing costs to the American consumer.
          Greater capital investment in transportation facilities
          will be required, impacting economic resources.

      C.  For those chemical processing plants located at a re-
          mote site and having specific requirements for dry
          rock, whether based on process  technology or water
          balance considerations, rock drying facilities must
          be installed at the point of use.  This action would

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         have accomplished only the transfer of an atmospheric
         emissions source from the study area to a remote site,
         and at the expense of a net  increase in overall fuel
         consumption.

II.  Wetlands

     On pages 1.71 and 1.72, the Proposed Action states that    i J- 4- 1
     wetland can be classified and that some wetlands must not
     be altered, some must be restored and  some have so little
     value that restoration is not necessary.  We believe that
     some very important factors were not considered in this
     determination or were not given  sufficient weight.

     A.  Protection and preservation  of wetlands overlying phos-
         phate deposits causes an irreversible and irretrievable
         loss of valuable phosphate resources.  This loss has a
         long term social and economic impact.  This impact on
         the local economy, our country's agriculture or our
         balance of trade deficit has not been considered any-
         where in the draft EIS.  This impact must be considered
         and weighed against the value of the wetlands that may
         be temporarily disrupted.

     B.  The prohibition of mining in certain types of wetlands
         is based on the supposition, stated in the third para-
         graph page 3.3, that adequate restoration techniques
         will not be developed.  The  mining of any area which
         can be restored should be left open as an alternative
         for future decision-making as suitable restoration
         techniques are developed and proven.

     C.  The classification of wetlands by  their associated
         water course needs to include additional considera-
         tions.  The jurisdiction of  the Corps of Engineers
         over wetlands is based on average  annual water flow in
         the associated water course.  This does not consider
         that some intermittent water courses may meet the
         Corps' flow requirements on  an average annual basis,
         but due to the intermittent  nature of the flow, the
         associated wetland would have much less value to the
         environment.  These and other considerations should be
         included in the classification system for wetlands,
         allowing mining to go forward in these areas having
         less value.

Ill,  Clay  Disposal

     On page 1.70, the Proposed Action indicates that sand/clay    4. JL
     mixing  techniques will be required in  order to meet the     U~
     goals of no above ground clay  storage  areas,  land use  for
      structures, and reclamation of water  from clays.  This  spe-
      cification of one method of sand and  clay disposal  is  un-
     necessarily restrictive and ignores many  significant  fac-
      tors.   The most  suitable  technique  for clay disposal de-

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pends on many factors such as mine pit geometry, clay
content of the matrix, sand/clay ratio, physical pro-
perties of the clay, etc.  These are site-specific fac-
tors that must be determined on a case-by-case basis.
At present, there are at least seven different methods
under study or in use.  The selection of the most
suitable method must be made on the basis of site-specific
considerations.

There is one field application of sand/clay mixing in
existence today as cited on page 2.20.  First, it is too
early to judge the ultimate success of that application,
though the initial results may be encouraging.  Secondly,
such preliminary results should not become the basis of a
requirement for sand/clay disposal at all sites and under
all circumstances.  Successful operation with this one
particular ore body does not necessarily show that it
would be technically and economically acceptable for
other ore bodies.  Reason dictates that a degree of flexi-
bility be retained in this area of rapidly developing tech-
nology.

One must also recognize the problem of sand/clay disposal
as one of volume.  For any given ore body and selected dis-
posal method", the volume of sand/clay material is fixed.      .
The final volume of material is ultimately determined by  fr^~ **
the settling and consolidation of the waste materials.
Given these basic facts, two considerations must be recog-
nized.  Any restriction on the height of the disposal area
requires an expansion of the area involved in order to
accommodate the volume of material.  Thus, more land area is
dedicated to clay disposal when all below grade disposal
is required.

Secondly, the depth of the clay or sand/clay system is a
major determinant of ultimate consolidation density.  By
restricting the height of the disposal area to natural
grade, a severe limitation is placed on the consolidation
process which occurs after the clays are in place.  We
find no indication that these factors were considered in
the development of the proposed action.

Thirdly, the prohibition of above ground storage areas
other than the initial area will render some phosphate
reserves unminable.  Certain reserves will have such
high percentages -of clay in their matrices that insuffi-
cient mining pit volume will be generated to contain the
waste material.  Thus implementation of the proposed ac-
tion will  result in the  irreprievable  loss of valuable
phosphate  resources.

Mississippi Chemical Corporation adopts by reference the
comments of the Florida  Phosphate Council on the Areawide
Environmental  Impact  Statement.

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While the preceding remarks reflect some of our immediate
concerns, MCC reserves the right to comment on any other
aspects of the Areawide EIS during site specific EIS
review.

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                                                                                  • 3 3 Jf
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-------
Curl T.

Z IIV1IV! E R fS/l/\N N • . \Hliimiilinii t'tiiisnllmil
3312 Village Green Drive
Sarasota,  Florida 33579
Tel. 921-4946                                      June 1, 1978
     Mr.  Eugene McNeill,  Project Manager
     Environmental Protection Agency, Region 4
     345  Courtland N.E.
     Atlanta,  Georgia 30308


     Dear Mr.  McNeill:

                      Unfortunately, I was absent from Sarasota at the
     time a public meeting was held at the Manatee Junior College,
     concerned with discussions of the Federal Environmental Impact
     Study of  phosphate  mining in Central Florida.

     There still appears to be some confusion as to the seriousness of
     phosphate mining on the Floridian environment, and a lack of under-
     standing  of the problems by the people in this area. However, I am
     inclined  to believe that your final analysis may provide specific
     recommendations to  be implemented by either Federal, State or Local
     legislature to exercise some type of enforceable control over the
     problems.lt will also be important that the people be informad about
     proposed  corrective measures - in a language that can be understood
     by the people and assure their active support.
    '""'   ? r,,.
     Prior to* retirement in Sarasota, I was active in U.S.A. and some
     European  Countries  as an Automation Consultant, primarily concerned
     with the  "Total Systems Engineering Analysis" of processing operat-
     ions - and application of proven technological developments for
     higher productive efficieny and economical justification. I am now
     making a  study of phosphate mining in Florida and its serious impact
     on the environment.  Special emphasis is on water consumption, water
     re-cycling, radiation sources and their control, air and water pollut-
     ionproblems, settling ponds, re-damation activities, recovery of
     radium from the overburden and phosphate rock, and latest develop-
     ments concerned with de-watering of clay wastes to eliminate the
     need for  settling ponds.

     It may take another 2 weeks before I can list specific recommendat-
     ions for  improvements, which I should like to submit to you. There is
     indication that my  recommendations will be in line with your own,
     and  I am  looking forward to EPA's proposals for corrective measures
     which can be agreed upon by legislature to assure prompt and strict
     enforcement.
Ve^y truly yours,
         )
         kil lit i+ /U«.«.u
                                                     I)
                                                     \k
                                                    '
     CTZ:ngs.                                 Carl T. ' ' Zimmermann

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          DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
                          PUBLIC HEALTH SERVICE
                         CENTER FOR DISEASE CONTROL
                           ATLANTA, GEORGIA 30333
                           TELEPHONE: (404)633-3311

                                   June 8, 1978
Mr. John E. Hagan, III
Chief, EIS Branch
Environmental Protection Agency
Region IV
345 Courtland St., N.E.
Atlanta, Georgia  30308

Dear Mr. Hagan:

We have reviewed the draft areawide environmental impact statement for
the Central Florida Phosphate Industry.  We are responding on behalf of
the Public Health Service.

One area of concern relative to the EIS centers around problems involving
fluoride effluents in the environment.  It is stated that fluorides will
be discharged into both the atmospheric and surface waters.  A great deal
of precaution should be taken to avoid excessive exposure of workmen and
residents in the area to high fluoride concentrations.

Previous studies by the National Institute of Occupational Safety and
Health indicated that very low background radiation was generated by the
phosphate operations in Florida.  In view of NIOSH's study, it does not
appear that radiation exposure from this industry would present a human
health problem.

While there are a number of pollution oriented problems with this opera-
tion as proposed, they do not appear to present an imminent human health
hazard.

Thank you for the opportunity of reviewing this document.  We would
appreciate receiving two copies of the final statement when it is issued.
                                   Sincerely yours,
                                   William H. Foege, M.D.
                                   Assistant Surgeon General
                                   Director

-------
                             DEPARTMENT OF THE AIR FORCE
                  USAF OCCUPATIONAL AND ENVIRONMENTAL HEALTH LABORATORY (AFSC)
                              BROOKS AIR FORCE BASE, TEXAS 78235
                                                           L        U78
*TTN OF:  EC

SUBJECT:  Draft Areawide Environmental Impact Statement (DEIS) on the Central
       Florida Phosphate Industry  (Your Ltr, 7 Apr 78)

   TO.  U.S. Environmental Protection Agency
       Region IV
       345 Courtland Street
       Atlanta GA 30308

       Subject document has been reviewed by staff members of this organization,
       No major environmental impacts upon Air Force installations or operations
       were identified.
       JCtiN/P. MEADE, Colonel, USAF, BSC
        "lief, Consultant Services Division
                                                          /-.' ;'•  , •• •
                                                          ^ic"
                                                             r,'??'1"" •>'
                                                                    1ST3

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                                       1504  Shelley Place
                                       Lakeland, Florida   33803
                                       May 8,  1978
Honorable Lawton Chiles
United States Senate
Federal Building
Lakeland, Florida  33802

Dear Senator Chiles:

After a thorough review of the Draft Areawide Environmental
Impact (DEIS) dated March 1978, I felt it necessary to en-
lighten you on several aspects of the document which, in my
opinion,  have been erroneously reported.  I have been
employed by the phosphate industry for eight years as a
mechanical engineer and I feel that I am qualified to provide
an accurate rebuttal to the DEIS.  I, too, enjoy living in the
Central Florida area and I am not interested in being a part
of environmental pollution.  However, there is a way for
industry and the environment to coexist for the betterment of
all people concerned.

With regard to the summary of major environmental impacts,
it would be incorrect to assume that recreational resources   U~4
will be reduced with phosphate mining.  The property now owned
by phosphate companies generally contains no recreational
areas.  One of the major benefits of a phosphate reclamation
program is to install lakes and parks as a part of the overall
plan.  Most any fisherman in the study area will tell you that
the best fishing can be found in reclaimed phosphate pits
which are usually stocked by the phosphate companies.  One
company intends to construct a reservoir as a part of their
program.   Other than the obvious municipal benefit, the lake
will provide outstanding recreational facilities for boating
and fishing in an area that is currently void of this resource.

One of the proposed actions for new source mines is to eliminate
conventional above-ground slime  (clay) - disposal areas.  If
this action is implemented as an industry-wide practice, the    U~
effects upon phosphate mining could be disastrous.  There is a
wide range of percent clays contained in ore bodies when comparing
one mine to another.  Due to the amount of water tied up in
various types of clays, one mine may rsquire considerably more

-------
Honorable Lawton Chiles
May 8, 1978
Page Two
volume than another.  If this volume is to be contained
below ground, the plan area would far exceed mined out areas
thereby rendering the mining operation uneconomical.  Even
with sand-clay mixing of waste material, it would not be at
all feasible to totally eliminate above ground storage.  Also,
with regard to the containment structures, there are many
references to the potential threat of a dike failure in the
DEIS.  Several years ago I would have agreed that there was
always some threat, however, since the dike failure in 1971,
technology, construction methods and inspection programs have
all but eliminated this danger.  In addition to the improved
design and construction of dams, all mines now have various
means of positive protection such as continuous monitoring of
ground water and daily inspection.

Section 2 contains an item under process modifications for     .  A
new sources which deals with conveying matrix from the mine  I*/~ ~
to the beneficiation plant.  A reprint of a letter from Brewster
Phosphates to the EPA describes the relative success of the
conveyor at their Lonesome Mine.  Unfortunately, there are
many factors to consider when determining the economical
feasibility of a matrix conveying system.  Items such as land
contour, mining plan, property layout, reclamation plan and
obstacles such as roads and creeks must be carefully studied
as they ultimately affect capital and operating costs.  The
system at Brewster Phosphates can be considered to be in a
development stage as they are still experiencing costly problems
such as spillage, lost feed when cycloning onto the conveyor
and belt slippage.  There is a definite energy savings in con-
veying matrix vs. pumping, however, the savings need to be weighed
against the higher capital cost and maintenance of a conveyor
system.  Due to the variables affecting the economics of a
conveyor, it is possible for one operator to realize a savings
with a belt, whereas it would be a losing proposition for another
mine.

References are made in Section "G" of the Alternative Assessment
of Secondary Effects of "Permit Existing and New Sources" to the
reduction of the scenic attraction of the area and the danger
to the tourist industry.  I am sure that everyone agrees that
mining activities are located in the more desolate areas of the
state and many miles from the multimillion dollar tourist
attractions.  Furthermore, regulations now require immediate
reclamation of mined out land adjacent to highways.  Also,
processing plants and settling areas requiring dikes are now set
well off roadways so as to minimize any scenic alterations.  A
prime example of this would be Agrico's Ft. Green Mine off State
Road 37-

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Honorable Lawton Chiles
May 8, 1978
Page Three
I felt it was important to call your attention to my eval-
uation of the DEIS and I hope you will consider my comments
when drafting legislation on EPA rulings.

                                     Very truly yours,
                                     David 0. Munson
DOM/jIc

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LAWTON CHILES
   FLORIDA
                                                      COMMITTEES:

                                                APPROPRIATIONS

                                                BUDGET
                                                GOVERNMENTAL AFFAIRS
                                                SPECIAL COMMITTEE ON AGING
                                                DEMOCRATIC STEERING COMMITTEE
                                                           420
                              WASHINGTON. D.C. 20510
                               May 30,  1978
Mr. John C. White
Regional Administrator,  Region IV
Environmental  Protection Agency
14201 Peachtree  Street,  NE
Atlanta, Georgia  30309

Dear Mr. White:
         I have recently  received the enclosed correspondence
         regarding a matter  involving your agency, and because
         of my desire to  be  responsive to all inquiries, I
         would appreciate having your comments and views.

         Your early consideration of this matter will be appre-
         ciated, and if convenient,  I would like to have your
         reply in duplicate.   In your communication, please
         return the enclosure  and make reference to this
         letter as indicated below.
                                      Since
                                               ILES
         LC/rob

         Enclosure

         RE:  In reply, please  refer to 17/David O. Munson
                   REPLY TO: FEDERAL BUILDING, LAKELAND, FLORIDA 33601

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        CF CHEMICALS, INC., Subsidiary of
                                                       Post Office Box 1480
                                                       Bartow, Florida 33830
                                                       Telephone: 813/533-3181
                            TM   wa  • na isa «• 
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Mr. R.E. McNeil 1
May 16, 1978
Page Two
5.  Page 2.50
    The top line indicates radioactivity in the lower Floridan of "196 ^_  4
    picocuries per liter".  This statement is in error.

6.  Page 4.3
    Requiring "once-per-shift manual sampling to ensure  that automated
    equipment is efficiently operating" is unnecessary.   Presently required
    monitoring and optional (but generally utilized) alarm systems are all tJ
    that is necessary to properly protect the environment from spills.


Under separate cover, CF Industries will present a more  formal  comment on the
content and issues of the draft EIS.

                                   Sincerely,
WAS/ 1m
                                           A.  Schir
                                   Chief Environmental  Engineer

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                                      INCORPORATED
                                                       INTERNATIONAL HEADQUARTERS:
                                                       STAMFORD, CONNECTICUT 06904, U. S. A
                                                       CABLE: DORROLIVER STAMFORD

                                             May 17,  1978


Mr. John E. Hagan III                                             .    A_ "? ~~J
Chief, EIS Branch                                               \/J ~~  ^     '
EPA Region IV
345 Courtland St., N. E.
Atlanta, Ga.  30308
                         Re:  DEIS, Central Florida Phosphate  Industry
                              Dated - March   1978
Dear Mr. Hagan:
We are suppliers of equipment and engineering to  the phosphate  industry.
Fluidized bed drying of phosphate rock has constituted  an  iirportant part  of
our work with that industry; but  (1) we span the  industry  with  equipment
for many processing methods, and  (2) we do not oppose carefully considered
and operable regulations to ensure that our drying systems and  other
systems are clean.

As we read it, the subject DEIS would practically legislate out of existence
one of the two principal flowsheets available for beneficiating phosphate rock,
namely, the "dry" route.  The other route is referred to as "wet".  We  urge
you to avoid such a blanket prohibition.

Some areas in sane phosphate rock processing plants using  the "dry" system
are unquestionably too dusty.  Standards should be established  to hold  dust
levels down to acceptable amounts.

As far as rock dryers are concerned, we can demonstrate at existing large
installations that our fluidized-bed dryer with reasonable maintenance  is
clean by the strictest standards in such industries today.  If  the cost of
meeting acceptable standards in areas like rock grinding,  product storage
and bagging should make capital and operating costs too high  (not likely),
then, of course, producers would use other flowsheets.  They would have been
given a choice.

Similarly an economic balance will determine whether the energy spent in  drying
rock at the mine justifies the extra expense of dust control equipment  less
savings in freight.

Regarding radiation we do not see evidence that levels  are above acceptable
figures now, even in plants where dusty conditions exist.   When dust  levels
are lowered, the radiation reported in Section  (2), last sentence, top  of
page 2.87, in the DEIS as being insignificant should be even less.  We  have
requested that Reference USEPA 1977 be sent to us when  ready for distribution
to the public, but we do not expect any change in this  belief after receiving
our copy.


                                     J-  1 98

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 3DOH.R.-OLIVER i
Mr. John E. Hagan III                                       ^V ^ 1978
Atlanta, Ga.  30308                                         Pa9e
To be as specific as possible, we draw your attention to the  following sections
of the DEIS and make brief comments:

     Page 1.70, Section E,  (1)  (a), first requirement:
     Establish clean air standards for all areas with particular
     care for areas that are now found to be dusty.

     Page 2.86, (2), last paragraph:
     The first and second sentences in this paragraph are inconsistent.
     Regarding the first sentence, establish clean air standards.
     Regarding radiation, cleaner air will mean even safer levels than
     those existing at present.

     Page 3.1, (1):
     Again, establish clean air standards for all areas.  We  have not
     received the'evidence behind the figures quoted here.  The fact
     that dust can be collected and S02, absorbed, appears to have been
     overlooked.

     Page 3.6, (4):
     Again, clean air standards for all areas would get at the crux of
     what problems there are,

We will arrange for one of our specialists in phosphate rock  processing to
meet with you and/or make some plant visits with you if greater understanding
on both sides would result.  Please advise.
                                   Very truly yours,

                                   DORR-OLIVER INCORPORATED
                                   Thermal Processing Division
                                   Telephone:  203-348-5871  X774
LVL/vjl

cc:  Mr. R. L. Klaer, Dorr-Oliver-Atlanta
                                              f

-------
                                                    7OO TWIGGS STREET
                                                    SUITE BOO
                                                    TAMPA. FLORIDA 336O2

                                                    TELEPHONE 1813) 272.9940
HILLSBOROUGH  COUNTY  PLANNING   COMMISSION
                                                    JOHN A CRISLIP
                                                    ,„,.„„«, «....!.».
    ( M i.uWK'N IIIIUNHILD


    t,, -HI I N I Oil MAN


    1.1 -iiiv r. imnwN
    | Ml MY M CAHtlR

    u»	I M K.HNANDEZ
    *»•""*" JOHNSON                    June 22, 1978
    i ,r; IIAWI S JR
    n ill Ml THOMAS
    Vi.  John C.  White
    ];.'iionnl Administrator
    linvironmcntal Protection Agency
    K.iMion VI
    345  Courtland Street, Northeast
    Atlanta, Georgia  30308

    Attn:   Mr.  Gene McNeil
           EIS  Branch
                                   •Re:  Draft Areawide Environmental
                                        Impact Statement, Central
                                        Florida Phosphate Industry
    Gentlemen:
    The  following presents the initial comments and recommendations
    of  the Hillsborough County Planning Commission staff on  the above-
    referenced EIS.

    We  concur with the general thrust of the proposed action and com-
    mend EPA for its comprehensive treatment of this subject.   We
    especially appreciate EPA's understanding of the extremely long
    time periods which are required in the reestablishment of mature
    forested wetlands.

    Our  major concern at this time is that the EIS might inadvertently
    weaken the implementation of adopted comprehensive plans at the   l
    State and local  levels.  In particular, the protection of wetlands
    may  suffer unless the EIS is modified to include more explicit
    support for locally adopted comprehensive plans which protect
    wetlands which  are under local jurisdiction but which may or may
    not  be under direct federal jurisdiction.

    In  order to illustrate the types of pertinent policies which may
    be  found in local comprehensive plans, we have attached  excerpts
    from the Conservation Element of the Hillsborough County Horizon
    2000 Plan — all of which is incorporated by reference into Hills-
    borough County Ordinance No. 77-26.  Pursuant to the requirements
             AN Al I IKMATIVI. At T1ON-KQHAI. OPPORTUNITY KMPI.OVKR

-------
••, .  John C.  White
V.i I" 2
•-.:>.- 22, 1978
,»!  chapter 75-390 Laws of Florida, the Horizon 2000 Plan was adopted
.   tho Planning Commission on August 1, 1977, and adopted by the
if'-.inl of County Commissioners on November 30, 1977.

it  is recommended that the following modifications be made to the
t.;:; in order to alleviate our major concern:

     1.   On page 1.70 change item E.I.a (2)  to read:

            "Meet the effluent limitations of the State of
            Florida and of local environmental protection
            commissions for all discharges,  including but
            not limited to dredge and fill activities in
            the waters of the counties."

     2.   On page 1.70 add a new item between items E.I.a. (2)
          and E.I.a.(3) to read:

            "Comply with all goals, policies, and guidelines
            of locally adopted comprehensive plans, to the   u/~ ^
            extent that they are not in direct conflict with
            the State Comprehensive Plan."

     3.   On page 1.72 add a third paragraph to item E.I.a. (9)
          which would read:

            "Local environmental laws, ordinances, rules and
            regulations which are stricter or more extensive
            than federal wetland standards shall prevail."

Please do not hesitate to contact us if we can be of further
Assistance.

                               Sincerely,
                               Gary S. Ellis, Chief
                               Environmental Section
GSE:kvh

Attachments

-------
                          CONSERVATION ELEMENT
                                   of
                            HORIZON 2000 PLAN
GOAL
     Conserve natural and environmental•resources for present  and  future
generations.

POLICIES
     1.   Hillsborough County  hereby  recognizes  that  the air and  water
          including, but  not limited  to,  lakes,  rivers, bays,  streams,
          fresh and salt  water marshes, aquatic vegeLation and  animals,
          and natural shorelines are  necessary for  the  maintenance of a
          high quality environment.  The enactment and continued enforce-
          ment of  land development  regulations which avoid the  destruc-
          tion or  alteration of such  ecosystems  are  necessary  for  the
          protection and  improvement of the quality of  the environment.
          Hillsborough County hereby recognizes that the other environ-
          mental features native to  the  County as described  in the  Con-
          servation Element perform a valuable function in providing the
          public with livable surroundings; and, thus,  these features
          are in need of adequate  protection  if  such advantages are  to
          be maintained for future  generations.
     3.   Hillsborough County hereby recognizes that the full  and  proper
          utilization of all governmental  powers is necessary  and  desir-
          able to help achieve the above Goal.
GUIDELINES
Air Resources
     1.   Discourage the  location of  new  point  sources  of  air pollution
          which would adversely impact existing  areas  of heavy pollution
          concentration.

     2.   Minimize  total  air pollution emissions from point  sources  to
          the  extent practicable,  in  keeping  with both socio-economic
          and  environmental  considerations,  by  encouraging  the  best
          available  air pollution control  technology  and by encouraging
          the recruitment of clean industry.

     3.   Minimize  total  air pollution emissions from  nonpoint sources
          by appropriately guiding land development and  by  improving the
          flow of traffic.
                                    3-30

-------
                    maintaining  the naturally free-flowing  character of
                    navigable  rivers  and  streams,  and
                    preventing shoreline  erosion,  preferably by means of
                    vegetation and  the  utilization  of other  shoreline
                    stabilizing  techniques  that  blend in with the natur-
                    al  environment.

    19.    Safeguard  the scenic  portions  of  the visual corridor  of the
          proposed  Interstate  75  extension  in a  timely  and  exemplary
          fashion:

    20.    Maintain and  enhance the  quality  of the  nighttime  environment,
          by eliminating  those   outdoor  lighting devices which  do  not
          efficiently  perform a  necessary function  and  by  controlling
          air pollution.

    21.    Ensure  the optimum management of  native  shade trees.

    22.    Minimize  serious  noise and odor pollution by  separating  in-
          compatible land  uses.

    23.    Maximize  the percent  of open  space in each new  development.

Earth Resources

    24.  -  Minimize the  waste of  earth resources  by:

                    discouraging   the  permanent  development  of  lands
                    underlain  by  valuable  and  potentially   valuable
                    mineral  deposits  (see Glossary) prior to the mining
                    thereof, and
                    encouraging   resource  recovery by  promoting  source
                    reduction  and recycling of solid  waste,  and
                    encouraging  the  constructive  disassembly of  build-
                    ings  so that the building materials  can be  reused.

    25.    Identify,  evaluate,  and  mitigate possible hazards  associated
          with  reclaimed  lands,  unreclaimed  mined  lands,  and  unrained
          mineral lands.
    26.    Minimize  the  adverse  impacts  of mining by:

                   prohibiting mining  in rivers, streams, and  alluvial
                   wetlands,   except   in  extreme  cases  of   overriding
   	public  interest, and	
                   requiring   timely  reclamation—using best available
                    *»*-*••«-»•••-~~"~ &j  »• v *.%_h_>^i_i*v.j..j.u«.**  v*. v^(jv-«^i^j.juh>4i.  Qn optxrnum
                    mix  of  land  forms,  land  uses,  and natural  vegetation
                    associations.
                                      3-303

-------
                                GLOSSARY*
A.   Alluvial wetlands - This natural vegetation  association is  found on
     frequently-flooded areas which consist of sediments  of  mixed origin
     that have  been deposited  near  streams  and  which are mapped  as Ac
     and PC  soils  by the Soil Conservation Service.  The dense  hammock
     vegetation  includes,  gumr  maple,  live  oak,  water  oak, ironwood,
     hickory, cypress,  cabbage  palmetto, vines,  shrubs,  and a few gras-
     ses and pines.

B.   Aquatic preserves - These are publicly-owned submerged  lands  which
     are covered by salt or brackish water and which are recognized by
     law or  regulation as  having exceptionally high biological,  aesthe-
     tic, educational and/or scientific value.
C.   Cases of Extreme Overriding Public Interest  mean  cases  in  which:
     1.   The proposed  action  is  found to have primary and  direct bene-
          fit to the public of the County; and
     2.   All reasonable  alternatives  to the proposed action have been
          presented  to  and fully considered by  the governing body;  and
     3.   All alternatives  are  found to  be publicly unacceptable  or are
          found  to  entail  substantially  greater cost  to the public or
          both; and
     4.   All  environmental impacts of   the  proposed  action have  been
          presented  to  and fully considered by  the governing body;  and
     5.   All potentially  adverse  environmental impacts  have been mini-
          mized to the greatest extent  feasible; and
     6.   The  proposed  action complies  with all  applicable  federal,
          State, and local  environmental  control laws.

D.   Cases of Overriding Public Interest  mean cases in which:
     1.   The proposed  action is  found  to have substantial benefit to
          the public of the County; and
     2.   All  reasonable  alternatives  to the proposed action have been
          presented  to  and fully considered by  the governing body;  and
     3.   All alternatives  are  found to  be publicly unacceptable  or are
          found  to  entail  substantially  greater cost  to the public or
          both; and
     4.   All  environmental impacts of   the  proposed  action have been
          presented  to  and fully considered by  the governing body;  and
     5.   All potentially  adverse  environmental impacts  have been mini-
          mized to the greatest extent  feasible; and
     6.   The  proposed  action complies  with all  applicable  federal,
          State, and local  environmental  control laws.

E.   Class I Waters  - These are  surface  waters  that  are used as  a pot-
     able source  of public water supplies or withdrawn  for  treatment as
     such.

F.   Class II Waters - These  are  coastal waters in  areas  which  either
     actually  or potentially have the capability of  supporting recrea-
     tional or commercial  shellfish propagation  and harvesting.


                                  12  3

-------
                providing norunonetary compensation  where possible by
                means of administrative and  regulatory  procedures—
                even  though not  required  by  law  to  provide  any
                compensation,
                giving  equal  attention to acts  of government  that
                result in "windfall" benefits to property owners as
                well  as  those  acts  which may  result in  "wipeout"
                losses,
                ensuring that  "windfall"  benefits  which accrue  to
                individual  property  owners  as a  result of  govern-
                mental action  are  identified  and  that  adequate means
                are  established whereby  the public  may be  compen-
                sated for such unearned gains,
                encouraging  programs  designed  to  increase  the amount
                of accurate  biophysical information available to  all
                buyers and sellers in  the marketplace for  land,  and
                encouraging  appropriate reforms  of the tax  system.
38.   Encourage both private and public  sectors to make a concerted
      effort to bring existing  laws,  regulations, governmental prac-
      tices, and private actions into  alignment with the letter  and
      the spirit of this Plan.   However,  existing environmental laws
      and regulations which are stricter  or more extensive than this
      Plan  shall  continue  to be enforced; and  such  laws and regu-
      lations shall  be  the minimum  standards;  and  nothing in this
      Plan shall be  construed  to state or  imply a  goal, policy,  or
      direction which  is  inconsistent with  such stricter  or more
      extensive laws or  regulations.
39.   Favor preventive  management so'^ty t§  Jiiijimize  the  need  for
      corrective action.

40.   Favor modified compact  growth and appropriate types of cluster
      development over urban  sprawl.

41.   Give timely  and favorable  attention to the following actions
      in  addition  to  all  other  specific  action policies  in this
      Plan:

                ensure that  all  lands  and  waters  in  this  juris-
                diction are zoned  and/or rezoned in a timely fashion
                in order to appropriately implement this element of
                the Horizon 2000 Plan.
                disapprove all  rezoning applications within conserva-
                tion areas unless the application  is  for a planned
                development which  requires detailed site plan review
                following  specific guidelines and criteria,
                eliminate  from the capital  improvements budget  and
                program all  projects  which cannot be modified so as
                to conform to  this Plan, and
                promote maximum feasible  participation of citizens
                in the decision-making process.
                              10  7-705"

-------
                              P. 0. Box 1305
                              Punta Gorda, Florida  33950
                              June 13, 1978
Mr. John E. Hagan III, Chief
EIS Branch, Region IV                            i ___ A tf.
U. S. Environmental Protection Agency          \/J     *
345 Courtland Street, N.E.
Atlanta, Georgia  30308

Dear John:

I wish to reemphasize some of the concerns I expressed at
the public hearing regarding the impact of the phosphate
industry on our area and its residents.

The Peace River already is a regional potable water supply
for residents in DeSoto, Sarasota, and Charlotte Counties and
possibly on down to Boca Grande in Lee County.  Nowhere in
the Draft EIS did I see where it pointed out the present and
future potential use of the Peace River as a potable water
source.  Attached is a letter on the use of the Peace River
by General Development Utilities, about which I had questioned
Mr. Harold E. Schmidt.  I wish for this letter to be included
as part of the record on the Draft EIS.

Many other municipalities along the Peace River may one day
have to make withdrawals from the river for their drinking
water.  Attached is a copy of a report by Tri-County Engineering,
Inc. for the City of Punta Gorda on future source of water for
the city.

The reason the City of Arcadia had to stop using the river for
drinking water was because of the quality due to phosphate
spills.  If the inland well fields go bad, then the only other
source will be surface water from the Peace River Basin.

We have attempted to upgrade and reclassify the Peace River
in DeSoto County to Class I Water (Potable) in an effort to
better protect it.

The 208 plans should also address water quality in the Peace
River Basin and not only all new, but also existing sources

-------
Mr. John E. Hagan III
June 13, 1978
Page Two
of pollution be required to conform to the 208 plans.

Not only is water quality important, but also quantity.
We need runoff, which, in turn, makes flow.   Adequate
flow in the Peace River is essential to maintain the ecologi-
cal balance in the Charlotte Harbor Estuarine complex.  There-
fore, total water retention by the industry would be very
harmful.

Again, I wish to reiterate the need for timely and adequate
monitoring on all aspects of phosphate mining from EPA,
DER, DNR, water management districts to the local county
level.  All of the rules, regulations, policies, are worth-
less, unless they are beneficial, followed and enforced.

We in Charlotte County are vitally interested in the Peace
River and Charlotte Harbor because, this without question,
it is the greatest natural resource we have in our area.

Thanks again for all the listening you have done and I hope
the final EIS will be a very good one.

                              Sincerely,
                              Robert N."McQueen
                              Advisory Committee Member
                              Charlotte County, Florida
RNMcQ:dd

-------
 General Development Utilities. Inc.
                                                        June 5,  1978
Mr. Bucky McQueen
Phosphate Industry
  E.I.S. Advisory Committee Member
P. 0. Box 1305
Punta Gorda, Florida 33950

Dear Bucky:

I have been requested to update the information you may  have available
on the General Development Utilities Water Plant now being  constructed
on the Peace River.

This Water Plant is being constructed to provide the potable water
needs of the Port Charlotte area and its surrounding environs.   The
Plant, as presently constructed, will have an initial capability of
six to seven million gallons per day.  However, present  structural
components of the Plant have been designed for 30 million gallons per
day.  There is sufficient land being maintained to expand the Plant
and transmission main well beyond its present design.

The Peace River was chosen .because it offered an adequate supply of
high quality surface water easily treatable by conventional water
treatment methods.  The energy needed to treat this type of water is
lower than that necessary to treat water by the reverse  osmosis  pro-
cess.   The amount of chemicals required to treat this water as  com-
pared to existing ground water in the areas is also less.   We have,
therefore, the best of all situations on adequate quantity  of fresh
water easily treatable by conventional low energy treatment systems.
This fresh water source, we believe, is being put to its best bene-
ficial use by providing a high quality potable water supply to the
citizens of Florida at the most economical price possible.

We have been approached in the last year by other associations request-
ing water from the Peace River Plant.  These include Rotunda, Gasparilla
Island, Englewood and Sarasota County.  You see, therefore,  that the
Plant could indeed serve as a regional water source for  this whole area
of Florida.

We are studying ways of moving water from our waterway systems of Port
Charlotte and Sarasota County to our reservoir system in DeSoto  County -
This will help supplement the water supply from the Peace River  and
help us keep the reservoir to a reasonable size.  The Peace River, how-
ever, is intended to be the main source of water and to  be  the prime
source of water to meet this area's needs.


                               3- jo 8
 Illl Soutii(!3vsp;>'i!l)iiV«i Mianv. li.«i(1.i33U1. Irt'phoni-' ;>0'> JliO i:>3l                    AGunetjl DI*

-------
Mr. Bucky McQueen                 -2-                    June 5,  1978
When the existing facility is constructed  to  its  present planned
capacity, our investment will exceed 30  million dollars.  Our commit-
ment to the Peace River as our source of potable  water,  as you can
see, is substantial.   Anything to degrade  the quality of the water
as it now exists will certainly have an  impact on the citizens on
this coast of Florida.

The Plant is scheduled to be completed by  March of 1979.  Should you
or your Committee care to go through the facility,  we would be pleased
to show it to you.  Most structural  work is completed, and we are in
the process of installing the mechanical and  electrical  equipment.

If you need additional information on our  Peace River Plant,  please
do not hesitate to contact me.
                                  Harold  E.  Schmidt
                                  President
HES:mgf

cc:  Wayne Allen
     C. C. Crump
     Dan Dennison

-------
Tui-COUNTY  KNGINKKRING. INC.

                  SECTION V - PEACE RIVER POTENTIAL

                  The Peace River would provide a water supply
             of more than adequate quantity  for many years to
             come.   The average  discharge at Arcadia is 1,250
             cfs and at Punta  Gorda is estimated at over 2,000
             cfs,  and during peak flows has  reached over 30,000
             cfs.   Water quality is such that normal  treatment
             will  adequately provide potable water (see follow-
             ing tabulations).
                  The'salinity line .above which a potable water
             supply source should be located, lies near Fort
             Ogden.  A raw water transmission line of some 12
             miles  in length would be required to convey the
             water  to the Shell  Creek Plant.  Accompanying this,
             a diversion structure must be placed in the Peace
             Riv.er  in such a way as to preclude inasmuch as pos-
             sible  the intake of phosphate slimes in the event
             of a spi11.
                  As a potential source, the Peace River quali-
             fies in all categories except one.  That category
             is economics and even though feasible, the cost to
             the community would be greater  than other sources.

-------
Form 9-240-7  SW Annul No.  7
                                     U. S. IWMOIKHI Ot TIIZ IlneMOR - CEOMJBICAl SURVEY
1)68
Florida
104
                                                       10D  PEACE RIVER MSIN

                                               2-2967.)  Peace River >C Arcadia, PU.
UcJtlon.--l.Jt  27M3'19", long 8l'52'34", In SEV, »ec.26, T.37 S., R.24 £., on left bunk 500 ft  upstream from bridge on State Highway
   70,  1.0 Dllc west of post office In Arcadia, DC Soto County, 6.1 miles upstream from Joshua  Creek,  and  36 mile*  upstream froa
   DOuth.

Drainage urea.—1,367 aq ml.
Records available
--April 1931 to September 1968. Prior to October 1950, published as Peace Creek at Arcadia.
Cage. --Digital water-stage recorder. Datura of gage Is 6.00 ft above mean sea level, datum of 1929; Mar. 20, 1964 to July 11, 1967,
staff gaie at mean sea level. Prior to July 19, 1931, staff gage, and July 19, 1931 to May 16, 1963, graphic water-stage recorder,
and May 16, to Sept. 30, 1963, digital water-stage recorder at saae cite at datum 2.25 ft higher. All gage helghta are at gage
datum.
Average discharge. --37 years. 1.252 cfa.
Extremes. --Maximum discharge dprlng year, 7,030 cfa July 13 (gage height, '12.66 ft); minimum, 60 cfa May 6 (gage height, 1.20 ft).
1931-68: Maximum discharge, 36,200 cfa Sept. 9, 1933 (gage height, 19,92 ft, preaent datum); minimum, 37 cfa Hay 28, 1949;
Blnlmua gage height, that of May 6, 1963.
Kaxlnm atage known, 20.6 ft (preaent datum) in 1912, froa Information by county engineer (dUcharge, 43,000 cfa, froa rating
Remarks. --Records good. Records of chenlcal analyses and water temperatures for the water year 1968 are
report. See page 103 for toble of gage height.
DISCHARGE, IN CUBIC FEET PER SECOND
CAT
OCT
I 4,0*0
2
\
*
»
6
7
8
9
10
11
12
13
14
15
16
17
U
|9
20
21
22
21
?4
25
26
}t
I'
JC

,740
,080
,450
,C1C
,T40
,7)0
,7CO
, 4*0
,79C
,440
.421
,190
, 100
877
7H
681
616
560
5ff
449
41)
4K
3'2
>*;
362
350
)18
))8
% \ tv
* j »
tlTsl 37,402
"US
M.\X
111.
C'SM
It.
t2r T
k ,flhO
J35
• Pft
1.02
C«l »R U67 1
«IR Y« !>(.« I
NOV
303
326
323
30*
317
323
303
268
244'
2)5
221
225
244'
266
286
2,,
2)6
208
2)3
214
214
231
2)6
246
268
265
244
216
210
> > i
e 1 1
7,611
25*
ii>
2))
.19
.21
"Til 276,111
Hal 4(9,10;
OEC
207
200
212
22)
22)
210
208
204
205
207
246
348
553
561
482
401
33)
312
302
290
287
276
254
241
245
235
238
;o)
29)
5*7
* 7 '
e.aoi 7
2*4
561
200
.21
.24
KF«N
Kf AN
JAN
261
256
268
237
212
197
204
224
235
242
24*
225
225
235
254
268
239
224
222
21S
209
2)2
258
254
249
2?2
206
213
234
J 1 ft
* 3 *
J laV'
*. "*•
i 2 ^0
2J4
268
197
.17
.20
756
I .257
FEB
232
242
225
211
245
247
248
247
224
187
195
202
197
208
200
• 191
179
162
209
245
284
257
236
249-
318
311
29P
2*1
267

6,7119
234
318
'62
.17
.16
*A( 4,
"A* 7,
published In Part 2 of this
, WATER YEAR OCTOBER 1967 TO SEPTEMBER 1968
HAK
243
21$
206
220
239
220
223
225
234
234
224
233
235
242
277
263
256
248
258
245
240
203
186
17)
15«
155
16)
167
172
1 ft, ft
it D n
1 SI
I •» J
6,67«
215
277
153
.16
.18
990 SIN
con NIK
APR
156
13T
124
165
159
143
112
124
145
141
144
138
150
1)6
133
128
135
143
127
99
37
S7
93
82
75
78
100
100
86
* JV »
1 *J 3
3,630
12*
' 6S
75
• C9
.10
• 4
»2
HAY
114
114
102
74
68
62
•8
111
in
97
92
•3
149
lei
1C8
212
196
17?
141
127
138
138
11)
115
137
2°1
407
3C6
)?2
» 5 *
if 6
170
4^7
*2
.12
.14
t"« .
CF\» .
JUN
256
215
21°
977
2,370
3,180
3,610
3 , 9?0
4,120
4,950
5,580
5,750
5.410
4,700
4,210
4,930
4,190
4,26"
4,)40
4,?00
4,110
4,1)0
4, '00
4,090
3.6)0
3,0?0
2.700
3,5)0
),»,40
3,
107, »?7
1, *i°P
^, 7SO
>l 5
?. 61
?.C4
« IM
V Ul
JUL
3,880
4.2BO
5,030
5.300
5,540
5,520
5,450
5,800
6,180
6,450
6,780
6,910
7,000
6,9)0
6,700
6,180
5,510
5,860
6,200
6,030
5,890
5,500
6,1)3
5,610
5,470
4,830
-,730
2,640
1,970
1 , 690
1 , 560
16), 150
5,26)
7,093
1,560
3.65
4.44
7.51
12.52
AUG
1,460
1,499
1,760
1,910
2,143
2,290
2,223
,930
,660
,440
,270
,173
,190
,063
856
712
64?
669
704
803
947
650
663
5o7
606
682
B2T
932
1 l!83
1 ,390
1, 490
37,5)7
1,211
2.2VO
»o7

1*02


SEP
1,470
1,360
1,140
947
828
832
1,290
1,860
2,240
2,490
3,130
3,740
4,240
4,540
•.,730
4,730
4,670
4,380
3,750
2,950
2,230
1,750
1,470
1,260
1,130
1,030
98T
968
989
911
68,069
2,269
4,730
828
1.66
1.63



-------
                                                    100   PEACE  Wf« 1ASIN

                                             02296750 PUCE  R1VCI AT AJCAMA, HJ.
                                                                                                                               *)
LOCATION. --tat  27M3'19", long 8l*52'34". DeSoto County,  at  l^glp* acatjon. on left banV 100 fe.t  upelrean fro* brl'lgft on Seal* Blgh-
   vay 70,  1.0  mile vctc of poet office in Arc0Jla,  6.1 nilfti upatreea frwa Joihuft Creek,  end  36 oillea upltrejut tun inouth.,

DUISAOE A»EA.— 1,367 aquare ollea.

IECOPI1S AVAILABLE.— Chentcal en»lyaee:  October 1961 to September 1969.
  Water le-nperalurea:   February 1962 to S.ptenber 1969.

     *£S,  1946-69. — Fluoride:  Hjalmun dolly, 1.9 ng/1  on aeveral days during fay and June;  nlntrauta dally. 0.5 ng/1 Sept. J  and 4.
  PhoapMte:  M«ltnui dally, 11 mg/1 Dec. 19 and April  20; ntn!.-u = dally. 1.6 ng/1 March 18.
  Specific  Conductance:  KajiliTjw dally, 450 otc ronhos May 14, 16; Dlnl.nu-o dally,  80 rolcroahoa  Sept, 4.
  pH:  Cj>.l-.g»  dally. 7.7 Oct. 6; n]nl=ui dally. 6.4 March 16, Aug. 19. Sept. 3,  4.
  Turbidity:  rUtlima daily, 350 ng/1 »s Silica Jan. 1; mlnl=uo dally, 3 JTU on July 2!.
  Water teaperaturea:   Kaxlaura, 34'C on Aug. 1; mlnlmis.  3*C Dec. 16.
       S. 1961-69. --01a»olveJ oollda (1961-67):   Kaxlcnjo,  335 r^/1 May 11-20, 1967;  otntoun,  50 cj/1 Aug. 21-25,  196J.
  Kardncaa (1961-67):  Ka>LLua, 2!4 ng/1 May 11-20,  27,  1967; nl^lr.un, 21 og/1 Sept. 20-28,  1962.
  Fluoride (1963-69):  Ha« Irun dally. 3.9 ng/1 Feb.  13 and  Apr. h, 1966; nlnlnja dally,  0.4  cg/1 Au|. 9, 10, 1966 ami June  11.  1969.
  Phoaphate (19M-69):   Ka«lnii» dally, 29 rg/1 Hjy 27, 1967; nlnlnur, dally, l.< rg/I M«r.  14,  1967.
  Specific conductance:   KJ»ln>.n dally, 1,750 ntcrOTho)  Feb. 3, 1963; olnlcruu dally, 45  nlcromhoa Sapt. 23,  1962.
  ^H:  y^xliij;a dally,  8.3 units Mar. 31. 1968; nlnlr.un dally, 5.1 unite Mar. 1, 1961.
  TurbldUy (1962-69):   Maxlc.ua dally, 2CO rg/1  aa Silica  July  16. 1962; rlnlcun dally,  0  114/1 aa Silica oo  lavaral day*  la Octobtr
   1965, Auguit 1966,  oany d«va during November, December  19ft7  and September 1963.
  Water te^peraturea:  rUxlrcurc, 35'C on aeveral  day* during July and August; nlnlmim, 3eC  Dec. 16( 1969.

K£MAJIX.S. — Turbidity values through May 1969 were reported  aa nllligra*a per liter of Slllc*.  valuea for Juna through Septenber  1969
   verc reported aa Jackcoo Turbidity t'nlta.
                               CHEMICAL ANALYSES,  WATER TEAR  OCT09E* 1969  IO SECIEMBEd  1969
                DATE

               OC(.
                01...
                IS...
                30...

               MOV.
                01...

                29...
                30...
               OcC.

                90,..
                91...
               JAN.
                OS...
                IS...
                21...
                21...
                31...
               FEB.
                02...
                16...
                a..:
                2S...
               Milt.
                01...
                12...
                15...
                51...

                Oil..
                15...
                14...
                27...
                30...
               JUNE
                30..


DIS-
CHARGE
ICf SI
_
—
—
--
	
--
__
--
	
„_
__
._
465
--
—
	
-•
..
—
	
4340
_-
"
„_
__
_•
...
--


FEMP-
ERAIURE
1040 Cl
29
27
20
25
2,
16
19
26
57
17
IS
12
19
19
20
IT
11
14
U
IT
IS
|$
22
19
20
24
24
22


SILICA
ISIU2)
IMO/L)
9.0
1.0
9.2
—
10
5.
9.
7.
9.
S.
7.7
6.7
7.7
7.9
—
6.9
T.I
6.9
— •
9.4
4.S
4.4
•5.4
5.3
9.9
--
2.2
— -
DIS-
SOLVED
IROM
(FEI
(UC/LI
60
70
90
--
60
90
50
60
JO
30
50
SO
40
40
—
60
60
40
—
30
70
90
90
SO
100
—
SO
—

C«L-
C1UM
1CAI
IMC/LI
29
32
24-
—
29
IS
33
35
43
-~
35
29
12
34
—
IT
33
35
—
39
13
14
22
22
41
21
41
—
MAG-
NE-
SIUM
IHOI
(MO/LI
9.7
10
7.5
—
9.1
S.S
11
11
14
14
11
9.6
U
12
—
|,
12
12
--
12
4.9
S.3
T.S
7.7
1 A
T.S
14
—


SODIUM
1NAI
(MGVll
12
13
12
—
IS
10
14
IS
16
IT
IS
IS
IS
16
—
IT
IT
19
—
12
9.0
9.7
II
14
17
—
16
—
PO-
TAS-
SIUM
Ul
CMC/LI
1.4
I.S
2.0
—
1.4
1.9
1.6
1.6
1.4
2.1
3.2
2.6
2.4
2.3
—
2.0
2.4
2.1
—
2.0
2.4
2.0
2.1
1.9
1.3
~—
1.0
—

BICAK-
BONA1E
IHC03)
IMC/LI
57
59
37
—
49
27
$9
56
94
94
0
64
67
74
—
92
IS
T6
—
91
22
29
47
SO
74
__
91
—
                                      26
                                                                -in A-

-------
                                  IOD  ruci IIVM uitu

                           02294730  rzici IIVM AT AXTADU, riA.

              CHEMICAL ANALVSEJ. VAIJR >EAR OCT03ER l«»»  TO  SEPTEHBER  1969
 OAlf

JULY
 01
 10
 II
 I*
 19
 10
 II
*uc
 02
 II
 21.
 31.
16PI
 01.
 IS
 10
          DIS-
         CHARGE
         ICF5I
 491
       TEHP-    SILICA
      CRAIURE   (SICUI
      IOEC C)   IMG/LI
26
10
30
It
21
26
29
                 01J-
                stxveo
                 IJION
                 IFEI
                IUG/LI
25JO
         29
         21
         2*
         29
         2*
         2»
                   5.1
                   5.4
                  II
          i.S
          T.2
          7.7
          9.6
          6.1
 CAL-
 CLJH
 ICAI
IMG/LI
             29
             31
             >9
             16
             21
             22
             13
             1*
             21
             11
                     HAG-
                      Ht-
                     SlUH
                     (HO
                    (MO/LI
     10
     9.7
     12
     6.1
     7.)
     • .I
     7.7
     4.7
     9.3
     7.9
     4.5
           SODIUM
             iriAi
           IMG/LI
     14
     14
     15
      (.4
     10
     12
     II
     7.0
     (.1
    II
     7.2
            IAS-    BICAR-
            SIUM    noNAre
            IKI     IHC01I
            ING/LI   INC/LI
                            I.
                            I.
                            I.
                            2.
                            1.
                            1.4
                            1.4
                            l.S
                            1.6
                            1.5
                            1.5
     63
     97
     69
     J6
     44
     5*
     2*
     31
     49
     24
      DATE

     OCT.
      01...
      15...
      30...
      31...
     NOV.
      01...
      15...
      29...
      30...
     DEC.
      15...
      30...
      31...
     JAN.
      05...
      15...
      2J...
      29...
      31...
     fit.
      02...
      16...
      27...
      29...
     MAR.
      01...
      12...
      15...
      31...
     APR.
      01...
      15...
      15...
      29...
      30...
     MAT
      31...
     JUNE
      30...


JUt FAT 6
IS04I
IMG/LI

CMIO-
Rioe
ICLI
IMG/LI

FlUO-
RIOE
(Fl
IMG/LI


NITRITE
(N02I
IMC/LI


NITRATE
1.10)1
IMG/l)
CRT HO
PHOS-
PHATE
IPCKJ
(HO/LI

PHOS-
PHATE
IP34)
IMG/LI
OIS-
soivfo
SOI. I OS
(SUM OF
CONSTI-
TUENTS)
IMG/l'l
     57
     6J
     50
     60
     32
     74
     •6

     98
     93
     II
     55
     67
     74
     13
     73
     72
     70
     26
     32
     41

     46
     92
     31
     95
      (.0
     14
     14
     14
     16
     14
      3.0

     16
     16
     II
     19
     19
     14
     13
     14
     13
     It
     14
     10
     17

     17
     16
     14
     17
1.5
1.5
1.9
1.7

1.4
 .4
1.2
1.4
1.2
1.3

1.0
1.0
 .«
1.0
I.I

1.4
1.2
1.9
1.4

1.2
 .5
 .7
1.0

 .9
1.5

1.4
1.5

t.9

l.S
                                 .02
                                .01

                                .03

                                .16
 .3
7.7
 .3
1.0

 .3
 .2
 .3
 .a
2.0
 .1
 .2
 .0

 .5
1.4
4.0
 .1

2.7
 .4
 .4
2.0

1.5
2.4

 .0
1.3

 .1

1.7
7.3
5.5
5.1
6.2

6.4
3.0
e.i
(.0
7.7
9.5

7.3
4.2
5.3
5.9
6.2

6.1
5.3
4.6
4.6

5.0
3.7
2.2
3.6

4.5
9.1

4.0
4.1

*.5

4.1
                                                          6.2
                                                          5.2
                        4.2
                        4.6
                        9.3
                                                 9.0

                                                 4.5
                                 161
                                 III
                                 144
                                 169
                                 103
                                 195
                           247
                           241
                                 209
                                 175
                                 192
                                 203
                                 220
                                 204
                                 207
209
 19
 93
137

146
299

234
                                      -10B-

-------
                             109  ruce MVM


                               Uf.t MV(.» AT AXCADIA, PA.


         CHCHICM.  ANALJiES,  MAIEK ȣȥ ClCIUdt* 1469 TO SE'TEH9E*


iOLfAlf
IS04I
CHWll

CHLO-
RIDE
ICll
1 MI/LI

FLUO-
RIDE
If I
I AC/11


NIIRITS
INOil
(HO/LI


HITDATE
matt
ING/L)
ORIHO
PMOS-
PMAIE
1 P0*l
ING/LI

M3S-
PHATE
IP3M
1 Hi/11
DIS-
SOLVED
SOLIDS
I SUH Of
CONSri-
lUEHtSI
IMG/LI
 01.
 10.
 It.
 It.
 24.
 10.
 II.
•UG.
 01.
 It.
 II.
 11.
SEPT
 01.
 l».
 10.
60
kT
«2
2*
41
41
4»
22
24
It
20
It
12
21
12
II
14
II
II

10
II
10
.01
.01
.01,
.01
.01
.01
.01


.01
.01
.01
.01
.02
.01
2.1
 .0
2.0
2.1
 .0
 .T
'1.0
:.;
i.r
».«
4.*

4.2
2.1
2.4
>.4

4.)
2.»
J.J
                                                               2.T
It*
i;o
22T
 fl
125
Ilk
 (1
 •t
I2T
 74
          am

         OCT.
          Olr..
          it...
          10...
          Jl...
         KJV,
          01...
          It...
          24...
          10...
         Oil.
          It...
          10...
          >l...
         JAN.
          II..
         MS.
          02..
          Ik..
          2T..
          211..
         *•».
          01..
          12..
          l>..
          11..
         «PK.
          01..
          It..
          It..
          2t..
          10..
         H»r
          Jl..
         JUNE
          10..
BIS-
SOLVED
SOLIDS
IHESI-
OUI 41
110 Cl
IHG/ll
tea
ie«
Ik4
lit
it
224
2kk
2tt
22k
l«>
212
2)2
231
21«
221
211
Ilk
I2t
Ikk
Ik2
24f
•*
241



HMD-
NESS
ICt.HGI
(MS/LI
10k
'121
«l
110
kO
121
Ikt
Ikt
111
112
I2>
lit
14k
111
III
1*5
S2
IT
Ik
IT
Itk
(4
IkO
NON-
CAB-
9UNATE
HARD-
NESS
IMG/LI
54
Tl
S4
™
TO
19
10
--
IT
4k
—
It
kO
Tl
T4
—
14
Tl
It
—
T4
14
14
4k
4k
4t
>~
44
—
—
_
SPECI-
fie
COND-
UCTANCE
IN1CRO-
HHOSI
2TO
240
210
2kO
271
IkO
240
240
110
170
110
lot
2ki
124
100
12f
IkO
114
140
140
140
170
114
220
2)0
Ikt
140
110
JtO
41D
250



PH

1 UNITS)
T.2
T.4
T.2
T.2
7.1
T.i
T.k
T.k
T.t

T.4
T.I
T.2
T.I
T.4
T.2
T.I
T.2
T.I
T.I
k.4
k.t
k.4
T.I
T.t
T.5
•—
T.I
.T.I
T.k
T.I'

COIOI
(PLtri-
INUH-
coatir
UNITS)
100
10
120
—
100
120
10
to
40
40
™
kO
10
50
50

10
to
50
"
40
100
110
too
kO
21
•-
2!
-•
—
_
                                            CM
                                     -10C-

-------
                                   Chemical Corporation
                              A SUBSIDIARY OF AMAX INC.
           402 SOUTH KENTUCKY AVENUE • SUITE 600 • LAKELAND, FLORIDA 33801 • IB13) 687-2561
JAMES L. COX

VICE PRESIDENT
                                                          June 23,  1978
Mr. John E. Hagan, III
Chief, Environmental Impact Statement Branch                   <•»,   * A
U. S. Environmental Protection Agency                            **'   -,^
Region IV                                                           * „   ^
345 Courtland Street                                                     ,,  C
Atlanta, Georgia 30308

Dear Mr. Hagan:

During the past several months, AMAX's Florida staff and related personnel
have analyzed the Central Florida Phosphate Industry Draft Areawide
Environmental Impact Statement to understand the technical bases uoon which
EPA has recommended new regulatory restrictions, assess the potential en-
vironmental benefits attributable to these recommendations, and evaluate
the technical and economic feasibility'of implementation.  The following
comments represent AMAX's views with respect to the policies EPA will be
proposing in the final areawide EIS.  Because of the detailed point-by-
point technical comments delivered by others at the three public hearings,
our comments address the recommended policies contained in the draft EIS.

I.  Protection of Wetlands

    The concept of preserving and restoring wetlands to increase the
    diversity of reclaimed areas, maintain surface water quality, and
    provide suitable wildlife habitat should enhance the quality of  life  in
    the study area in future years.  Discussions with EPA staff, testimony at
    the public hearings, and papers presented at technical seminars  confirm
    that the public holds widely divergent opinions regarding the goals  to be
    attained through wetland restoration efforts; the techniques for creating
    self-sustaining wetlands following mining; the amounts of land which  should
    be devoted to this use; and the time required to achieve successful
    restoration.  By requiring preservation of the most critical wetland  areas,
    we assume that EPA will not require restoration efforts to create wetlands
    equalling the preserved Class I wetlands.  To do so would result in wetlands
    homogeneity countercurrent to the basic intent of creating diverse wetlands
    through restoration.

    Early attempts to restore wetland acreages are likely to be less successful
    than planned because of man's inability to simulate nature, the  traditional
    learning curve, and because EPA's recommendations may not be accepted

-------
Mr. John E. Hagan,- III               -2-                  uune to, .1.3/0
universally by the governmental units which have jurisdiction over new
source mining projects in Florida.  These and other related factors dictate
the need for EPA to implement reasonable requirements reflecting man's
technical and economic capabilities to restore wetlands, the need to balance
sometimes conflicting regional and local public interests, and the concepts
of diversified multiple land uses.  As with other ecological issues, the
creation of productive wetland systems requires deliberate and careful
attention and may require years to achieve.

The Agency must also carefully assess in the site-specific EIS the detrimental
impacts of restricting access to recoverable tonnages of phosphates deposited
below wetland preservation areas.  A prudent site-specific policy should
encourage exploration of these areas to insure that the integrity of NEPA is
maintained by including the lost phosphate resources as a consideration in
wetlands preservation determinations.

I I .  Process Water Recirculation
                                                                          lJ-
    The recovery and re-use of process water liberated by utilizing one of the
    emerging waste-clay settling technologies will help conserve the water
    resources of the region,  Site-specific application of these technological
    advances is an objective to which AMAX is devoting diligent studies and
    research.

    The ability to recover significant quantities of water from clays with
    varying mineralogical characteristics requires proving an advanced settling
    technology on a site-specific basis,  Further, the use of recirculated
    process water recovered from rapidly settled clays in new source mines
    containing less salable pebble product and higher percentages of concen-
    trate product will require improvements in water treatment procedures and/
    or amtne flotation technology.  Studies have shown that the use of re-
    circulated water for the amine flotation medium reduces metallurgical
    recovery and increases reagent consumption resulting in lost phosphate    ;
    resources.  A site-specific environmental analysis may indicate this trade-
    off to be an irretrievable commitment of resources unworthy of implementation.
    EPA's January 31, 1978 recommended scenario acknowledged the limits of
    flotation technology.  We believe the final draft should recognize them as
    well.

III. Eliminate Rock Drying
                                                                               ,
    The recommendation to eliminate rock drying at new source beneficiation  (^
    plants differs  from the other recommended process modifications because of
    the potential impacts this requirement will have upon new mines to compete
    in an international market trading an intermediate product commodity.  We
    note that EPA has recognized that this recommendation- has been drafted only
    considering the seven county study area because of the statement on page
    2.21 which reads:  "For purposes of effects assessment, this process is
    applicable to that portion of the mined and beneficiated rock to be
    chemically processed in the seven county study area."  Therefore, we assume
    that EPA has not considered the economic effects of eliminating rock
    dryers upon the industry beyond the seven county area.
                                      - 31

-------
Mr. John E.  Hagan, III                -3-                  June 23,  1978


    A review of the market structure of phosphate fertilizer intermediate
    products confirms that dried phosphate rock is traded  internationally.
    AMAX's market research efforts do not reveal  an immediate trend toward
    international trading of wet phosphate rock.   Thus,  a  requirement that
    new source mines without captive markets  for phosphate rock intermediate
    products must market wet rock is an illustrative example of an  apparently
    simple environmental regulation which fails to consider all  of  the direct
    and induced impacts upon the health of the  industry  being regulated.  We
    note no  comments reviewing the economic impacts induced by this regulation
    other than energy considerations.   The intent of NEPA  will  not  be fulfilled
    by limiting the effects assessment to the seven county region.

    When drafting this  requirement, we do not believe that EPA has  given  due
    consideration to the fact that eliminating  dryers will  effectively restrain
    new source mines from the international  dry rock commodity markets.   Limit-
    ing an industry's markets will eventually limit that industry's ability to
    compete  domestically as well.  Potentially  limiting  (of)  new source mines'
    output to domestic sales only because of the inability to produce dried
    rock creates a pricing disequilibrium in  domestic phosphate rock markets
    during the short run which will limit the ability to attract the necessary
    investment capital  to assure a domestic source of supply in the long  run.
    Secondly, elimination of rock dryers at the new source mines of companies
    not currently producing phosphate in Florida  restrains access to markets,
    which in turn allows existing producers to  gain market shares artificially
    at the expense of free competition.  This restraint  of trade does not
    appear to have been considered by the Agency when drafting this recommenda-
    tion.  We believe that the Agency would not have recommended eliminating
    rock drying at new source mines had these considerations  been included  in
    your analysis.

    The justification for elimination of rock drying presented in the draft
    EIS is logical for integrated producers (.i.e., those who  produce phosphoric
    acid as  well as rock) in Florida.   We believe that companies which produce
    only phosphate rock can build dryers at new source mines  which  do not
    endanger public health or significantly degrade air  quality by  using
    currently available emission control equipment.   The technology of wet
    scrubbers and wet electrostatic precipitators is well  proven.   Florida  DER
    air pollution emission limitations and EPA's  PSD review requirements  have
    been drafted to protect the quality of ambient air.  We believe that  these
    requirements are sufficiently stringent to  safeguard air quality and  that
    new source dryers which can meet these requirements  should be approved  by
    the Agency.

In closing,  we believe that the Agency's study  of the environmental impacts of
Florida phosphate industry has been worthwhile  and beneficial.   You should  be
commended for your efforts to complete the difficult directive assigned you in
1976.  As our above comments have indicated,  we believe  that the health of  the
phosphate industry can  be impaired not only directly but also indirectly  by the
economic impacts of regulations intended to enhance environmental quality.
Both environmental quality and economic vitality  are important to Florida and the
United States.   Thus, direct and indirect environmental  and economic impacts of

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Mr. John E.  Hagan, III
-4-
June 23, 1978
your proposed regulations must be carefully assessed  in  the  final EIS.

                                         Sincerely,
OLC:nf
                                         James  L.  cox
                                     //Vice President

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  DATE:
        UNITED STATES ENVIKONMENTAL PROTECTION AGENCY

JUN ? 2  197"
SUBJECT:   Draft Areawide Environmental Impact Statement on the Central Florida
          Phosphate Indus try. v'oji'me YU_

  FROM:   Ray Cunningham, Chief
         Air Strategy Development Section

    TO:   Frank Redmond
         EIS Branch
         VolumeVHI, Section I - Atmosphere: This document provides, in part,
         the historical information to describe typical weather patterns existing
         in the seven county study area. Topics covered include fog, humidity,
         temperatures, precipitation, and prevailing winds. It is assumed the
         data presented is accurate.

         VolumeVlI, Section II - Air Quality: This document contains the
         procedure used to collect and evaluate data, site locations and
         bias, and emission inventory and sources of pollution in the seven
         county area-wide study area. There are only two counties, Hillsborough
         and Polk, where data is given which indicates violation  cf SO- and TSP
         NAAQS for the years 1972 mid-1976, (see pages 2.8 and 2.13)

         The phosphate industry is identified as contributing 70% of S02 emissions'
         in Polk County and 10% in Hillsborough County. 20% of particulates in
         Hillsborough and 807, in Polk County is caused by the phosphate industry.
         (see page 2.73)

         The treatment and evaluation of the air quality data appears to be
         adequate and to satisfy its reporting requirements of NEPA. (Disclosure)
           le project stu9v area co\ers an\area designated by EPA
             for^SOo and TSP (Sarasdta, DeSota, and Charlotte)\nd Cla-ss I
         S0  and T§P in Hilr^borough,xplk, Manatee andlia^rdee Counties!
         Action

         No additional comments at this time.


         Background

         Draft EIS attached.


         Attachment #195-78
                                                                  JUN  ? 2  1978
EPA FORM 1320-6 (REV. 3-76)
                                      3-211

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                 DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE

                                  REGION IV

                           101 MARIETTA TOWER, SUITE 1403

                             ATLANTA, GEORGIA 30323
                               June 9, 1978                      OFFICE OF THE
                                                               Principal Regional Official
                                                 Re:  HEW-858-4-78
Mr. John E. Hagan,  III
Chief, EIS Branch
Environmental  Protection Agency
Region IV
345 Courtland  Street,  N. E.
Atlanta, Georgia  30308

Subject:  Central Florida Phosphate Industry

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.   The
impact statement has been adequately addressed for our comments.

                                            Sincerely yours,
                                            Philip P. Sayre
                                            Regional Environmental  Officer
                                            Region IV,DHEW
cc:  Ms. A. McGee

     Mr. Raymond Goldberg
                                                   JUN  1  4  1973
                                        O

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                     DEPARTMENT OF THE ARMY

               JACKSONVILLE DISTRICT.  CORPS OF ENGINEERS
                            P. O.  BOX 497O
                      JACKSONVILLE.  FLORIDA 322O1
 "AJEN-EE                                        14 June 1978
Mr. John E. Hagan III
Chief, EIS Branch
Environmental Protection Agency
Region IV
345 Courtland, NE
Atlanta, Georgia  30308
Dear Mr. Hagan:

The Draft Areawide Environmental  Impact Statement,  Central  Florida
Phosphate Industry has been reviewed by elements of the U.  S.  Army
Engineer District, Jacksonville,  in accordance with provisions of
Section 102 of Public Law 91-190.  Our comments follow:

    a.  On page T.2, paragraph 2, the Bureau of Mines'  conclusion is
that the U. S. could be a net exporter of phosphate rock through the
year 2000, but that the demand would likely exceed  the  domestic supply
before year 2010.  Later in the paragraph is the conclusion that lower
grade rock in Manatee and Hardee  Counties would become  the  source for
future mining operations.  Table  1.1, page 1.3, shows that  the total
recoverable phosphate rock totals 1,722 million short tons.  In our
preparation of studies on Tampa Harbor, we obtained data from  a local
expert consultant to the phosphate industry.  The data  from that source
support an estimate of 2,800-3,000 million short tons of phosphate re-
serves and resources in the area.

    b.  The proposed action includes several factors helpful to manage-
ment of the quantity and quality  of water resources. These are:

    (1)  Meet Florida's effluent  limitations for any discharges.

    (2)  Eliminate conventional above-ground slime-disposal areas.

    (3)  Meet Southwest Florida Water Management District consumptive-use
requirements.
                                3-21  I

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SAJEN-EE
Mr. Hagan
14 June 1978
    (4)  Provide storage capacity for reel reulation of water.
    (5)  Use connector wells to exploit the water-table aquifer and to
replenish part of the water pumped from the Floridan Aquifer.
    (6)  Protect or restore wetlands under the Corps of Engineers Section
404 jurisdiction.
Thank you for the opportunity to comment on the Draft EIS.
                                 Sincerely yours,
                                    IS L.  GARLAND
                                 Chief, EngineeringTJTvision

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UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE	.	„

 State Office, P. 0. Box 1208, Gainesville, FL  32602

                                                       May 15,  1978


 Mr.  John C. White
 Regional Administrator
 U.  S, Environmental Protection Agency
 Region IV
 345 Courtland Street
 Atlanta, GA  30308
 Dear Mr. White:

 RE:  Draft Areawide Environmental Impact Statement on the Central Florida
     Phosphate  Industry

 Our major concern within the subject study area would be the land use
 changes affecting agriculture and soil resources.

 The last paragraph on page 2.69. alludes to some change but only to truck
 crops  and citrus acreage.  We assume the 100,000 acres of rangelando
 would  be lost or converted to improved pasture and would have an impact
 on the cattle industry in the area.  A percentage of the truck crop land,
 such as organic soils, may be considered "unique" farmlands.

 We feel that methods to lessen impacts of mining such as wetland restor-
 ation  technology and management practices are particularly important.
 These  concerns  should be addressed in the site-specific environment
 assessment and/or impact statement.

 We appreciate the opportunity to review this statement.

 Sincerely,
 William  E. Austin
 State  Conservationist

 cc:  R.  M. Davis
                                                 MAY  1 8  1978

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                      UNITED STATES ENVIRONMENTAL  PROTECTION AGENCY


         MAY 25 1978
SUBJECT:  DEIS, the Central Florida Phosphate Industry

  FROM:  Walter J. Hunt, Chief, ICB/EGD   tll\\\.^T* *° ["* "
                                           ^-^ '
    TOr  John C. White, Administrator-Region IV
        Attn:  John E. Hagan, Chief, EIS Branch
  THRU:/./Robert B. Schaffer, Director^V^-
      'l TffTiic-nt- n,i-M
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Comments:  Draft of Areawide Environmental  Impact  Statement
           Central  Florida Phosphate Industry,  EPA 904/9-78-006,
           March, 1978

Hi.  c. l)a)  Ponds will  "flush out"  perodically  unless  complete  site
      rainfall  runoff management is  established.   At  most sites,^runoff
      must by-pass  ponds in excessively rainy periods.  The  initial
      run-off sweeps up most site pollution.   The  subsequent runoff,
      in heavy rainfall, is normal  uncontaminated  runoff, and must be
      by-passed to  prevent pond flush  out.

1ii.  c. 2)a)  Same comment as preceding comment.    The reported volumes
      of 10 year 1  day rainfall values differ little  from 25 year  1 day
      values.  Present regulations  prevent  flush out  only when rainfall
      in one day is 1/2 of the maximum 10 year  lor 25 year)  value.
      Present regulations  will not  prevent  flush out  by long rainy
      periods,  i.e. periods over 1/2 day in duration.  Excessive rainfall
      over several  weeks is common.

iii.  c. 2)b)  Same as for C. 2)a)  - Note:  Severe flush  out incidents
      are highly undesirable.  Surface waters may  receive massive  dis-
      charges of SS, fluoride, acidic  and radioactive pollutants.

Page 2.5  2.13 - Required  reduced water usages  - - -? Site  drainage
      management is the key to reducing or  eliminating process waste-
      water discharges at  manufacturing plants.  Much evaporation  occurs
      from manufacturing plant processes.  Most water in  use in phos-
      phate manufacturing  is recycle water  and  reduction  of  "recycle"
      does not reduce the  potential  hazard  of discharge in periods
      of excessive  rainfall.

Page 4.4  2 - Dam Ereaks - Inadequate  attention is given  to  the topic
      of pond retaining structures.  Many breaks have occurred in  the
      past, particularly at mining  sites.  Massive contamination of
      surface waters has occurred from these  dike  breaks. These breaks
      have had disastrous  effects because of  discharge of fluorides,
      radioactive pollutants, acidic water  and  huge volumes  of slime.

      The major factors in control  of  dam breaks is sound design and
      reliable construction practices.  These factors are covered  in
      EPA-440/l-75/043-a,  Group I,  Phase II,  Development  Pocument  for
      Effluent Limitations Guidelines  and Mew Source  Performance
      Standards for the Other Non-Fertilizer  Phosphate Chemicals Segment
      of the Phosphate Manufacturing Point  Source  Category,  June 1976.

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                          -2-
Some attention should be directed to "Stabilizing"  thfi  gypsum piles
at wet phosphoric add plants.  These piles  yield highly addle
leachate from rainfall percolation.   This  addle leachate may
continue to contaminate both surface and ground water for many
years.  The long-term hazard of radio active wastes  and fluoride
1n this leachate should be thoroughly studied.

It may be necessary to develop a liming program for  these piles,
and to cap with clay, or other Impervious  material  to stop ground
water contamination from running long Into the future.

Attention should be directed to future problems that may arise from
abandonment of elemental phosphorus  manufacturing areas.   Thousands
of tons of elemental phosphorus may  be accumulated  1n recycle pond
bottoms.  This will remain 1n the elemental  form for extremely long
periods (probably for centuries) where the site remains wet.   This
may be a harmless deposit 1n 'a sealed pond not subject  to leaching
or digging.  However, any future development or construction  opera-
tion that disturbs this site may encounter this hazardous deposit.
If these deposits are disturbed and  made subject to  leaching, the
leachate-will be phossy water.

It 1s advisable to drain and aerate  these  areas,, or  otherwise
arrange for the destruction of elemental phosphorus  before the
areas are abandoned for phosphate manufacturing.
7-)
/rf
                               ,
                               f >
                          Jo*

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                      SECTION 4
             RESPONSES TO WRITTEN COMMENTS

(Note:   Responses are numbered W-l through W-455.   Numbers
        are assigned to substantive comments in the margin
        of the reproduced written submittals in Section 3.)

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                                WRITTEN COMMENTS
W-l
          The time frame for effects of mining and reclamation is both
immediate and long term, as spelled out in the text of the FEIS and Working
Papers.
W-2
          The Fish and Wildlife Service contract study by Archbold Biological
Station provides documentation on reduced productivity.
W-3
          We agree that there is a potential for equalling or exceeding
pre-mining recreational resources, but not archeological values or aesthetic
aspects.
W-4
          As of the date of publication of the DEIS, no new source chemical
plants were projected to be located in the study area.  We understand that
Farmland now proposes a new chemical plant in Hardee Co.
W-5
          See text.
W-6
          See text.
W-7
          See text.
W-8
          The statement "mining has not appeared to have played a significant
role in the growth of the region since 1960" is believed to be a true one.  The
statement is not meant to detract from the very large economic role phosphate
mining plays in the region.  However, as can be seen by examination of Table 1.27,
mining has been a somewhat steady economic force while increasing demands for
                                    4-1

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goods and services for the tourist, retirement and recreation purposes seems
to have been the stimulus for increased economic growth in the study area.
W-9
          Table 1.3 shows Ad Valorem Taxes that have been paid by the
phosphate industry.  New tax adjustments in Hardee and Hillsborough counties
would increase revenues substantially, but until passed into law would only
be conjecture.
W-10
          Correction made in text.
W-ll
          Correction made in text.
W-12
          Figure has been revised.
W-13
          The effects of mining activity on soils are discussed in more
detail in the working papers (Volume XI, Section 2/Volume VII-NTIS).
W-14
          The study area is part of peninsular Florida.  We agree that
biological assemblages are shaped by their environment, including members of
the assemblage.  The environment of peninsular Florida, including the extent
of recoverable phosphate reserves, is unique within the United States.
          The term 'regional ecosystem' is unclear.  We agree that man needs
to manage his environment wisely.  It seems, however, as indicated most
recently by the virtually futile attempts to effect voluntary conservation of
energy, that he will not do so unless constrained by laws, regulations, and
economics.
W-15
          The quoted lines are from the description of the present environment
in the EIS, yet the subsequent comment references a discussion of threatened
and endangered species (working paper Volume VI, Section 5, p. 5.95).  When
considered in the proper context, emphasis on the three vertebrates named and
                                     4-2

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the three vertebrate subspecies clearly stems first from their threatened or
endangered states as designated by the FGFWFC or the Department of Interior.
Secondarily, their endemic status, in conjunction with their range and other
factors, was considered in assessing impact relative to other threatened and
endangered species.  As demonstrated by the recent Supreme Court decision on
the snail darter, geographically restricted threatened and endangered species
are more likely to be fully protected than those with wider ranges.   Thus,
the weighting factors used apparently are not unrealistic.  Obviously, the
endemic biota in the quote from the introduction to the terrestrial  biota of
the study area includes species other than vertebrates.  It is not within the
scope of the EIS to name them, nor, undoubtedly, are all of them known.   The
point to be considered is that peninsular Florida has a high percentage  of
endemic biota compared with other geographic areas.
W-16
          Restoration of natural habitat is not certain, nor even probable
under current laws and regulations and reclamation practices,  as stated
throughout this EIS.
          Regarding quantification of natural habitats, several tables are
provided in Volume XI (Volume VII-NTIS) listing acres by habitat type.
W-17
          On-site visits to reclaimed areas indicate the post-mining conditions
of pasture and cropland are as intensively managed as pre-mining conditions.
          Most land to be mined is not in pasture and cropland, as this  commen-
tary states.  In Volume XI of the working papers (Volume VII-NTIS) data
indicates that only 32 percent of the land to be mined by the year 2000  will
be cropland and pasture.
W-18
          The exact amount of pine flatwoods in the entire study area is not
available.  A detailed vegetation cover map was beyond the scope of  this
project.  The extent of pine flatwoods in pending permit was presented in
Volume XI, Section 2 (Volume VII-NTIS).  This table does not specify, however,
the degree of modification, or intensity of management of the pine flatwoods.
                                      4-3

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          As mentioned in the response to Comment W-17, on-site visits to
reclaimed areas indicate the post-mining landscape to be intensively managed.
A greater habitat diversity is not the end result of mining.
W-19
          We agree that dry, or palmetto, prairies as well as other cover
types should be identified and mapped as indicated by a comprehensive statement
in working paper Volume XI (Volume VII-NTIS).  We regret that such an extensive
undertaking was not within the scope of this program.  The general distribution
of palmetto prairie, as portrayed by the Florida Department of Natural Resources
(1975) and adapted from Davis (1967), does include an area in Manatee County
that may comprise part of a proposed mining area.  Davis (1967), whom you quote
later, considers the type endemic to Florida.  Again, however, as in the case
of endemic species, the initial emphasis on the type stems from its highly
endangered status as designated by the Florida DNR.
W-20
          Producing a detailed vegetation cover map was beyond the scope of the
requirements of this EIS.  As mentioned in Volume XI, Section 2 of the working
papers (Volume VII-NTIS), a detailed vegetation map was a recognized data gap
for impact assessment.  Available maps were deficient in characterizing cover
types.  The DRl's were consulted regarding forest displacement.
          The decline in diversity mentioned in this comment was attributed in
this EIS primarily to the loss of wetlands, with some decline attributed to loss
of deciduous forests, sandhills, sand pine scrub, and dry prairies.
W-21
          The value and indeed necessity of a vegetation cover type may of
appropriate scale to accurately assess conditions in the study area has been
interated several times.
          The potential for mining to increase wetlands extent currently is
not a possibility-
                                     4-4

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W-22
          Like its phosphate resource, Florida's wetlands resource has nation-
wide value based on remaining significant extent.  The status of wetlands
reserve, then, also can he considered a national concern.  Unlike the phosphate,
however, when the national wetlands resource is used, importation is. not a
viable mechanism for supplying the resource.  The Florida DNR's endangered land
designations are responses to the Land Conservation Act of 1972 (Chapter 259,
Florida Statutes), which calls for the protection of environmentally unique and
irreplaceable lands.
W-23
          Assuming the 1956 inventory of wetlands still valid as far as
relative extent is concerned, then land areas (Florida and Louisiana)  comprising
less than 4 percent of the contiguous states contain 30 percent of the wetlands
resource.  Such concentrations of resources are significant (see above comment).
W-24
          The statement stands.  Refer to reasons pointed out in Responses to
comments T-41, T-42, T-44, T-46, and T-47.
W-25
          This quote, which follows the above quote in the text, is part of the
description of the study area's present environment and is a lead-in to what
may be expected in the impact section.  Elaborations supporting the statement
are found in the impact section as well as in the effects assessment volume
(working paper Volume Xl/Volume VII-NT1S).
W-26
          This statement also is part of the description of the present
environment.  It is tantamount to giving acreage of the study area, human
population, etc.  It is not intended to imply, nor does it, that each species
will be impacted - just as each acre or person will not be impacted.
W-27
          In compiling the list of special status species, we have expressed the
combined views of the Florida Game and Fresh Water Fish Commission, the Department
of the Interior, the Florida Committee on Rare and Endangered Plants and Animals,
and the Archbold Biological Station report to the FWS.
                                        4-5

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W-28
          The net ecological impact of mining can be mltigated, as we have
stated several times by modifying current practices and researching recla-
mation procedures other than those of greatest economic benefit.
          Just as you suggest, the use of "important" when referring to
certain species is a reflection of abundance, scarcity, economic significance,
recreational significance, and medical significance.  All suggestions of
importance, the criteria determining important species, and subsequent
allusions to their management comprise these very elements.  We thought it
unnecessary to point out that labeling certain species Important does not imply
all other species are dispensable,
W-29
          We disagree, for reasons abundantly stated, that wetlands and mixed
forest habitats will or can be increased following mining.  The value to
wildlife of existing habitat, although modified and predominantly agricultural,
compared with lake systems, improved pastures, and land awaiting reclamation Is
addressed in Responses to Comments T-39, T-40, T-44, and T-47.  The impact to
terrestrial biota was not assessed on the basis of "enormous potential" that
is uncertain, heretofore unmentioned, and still unpromised.  Neither current
projections, reclamation technology nor economics indicate such ecologically
sound systems.  The projected reclamation, as noted in the existing phosphate
DRI's, is primarily improved pasture and lakes (land and lakes); small  extents
of parkland, plantations, and croplands are projected, and one mine proposes to
attempt a small acreage of marsh (working paper Volume XI, Section 2/Volume VH-NTIS).
          Before addressing the remainder of your comment, we would like first
to point out that mining Ij3 evolution, as is glaciation.   Secondly, an  obvious
omission to your comments on glaciation is the importance of Florida as a
refugium during recent glaciations and the resultant presence of many relicit
populations - several of which occupy sandhills and sand pine scrub habitat.
          As for displacement, water Is displaced, landuse is displaced, capital
investment is displaced, and populations are displaced.  The reference  obviously
means removed from a particular location (or denied) by the mining process and
                                     4-6

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so removed  (or denied) for a time span that is meaningful  to  the judgment  of
impact.  All resources considered in the impact analysis - social,  economic,
mineral, biological, etc. - will change in the context of geologic  time  to
an extent that cannot be described or even imagined.  Geologic time simply
is not an appropriate frame of reference for assessing impact here  and now
and in the  foreseeable future.  Plants and animals occupying land area that
through mining becomes a lake will be permanently displaced from that location.
W-30
          Mining alterations to topography and soils dp cause changes beyond
the tolerance limits of certain biota; these species will not be among those
occupying mined land.
          Regarding reversibility, we would like to point out that a
Phosphate Council spokesman said at the Bartow Public Hearing on this EIS  that
wetlands would be easier to restore than virtually any of the other natural
systems that are present oh land to be mined (see Response to Comment T-46).
This, coupled with a phosphate company request (Araax 1978) to consider man's
technical and economic ability to restore wetlands before implementing
requirements, does not lend credence to claims of restoration of such a
spectrum of habitat types.  It should be noted that this quote,  the above two,
and the next quote are from the same paragraph in the text.  Two sentences
between this quote and the next, however,  are omitted.  To avoid the inferences
possibly fostered by your selection of certain sentences, we  would like to
insert for the benefit of-ihe reader the missing sentences , (DEIS,  p. 1.26, 1.27),
          ...nonforested wetlands.   Rather than promote some  degree of
development of natural habitat as has occurred in long-abandoned mining areas,
current reclamation regulations and practices produce a landscape of managed
systems - primarily improved pasture..  As  the landscape diversity in the area
declines, so does the faunal and floral diversity.  Although  diversity
declines....
W-31
          Several of these comments are extraneous to both this  quote and its
context.   We have not correlated habitat quality or community stability wifeh
                                     4-7

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 versity nor have we indicated that forested wetlands, sandhills, etc. are
climax communities.  We have already discussed what is happening in the way
of reclamation and what could happen as well as the apparent decline in
diversity in the mining area  (we did not use "areawide" as did the commentor,
although it is not without possibility).
          We regret that we are not familiar with what could be sandhills or
sand pine scrub habitat on the mined lands you cite and would be interested
in documentation of their presence as well as the fact that the particular
location was mined.  We feel that the cypress stand at the Teneroc site is
occupying unmined land that was disturbed by mining activities.
          Further comment on the state of the art of reclamation as well as
its priorities is unnecessary.
W-32
          Data to support this statement are available in the Tampa District
Office, Florida DER files.
W-33
          The statement extracted from p. 1.32 of the DEIS was part of a more
extensive summary of conditions in one of the working papers, which explains
why conditions favor the entrance of contaminants into the water table and
Upper Floridan aquifers.  (Volume V, Section I/Volume V-NTIS).
W-34
          Data on waterbodies of the study area are found in working paper
Volume V, Section 2/Volume V-NTIS.  The views of the Florida Game and Fresh
Water Fish Commission on the poor life-support value of the mine pit lakes have
already been stated (see Response to Comment T-44).  Wildlife usage of these
lakes is discussed in working paper Volume XI, Section 2/Volume VII-NTIS.  As
indicated in working paper Volume V, Section 2/Volume V-NTIS, Lakes Parker,
Banana, Hancock and others in the mining area of Polk County have become
degraded and/or eutrophic considerably faster than lakes in the southeastern
part of the county.  These mining area lakes have little to no sport fishery
and contain dense shad and tilapia populations, while Lakes Walk-in-the-Water
and Reedy in southeastern Polk County have a viable sport fishery.
                                    4-8

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          The "extremely shallow, periodically dry systems"  replaced by mine
pit lakes sound more like an incomplete description of a wetland  than a
natural lake.  At any rate, no natural lakes are projected to be  replaced,
only wetlands and upland habitats.
W-35
          These five paragraphs neither add to nor change the impact  assess-
ment on the manatee, American alligator, or Suwannee cooter.  We must,
however, disagree with your prediction of increased alligator populations
over the long-term from mining.  The mine pit lakes and reclaimed slime  ponds
of the long-term will not support alligator population's equivalent  to  those
of swamps and marshes now occupying the land to be mined.
          The comment on important species iterated in the first paragraph
has been addressed (see responses to Comments T-l,  T-2,  T-42, W-27,  and W-28).
We do not understand the relationship among the list,  aquatic species, and
effects of mining you are describing.   The list referred to  comprises all
vertebrates except fish, a category generally recognized as  wildlife.  It
includes aquatic as well as  terrestrial species.   The  number of  aquatic and
water-oriented species on the list is equal to the number of terrestrial
species.  Mining poses potential or actual adverse effects on 3  of 13 threatened
and endangered species treated in the aquatic biota section  and  at least 12 of
32 threatened and endangered species treated in the terrestrial  biota section.
A source of confusion in addressing impact on biota in this  and  other cases is
the requirement of most report formats to  treat terrestrial  and  aquatic biota
separately,  when indeed numerous species  cannot be categorized ecologically as
one or the other.
W-36
          This sentence is part of the description of  the natural environment
of the study area - not the  mining area.   It does not  imply,  nor does its
context imply, that the problem is greater in the mining area.
W-37
          Text modified.
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W-38
          Details supporting Figure 1.15 are given in a working paper Volume VI,
Section 4/Volume VI-NTIS.
                                COMMENTS
FLORIDA PHOSPHATE COUNCIL  (Homer Hooks' letter of June 20, 1978)
     p. 1.49, Figure 1.15
     The ranges are defined as shown.  However, the reference to "high" and "low"
BPL should be reversed to  correspond with correct U30g equivalents.  Low BPL in
this case corresponds to 100 ppm or 0.01% l^Og, and high BPL corresponds to
200 ppm or 0.02% U308-
W-39
          The reference provided in the text for the dose rates cited is the
Florida Department of Health and Rehabilitative Services (1977).  This report,
apparently a draft, has been superceded by a 1978 publication of the same title,
whose values correspond to those cited by Mr. Hooks.  The dose rate values will
be changed to reflect the  1978 report  (which does not include a gonad dose value).
W-40
          Text modified.
W-41
          Refer to response to comment number W-8.
W-42
          Text modified.
W-43
          Text modified.
W-44
          Text modified.
W-45
          Refer to responses to comments T-5 and T-13.
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W-46
          The referenced statement is correct, i.e. most archeological sites
are extremely fragile and would be permanently altered or destroyed if mined.
          Most of the comments in the Phosphate Council's letter are adequately
covered (working papers, Volume Xl/Volume VII-NTIS).
W-47
          The referenced table was not intended to indicate whether or not the
recreational area was a product of reclamation by the phosphate industry.
          Also, the section cited was not the proper place to indicate a positive
impact.  The positive impact due to reclamation by the phosphate industry is
mentioned in this EIS.
W-48
          Guidelines established by the Steering and Advisory Committees  in effect
directed assessment efforts toward existing information with the goal that
issues deserving continued investigation and applied research would result.  Use
of lands subsequent to mining, definitions of options available, and an assessment
of the mitigatory value of those options deserve attention,  and are presently
being investigated by Federal, State and local agencies as well as by environ-
mental groups and the phosphate industry.
W-49
          The methodology used to summarize effects is indeed subjective, but
not arbitrary.  The values assigned to impacts have context within the groundrules
of the assessment program and the rationale supporting each value as documented
in Volume XI (Volume VII of the NTIS papers) of the working papers which deals
with impact assessment of the alternatives.
W-50
          Text modified.
W-51
          All aspects of the important species list have been covered in prior
comments except perhaps one:  if the important species are maintained, obviously
other species will also be.
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 W-52
          World Phosphate Reserves  table has been  corrected.
 W-53
          It  is true  that some  abandoned slime ponds have provided wetlands
 type habitat.  However,  this  is temporary  in nature, unless the abandoned
 pond is  continuously  managed  to maintain the wetlands vegetation.  Filling
 mined  pits with clay  and tailings does  not preclude possible  creation  of
 lakes  and/or  wetlands type  habitat.   Phosphate ore removed still leaves a
 net void in material, precluding return to original contour throughout the
 mining area.
 W-54
          The potential  for sustaining  overburden  pressures resulting  from the
 full range of practical  uses  for reclaimed slime ponds needs  to be investigated
 as an  integral part of the  on-going reclamation research.  The cautious concern
 expressed in  the  EIS  sustains.
 W-55
          Text modified.
 W-56
          Because of  continued  concern  regarding potential groundwater contami-
 nation by the highly  contaminated gyp ponds, the site-specific studies for new
 sources must  of necessity initiate with the assumption that pond lining is needed
 to protect groundwater quality.   This is no different from existing requirements
 for other industries which employ ponds containing chemically or radiologically
 contaminated water.  Even if the industry study on these ponds were to show lack
 of groundwater contamination at  the three sites tested,  the need would still
 exist for a basic assumption that pond lining is  needed for new sources until
 hydrogeologic testing proves otherwise.
W-57
          The disclaimer is already noted in the  text.
W-58
          The intention of  the calculation  was  to  estimate the magnitude  of the
 storage requirements required  by the proposed action,  not to  design a containment
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system for a specific site.   A more sophisticated computation will be necessary
to design each specific system.
W-59
          We agree with comment.
W-60
          The alternative action in the context from which this quote was taken
would have required replacement of wetlands habitat equivalent to that which
now supports certain important species.  These species are not (nor claimed)
restricted to wetlands habitat necessarily but, according to reported occurrences,
are most abundant or most frequently present in wetlands.
          Further response to the remainder of this comment is unnecessary.
W-61
          Farm ponds, reservoirs, other man-made impoundments, ponds, most lakes,
and borrow pits are not wetlands by most definitions nor those of this report,
most literature cited, and the Florida Department of Natural Resources.  See
response to Comment T-42 for references to wetlands definitions and descriptions.
          The most recent research on wetlands restoration is summarized and
documented in working paper Volume XI, Section 2/Volume VII-NTIS.  The conclusions
of this EIS were based on the state of the art of wetlands restoration and field
observations.
          Our consistent references to the value of unreclaimed mined habitat
and the efficacy of allowing more to develop show little difference in your
message and ours.  It should be remembered, however, that impact was based on the
environment as perceived up to the end of 1977 (including proposed mining and
reclamation plans) and not elucidations prompted by the conclusions of this EIS.
          Man-made marshy areas likely are more productive for many waterfowl
than wetlands, as are mining pits and as would be managed slime ponds if realized.
In working paper Volume XI,  Section 2/Volume VII-NTIS, a prediction is documented
that little impact from mining to those species considered 'important' to Ducks
Unlimited is expected.  As indicated in the list of species expected to be
affected by wetlands loss in this EIS, bitterns, rails, and herons generally are
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more dependent on wetlands than ducks.  None of the ducks of the mining area
is a species of special concern as designated by the Florida Committee on Rare
and Endangered Plants and Animals, although the referenced wading and shore
birds are.  The alternate wet/"dry" regime of wetlands is a basic characteristic.
          The editorial in Fisheries references a court decision that was based
on expert testimony and data presentation.  Apparently evidence of man's inability
to duplicate existing wetlands conditions outweighed that of opposing views.
W-62
          These activities on the part of state and federal agencies are mani-
festations of your previously expressed (Response to Comment W-14) need for man
to manage his environment.  Whether all aspects of the management are in the best
interest of natural succession is a point to be debated among the parties involved
and not within the scope of this EIS.  Whatever the end product of the management
may be, however, the initial impetus was conservation of a valuable resource, as
are most results.
W-63
          The economic elements were carefully considered by two professional
economists experienced in environmental analysis.  Both economists agree that
there would be some difference in impact for the various scenarios.  However,
within  the framework of existing economic information, there was no way to quantify
these differences within the guidelines for this study.  Overall, the economists
believe the differences would not be of large significance.
W-64
          The bias toward environmental elements is the result of the intent of
the National Environmental Policy Act  (NEPA) and the expressed concerns of the
members of the Steering and Advisory Committees.  Whether environmental impacts
are balanced by socioeconomic benefits is a subjective and potentially arbitrary
judgement.  Such judgement is- the responsibility of the decision maker and
justifies an explanation of rationale  in the manner advocated by recently issued
regulation of the Council on Environmental Quality for implementing procedural
provisions of the NEPA.
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W-65
          Text modified.
W-66
          Text remains the same.  Comment indicates the "may" should be changed
to "will," but we have not found sufficient evidence, including the Devall
paper, to indicate the soils are generally better than or even equal to those
existing prior to mining.  There are certainly instances whereby poor soil is
improved for some uses, but there are also certainly instances whereby soil is
degraded with respect to certain uses.
W-67
          How closely reclamation will return each mined area to its original
contours will depend on the site-specific mining and reclamation plan which will
be required for the site-specific EIS and the Florida State DRI.  The choice
between natural habitat systems and human use will have to be considered when
developing the reclamation plans.
W-68 through W-74
          All of these comments are iterations of previous ones and have been
addressed.  The only different aspect is the reference to biological productivity
versus diversity.  Although not in this EIS, part of the rationale for the
conclusions stated herein (working paper Volume XI, Section 2/Volume VII-NTIS) is
that:  "Were the mined land allowed to naturally revegetate, there might
eventually be greater productivity in terms of life support."  This was specifi-
cally in reference to sandhills and sand pine scrub versus the deciduous forest
that possibly could develop on mined land.  The statement is not so readily
applicable to hammocks or wetlands.  The remainder of the thought (same page) is
important also:  "The argument, however, obscures the uniqueness of the
vegetation and associated fauna and the fact that the sclerophyllous plants
characterizing this native type (i.e., mixed forest) support a greater variety
of wildlife than either natural nonforested habitats or the various agricultural
habitats of reclaimed area."
W-75
          If native habitat could establish on mined land, there would be no
impact associated with its loss.  The types of communities that will establish on
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mined land, as described in the EIS, the Edscorn paper, and your comments,  are
not those existing.  The success of pine plantation (slash pine only - not  the
premining naturally dominant longleaf pine) is debatable (see working paper
Volume XI, Section 2/Volume VII-NTIS).  Importantly, pine plantation does not
approach the biological productivity of pine flatwoods.  The dependence of  mixed
forest on moisture conditions is not unlike that of any other forest type.
Moisture conditions, of course, are partly determined by the soil type.
W-76
          This EIS does state that pine flatwoods comprises the greatest amount
of remaining forests - and the important word in the sentence is "remaining":
170,000 out of nearly 3 million acres is not much.  Secondly, its status as the
predominant forest in Florida also is important since the forest that possibly
will replace it and other native forests on mined land is most similar to the
more expansive eastern deciduous forest.  The paucity of remaining extent of
both the pine forests and deciduous forests in eastern United States is of
concern of course, but the desirability of deciduous forests replacing native
Florida forests is debatable.  This point is expressed in our effects assessment
and was brought up by a Florida Audubon Society spokesman at the Bartow Public
Hearing  (Transcript, p. 74-75).
          The "mesic hammock" at the Christina site apparently is different from
the native hammock since you earlier state (see response to Comment W-31) that it
would not be vegetationally distinguished by most experienced naturalists as other
than a natural hammock and Edscorn calls it a hammock situation.  A description
of native hammocks is given in working paper Volume VI, Section 5/Volume VI-NTIS.
W-77 through W-81
          These comments have been addressed previously.  As additional support
for our conclusions, we would like once again to point out the statement made by
a Phosphate Council spokesman at the Bartow Public Hearing for this EIS that
indicates the difficulty in establishing any native habitat on mined land.  This
statement directly contradicts claims of presence of true hammocks and other
native habitat on mined land as well as the imminency of their presence via
man-directed activities.
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W-82
          We regret that apparently the commentor misunderstood the context of  this
quote.  As we stated in the same paragraph, "mining and subsequent reclamation
are producing a uniform habitat."  Comparisons were then made between the
primarily agricultural habitats of reclamation and those of natural systems.  As
of the date of this EIS, there is no evidence of the desire or intent of any
significant amount of natural system development on mined lands (see response to
Comment W-29).
W-83
          The present fragmented system, as indicated by the quote and its context,
contains optimal habitat for these species; it is limited and further fragmentation
will indeed reduce carrying capacity for both species.  We have already stated  that
wildlife carrying capacity generally is enhanced by the juxtaposition of habitat
types.  Further comment on the fact that reclamation is producing a uniform habitat
is unnecessary.
W-84
          The likelihood of the threatened and endangered species being affected
by mining is more likely than restoration of native habitat being effected and
other "enormous potential" being realized.  Technology and economics do not
indicate the latter will occur.
          Omission of the table has been addressed and it has been inserted.
Reference also has been made to additional comments on threatened and endangered
species:  working paper Volume XI:  pp. 2.41 - 2.47.  See response to Comment W-35
on aquatic threatened and endangered species and the context in which all
threatened and endangered species are treated.
          There is another point of agreement besides that of impact to the
Osprey and Caracara,  To quote from the same paragraph:  "...the Least Tern and
Peregrine Falcon, both primarily coastal species, may be attracted to the mining
areas."  As indicated, this is considered an outside possibility for the rare
fa.lcon.  We have no evidence that would indicate a change in the evaluation of
impact to the threatened and endangered species.
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W-85
          It is doubtful tha,t  improved pasture  is  similar  to  the  relatively
young successional habitat of  study area  game management lands  such as  the
C. W. Webb and Avon Park Wildlife Areas.  Apparently  the only impact assessment
you really disagree with concerns the  Bobwhite.  This species is  most success-
fully managed in  field-forest  edge, which is more  scarce on reclaimed lands than on
existing ones.
W-86
          This quote  does not  say that certain  species will be  eliminated from
the area.  Please see working  paper Volume  XI,  Section 2/Volume VII-NTIS  for a
more complete discussion of  the  effects of  mining  on  recreational and commercial
species, including the opinion of certain Florida  game management authorities that
landuse changes generally determine what  species comprise  the game list and that
Florida's game list has dwindled because  of habitat loss and  may  continue to do  so.
W-87
          As indicated previously (see Responses to comments  T-l  and T-2),  our
assessment of impact  to these  species  in  general is supported by  the findings of
the Archbold Station  and the Florida Game and Freshwater Fish Department.   We
regret  that your  review of this  statement apparently  did not  include the  effects
assessment  (working paper Volume Xl/Volume  VII-NTIS),  but  we  invite your  attention
to Section  2 of  that  document.
          The Florida Committee  on Rare and Endangered Plants and Animals has
reviewed  the status of most  vertebrate species  in  Florida  and is  continuing review
of plants and invertebrates.  The result  is an  extensive list and treatment of
species other than those recognized as threatened  and endangered  by either  the
FGFWFC  or DOI.   The significance of these species  as  assessed by  FCREPA,  as well
as the  FWS  through the Archbold  Biological  Station Report, indicates that con-
sideration  of the species should be a  part  of future  development  activities in
Florida.
W-88
          Information on nuisance and  pest  species of the  study area is in  working
paper Volume VI,  Section 5/Volume VI-NTIS and working paper Volume XI,  Section 2/
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Volume VII-NTIS.  Our assessment of mining and reclamation increasing the
potential of several species to reach pest proportions remains as does the
prediction that the populations will be controlled as "successfully" as ever
(working paper Volume XI, Section 2/Volume VII-NTIS).  Control methods
generally impact other biota.  We repeat, as before, that some of the impacts
of mining are no different from those of other development.  We repeat also
that mining is projected to cause most of the cultural alteration in the inland
study area between now and 2000.
W-89
          Text modified.
W-90
          This is in reference to the EPA report on radium-226 in ground water
(EPA/520-6-77-010).  There have been field observations (by the State of Florida
and SWFWMD) of slime and gyp ponds failure by sinkhole collapse.  Water budget
studies show there is known seepage or loss of water from slime ponds (Zellars
and Williams, Inc., 1977).  Although the evidence may not be complete, indications
of contamination do exist and, therefore, need to be addressed.  To our knowledge,
definitive studies in support of a contention of no ground water contamination due
to phosphate industry activities do not exist.
W-91
          As stated in response to Comment     , EPA effluent discharge standards
are not sufficient to protect water quality in the Tampa Bay and Peace Basins.
W-92
          Surface water in West Central Florida tends to exceed recommended
concentrations of plant nutrient material to prevent overenrichment whenever the
water is impounded, whether or not the water has been affected by phosphate
operations.
W-93
          See response to Comment W-56.
W-94
          Text Modified
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W-95
          See response to Comment W-35.
W-96
          The conclusion of the paragraph  containing the quote is:  Although  the
immediate effects of  (a slime) spill are severe,  the impact  is reversible because
stream ecosystems generally recover in  2 to 5 years  (based on the spill's
magnitude).  The implication  that we assigned a significant  magnitude  of impact
to aquatic threatened and endangered species is not  founded.
W-97
          Recovery of a disturbed wetland  is not  in  question; restoration of
wetland destroyed by  mining is.
W-98 and W-99
          The proposed action recommends several  alterations to  current mining
and reclamation policies.  The mine pit lake systems,  including  their  value as
habitat, their unavoidable existence, and  their expected viability  are addressed
above  Csee responses  to Comments T-40,  T-41, T-44, T-46, and T-47).
W-100
          The truth of the first paragraph in this comment appears  to  have no
relevance to our impact discussion.  Concerning the  next paragraph, we regret any
inferences that wet areas are wetlands; we consider  the statements  relative to
impact on nuisance and pest species as  not at all contrary to those pertaining to
the  importance and value of wetlands.
W-101
          Standing water as defined in  the paragraph above the one  comprising this
quote  includes lakes.
W-102
          Economic data on commercial fishing as  well  as observations  of the
FGFWC support this prediction  (see Volume V, Section  2/Volume V-NTIS).
W-103
          Magnitude of community alteration will  be  a  function of extent and  kind
of nearby watershed disruption.  Without a knowledge of details  of  a proposed
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action in a given area as well as some good baseline and applicable historical
data, it would be a rather meaningless exercise to apply quantitative predictions.
The qualitative description of potential effects provided in the text is adequate
for impact assessment purposes.
W-104
          This statement is somewhat misleading in that it was not intended to
contrast resource value of standing versus flowing water communities within the
study area, but rather, to indicate that reduction of flow in stream habitats
results in undesirable community changes and concomitant reduction in resource
value.  (It should be pointed out, however, that when contrasting resource value
of standing versus flowing water communities within the study area, all evidence
indicates a greater resource value for flowing water communities; the values of
each are discussed in the Aquatic Biota working paper (Volume V, Section 2/Volume
V-NTIS).  The statement will be clarified by the following rewording:  This will
represent an adverse effect, since shifts to lentic community characteristics in
a stream habitat are undesirable and result in loss of resource value.
W-105 and W-106
          The document does not state, or imply, that the phosphate industry has
precluded growth of a tourist/retirement economy in Polk, Hardee, and DeSoto.
Quite the contrary, the tourist/retirement industry has been growing in Polk
County especially, and as pointed out, "service businesses catering to the needs
of the retirement and tourist sectors are in direct conflict with the phosphate
industry" (for workers, goods and services).  In other words, both compete for
goods, services and workers to satisfy their needs.
W-107
          Text modified.
W-108
          Trade in phosphates is quite sensitive to transport costs.  Consequently,
firms are able to export significantly if they are favorably situated with respect
to low cost water transportation routes.  This requirement is met by phosphate
production regions in Florida.  Clearly, Tampa Harbor is being developed as a
deep draft, bulk-cargo port.  The only significant bulk cargoes are petroleum
and phosphate.  Of the two, according to Corps of Engineer statistics, phosphate
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export predominates (.i.e. shipment of phosphate rock and development of Tampa
Harbor [for bulk cargo] are synergistic or mutually cooperative.)
W-109
          The collapse of Karst structures was discussed as a potential impact
only because gypsum stacks and some waste clay storage will be above grade, thus
increasing the load on below-grade structures and presenting the possibility of
collapse.
W-110
          Available aerial photography of the study area as well as generalized
vegetation cover maps are either of inappropriate scale or accuracy for use in
showing such fragmented habitats as sandhills and sand pine scrub and naturally
isolated hammocks.  This was pointed out earlier (see response to Comment W-17
and working paper Volume XI, Section 2/Volume VII-NTIS).  The alteration by
mining of any extent of these endangered habitats is of significance.  That 30%
of the study area's mixed forest habitat (sandhills and sand pine scrub) will be
altered by mining is most significant; no other habitat type will be altered to
that extent.  These observations portend a greater perturbation on these habitats
than indicated in this EIS.
W-lll
          Text modified.
W-112
          Further comment on the value of mine pit lakes is unnecessary.
          That you recognize this as "one of the few" references to the value of
abandonment versus reclamation is contradictory to numerous previous comments in
which complete unawareness is implied or stated.  Much of the redundancy in your
total statement could have been avoided by regarding the impact to terrestrial
biota in its proper context rather than pulling out certain sentences.  Reasons
for the choice of improved pasture and similar habitat on reclaimed land, stated
often in working paper Volume XI, although not denied in your statement, are
ignored.  Especially noticeable is the fact that its projections as a land use are
not questioned.
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W-113
          The word "inland" was omitted from the sentence.  The sentence has
been corrected to read "...change in inland land use...."  Mining is not
expected to change significantly Coastal Lowlands biota.
W-114
          None of the statements in this EIS on improved soil conditions pertain
to terrestrial/wetlands biota.  The statements refer, and possibly correctly, to
the improved soil condition for crop and pasture production.   Habitats of the
foreseeable future, either reclaimed or natural, on mined land are not expected
to exhibit either life-support value of existing wetlands or diversity comparable
to that of the present mix.  As stated, diversity is expected to decline
primarily from loss of swamp hardwoods and mixed forest - neither of which is
expected to develop on mined land.  This is a comparison of expected versus
existing habitat types.  The foreseeable future encompasses maturation time.
Regardless, a comparison between existing systems and the systems expected from
reclamation, which is the context of this particular quote, is certainly valid in
assessing impact of mining activities.
W-115
          This comment merely points out inadequacies in the data base, which
have already been acknowledged.  In all probability, and appropriately, data on
threatened and endangered species distribution will come from site-specific EIS's.
          As stated in working paper Volume VI, Section 5, the data included in
the description of the study area's threatened and endangered species was derived
mostly from FCREPA's Inventory of Rare and Endangered Biota of Florida.  The FWS
report was issued much later than was Volume VI, Section 5/Volume VI-NTIS.
Importantly, the FWS report was available prior to evaluating impact on the species.
We see little need to revise the general range maps since the species likely to
be affected have been identified and their distributions in specific locales can
be ascertained and mapped during site-specific studies.
W-116
          Regional carrying capacity, as defined in the sentence, pertains not
only to biologic carrying capacity but also economic, social, hydrologic, etc.
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In this extension of the concept, activities may indeed be limited by the
factors determining the carrying capacity.  One of the factors that may be used
to determine regional (or other unit) carrying capacity is the proportion of
intensely managed biologic systems to essentially natural or moderately modified
systems.  Since the concept cannot be applied areawide to all resources, the
reference has been deleted.  The sentence pertaining to the increase in managed
versus natural systems stands.
W-117
          The statement on p. 2.45 (DEIS) is:  most of the affected ecologically
significant species "...are closely ass-j_iated with various little-modified
habitats, including wetlands and natural ponds and lakes that have gently sloped
sides...."  Besides the fact that wetlands include forests, which in this case
are most important, upland forests also are among the "various little-modified
habitats."  Loss of forests identifies the greatest impact; this does not imply
that loss of other habitat does not have impact.
W-118
          The context of the referred material (from page 2.44 and 2.45 of the
DEIS) is the 1985 and 2000 environment of the study area with presently
permitted mining only.  It is a statement of the effects of mining, including
proliferation of pests, etc.  Impact is judged on alternatives to this "no
action" state.  The context of p. 2.74 (of the DEIS) is existing mining plus all
pending permit mining.  Although the effects described in this EIS, and more
fully in working paper Volume XI, Section 2/Volume VII-NTIS, are expected to be
enlarged by additional mining, impact was judged to be minimal because both
categories of species are intensely managed, i.e., essentially controlled.
Similar management is not true of biota in general nor of threatened and
endangered species and ecologically significant species in general.
          The context of the paragraph on p. 2.74 of the DEIS is important as
well.  Reference is made to the fact that land use change expected from mining
will contribute to the increased costs of future management of these species;
further, it is implied that could the increased costs attributable to mining
be discerned, and were they substantial, then impact would be greater than minimal.
The costs are not all monetary; they include, for example, the impact of
increased pesticide usage.
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W-119
          Text modified.
W-120
          Text modified.
W-121
          The word, "catastrophic," was chosen to indicate a "worst-case"
situation, i.e., a -10 impact.  The loss of archeologic sites unquestionably
represents a worst case situation for that site.  Even though the artifacts
may be recovered, as was mentioned in mitigation, the site itself is lost.
W-122
          Refer to response to comment W-63
W-123
          Text modified.
W-124
          Text modified.
W-125
          Text modified.
W-126
          The dam height associated with the proposed process modification was
obtained from a description of the sand-clay waste disposal method by Timberlake
(Volume XI, Section 4/Volume VII-NTIS).  The risk of collapse will always exist
unless it can be guaranteed that no slime storage will take place over carst
structures, even though history has shown the risk to be slight.
W-127
          Restoration to original topographic surface was not stated to be an
overriding consideration.  If it were, there would be a reduction, if not
elimination, of phosphate strip mining.
W-128
          Text modified.  EPA sampling has shown significant exposure levels as
far as 400 meters from a controlled dryer stack.
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W-129
          Text modified.
W-130
          Text modified.
W-131
          There have indeed been vegetation changes in the South Prong of the
Alafia River  (Burgess, 1966, State Board of Health, Rapo-t on Biological,
Physical, and Chemical Conditions of the V.afia River).  There have probably
been no further adverse changes since 1966, because water quality in the
South Prong has improved since that time.
W-132
          Reserves under Category I wetlands should be considered resources as
long as mining is precluded.  If in the future, due to changing technology in
wetlands restoration, and/or dire national need, mining is allowed in Category I
wetlands, the resource may again become reserves.  In any event, preclusion of
mining does not destroy the resource.  It may, however, cause mining to be more
costly at any given time in the future.
          Determination of reserves lost to wetlands preservation will have to be
made in site-specific studies.
W-133
          Even with all the variables mentioned in this comment, a net void is
still to be expected.
W-134
          After weighing all positive and negative effects of slime ponds, including
potentially catastrophic negative effects, elimination still has a greater positive
than negative impact.
W-135
          Collapse of underlying strata occurred at the CF Industries, Inc.,
Mulberry, Florida, gyp pond in April, 1975.  An estimated 90,000 cubic yards of
gypsum and 4.5 million gallons of contaminated pond water entered the aquifer.
W-136
          Text modified.

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W-137
          Several responses on the apparent differences in our concepts of wetlands
appear above; the value of wetlands to waterfowl is discussed in Response to
Comment W-61; and the state of the art of reclamation is discussed in several
above responses.
W-138
          Refer to responses to Comments T-55 and W-56.
W-139
          Changes are not too insignificant to measure, and text has been modified
to reflect this.  See EPA report entitled "Population Radiation Dose Estimates
from Phosphate Industry Air Particulate Emissions," Partridge, et al.
W-140
          See response to comment W-132.
W-141
          We can see no reason to exclude listing Federal requirements for strip
mining of coal, which is similar in many respects to strip mining of phosphate.
W-142
          This comment does not explain why spills, which enter and harm receiving
water quality, occur quite frequently. (Tampa DER files)
W-143
          We agree with the comment, though extraneous to the topic of soil types.
Also, agricultural activities are limited to the extent that the land is too
unstable to support heavy agricultural emplements.
W-144
          This statement does indeed imply other than the intended message that
current mining and reclamation practices are producing managed systems.   It has
been deleted.
W-145
          Text modified.
W-146
          The wording in the EIS has been changed to be consistent with this comment.
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W-147
          Reference to the difficulty in discerning true palmetto  prairie  from
palmetto growth  (both lumped as rangeland) using existing vegetation maps  is in
working paper Volume XI, Section 2/Volume VTI-NTIS.  From known distribution of
the type, we have indicated that it may exist on land proposed to be mined  in
the southernmost portion of Manatee County.  We agree that only field analysis
or perhaps small scale photography will identify the type.
W-148
          The area's development progress, other than with respect to phosphate
mining activities (Volumes V and VIT-NTIS, respectively) is acknowledged in
Volume IV (Current Land Use), and Volume XI.
          The need for additional improved pasture is questionable, at best.
Arguments against additional improved pasture are presented in Volume XI, p.3.47.
It must be kept  in mind that reclamation will result in a net loss of land.
W-149
          We are unaware of studies showing additions of phosphorus from stream
discharges to have no additional effect on Tampa Bay.  To the contrary, phosphorus
and other plant  nutrient materials introduced into Tampa Bay by various activities
of man have been shown to be quite harmful to water quality in the bay system.
EPA will not adhere to a policy which would allow additions of a harmful material
because the body of water has already been degraded below the point where
additional materials can do no further harm.  Instead, we strive to remove the
harmful materials being introduced while at the same time preventing new discharges
of the material.  This is why the City of Punta Gorda is planning to land spread
treated sewage,  and the City of Tampa is spending $90 million on advanced waste
treatment, which will remove nitrogen and phosphorus from its discharges.  It is
also  the reason  chemical phosphate plants in the Tampa Bay Basin reduced daily
discharges of phosphorus from 80,000 pounds per day in 1969 to less than 5,000
pounds per day in 1972, at a considerable cost.  Let us not reverse these advances
made  in the past few years with a philosophy based on allowing further degradation
simply because a body of water is already degraded.
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W-150
          If the change is 53 mgd and 21 mgd is associated with phosphate industry
usage, the phosphate industry is a major factor in the projected change, accounting
for about 40 per cent of it.
W-151
          The 1500 gallon per ton figure was based on a survey of phosphate industry
users carried out by the EPA for this study, and was an average of the usage rates
reported.  Details of the water demands in the study area are shown in a working
paper (Volume V, Section 2/Volume V-NTIS).
W-152
          We believe this estimate of cost per acre for reclamation with the
"Brewster" (or a similar) method is quite high.  Also, this estimate of the value
of agricultural land in Central Florida is certainly low.  One must also consider
the cost of constructing, operating, and reclaiming slime ponds if conventional
slime settling ponds were utilized.  This cost approaches the cost of alternative
methods of slimes utilization.  With pre—thickening as necessary, one of the
alternative uses is feasible at all Central Florida mines.
W-153
          The dry conveyor is not part of the recommended scenario nor proposed
action.
W-154
          The Proposed Action will require above ground water storage, though not
containment of 10-year nor 25-year storms at mines.  This amount of storage was
deemed infeasible.  Instead, the Proposed Action requires storage to allow capture
and reuse of water otherwise tied up in slime ponds; and a re-use factor
approaching 100 percent on an annual average basis.  Amount of storage is to be
determined in site-specific studies.  The advantage of water conservation
resulting from above ground storage outweighs disadvantages mentioned in the
EIS and in this comment.  The writer may have confused disadvantages spelled out
for above ground slime disposal with above ground fresh water reservoirs.
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W-155
          This is a correct statement.  However, this. EIS concludes that
Category I Wetlands are to be mapped in site-specific studies, and protected.
Section 404 Permits are to be issued for Category II Wetlands, but after plans
are developed for restoration.
W-156
          Refer to numerous responses above for wetlands definitions and other
information on wetlands, as well as reference  to the need for further development
of criteria for judging their relative value.
W-157
          Refer to working paper Volume XI, Section 2/Volume VII-NTIS for
information on criteria used in judging wildlife habitat types.  Working paper
Volume VI, Section 5/Volume VI-NTIS contains reported vertebrate (except fish)/
habitat type presence and abundance.
          We agree that all things being equal, there is no need to rank habitat.
All things were not equal in this impact analysis, however, since, among other
factors, all habitat cannot be restored on mined land.  Similar loss of habitat
occurs with other development.  The ranking of habitat to achieve recognition,
if not conservation, of productive or diverse  or endangered habitat is not
unrealistic and rarely controversial except as to the order of rank.
W-158
          The combination of slime ponds, improved pastures, and mine pit lakes
of most reclaimed mined land does not approach the previous landscape diversity.
The value of slime ponds in this context, however, is recognized and was
discussed more fully in working paper Volume Xl/Volume VII-NTIS (Refer to response
to Comment T-36).  The statement in the EIS that neither fairly immediate use of
abandoned slime ponds for improved pasture  (flocculation method of restoration)
nor the more immediate availability (within 2  years with sand tailings method)
for similar purposes is preferable from the standpoint of wildlife production is
a strong endorsement for slime ponds.  The decision to eliminate them was made
despite their temporary wildlife value.
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W-159
          Refer to responses to Comments T-14, T-42, W-28, and W-61.
W-160
          The conditions of the proposed action indicate that the effects
assessment made decision makers aware of the potential impact to the area  s
biota.  Elaborations will be made on these impacts along with appropriate
mitigation in the site-specific EIS's.
W-161
          Volume I of Final EIS should satisfy this comment.
W-162
          Refer to responses to these referenced comments.
W-163
          Additional original data is always desirable in any study of this
nature.  However, we believe data is sufficient to support basic conclusions of
the study.  Additional data will be necessary for each site-specific EIS.
Responses are made elsewhere to each of the examples (3a through 3f).
W-164
          The production figures and projections of phosphate rock demands versus
domestic supplies are estimates made by the Bureau of Mines and are updated
annually.  The latest projections are available from them.  They show that there
is time to formulate a policy on exporting phosphate rock.  That type of policy
is not within the charter of the EPA to recommend, however, the EIS is the
medium by which EPA is communicating the resource projection "information  to
Federal, State and local agencies as well as to the public."
W-165
          The EIS does not determine quantity of fossil fuel utilized for
shipping phosphate rock.  See response to Comment T-4.
W-166
          The statement refers to relieving public anxieties about the adverse
effects of phosphate mining.  The author of this comment lifted out of context
this important "charge" to industry, government and to the general public  to be
informed and pursue with diligence the resolution of all issues involved  (research,
drafting of regulations, monitoring, planning and operation).
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W-167
          Refer to response to Comment T-4.
W-168
          Refer to response to Comment T-4.
W-169
          Refer to response W-63.
W-170
          Conclusions of the Final EIS are as  stated in Volume I.  Rationale
is given in  these responses, in Volumes  I and  II,  and in  the revised Working
Papers.
W-171
          Category I Wetlands, for which mining  is precluded, is adequately
defined on an  areawide basis.  These  areas will  be mapped in the site-specific
studies.
W-172
          Refer to responses agreeing with need  for an increased monitoring and
enforcement  program.
W-173
          The  National Wetlands Inventory Office has been consulted, and has
assisted.  Current mapping by  this office will assist greatly in determination
of  Category  I, II, and III Wetlands in site-specific studies.
W-174
          Available reports and observations of  threatened  and endangered  species
on  or  using  land  to be mined should be addressed in site-specific  EIS's.   Known
occurrence as  of  the end of 1977 was  reported  in working  paper Volume XI,  Section 2/
Volume VII-NTIS.
W-175
          The  FWS Report generated by Archbold Biological Station  was discussed  in
Comments T-l and  T-2.  As indicated,  its conclusions were reviewed prior to
publication  of this EIS in draft form and many,  though not  all, corroborate  the
conclusions  of this EIS.  The  report, though an  aid to the  EPA's Central Florida
Phosphate Industry Areawide Effects Assessemnt,  is not included as a distinct document.
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W-176
          Responses to the Florida Audubon Society letter are provided in
responses to oral comments T-25 through T-28.
W-177
          Because these are 'important' species for which suitable habitat must
be considered as part of mining and reclamation plans (via the proposed action),
the site-specific ElS's will provide information on their occurrence as well as
measures to mitigate impact to them.  None of the mining area has been designated
by the DOI 'critical habitat' of a threatened or endangered species and thus is
not legally protected for their use.
W-178
          Current State requirements should assure that reclamation is equal to
or greater than the rate of mining.
W-179
          See responses to Comments W-265 and T-26.
W-180
          This comment is addressed in text of Volumes I and II, FEIS, and in
responses to other comments.
W-181
          This is a correct understanding.  Site-Specific EIS's will be
distributed for review.
W-182
          Much of this information will be provided in site-specific studies.
See Working Paper Volume III/NTIS Volume III for area wide effects.
W-183
          Text of Volumes I and II modified, based on these comments regarding
effects and -mitigation of effects on archaeological and historic sites.
W-184
          This paragraph will be included in requirements for site-specific EIS's.
Consultants will be advised to contact the Florida Division of Archives, History
and Records Management during the Plan of Study state of each site-specific EIS.
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W-185
          Energy is considered, but we  agree  that  this was not  an  overriding
consideration in evaluation of scenarios.  We believe increased emphasis  on
energy utilization would have led  to  the same conclusions.
W-186
          A comparison  is not needed  for rock processed  in Central Florida.
Drying obviously requires more energy than transporting  approximately  eight
percent  excess moisture.  Proposed Action does  require energy comparison  on
rock shipped outside  the State.
W-187
          Agree.
W-188
          Agree - see response to  Comment T~8.
W-189
          The USGS is not willing  to  publish  the model results  which includes
other municipal and industrial uses as  of publication of the FEIS.  EPA does not
intend  to develop guidelines for water  withdrawals  for phosphate mines in Central
Florida. This is a State responsibility.
W-190
          This method has been shown  to be ineffective in instances where top
soil  consists of highly porous soil such as exists  in many areas in Central
Florida. Radon gas emanation is not  impeded  sufficiently to allow decay.
However, site-specific  studies will determine if this method is applicable in
any given area.
W-191
          See responses to  comments T-5 (Point  #20)  and  T-42.
W-192
          It was within the purpose of  this EIS to  point out the perceived
deficiencies in the lake systems created by mining  but not within  the  scope to
investigate and formulate alternative designs.  Among the comments received in
response to the DEIS  was one from  the Florida Chapter of the Wildlife  Society
indicating  that offers  to assist the  Florida  Department  of Natural Resources in
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formulating restoration designs have met with ng success.  Contact with
Nicholas Holler, President, Florida Chapter of; the Wildlife Society may be
beneficial.  (We do not have an address or telephone number.)  Additionally,
the Lakeland Office of the Florida Game and Freshwater Fish Commission may
have suggestions.  Mr. Charles Lee of the Florida Audubon Society may also
be of assistance.
W-193
          We agree with this comment, and believe the Proposed Action to be in
accordance with it.
W-194
          It is believed that the proposed action does mitigate the impacts
listed, in the context of the following definition of mitigation from the proposed
regulations for implementing procedural provisions of the NEPA (FR, 43:112 -
Friday, June 9, 1978 - Part II):
     '"mitigation* includes: (a) Avoiding the impact altogether
     by not taking a certain action or parts of an action.
     (b) Minimizing impacts by limiting the degree or magnitude
         of the action and its implementation.
     (c) Rectifying the impact by repairing, rehabilitating,  or
         restoring the impacted environment.
     (d) Reducing or eliminating the impact over time by
         preservation and maintenance operations during the life
         of the action.
     (e) Compensating for the impact by replacing or providing
         substitute resources or environments."
W-195
          The NEPA is not applicable to Existing Source NPDES Permits.
W-196
          See response to Comment W-144.
W-197
          Little is documented about the effects of nearby or/adjacent mining
on preserved wetlands.  It is anticipated via the proposed action that future
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formulating restoration designs have met with no success.  Contact with
Nicholas Holler, President, Florida Chapter of the Wildlife Society may be
beneficial,,  (We do not have an address or telephone number.)  Additionally,
the Lakeland Office of the Florida Game and Freshwater Fish Commission may
have suggestions.  Mr. Charles Lee of che Florida Audubon Society may also
be of assistance.
W-193
          We agree with this comment, and believe the Proposed Action to be in
accordance with it.
W-194
          It is believed that the proposed action does mitigate the impacts
listed, in the context of the following definition of mitigation from the proposed
regulations for implementing procedural provisions of the NEPA (FR, 43:112 -
Friday, June 9, 1978 - Part II):
     "'mitigation1 includes: (a) Avoiding the impact altogether
     by not taking a certain action or parts of an action.
     (b) Minimizing impacts by limiting the degree or magnitude
         of the action and its implementation.
     (c) Rectifying the impact by repairing, rehabilitating, or
         restoring the impacted environment.
     (d) Reducing or eliminating the impact over time by
         preservation and maintenance operations during the life
         of the action.
     (e) Compensating for the impact by replacing or providing
         substitute resources or environments."
W-19.5
          The NEPA is not applicable to Existing Source NPDES Permits.
W-196
          See response to Comment W-144.
W-197
          Little is documented about the effects of nearby or/adjacent mining
on preserved wetlands.  It is anticipated via the proposed action that future
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descriptions of mining effects on the wa.ter table will include effects on
preserved wetlands.  Site-specific studies will determine the need to protect
preserved wetlands from operations on adjacent areas.  See response to
Comment T-27-
W-198
          Refer to response to Comment W-195.
W-199
          The Proposed Action minimizes consumptive use of water by the industry.
Projected Phosphate Industry use continues to decline through the year 2000.
W-200
          Specific effects on the Myakka River System will be addressed in site-
specific EIS's.  We have indicated potential effects from alteration of flow
regime, increased pressure from wildlife displaced from mining areas, etc., and
anticipate that the magnitude of these effects will be addressed in the context
of each mining site.
W-201
          See response to Comment T-4.
W-202
          Under the guidelines set by the Steering and Advisory Committees it
was decided that future mining projections would be on the basis of consistency
with production projections made by the Bureau of Mines.   If the reader adds
the cumulative production of all mines presently in operations, those in permit
processing and those projected by individual phosphate companies, you will
determine that figure is far in excess of the Bureau of Mines projections.  The
key to resolving "whose view is correct" is the analysis of the relationship of
the site-specific State and Federally required environmental planning studies
to this areawide impact statement and how that information is used in decision
making.
W-203
          Text modified.
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W-204
          Text modified.
W-205
          See response to Comment W-195.
W-206
          See response to Comment T-4.
W-207
          Text modified.
W-208
          The author of this comment is correct in stating that the four listed
issues were not focal points in the design of the alternative scenario investi-
gated.  However, those issues were not justifications for the proposed action.
Indeed, as the commentor points out, they represent short-term uses of man's
physical environment which must be (and were) considered versus long-term pro-
ductivity of the physical environment by the decision makers.  The concerns
expressed by the commentator are valid ones, but deal more with the socioeconomic
systems than the physical environment - the latter being the focus for this
section of the EIS.
W-209
          We share your disappointment as to the lack of biological data which
were presented for the fresh water aquatic systems of the study area.  We did,
however, include all readily available data and made an effort to obtain certain
unpublished data.  During the preparation of the working paper on aquatic biology,
for instance, we solicited the Florida DER data on Horse Creek, the Myakka River,
and a station on Peace River, but received no response after two requests.
Although these data would have been helpful in providing a more thorough coverage,
they do not substantially alter the basic characterizations presented in the text.
The data submitted are included in the FEIS.
W-210
          We have reviewed the Florida DER Peace River periphyton and benthos data.
We feel the data hardly qualify as extensive, although perhaps adequate for state
water quality monitoring purposes.  As stated above, we did attempt to obtain other
pertinent data from the DER.
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          The message of the last sentence In your comment is unclear; however:
all benthic forms are dependent upon dissolved oxygen, and those dependent upon
high concentrations can be collected in the same manner as those requiring less;
adult aquatic beetles and bugs use oxygen from air obtained at the water's surface,
and most are surface dwellers or free swimmers rather than bottom or near bottom
dwellers as are benthic forms.
W-211
          Again, this information would have been helpful during preparation of
the working paper describing the aquatic systems of the study area.  The record of
psychomyiid Genus A (== Nyctibphylax) from the Lower Peace River Basin, as cited in
the aquatic biota, working paper, is believed valid; it is based on a collection
of larvae and pupae from the Peace River in the vicinity of the DeSoto-Hardee
county line during March, 1976.
W-212
          This information on Horse Creek should be of value in the preparation of
site-specific EIS's.  We did not, however, discuss the creek in the aquatic biota
working paper and made no reference to its flow regime.  That the richness of
Horse Creek fauna (as opposed, for instance, to that of the Peace River)  reflects
the more natural or pristine conditions of an undisturbed stream may be so;
however, the taxa list for Horse Creek is based upon nearly twice the number of
samples as that for the Peace River, and most likely, a similar effort in the
Peace River could easily accrue at least the 17 additional taxa needed to make the
Peace River list equivalent.  Although there have been some catastrophic pollution
events in the Peace River (some of which have resulted in the permanent loss of
certain taxa), significant recovery seems to occur within several years,  and,
based upon historical descriptions of the river, there is no evidence of permanent
loss of natural habitat diversity.
W-213
          See responses to comments W-209 and W-211.
W-214
          Taxa lists were developed from existing data in available literature.
A certain degree of misidentification is inherent in most studies similar to those
cited.  Classifications, of course, differ and are subject to continuous
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interpretation.  It was not within the scope of this study to organize  the
taxa into any particular classification, and mostly those names reported  in
the literature were us«d.  Reference to the literature generally will reveal
the classification used in a particular study.  We regret typographical errors,
but find both typos and misspellings essentially unavoidable (e.g.,  'occures',
'lieklyhood* and 'undoubtably' in your comments).
          Crepidula was listed, along with other gastropods and macroinver-
tebrates, as occurring within a major river basin of the study area.  Thus, the
Peace River basin list consists of taxa from the Peace River main stem and
streams and tributaries within the basin.  It is not uncommon to collect  marine
or estuarine organisms in the freshwater portions of rivers immediately upstream
of the fresh/saltwater interface.  Blue crabs have been found as far upstream as
Gardner, and barnacle larvae are common in zooplankton samples taken near
Hwy. 761 bridge and Shell Point.  Crepi'diila has been collected in both August and
October in the vicinity of Shell Point in the Lower Peach River.
          As- indicated above, the comment on Neocloeon is more of academic interest
than pertinent to biotic characterization since nomenclatural changes occur almost
daily.  The organization of taxa into a particular classification would have been
a herculean task of only minute relevance to the real purpose of this study.  We
regret incorrect records, misidentifications, etc. but, again, we feel the
incidence of such errors is low and not sufficient to affect the characterization
presented.
W-215
          These comments elicit responses similar to those above.  We would,
however, like  to emphasize the essentially subjective nature of higher taxonomic
categories by  pointing out the use of Neuroptera to include the Megaloptera
in several sources, including the widely used Introduction to the Study of Insects
by Borror, DeLong, and Triplehorn (1976).  The use of Megaloptera to separate
alderflies, fishflies, and dobsonflies from similar species at the ordinal level
is a matter of interpretation and the term  'outdated1 is not applicable.  As far
as nomenclature at the ordinal level is concerned, some would take issue  with your
use of Hemiptera ins-tead of Heteroptera.
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W-216
          Refer to response to Comment 194.
          The modeling was deliberately designed to isolate the changes  due
to the phosphate industry.  Further reductions in the groundwater head will
result from increased water pumpage by other users.  As these data are
developed, they will be included in the simulation and analyses of the Floridan
aquifer by use of the USGS digital model.
W-217
          We believe projections were made as far into the future as possible
to maintain the level of precision needed to support the types of conclusions
necessary in an areawide or generic study.  The Areawide EIS should be updated
periodically to reflect changing estimates of reserves and resources, as well as
changing technology.
W-218
          The economic impacts of resource depletion have been addressed.  See
FEI.S, Volume I, and Working Papers Volume III/NTIS Volume III.
W-219
          Modeling approaches are applicable to organic pollutants, but not to
inorganic pollutants encountered with the phosphate industry.  An assessment and
description of effects of these inorganic materials is made in this EIS.
Conclusions regarding need for reduced discharges of plant nutrient materials
(Volume X), are based on this assessment.
W-22Q
          Non^point discharges not related to phosphate operations are addressed
in the three Section 208 Water Quality Management Plans in the Study Area.  For
both mining and chemical processing operations, runoff from areas affected or
disturbed are routed through settling areas and thence to permitted point source
discharge locations.
W-221
          The further treatment of air quality data in the study area to determine
the relationship between phosphate industry air pollutants and atmospheric
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temperature inversions would require data from continuous rather  than 24-hr.
monitors in the effected areas, and/or detailed computer modeling.  Continuous
monitoring data were only available to a limited extent at the time data was
collected for this study, and not in the area most affected by phosphate
industry emissions.  The modeling that was reviewed for this study was
concerned with annual average values of pollutant concentrations, and not
directly related to the effect of diurnal inversions.  Detailed short-term
modeling of the existing and proposed emission sources was beyond the scope of
this study.  Any new air emission sources will be required to look in detail
at the effect of such inversions on the air quality in the area around them as
part of new source permitting requirements, and the Clean Air Act Amendments
of 1977.
W-222
          The data reviewed in preparing this EIS did not provide enough
information to identify all of the existing sinkholes in the area, much less
identify specific locations at which sinkholes could be expected  to develop.
The identification of existing karst structures that have not yet developed into
sinkholes would be very difficult to do even with an extensive seismic survey,
due to  the high surface water table which tends to flood voids in subterranean
structures and thus reducing the contrast necessary to identify changes in sub-
terranean structures from seismic data.  Also refer to Volume VI  (Volume VI-NTIS)
of  the working papers.
W-223
          The study of airborne fluorides will require more and better ambient
concentration data to warrant a more extensive analysis (working  paper Volume VII,
Section  2/Volume III-NTIS).
          Vegetative fluorides appear to be inversely related to  rainfall
frequency, as stated in a working paper  (Volume VII, Section 2/Volume III-NTIS),
not on  the total rainfall during the year.
W-224
          Implementation of the Proposed Action at the Federal level will be
through  site-specific Environmental Impact Statements, New Source NPDES Permitting,
and Section 404 Permitting.  A discussion of the relationship between the Areawide
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and site-specific studies is provided in Vqlume I, Section 2A, FEI.S.
W-225
          This is an appropriate comment.  We hope the Final EIS language
provides sufficient flexibility to allow for changing technologies as well as
development of new information.  This is certainly a reason for requiring site-
specific EIS's, using the Areawide EIS as a baseline.  Departures from the
baseline can be made whenever departures are justified based on technology,
new information, or improved environmental, economic, or social effects.
W-226
          Refer to response to Comment Number 216.
W-227
          Refer to response to Comment number W-63.
W-228
          Local and cumulative impacts are also considered.  Working Papers,
Volume I/NTIS Volume I.
W-229
          See response to Comment W-224.
W-230
          See response to Comment W-220.
W-231
          Pond emissions were discussed in a working paper (Volume VII, Section
2/Volume III-NTIS).  The TRC report, by no means in itself a definitive study of
pond emissions, only tended to support the emission estimates shown in the
working paper.
          See Section in Volume I on Research Needs.
W-232
          The EIS does not state that "release of nutrients will be beneficial;"
it states simply that the outstanding productivity of Tampa Bay and Charlotte
Harbor can be attributed largely to significant contributions of inorganic
nutrients by the major contributing streams.  It is true that estuaries of the
study are apparently not phosphorus limited at this time because of high phosphorus
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concentrations, but to apply this, statement to all Florida estuaries would be
tenuous.  From a biological standpoint, the statement that all estuaries of
the study area are overnutrified at this time is incorrect.  Except for areas
of low circulation and nitrogen enrichment (as in Hillsborough Bay), detrimental
influences of nutrient enrichment on these estuarine ecosystems is minimal at
this time.  The stimulation of productivity resulting from present levels of
inorganic nutrient loading helps support some of the most productive estuarine
fish and shellfish communities along the southeastern U.S. coastline.  It should
be pointed out, however, that potential for over-nutrification in the study area
estuaries is high.  The best available evidence suggests that since Charlotte
Harbor and Tampa Bay have abundant supplies of phosphorus, combined nitrogen is
a significant limiting factor to further productivity.  The addition of
substantial quantities of combined nitrogen (as in sewage effluent) could easily
result in over-enrichment and undesirable biological alterations as has been
experienced in the Hillsborough Bay area.  Additionally, a reduction in water
circulation and mixing in these estuaries might also be manifest in areas of
over-enrichment, even at present nutrient loading levels.  A conclusion of the
EIS (Volume I, Proposed Action), is that reduction of artificially induced plant
nutrient material is needed to protect water quality.
W-233
          We are unaware of any adverse effects of reagents utilized in the
beneficiation process.  Concentrations of any of these reagents in discharges
would be extremely low.  No adverse effect on biota in settling areas nor in
receiving streams containing 100 percent settling pond discharge have been noted.
One possible exception is the use of ammonium hydroxide in lieu of sodium hydroxide
in the beneficiation process.  This has in some instances resulted in over-
enrichment of settling ponds, resulting in increased mosquito production (personal
communication with Mr. Frank Wilson, Polk County Environmental Control Dept.).
W-234
          The concern for new data is one shared by  the  EPA, but perhaps a
clarification of what is meant by new data is in order.  Data and information
pertinent to assessing the environmental impact of the central Florida phosphate
                                      4-44

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industry is. contained in numerous bas.ic and applied research reports, journal
articles, trade publications, monitoring reports, data bases, exhibits for
State and Federal permits, government agency reports and public media reports.
The EPA performed a field survey, and with the contractor and other agencies
developed data and information useful in analysis of the state of present and
projected future environmental systems.,  The commentor will find these data
and information in the working papers (revised and available through the NTIS).
There are several issues requiring continued investigation and analysis to
resolve and many of them have been identified in the working papers and the EIS.
W-235
          The Development of Regional Impact (DRI) Application for Development
Approval (ADA) was described in the working papers (Volumes II and III of the
NTIS papers).  Specific mention of the DRI/ADA process and the opportunities for
environmental management presented by it are now included in the EIS (Section 4.3).
W-236
          Limitations of the study are acknowledged.
W-237
          The section on radiation was prepared with the intention of providing  a
full perspective of the radiological impact associated with the phosphate industry.
Recognizing that specific recommendations to the State of Florida concerning
indoor radiation exposure due to radium-226 associated with phosphate-related land
are currently under development by the EPA (to be tentatively proposed in the
Federal Register in October 1978), specific statements in this EIS on this subject
would be premature.  With regard to radiation exposure via the ingestion pathway,
a report has been drafted by EPA's Eastern Environmental Radiation Facility entitled
"Doses Due to Consumption of Food Associated with Reclaimed Land and Phosphate Ore.
By-product Usage."  This draft report is undergoing final review prior to publication.
Upon release for publication, the data provided in this report will be incorporated,
time permitting, in the EIS.  In any case, this report and the information in question
will be available by Fall 1978.
          The quality of water entering the deep aquifer through connector wells
is actively monitored.  Regulations of the Southwest Florida Water Management
                                     4-45

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District OSWFWMD) concerning monitoring can effectively be applied depending
on the effectiveness of implementation and the full cooperation of Indus-try.
A surveillance monitoring program of radiation levels is probably a good
suggestion, particularly in areas of Sarasota and Manatee Counties where
radium-226 in ground water is already rather elevated relative to other areas
of Florida and relative to acceptable drinking water quality.  The problem will
be to bound the goal of monitoring to some manageable level in terms of
involved agencies, costs, etc.  It will also be necessary to focus the effort
to the most serious matters and for sufficient duration and intensity to produce
at least a statistically valid data base.
W-238
          Recognition of local, State, and Federal governments in the review,
permitting, and monitoring of mining activities is provided in Working Papers,
Volume II (NTIS, Vol. II).
W-239
          See response to Comment W-235.  The applicants with which EPA has dealt
to date have for the most part completed the DRI process.  For those that have
not, there would be every reason to proceed simultaneously, utilizing the same
original data for the DRI and EIS.  EPA has pursued the possibility of combining
the  two processes, and encountered certain problems.  For example, the third
party EIS process requires the consultant to be selected and paid by the
applicant, but approved by and directly responsible to EPA.  Industry has not
been amenable to paying a consultant to develop a DRI, while the consultant is
directly responsible to a government agency.  In any event, EPA is certainly willing
to do its share toward minimizing duplication of effort, by combining as much
original data gathering as possible, and assuring that this is done during
development of the Plans of Study.
W-240
          This is precisely true.  The legal basis provided by NEPA to develop
this EIS is indeed the federal permit system.  The NEW Source NPDES Permit
constitutes the Federal Action which is subject to NEPA,  Therefore, mitigation
of impacts must be implemented through the federal permit system.
                                      4-46

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W-241
          Text modified.
W-242 through W-254
          These comments, which are also part of the Bradenton Public Hearing
record, have been answered previously (_T~6 through T-17).
W-255
          Text modified.
W-256
          See response to Comments T-12 and T-54.  The water quality impact is
certainly both local and regional.
W-257
          The applicable requirements of the Surface Mining Control and
Reclamation Act and regulations should certainly be considered in the site-
specific EIS's, but we cannot legally require adoption of the coal mining
requirements through the EIS process.  The State of Florida has reclamation
requirements and an EIS must first evaluate effects of a mining plan meeting
existing requirements.  If mitigating measures are in order, Surface Mining Act
requirements which go beyond State requirements should then be considered.
W-258
          Refer to responses to Comments W-175 and W-177.
W-259
          These sections of the FWS report should indeed be a source of infor-
mation for persons preparing site-specific mining and reclamation plans that are
taylored to fit the proposed action.
W-260
          Refer to response to Comment number T-6.
          Detailed analysis of the pollution potential of any major new air
pollution source proposed by the phosphate industry (the projections in the EIS
includes none) will be required by the Federal Clean Air Act Amendments of 1977
(Federal Register, Volume 43, No. 118 - Monday, June 19, 1978).
                                     4-47

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W-261
          Data used by the DER indicate  that the inverse relationship  seems  to
extend as far back as 1967 (Volume VII,  Section 2/Volume III-NTIS).,  No  attempt
was made in the DEIS or the working papers to downplay the importance  of a
continuing monitoring program for vegetative fluoride levels.  To  the  contrary,
a vegetative fluoride monitoring program is recommended.
W-262
          Concur.
W-263
          Text modified.
W-264
          While this information is still not in the FEIS, it will be  included
in the Proposed Radiation Protection Recommendations to be published in  the
Federal Register this month.
W-265
          Existing data on radionuclide  concentrations in food associated with
reclaimed land will be provided in an upcoming EPA report. (See response to
Comment W-237)  Any specific impacts due the proximity of food crops or  cattle
on phosphate-related land would be evaluated in the site-specific  EIS.  Because
sufficient radiological pathway data is  lacking, it is not possible to deal with
the associated population impact in a quantitative manner.
W-266
          Text modified.
W-267
          Concur.  Text modified.
W-268 through W-272
          The commentor is correct in discerning that section 5 of the DEIS is
composed of generalizations.  The purpose was to remind the reader, in a
succinct manner, how the short-term use  of our physical environment (which must
necessarily include economic '"oranges'") compares to the maintenance  and
enhancement of long-term productivity of our physical environment  (environmental
'"apples'").  This generalized approach  is consistent with the recently  proposed
regulations by the Council on Environmental Quality, which it is assumed the
commentator referred to.  Those regulations state that the Council does  not
intend  that material such as contained in Section 5, be a duplication  of
                                     4-48

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material contained in other sections such as presented in sections 3 and  4  of
Volume I and Section 2 of Volume II of this FEIS.  Also, please refer to  the
response to Comment number W-208.
W-273
          Text modified to be specific as possible while maintaining flexibility
for future changes.
W-274
          The Federal Government does in effect adopt Florida Standards, and
include Florida Standards in NPDES Permit Conditions, in accordance with
Section 301(b)(l)(c) fo the Clean Water Act.
W-275
          Text modified.
W-276
          The commentor properly points out a limitation on mitigation of
disturbance of land by reclamation and preservation.  The action by the Federal
Government under evaluation by the EPA for this EIS is realted to issuance  (or
non-issuance) of air and/or water permits not whether to restrict (or not
restrict) land uses subsequent to mining.  Restrictive covenants administered by
State or Federal authority are one alternative for preserving the benefits of
preservation or reclamation of lands.  This issue is more properly addressed by
State, regional and local land planning authorities as it involves physical and
socioeconomic impacts beyond the phosphate industry.  It justified an impact
assessment as an integral part of a comprehensive environmental land use
planning program encompassing several alternative land uses.
W-277
          A standard practice used by EPA in regulatory development to achieve a
balance between the health effects controllable by a standard or guidance, and
the cost associated with achieving this control is termed a cost-benefit analysis.
Such an analysis is normally calculated over the projected term of the exposure
with consideration for "immediate economics" limited to those instances where the
                                     4-49

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soils and increase the rate of runoff.  La,kes. would act as impoundments  and
tend to .reduce runoff.
W-282
          The reduced water usage scenario was not chosen because of its effect
on runoff in the study area.  It was treated in more detail in a working paper
(Volume XI, Section 5/Volume VII-NTISl.
W-283
          Referring to the response to W-281, the flow changes due to the proposed
action are associated with rainfall events- which relate to high flow periods in
the Peace River.  The amount of the change will be slight relative to the river
flow at these times, and hence have little effect on the estuarine system.  The
changes which were projected to be noticeable by the year 2000 are not expected to
occur in the Peace River itself or its larger tributaries, but in the small
tributaries that might be quite seriously affected by local mining activity.
W-284
          The change in electrical demand attributable to the expansion of
phosphate mining to the south  while closing mines in the northern part of the
study area is insignificant, representing a very small change in the power generated
in the Tampa area.  That change in demand does not in itself provide justification
for  the FP&L De Soto plant or any other expansion of generating facilities in the
area.  The construction of a cooling lake to be filled from the Peace River will
require a detailed analysis to determine its effect on the river-harbor system,
but  is not within the scope of this study which is concerned with effects resulting
from phosphate industry activities.  (Also note W-278, T-5)
W-285
          The commentors concern for (waters of the U.S. and Wetlands) is shared
by the Federal government and thus the proposed action contains provisions for
protecting those resources (see Section 2 of this FEIS).
W-286
          These species are included among the important ones whose destiny brought
about the considerations of equivalent wildlife habitat and wetlands in the
proposed action.
                                       4-50

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W-287

        The commentors concern for (waters of the U.S. and wetlands) is shared

by the Federal government and thus  the proposed action contains provisions for

protecting those resources (see Section 2 of this FEIS).

W-288

        (Letter from Mr. Allen Jaeggi to Senator Chiles)

        Copy of response is reproduced below:

                         June  5,
 Honorable Laxton  Chiles
 Uaited States Senate
 Federal Building
 Lakeland, Florida  33301

 Dear Senator Chiles:

 T^27.x you for your  letter of May 17, 1973, transaitting the
 co&aeots of Mr. Alien  Jaeggi on the Draft Areawide Environ-
 Eeatal lapact Stateaent,  Central Florida Phosphate Industry.
 Mr. Jaeggi1s letter and responses to it will be included in
 tie Final EIS which is projected to be coapleted by July 31,
 but ve will coaaent on his letter at this tiae so you may
 reply-

 The Areawide EIS  offers a scenario of developaent of the
 phosphate industry  which  we feel stakes the industry as com-
 patible as practicable with other desired and intended land
 uses in Central Florida.   It is an areawide, ieneric EIS,
 and, as such, provides a  base line for required Environaental
 lapact Stateaents and  Development of Regional lapact State-
 Beats for new source Bines and chemical processing operations.
 These site specific studies would have been required with or
 without th<* Areawide EIS.  It provides areawide and cuaulative
 effects of the entire  Central Florida Industry which would not
 have been adequately covered in individual site specific studies

 Mr. Jaeggi's comnents  ia  paragraphs two through seven refer to
 the sunaary sheet in the  Preface of the Draft EIS.  He is
 correct in stating  in  paragraph two that other land uses also
 alter the surface,  and that soae of these aar have a more
 drastic effect on such things as wildlife habitat.  However,
 all or these other  uses combined do not approach the surface
 area altered per  year  by  phosphate raining in the seven county
 study arsa.    .is is not  to say that adverse effects of any
 of these uses should not  be rainiaized.  The areawide cI3 takes
 a-Jvinta^e of available technology, most of which was developed
 by the industry,  to ainiaize adverse effects of the phosphate
                                4-51

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industry while allowing continued industrial development.
Paragraphs three through seven of his letter refer to 3.B.
through 3.J. of the Suamary Sheet.  These effects indeed
occur, and t.ie extent to which they occur are detailed in
the EIS and the Working Papers.

Mr. Jaeggi's comments on the Proposed Action in the remainder
of the letter indicate that he believes decisions regarding
elimination of rock drying, eliaination of conventional above
ground slime ponds, protection of wildlife habitat, and
protection of wetlands should be left to the industry and
not to "^overnraental agencies regulating where they shouldn't.'
As stated, the Areawide EIS utilizes available technology to
minimize effects of an industry which raost Central Floridians
will tell you has not always been compatible with other land
uses.  Jeveral proposed new source mines with which we are
currently dealing have already agreed to iapleaent all of the
requirements in the Proposed Action.  There is one proposed
new source mine which wishes to dry rock for export, out
intends to meet all of the other requirements.  If this dryer
is allowed, the site specific study will doterraine methods
to minisize its effects.  We believe that these examples
demonstrate the industry's general willingness to aake itself
more compatible with other land uses in Central Florida.

'ir. Jaeggi's coanents, and others we are receiving on the
Draft EIS, are welcome.  ^e believe that revisions to be
incorporated into the Final EIS as a result of these comments
will make it a nuch more valuable document, not only to EPA,
but to other agencies, citizens of Central Florida, and to the
industry.

                               Sincerely yours,
                               -,' - -r_a j,  vvhica
                               John C. ',;hite
                               Regional Administrator


REMcNeill:ai:6/S/73
                               4-52

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W-289
          The FEIS format has been revised, and it is hoped the commentor finds
a clear and coherent identification and analysis of impacts.
W-290
          Statements on pp. 1.70 and 4.3 of DEIS have been revised, based on
comment from Secretary of Interior.
W-291
          This paragraph indicates a gross misinterpretation of the conclusions
of the DEIS.  Hopefully, Volume I and the responses in Volume III of the FEIS
will clarify the conclusions.  Responses to individual comments on each of the
issues mentioned in this paragraph follow.
W-292
          This comment has been addressed by revising the subject statement.
W-293
          Text modified.
W-294
          Mapping precise locations of slime ponds in the study area was beyond
the scope of this project.  Locating slime ponds is not a prerequisite to
stating a relationship between slime pond spills and negative effects on water-
based recreation.
          Slime pond placement in relation to watersheds in the study area was
carefully considered when stating a potential negative relationship with regard
to wastewater spills nad water-based recreation.
W-295
          Saltwater encroachment near the coast is a potential if one or a
combination of the following should occur:  1) if the potentiometric surface
near the coast were decreased toward sea level; 2) if the potentiometric
gradient near the coast were decreased causing a decrease in fresh water outflow
to the sea; or 3) if pumping of the groundwater supply near the coast became
extensive.  The third item would have the effect of generating a local depression
in the potentiometric surface.  The analyses performed in preparation of this
                                      4-53

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EIS indicates that present and projected phosphate industry water usage will not
in itself seriously affect the potentiometric surface or gradient near the coast.
In summary, the projected action seems to provide little impetus for the salt-
water encroachment that is feared by coastal water users.  Existing data do not
demonstrate encroachment of the salt front (other than locally due to excessive
pumping) due to recent changes in the potentiometric surface mapped by USGS;
changes which are a result of all aquifer users, not just the phosphate industry.
A study designed to characterize the location and movements of the salt-fresh
water interface would be desirable for th-se planning municipal water supplies
near the coast, but was beyond the scope of this areawide impact study.
          One other factor regarding the water usage projected for the phosphate
industry in response to the proposed action is that many areas proposed to be
mined are currently under irrigation for agricultural purposes.  In these areas
the use of the water would change, but the quantity used could increase, decrease,
or remain unchanged depending on the extent of existing agricultural pumpage.
This factor was not precisely simulated in the modeling analyses done by USGS for
this study, due to a lack of detailed data on agricultural water usage.
          The aquifer is recharged to various degrees in many portions of the
study area by surface recharge.  Water is also transported laterally from the
higher  areas inland toward the coast, but slowly.  The pumping by the phosphate
industry in response to the proposed action is not expected to further deteriorate
the water supply problem due to intercepting and cutting off the freshwater flow
from inland areas toward the coast.  The Floridan aquifer has historically been
of poor quality near the coast, and should not be materially affected by the
proposed and projected industry pumping (working papers Volume V, Section I/
Volume V-NTIS).
          Available data indicate upconing of mineralized water from underlying
areas of the aquifer will not be a problem in areas to be mined under the
proposed action.  This has been a problem in some areas due to abandoned or
improperly constructed wells.
                                       4-54

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          Most of the lakes in the Ridge area communicate with the surface water
table, and their level will fluctuate with the surface water table.  Those that
are fed by connections with the Floridan aquifer through sinkholes or springs
will be affected by changes in the potentiometric surface.  However, the changes
are generally reversable, and as the mining activity moves south,  the
potentiometric surface should recover in the Polk County Ridge area.
W-296
          Concur with this statement.
W-297
          The revised text, and responses to Comments T-54 and T-55, address this
comment.  "Water pollution control equipment" for phosphate mines consists of
earthen settling areas; and for chemical plants consists of chemical (lime)
feeders and earthen settling areas.
W-298
          The potential for extremely damaging pollution loading through failure
of a slime pond dike was certainly a major factor leading to the conclusions
reached in this EIS.  The Proposed Action will minimize this potential.
W-299
          Mapping of the study area was outside the possibilities of this effects
assessment.  Additional information on upland and wetlands habitats and their
significance is in working paper Volume XI.  In an effort to maintain an EIS of
reasonable length, effects and impacts were summarized - perhaps to the exclusion
of important points.  Selection of what to cover was difficult, and since the
wetlands situation apparently is of greatest import to Florida and is the
greatest extent of endangered lands to be mined, it is emphasized.  Equal "worst
case" impact was given to mining sandhills, sand pine scrub, and natural hammocks.
Definition of specific wildlife impacts was precluded by the inability to perform
field work.
W-300
          Similar conclusions were stated in this EIS.  A review of our effects
assessment (working paper Volume Xl/Volume VII-NTIS) will reveal several
references to the FWS report.
                                       4-55

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W-301
          We believe the wording of the FEIS is  clear in its  discussion of the
radiation hazards to human health.  Indoor radiation levels observed  in
structures built on phosphate-related  land indicate that external  gamma
radiation and radon decay product levels  are frequently higher  than normal
background.  In considering health risk estimates, the relative health  risk
associated with exposure to short-lived radon  decay products  is usually much
greater than the accompanying exposure to direct gamma radiation.  Although it
is desirable to minimize exposure to both components, the  reduction of  exposure
to radon decay products is of principal interest.
          With respect to radon release from gypsum piles  and slime disposal
areas, some very good points are raised.  Such point sources  are analogous to
uranium tailings piles, but there are  sharp differences in radium  (radon parent)
and moisture contents which in turn affect the radon release  per unit time.  NRC
is advocating soil  cover and other stabilization techniques to  reduce the  radon
release from uranium tailings piles to no more than twice  background.   Site-
specific studies must first determine  the release rates from  phosphate  piles,
compare these to background, and then  develop  stabilization requirements.
           The State of Florida is licensing uranium recovery  facilities (they
are  not classified  as mills) under Section 274 of the Atomic  Energy Act.   At
present, there is one operating, licensed facility, with two  licensed,  but not
operating.  Pursuant to the license issued, specific requirements  include  a
preoperational radiological survey, with  an annual resurvey,  continuous stack
monitoring, and individual occupational monitoring.  Further  details  are available
from Mr. Ben Warren (Licensing and Legislation Division, Radiological Health,
DHRS)  904-487-2437.
           As noted  in the DEIS (pp. 1.50  - 1.52), radon-222 and its decay  products
are  major  sources of exposure to occupants of  structures located on phosphate-
related landi.  For  individuals exposed occupatlonally in the  phosphate  industry,
radon-222  and its decay products are of less significance  due to various factors
including  ventilation and term of exposure, whereas, direct exposure  and radium
ingestion  become relatively more important.  Radon exhalation from phosphate
                                       4-56

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waste sites (gypsum piles, slime ponds, etc.) may be significant as a source
term, although the actual increased exposure due to elevated radon concen-
trations would likely be small in most cases for off-site residential occupants.
However, due to the possibility of exposure from these so-called "point
sources," the EPA is currently evaluating the need for regulatory action under
the authority of the Clean Air Act, as amended.
W-302
          The revision to reserve and resource data is appreciated.  The reader
must appreciate, though, that when projections as complexly interrelated as are
those made to make assessment of impacts of the alternatives herein considered,
groundrules must be set so as to be able to describe projected conditions.  If
the data submitted by the commentor were to replace the data used, it would
imply that data was part of the groundrules and then a basis for projections.
However, to make that implication true, a reanalysis and new projections are
required.  In summary, as any of the data bases are updated or refined, a
reexamination of the efficacy of the findings  and decisions documented in this
EIS is in order.  Such activities are the heart of the planning and implementation
process to which this EIS is to be a tool.  The tables offered by the commentor
are reproduced herein for the readers examination.
W-303
          See response to Comment W-384.
W-304
          Data supporting the quoted statement are provided.  The EPA report
"Population Radiation Dose Estimates from Phosphate Industry Air Particulate
Emissions" provides the data, which are utilized in the EIS and in response to
Comment 384.  As for problems encountered in transporting undried rock, these
problems have been overcome.  The Proposed Action allows an exception to be
made in cases where rock is shipped outside the State of Florida.  In such
cases, the site-specific EIS will determine control measures to resuce radio-
nuclide emissions to acceptable levels.  This will require more efficient
controls than those needed to meet existing requirements for particulate
emissions.
                                       4-57

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W-305
          The "dry conveyor" is not part of  the Proposed Action.  Methods  of
dewatering colloidal clays have been proven  at several mines other  than  Brewster.
W-306
          Wording of the Proposed Action allows recovery of phosphate  from slimes.
It does not categorically require combining  slimes  and tailings.
W-307
          Conclusions of the FEIS are  totally compatible with  subject  legislation.
Goals are apparently quite similar.
W-308
          A preliminary version of that USGS report which was  used  to  support  this
DEIS presented  information that led to the conclusion.  The open-file  report cited
does not contain any specific  conclusions with regard to the Sarasota  ground water
supply.
W-309
          To  the best of our knowledge, this statement is incorrect.   The  new
 source mines  in Manatee, Hardee, and DeSoto  Counties have proceeded on or  ahead
 of schedule  toward permit application  and environmental studies.  EPA  has  not
 been informed of any cancellation or delays  of plans for new mines  in  these areas
 because  of market conditions.
 W-310
          Along with the commentor's brief overview, the reader is  encouraged  to
 read working  papers Volumes  I  and II  (the NTIS version), and "Environmental Land
 Use  Planning," proceedings of  a seminar in Bartow,  Florida, July  27-28,  1977,
 published jointly by EPA and Texas Instruments Incorporated.
W-311
          The transcript of hearings,  and reproduced written comments  provided
 in this  volume should satisfy  this concern.
W-312
          Text modified.
                                        4-58

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W-313
          Text modified.
W-314
          Text modified.

W-315
          Text modified.

W-316
          See NTIS Volume II, for a description of State and local regulatory
authorities and responsibilities.

W-317
          The sampling problems were related primarily to the thermal degradation
of the sample collecting solution both during the actual sampling period, and
after sampling but prior to sample collection and processing.  The problems are
discussed in more detail in the working papers (Volume VII, Section 2/Volume III-
NTIS).

W-318
          Text modified.

W-319
          Text modified.

W-320
          Text modified.

W-321
          Text modified.

W-322
          Text modified.

W-323
          Text modified.
                                       4-59

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W-324
          The contamination from abandoned or uncased wells is a more apparent
potential impact to water quality than upconing due to inland pumping because
the former has been documented to occur.  The details of projected water demands
are shown in a working paper  (Volume V, Section I/Volume V-NTIS).

W-325
          The use of average  daily rates in terms of mgd allows the use of more
conveniently sized and recognizable numbers in tables.

W-326
          Text revised.

W-327
          Recovery of any material, radioactive or not, for a useful purpose is
certainly the most effective  method of pollution control

W-328
          It cannot be stated that these concentrations are unrelated to phosphate
occurence.  It can be stated  with a high degree of certainty, however, that they
are unrelated to phosphate mining and processing activities.  The text has been
revised.

W-329
          Text modified.
          The intended purpose of the table was to allow the reader to examine the
sources of income within the  study area.  The information used was from the
University of Florida and considered more appropriate for the purpose than infor-
mation from U. S. Department  of Commerce "County Business Patterns."

W-330
          Multipliers used were those estimated by the U. S. Bureau of Mines.
These were examined and tested by the Study Team economists and considered valid
for impact analysis.  BEA multipliers are more macro in nature.

W-331
          Text modified.
                                       4-60

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W-332
          The details of the use of connector wells on water quality are
discussed in Volume XI, Section 2/Volume VII-NTIS.  The potentiometric surface
map referred to is found in Volume V, Section I/Volume V-NTIS.

W-333
          Mapping of areas within the three categories of wetlands will be
possible when the Fish and Wildlife National Wetlands Inventory completes
wetlands mapping for the seven county study area.  Meanwhile, mapping will have
to be accomplished on a site-specific basis for each New Source EIS.

W-334
          See response to Comment W-56.

W-335
          Our data does not agree with the statement.

W-336
          See response to Comment W-305

W-337
          EPA has not redefined wetlands.  The categories are in order of
importance and need for protection.

W-338
          Text modified.

W-339
          The values discussed are based on an industry survey of water usage,
carried out by EPA in 1977 (Volume V, Section I/Volume V-NTIS).

W-340
          Slimes have certainly proved amenable to flocculation.

W-341
          This topic is discussed in more detail in working papers Volume XI,
Section 2/Volume VII-NTIS.
                                        4-61

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W-342
          This comment is quite inconsistent with Comments 1 through  8 on
page 4 of the first attachment to the Dept. of Interior comments.  As for  the
March, 1978 Fish and Wildlife Service report on  the Osceola National Forest,
we find much of the Summary and Conclusions to be in total disagreement with
the text.  It was not used for reference  in this EIS.

W-343
          Text modified.

W-344
          It would be desirable to project the changes in the aquifer system
as a result of all water demands as well  as being able to isolate the phosphate
industry contributions.

W-345
          Text modified.

W-346
          Text modified.

W-347
          Text modified.

W-348
          Text modified.

W-349
          Text modified.

W-350
          Text modified.

W-351
          Since the model runs available  prior to the preparation of the impact
statement were considered preliminary, it was felt that displaying such change
maps would create the false impression of a very accurate prediciton, as opposed
to the first approximation that they indeed represent.  Also refer to response to
Comment 348 from DOI.
                                        4-62

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W-352
          No comment on the first part of this comment.
          A study of the lake levels in the Ridge area that fluctuate with the
potentiometric surface of the Floridan aquifer was not done as part of
preparing this EIS.  In general, the movement of mining activity to the south
is expected to result in a decrease in the withdrawal rate in the Ridge area.

W-353
          Mitigative measures have been discussed in this EIS.
          Documentation of upconing due to pumping in inland regions of the study
area was not obtained in the existing data.

W-354
          "Unfortunately" seems appropriate.

W-355
          Text modified.

W-356
          Quantification of dislocation of the labor force and social costs of
unemployment was not considered feasible due to insufficient data on monetary
factors.

W-357
          Use of constant dollars over time is an accepted economic analysis
methodology.  Use of constant dollars allows for a more perceptive view of effects
without the distrotion or uncertainties of inflation being introduced.

W-358
          Text modified.

W-359
          Transfer of water to or from the surface water table would effect
changes in the potentiometric surface, but the extent of the changes is not
sufficiently documented to be quantified.
                                      4-63

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W-360
          Text modified.

W-361
          Refer to Volume XI, Section 2/Volume VII-NTIS.

W-362
          The statistics cited are based on  the U.S. Corps of Engineers' Four
River Basins Study.  The validity of these data are discussed in Volume XI,
Section 2 and 3/Volume VII-NTIS.
          Discussion of benefits of the lakes is not appropriate to this section.
The value of lakes is discussed elsewhere in this EIS.
          It is appropriate  to mention here  what might occur given different
regulations regarding reclamation.  The potential for prevention of loss of
wetlands is discussed in the "potential mitigation" measures section of this EIS.

W-363
          Refer to response  to response to Comments 353,  324.

W-364
          Refer to response  to Comment number 351.

W-365
          Text modified.

W-366
          Mention of problems near boundary  nodes was made in the DEIS.

W-367
          Text modified.

W-368
          Because of the small amount of timber involved, its loss, as a mineral
resource, due to  mining was  considered to be of negligible impact.

W-369
          The commentor is referred to Section 6, Volume  I of this FEIS.
                                        4-64

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W-370
          Text modified.

W-371 and W-372
          Refer to response to Comments 295 and 308.

W-373
          The changes referred to are comparing the simulated 1985 and  2000
potentiometric surface  to 1975.  See response to Comment 351 for reference
to the change map.

W-374
          The 10-foot decline predicted by the model does occur in a "thick"
area of the Floridan aquifer.  Also refer to response to Comment 295.

W-375
          The water quality in the Floridan aquifer is discussed under  "primary
effects."

W-376
          Refer to response to comment number 357.

W-377
          The commentor is correct in pointing out the, what we assume  to be,
economic considerations of scale and costs of extraction.

W-378
          Previous discussions have indicated that there would be little impact
on the quality or quantity of water in the Floridan aquifer due to the  proposed
action.

W-379
          The commentor,  and reader, are referred to figure 2.3, Section 2,
Volume II of this EIS, which shows that 98 percent of the estimated reserves
would be mined under the  proposed action by the year 2000.  Even a more liberal
estimate using the cumulative sum from mining operators projections (based on
land use data) and the 1978 revised reserve estimate (see response to Comment  302)
                                        4-65

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shows the depletion of reserves at 92 percent in the five  county area  reported
by the year 2000.

W-380
          Text modified.

W-381
          Text modified.

W-382
          Refer  to numerous  responses above  for wetlands definitions and  other
information on wetlands,  as  well  as  reference to the need  for  further  development
of criteria for  judging  their  relative  value.

W-383
          The purpose of this  EIS is not to  defend the Surface Mining  Control  &
Reclamation Act  of  1977-   We reiterate  that  while  the  Act  and  regulations published
to date apply primarily  to coal mining, there are  some provisions  which should  be
considered  to be applicable to phosphate mining.

W-384
           The rationale  for eliminating the  drying process in  the  Proposed Action
 (selected scenario)  are  as follows:

     1.  Technology has  been developed  within the  last few years whereby  wet rock
 can  be  acidulated with undiluted  commercial  grade  sulfuric acid.   This process
has  proven  to be economical, efficient, and  results in a significant decrease in
atmospheric emissions of particulates and radionuclides.   A typical rock  dryer
meeting EPA and  State air emission standards emits 60,000  kg (66 tons) of
                                             Q
particulate annually, which includes 27 x 10 pCi  (picocuries) of  radium  226,
        8                                8
27 x 10  pCi of  thorium  230, and  50  x 10  pCi of uranium.   Emissions of radio-
nuclides exceed  those allowed  by  NRC for a 1000 megawatt nuclear power plant by
greater than ten-fold.   In addition  to  stack emissions from the dryer, emissions
from transfer and transportation  of  the dryed rock from the dryer  to the  chemical
plant are equal  to  or greater  than those from the  dryer stack.
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     2.   Three chemical plants in Central Florida have converted to wet rock
acidulation on a full scale basis.  Two others are in planning or design stages
of conversion.  The trend indicates that all chemical plants in Central Florida
will convert to wet rock processing within the next few years.
     3.   We agree that environmental regulatory agencies cannot and should not
dictate  production processes.  However, in establishing emission limitations,
EPA is required to take into consideration technology and costs of control
equipment.  Emission limitations are always based on available equipment which
is economically achievable, while at the same time considering environmental
effects.  After emission limitations for phosphate rock dryers were established,
technology developed which allows elimination of the drying process for rock
chemically processed in Central Florida.  The Areawide EIS of necessity con-
sidered this new technology, and since the trend was toward wet rock processing,
the selected scenario of phosphate development which became the basis of the
Proposed Action and delineated effects, included this new technology.  The
Areawide EIS is not regulatory, but instead is the basis for initiating site-
specific EIS's.  However, any new source mines which deviate from conditions in
the Proposed Action will need to make a case for the deviation, and establish
areawide as well as site-specific effects.
     4.   The argument that the Areawide EIS should not have mixed energy con-
siderations with environmental considerations is unfounded.  The National
Environmental Policy Act specifically requires that consideration be given to
irreversible and irretrievable commitments of resources.  The site-specific EIS's
will also be required to consider commitment of resources, including energy
resources.  For this reason, when exceptions are made to the proposed action,
effects on resource depletion will have to be determined as well as environmental
effects.
     5.   Wording of the Proposed Action allows exceptions to the dryer elimination
condition.  The EPA Office of Radiation Programs has agreed to provide guidance on
allowable radionuclide emissions and exposure levels to be considered in site-specific
studies where the exception applies.  Effects on ambient particualte and fluoride
levels can be determined with modeling after applying the PSD requirements.
                                      4-67

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W-385
          The Florida Effluent Limitations are existing  requirements.   See
response to Comments T-53 and T-54.

W-386 through W-390
          Changes have been made in wording of the Proposed Action.  Each of
these comments have been addressed in other responses.   Suggested wording
provided in these comments would not result in meaningful bases for site-specific
studies.

W-391
          See response to Comment W-237.

W-392
          Beker Phosphate Co. has been determined to be  an "Existing Source,"
and thus is not a part of the Proposed Action.  However, since this company has
not initiated mining and beneficiation operation, new technology such as
elimination of conventional above-ground slime settling  areas would certainly
be feasible,

W-393
          Agree.

W-394
          Additional radiological samples have been taken in the Peace River
over the past year by the EPA Eastern Environmental Radiation Laboratory in
Montgomery.  As in previous sampling, the Peace River and other surface waters
in Central Florida have remained well below drinking water criteria for
radium  226 and other radionuclides.

W-395
          Slimes do contain a significant quantity of radionuclides
(45 picoCuries/gram on a dry weight basis).  During a slime loss or slime pond dam
break incidents, the river certainly exceeds drinking water criteria several fold
if samples are not filtered.  These radionuclides and other contaminents associated
with slimes are in insoluble form, however, and thus do not offer a significant
                                     4-68

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public health hazard.  If and when such water is used for potable supply,  it
is undoubtedly subject to filtration, and suspended solids are removed.  This
is not to say the concern expressed by Mr. Smith is not valid.  The industry
and regulatory agencies must continue to strive to prevent any future dam  breaks
or slime spills to the river.

W-396
          Sampling of sediments in the lower stretches of the Peace River  for
radiological analyses is needed.  It is probable that the slimes deposited in
the river and harbor in the past are not a problem because of subsequent
sedimentation and burial.  Because of this, and reasons listed in the previous
response, such sampling has not received a high priority.

W-397
          A report entitled "Florida Phosphate Land Evaluation Criteria," by
EPA Eastern Environmental Radiation Laboratory, is in draft form and will be
made available to Manatee County.  This report should answer Mr.  Bartle's
questions and concern.

W-398
          Revised Working Papers will be sent as required.

W-399
          See revised Working Papers Volume II.

W-400
          See section in Volume I, FEIS, on relationship between  site-specific
and the areawide EIS.

W-401
          See response to Comment W-384.

W-402
          Wording has been revised in Volume I, FEIS.

W-403
          See response to Comment T-54.
                                      4-69

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W-404
          There is sufficient precedent to assure wetlands contiguous  to waters
of the U. S. and the State of Florida can be protected.

W-405
          Determination of categories 1, 2, and 3 wetlands will be made on a
site-specific basis.

W-406
          This will certainly have to be considered in site-specific determinations.

W-407
          The wording in the DEIS was not intended to imply that wetlands
protected from phosphate development would not need to be protected from any
other type'pf development.  The need for protection or for restoration as a
wetland applies to any type of development.

W-408
          See response to Comment W-56.

W-4Q9
          The wording in Volume I, FEIS, is intended to result in recirculation
of non-process water to the maximum extent practicable for new sources.  The
recommendation for existing source chemical plants to also strive for maximum
recirculation of non-process water still stands.

W-410
          The FEIS contains sufficient caveat.  In a study of this type, data
are seldom  sufficient for proof of conclusions beyond any doubt.

W-411
          See response to Comment W-384.

W-412
          See response to Comments T-53 and T-54.  The State effluent limitations
take precedence in any case where State limitations are more stringent than those
of EPA.
                                      4-70

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W-413
          See response to Comment W-306.

W-414
          See response to Comments W-404 through W-407.

W-415
          Where fluoride recovery exists, the pond water fluoride concentration
is lower, and emissions of fluorine to the atmosphere are thus lower.

W-416
          See response to Comment T-55.

W-417
          See response to Comment W-384.

W-418
          We believe the conclusions reached in the study are sufficient to
support the Proposed Action.  Site-specific studies will be required to develop
further information needed prior to issuance of each new source permit.  See
response to Comments T-4 and T-5.

W-419
          We believe the FEIS is sufficiently flexible, and does require
individual site-specific EIS's for new source operations.

W-420
          The Proposed Action recognizes the need for an initial slimes holding
area, and holding capacity for excess clays.

W-421
          Such testimony was given both at the Public Hearings and in written
comments, and have been seriously considered.  The DEIS and Proposed Action have
been revised as a result of the testimony.

W-422
          See response to Comment W-384,
                                      4-71

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W-423
          See responses to Comments W-29, W-30, W-61 and W-97.  Wording of  the
Proposed Action allows flexibility in interpreting categories of wetlands.  For
example, if it is later shown that wetlands can be restored to perform pre-mining
functions, then those that are now Category I would become Category II.

W-424
          The Proposed Action purposely does not specify a method of sand/clay
mixing techniques, nor even what alternative use is to be made of the clays.  The
reason for not specifying a method is to encourage development of technology for
alternative uses of slimes.

W-425
          The alternative use of clay, such as sand/clay disposal, will certainly
have to be determined on a site-specific basis.

W-426
          The concerns in this letter have been addressed in the FEIS, and in
responses to other comments in this Volume.

W-427
          Text modified.

W-428
          See response to Comment W-430.

W-429
          The dry conveyor is not part of the proposed action.

W-430
          Response to Mr. Kelahan's letter to Senator Chiles is reproduced as
shown:
                                            4-72

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                       June 6,  1978
Hon. Lawton Chiles
Federal £iii!4ic£
Lakeland, Florida  55801

Dear Senator Chiles:

Thank you for your letter of May 10, 197S,  transmitting the
consents of Wr. Kichael E. Eelahan on the Draft Areawide
Environeenta.1 Impact Statement, Central Florida Phosphate
industry.   ir. Kelahan's letter and responses to it will be
included in the Final EIS which is projected to b« cocpleted
by July 51, but we will consent on his letter at this tisse
so you say reply.


The Areawide EIS offers a scenario of development of the
phosphate industry which we feel Bakes the industry as coc-
^atible as practicable with other desired and intended land
uses in Central Florida.  It is an areawide, generic EIS,
and, £s suca, provides a base line for required Environments!
lapact State&ents and Development of Regional Impact State-
ments for new source Bines and che&ical processing operations.
Vhese site specific studies would have been required with or
without the Areawide EIS.  It provides areawide -and cumulative
effects of the e&tire Central Florida Industry vhich would net
have been adequately covered iu individual site specific studies.

Of the four comments made in Mr. kelahan's letter, only the
one regarding elimination of slice ponds applies to the selected
scenario,  his other comments are on portions of scenarios
which are not included as part of the Proposed Action.  
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Temporary sliiaes settling and storage is allowed in cases
where the percentage of clays versus tailings is too high
for utilizing proven raethods of slimes-tailings reclamation.
Please refer to page 1.70 of the enclosed Draft EIS for the
Proposed Action, which constitutes the selected scenario.
The paragraph at the bottoa of page 1.70 and top of page 1.71
should relieve Mr. Kelahan's concern.

Mr. Kelahan's coaments, and others we are receiving on the
Draft EIS, are welcome.  .;'e believe that revisions to be
incorporated into the Final EIS as a result of these comments
will Bake it a much wore valuable document, not only to EPA,
but to other agencies, citizens of Central Florida, and to the
industry.

                             Sincerely yours,

                             /s/ John C. Whiter

                             John C. White
                             Regional Administrator
REMcNeill:rl:6/6/78
                                4-74

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W-431
          Text modified.

W-432
          Text modified.
W-433
          Text modified.

W-434
          See response to Comment W-409

W-435
          Text modified.

W-436
          Once per shift sampling is necessary to assure monitoring systems
remain calibrated, and are operating properly.  There have been several
incidents where acid spills occurred during periods when pH monitoring equip-
ment was not operating.

W-437
          See response to Comment W-384.

W-438
          Explicit support of local regulations and requirements are not
                                         \
necessary in this EIS.  One of the ground rules of the Plan of Study was that
all existing local, regional, State and Federal requirements would be part of
each scenario examined.  In most situations, local approval has been obtained
prior to the time initial application is made to EPA.

W-439
          Text modified.

W-440
          Text modified.
                                     4-75

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W-441
          Text  modified.

W-442
          Totally agree with these comments.

W-443
          Concur.

W-444
          Concur

W-445
          See response to Comment W-384.
                                         4-76
                            rtU.S. GOVERNMENT PRINTING OFFICE: 1979-61+1- 82ff 6271REGIONNO 4

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