FINAL
ENVIRONMENTAL IMPACT STATEMENT
NORTH DADE COUNTY
FLORIDA
CI20375
(g&j
ENVIRONMENTAL PROTECTION AGENCY
MK«ION IV
1421 PEACHTHCC (TNirT. N. E
ATLANTA, OCOKOIA
-------
FINAL ENVIRONMENTAL IMPACT STATEMENT
NORTH DADE COUNTY REGIONAL COLLECTION,
TREATMENT AND DISPOSAL SYSTEM
Project C120375
Prepared by
Environmental Protection Agency
Region IV
Atlanta, Georgia 30309
Approved by:
'WW* 9-13-73
//Regional Administrator Date
-------
TABLE OF CONTENTS
Summary 1
Introduction 6
I. Description of Proposed Action 8
A. Project Description 8
B. History 9
1. Enforcement Conference 9
2. State, Local and Other Federal Actions 18
3. Ocean Outfalls and Other Methods of Treated 21
Wastewater Disposal in Southeast Florida
C. Interrelationship with Other Projects 22
1. Central and Southern Flood Control Project 23
2. Existing Wastewater Systems 25
3. Proposed County Management Systems 26
4. Land Use 27
D. Physical Description 30
1. Physical Geography 30
2. Climate 30
3. Physiography 31
4. Natural Resources 33
5. Ground and Surface Waters 34
6. Existing Treatment Systems 39
7. Settlement Patterns 41
8. Water Quality 42
II. Environmental Impact of Proposed Facilities 44
A. Beneficial Impacts 44
B. Adverse Impacts 47
1. Land Resources 47
2. Water Resources 55
3. Air Resources 63
4. Socio-economic Resources 66
III. Adverse Impacts Which Cannot Be Avoided Should the 69
Project Be Implemented
A. Construction and Operation of Proposed Treatment 69
Facilities
B. Construction and Operation of Proposed Ocean Outfall 74
Disposal Facility
C. Construction and Operation of Proposed Collection 79
System
-------
Page_
IV. Alternatives 83
A. Wastewater Treatment 83
1. Secondary Treatment 87
2. Tertiary Treatment 88
3. Recommended System 91
B. Sludge Disposal 96
1. Application to Land Surface 99
2. Landfill 99
3. Ocean Disposal 100
4. Subsurface Disposal 100
5. Incineration 101
6. Miscellaneous Methods 102
7. Alternative Sites 103
C. Effluent Disposal 105
1. Capital Costs 112
2. Flexibility 113
3. Relative Recycle Potential 114
4. Compatibility with Present Construction Program 117
5. Feasibility of Initial Pollution Abatement 117
Program
6. Positive Community Development 118
7. Compatibility with Metropolitan Plan 119
8. Recommended Action 119
D. Alternative Management Plan 120
1. Reduced Plan 121
2. Initial West District Plant Plan 122
3. Expanded Central District Plant Plan 124
4. "Plan C" 126
5. AWT Plan 129
6. Tri-county System 132
E. Alternate Site Location 136
V. Relationship Between Local Short-term Uses of Man's 147
Environment and the Maintenance and Enhancement of
Long-term Productivity
VI. Irreversible Commitment of Resources Which Would Be 156
Involved in the Proposed Action
A. Land Resources 156
B. Offshore Reef 157
C. Construction Materials 157
D. Operation of the Treatment Facility 158
E. Discharge to the Ocean 159
VII. Public Comments 161
A. Response to Comments Made at Public Hearing 161
B. Response to Written Comments 171
-------
Page
References 202
Appendices 207
I. Summary Analysis of Ocean Outfalls and Other 208
Methods of Treated Wastewater Disposal in
Southeast Florida
II. Administrator's Decision Statement No. 5 223
III. Florida Law 865.06 - Preservation of Wild 232
Trees, Shrubs and Plants; Penalty
IV. Outfall Data 238
V. Interama Sewage Treatment Site Vegetation Survey 247
VI. St. Petersburg Wastewater Effluent Spray Irrigation 266
Project
VII. Written Comments 269
VIII. Public Hearing 320
IX. Projected Population Trends North Dade County 445
-------
FIGURES
No. Title Page
1 Proposed North Bade Wastewater Management System 12
2 Wastewater Collection Zone Map 13
3 Central and Southern Florida Flood Control 24
Project
4 Alternate Development Patterns 28
5 Wastewater Treatment Plant Flow Curves 29
6 Generalized Hydrogeologic Cross-section Along the 35
Tamiami Canal
7 Extent and Base of the Biscayne Aquifer 37
8 Site Plan, North Bade Treatment Plant 70
9 Northeast Dade Treatment Plant Location 138
10 Proposed Route of the North Dade Ocean Outfall 144
-------
TABLES
No. Title Page
1 Proposed Projects - North Bade 10
2 Summary of Water Balance 32
3 Elimination of Inland Wastewater Discharges, North 45
Dade Wastewater Management District
4 Management Alternatives Evaluated 84
5 Comparison of Treatment Alternatives 94
6 Disposal Alternatives 106
7 North Dade Alternate Wastewater Treatment Site 140
Comparison
8 Final Site Selection Criteria 143
9 Wastewater Disposal 154
-------
ACKNOWLEDGEMENTS
This Statement has drawn liberally from the texts of the
following published reports!
Environmental Assessment of the Interim Water Quality Manage-
ment Plan - Metropolitan Bade County Water and Sewer Authority,
September 1972, by Post, Buckley, Schuh & Jernigan, Inc., Miami,
Florida and Hazen and Sawyer, New York, New York.
Interim Water Quality Management Plan for Metropolitan Dade
County - Metropolitan Dade County Planning Department, June
1972, by Greeley and Hansen, Sanitary Engineers, Chicago,
Illinois and Connell Associates, Inc., Consulting Engineers,
Miami, Florida.
We also acknowledge the cooperation and assistance of the
Metropolitan Dade County Planning Department, Metropolitan Dade
County Water and Sewer Authority, and the following firms who have
provided information utilized in the text of this Statement.
Black and Veatch, Inc.
H. J. Ross Associates, Inc.
Post, Buckley, Schuh and Jernigan, Inc.
Connell Associates, Inc.
Greeley and Hansen, Sanitary Engineers
The following individuals are acknowledged as having participated
in the preparation of this environmental impact statement:
Mr. Charles W. Sever
Mr..James H. Sargent
Mr. Scott P. Berdine
Mr. John F. Hurlebaus
Mr. Richard C. Gingrich
Paul L. Wagner
Environmental Engineer
Water Quality Planning
Environmental Protection Agency
Region IV
-------
SUMMARY SHEET FOR ENVIRONMENTAL
IMPACT STATEMENT
NORTH DADE COUNTY
FLORIDA
( ) Draft
(X) Final
Environmental Protection Agency
Region IV, Atlanta, Ga. 30309
Administrative action (X)
Legislative action ( )
SUMMARY
The proposed project includes an 80 million gallons per day (mgd)
secondary treatment facility to be constructed at the Interama site
east of Biscayne Boulevard in two phases, with immediate construc-
tion of a 60 mgd phase, and major elements of an integrated
sewage collection system to be constructed in the northern portion
of Dade County over a period of three to five years.
The method of wastewater disposal will be via a 22,850-foot
long, 90-inch diameter ocean outfall traveling from the proposed
treatment plant site at Interama to a point approximately 500 feet
beyond the seaward reef, terminating in the Atlantic Ocean approximately
12,500 feet from shore in approximately 90 feet of water.
Sludge disposal will be accomplished through pumping of sepa-
rated solids in a closed conduit from Interama to an existing sludge
disposal area on Virginia Key for further treatment and disposal by
land application.
-------
These facilities have been designed as the initial construction
phase of the north Dade regional wastewater management system. The
system was proposed at the culmination of a two-year water quality
management study by the Metropolitan Dade County Planning Department,
jointly sponsored by Dade County- the Environmental Protection Agency
and the Department of Housing and Urban Development.
The Dade County system embodies a regional approach to water
quality management which will result in partitioning the county into
initially three, and eventually four, management areas. The ultimate
objective of this plan is to serve all waste sources within the
county, both domestic and industrial, with these regional collection
and treatment systems and to eliminate essentially all waste dis-
charges to surface, shallow ground and estuarine waters. The pro-
ject proposed in this environmental impact statement (EIS) is con-
sistent with the objectives of the management plan.
The project will result in some temporary minor detrimental
environmental impacts which will be incurred by the construction of
the system, but these should be of only short-term consequence.
Long-term adverse impacts may include minor damage to the ocean
bottom along the path of outfall construction, including : damage to
the offshore reef; minor chemical and biological degradation of the
ocean waters in the vicinity of the outfall terminus; possible
localized contamination of groundwaters in the vicinity of the
-------
sludge disposal site;, irretrievable commitment of potentially
recycleable wastewaters I disruption of the existing ecology of
portions of the Interama site; commitment of materials required in the
construction and operation of the facilities; and secondary environ-
mental effects which may arise as a result of the population settle-
ment patterns encouraged by the availability of the collection system.
These adverse impacts will be far outweighed by the beneficial
environmental effects which will result from the availability of
adequate sewage collection, treatment and disposal in north Dade
County. The beneficial impacts will include upgrading the surface
waters and estuarine waters of the region and protection of the
groundwater supply, reduction of the present public health risk,
and improvement of the recreation potential of all waters of north
Dade County.
The following Federal, State and local agencies and interested
citizens commented on the draft EIS:
Forrest W. Howell
Department of Housing and Urban Development
Sidney R. Caller
Department of Commerce
Col. Emmett C. Lee, Jr.
Corps of Engineers, Jacksonville District
Lawrence Lynn
Department of the Interior
H. E. Wallace
Florida Game and Fresh Water Fish Commission
-------
L. Ross Morrell
Bureau of Historic Sites and Properties
Garrett Sloan
Miami-Bade Water and Sewer Authority
Colin Morrissey
Metropolitan Bade County Pollution Control
Richard Brusuelas
Greater Miami Chamber of Commerce
Mrs. Anne Ackerman
"Pollution Revolution"
Dr. Hobart Feldman
Alert Citizens Tri-county Alliance
E. E. Maroney
Department of Administration
Donald P. Schiesswbhl
Department of Pollution Control
James G. Smith
Division of State Planning
William E. Austin
Soil Conservation Service
Frank J. Groschelle
Department of Health, Education and Welfare
B. E. Stultz, Commander
Office of the Oceanographer of the Navy
Frederick W. Honing
Forest Service
Bruce A. Bell
New York University
-------
The draft statement was made available to the Council on
Environmental Quality and the public on April 27, 1973. The final
statement was made available to the Council on Environmental Quality
and the public on October 9, 1973.
-------
INTRODUCTION
This environmental impact statement (EIS) has been prepared
pursuant to the National Environmental Policy Act (NEPA) of 1969,
which directs the responsible Federal agency to develop EIS's in
accordance with guidelines set forth by the President's Council on
Environmental Quality (CEQ) on all major actions which have a signi-
ficant impact on the quality of the human environment.
Under the statutory authority of the Federal Water Pollution
Control Act Amendments of 1972, the U.S. Environmental Protection
Agency (EPA) is charged with administering Federal financial assistance
for the construction of publicly owned wastewater treatment facili-
ties and their appurtenances. The EPA will also issue permits to
municipal governments to allow the discharge of treated wastewater
effluent into navigable waters in such a manner as to protect the
health and welfare of the public and the environment. The 1972
Act established a national goal of eliminating the discharge of
pollutants by 1985. In addition, "that wherever attainable, an
interim goal of water quality which provides for the protection and
propagation of fish, shellfish, and wildlife and provides for recrea-
tion in and on the water be achieved by July 1, 1983".
For purposes of this Environmental Impact Statement, EPA, Region
IV, Atlanta, Georgia, is the "Responsible Federal Agency" as required
by NEPA.
-------
This EIS is based on currently available data and infor-
mation. It is intended to determine methods of wastewater
treatment and disposal with maximum beneficial environmental
impacts consistent with water quality goals and cost effective-
ness .
Irrespective of prevailing statutory or regulatory actions
and impositions on wastewater treatment and disposal, NEPA man-
dates a full disclosure of all reasonable alternatives and their
identifiable environmental impacts. Alternatives for waste
disposal methods discussed in this EIS may fall outside the impli-
cit regulatory and enforcement authority of the Environmental
Protection Agency.
-------
I. DESCRIPTION OF PROPOSED ACTION
I.A. Project Description
The proposed project consists of an 80 million gallon per day
(mgd) secondary level sewage treatment plant which will be constructed
in two increments (a 60 mgd phase followed by a 20 mgd phase) to be
located in a portion of the Interama tract in northeast Dade County;
11 major sewer interceptor mains located in north Dade County, to be
constructed in incremental phases over the next three to five years;
and a treated wastewater disposal system utilizing a 22,850-foot long,
90-inch ocean outfall. The proposed 60 mgd capacity initial phase
construction of the North Dade Treatment Plant is based upon informa-
tion provided by the Miami-Dade Water and Sewer Authority and contained
in the final draft of the Dade County Water Quality Management Plan.
Sludge disposal facilities will include a force conduit from
the Interama site, south to the present sludge disposal area on
Virginia Key and a sludge digestion and land application system to
effect stabilization and drying of the sludge at the Virginia Key site.
The construction of the collection system and the treatment plant
will be phased over a period of years to insure efficient and timely
expenditure of funds.
The project is designed to eliminate several individual sewage
treatment facilities, many of which are producing violations of State-
Federal water quality standards in receiving waters or x^hich are
-------
discharging treated wastewaters which do not conform to State and Federal
effluent water quality standards. The project will also provide for the
elimination of a large proportion of the region's septic tanks and will
allow continued growth of population in north Dade County while pro-
tecting and enhancing water quality of the waters in, and adjacent to,
this area.
The proposed project is part of a comprehensive water quality
management plan developed for Dade County as a result of a two-year
study by the Metropolitan Dade County Planning Department. The
individual projects proposed in this statement are essential elements
of this management plan which has been approved by the Dade County
Commission and the State of Florida, Department of Pollution Control.
The individual elements of the proposed project are described in
Table 1 and are shown on the accompanying map (Figure 1).
I.E. History of Pollution Control in Dade County
I.B.I Enforcement Conference
On September 25, 1970, Secretary of the Interior, Walter B.
Hickel, at the request of Governor Claude R. Kirk, Jr., of Florida,
called a conference in the matter of pollution of the navigable
waters of Dade County, Florida, tributaries, embayments, and coastal
waters in accordance with Section 10 of the Federal Water Pollution
Control Act, as amended (33 U.S.C. 1151 et.seq.). The first session
was held October 20, 1970, in Miami, and the parties were the Florida
-------
Table 1
PROPOSED PROJECTS - NORTH BADE
Project Description
North Dade STP (Phase I)
North Dade Outfall*
North Miami Interceptor*
North Dade Interceptor
(Phase I)*
Sunny Isles Interceptor*
North Dade Interceptor
(Phase II)*
North Dade Interceptor
(Phase III)*
Hialeah Relief Interceptor*
Hialeah Connecting Main*
North Dade STP (Phase II)
El Portal Interceptor*
Andover STP Interceptor*
*-
North Central Dade Interceptor
North Dade Interceptor
Project no.
3a
1
32
8-1
2
8-2
8-3
29
6
3b
4
10
5
11
Zones Served
North Miami
102,111
105
101,205,209
207,210
203,204
211
109
206/p
321,107,208
110
Construction
Initiated
1974
1974
1974
1975
1975
1975
1975
1975
1975
1976
1976
1976
1976
1976
Cost ($Million)
37.50
14.92
.38
4.70
2.23
10.51
5.59
1.84
1.55
7.30
1.81
.87
3.68
1.68
initial i-iow
Collected (mgd)
30.0
4.1
2.0
7.2
3.4
7.4
9.1
3.5
.7
2.7
1.3
(Phase IV)
-------
Construction Initial Flow
Project Description Project no. Zones Served Initiated Cost ($Million) Collected (mgd)
Riverdale STP Interceptor* 9 206/p 1976 1.12 .7
Golden Isles Interceptor* 12 103,104 1976 4.04 1*5
Northwest Bade Interceptor* 7 201,202 1976 5.85 2.2
Note: * Includes cost of pump stations
-------
Figure 1
PROPOSED NORTH DADE
WASTEWATER MANAGEMENT
-------
Figure 2
GREELEY AND HANSEN
CONNELL ASSOCIATES
ENGINEERS
13
DADE COUNTY, FLORIDA
WASTEWATER COLLECTION
ZONE MAP
-------
Department of Air and Water Pollution Control and the U.S. Depart-
ment of the Interior, Federal Water Quality Administration.
The Federal report at this first conference concluded that the
canals of Dade County, including those in what we now describe as
the North Dade Region, were grossly polluted and in violation of
the Dade County and the Federally-adopted State of Florida water
quality standards; that septic tanks were a public health hazard
and contribute to over-enrichment and algae nuisances in adjacent
waterways; that small package treatment units constitute a potentially
significant source of organic and bacterial pollution; that present
methods for disposal through ocean outfalls without treatment require
modification because of public health hazards and detrimental effects
on water quality and that the major cause of poor water quality in
Dade County was inadequately treated municipal sewage effluent.
Based on this evidence and a great deal of additional testimony
from State and local officials and other interested parties, the
conferees concluded that pollution which endangers the health and
welfare of Dade County residents was occurring, and that measures
taken to abate this pollution were inadequate.
14
-------
The conferees recommended that the Metropolitan Dade County
Commission present, by November 1, 1971, a master plan for abatement
of pollution from all sources in Dade County. The plan was to be in
a form acceptable for certification under applicable State and
Federal laws and regulations, and was to contain sufficient detail
so that all significant sources would be identified. It was to
include a time schedule for construction of remedial facilities, with
interim dates for arrangement of financing, preparation of prelimi-
nary plans and specifications, preparation of final plans and speci-
fications, award of contracts, and initiation and operation of
such facilities.
The conferees also recommended: cessation of all waste dis-
charges into the inland canal system of Dade County not later than
January 1, 1973; providing a minimum of secondary treatment (90%
BOD removal and year-round chlorination) for all ocean discharges
not later than January 1, 1974; that all new construction be
connected to adequate sewage collection and treatment systems; and
that the Metropolitan Dade Commission be prepared to discuss an
action plan for controlling additional sources of pollution
15
-------
during the design and construction period of the pollution abate-
ment program, including particularly a program for the elimination
of septic tanks in all urban areas of the county. They further
recommended the prohibition of additional waste discharges to
lower Biscayne Bay and its tributaries and canals draining to
the Everglades. Removal of existing discharges from these waters
was to be accomplished as rapidly as possible, but not later than
January 1, 1974.
As a result of recommendation No. 4 of the first session,
requiring the Metropolitan Bade County Commission to prepare and
present to the conferees by November 1, 1971, a master plan for
abatement of pollution from all sources in Dade County, the county
applied for a planning grant under Section 3(c) of the Federal
Water Pollution Control Act in February 1971.
At the second and third sessions it became evident, as a
result of the on-going Industrial Waste Inventory, prepared by
the Lower Florida Estuary Study and the Surveillance and Analysis
Division of EPA, and completed in September, 1971, that industrial
16
-------
wastes were a larger part of the pollution problem In Bade County
than had first been estimated.
At the second session, February 18-19, 1971, the conferees
noted that the county's interim report (consisting of a Supple-
ment to the 1961 master plan) on the development of an updated
master plan indicated general progress. They called for a further
interim progress report in April 1971.
An "Amendment Supplement to the 1961 master plan" was pre-
sented to the conferees' at the third session of the conference,
July 2-3, 1971. It set forth the concept of three regional waste-
water treatment and collection systems, one of which would be
located at the Interama site in north Dade County.
The conferees found Dade County's amended interim regional
plan acceptable in principle as a first step in the development
of the master plan called for at the first conference, but lacking
an adequate time schedule for construction, arrangements for fi-
nancing, and consideration of water reuse. These shortcomings
were addressed in the county's final submission of the "Interim
Water Quality Management Plan for Metropolitan Dade County,"
published June 25, 1972, and subsequently approved by the County
Commissioners, and the Florida Department of Pollution Control.
This plan was structured largely around the conclusions and rec-
commendations of the three conference sessions.
17
-------
I.E.2 State, Local, and Other Federal Actions
Shortly after the first conference session, the Rules of
the Florida Department of Pollution Control were amended to re-
quire 90% removal efficiency for BOD^ and year-round chlorination
for all discharges from municipal and privately-owned domestic
waste treatment plants not later than January 1, 1973. Those
plants discharging sanitary sewage through ocean outfalls or
disposal wells must achieve that standard by January 3, 1974
(Chapter 17-3). This standard was required by the conferees
and has guided planning and enforcement efforts since that time.
There has been no significant planning effort on either
the State or local level for approximately 10 years before the
first Enforcement Conference. The explosive growth of Dade
County has resulted in a proliferation of subdivisions either
on septic tanks or sewered by small package plants discharging
to the canal system. As a result of conference recommendations,
planning became imperative and the County Commission entered into
an agreement in November 1970 with Greeley & Hanson-Connell
Associates, a joint venture, to prepare an updated master plan.
After several attempts at amending the 1961 master plan, the
consultants essentially rewrote the plan and the final result
was the "Interim Water Quality Management Plan," referred to
hereinabove, which was deemed acceptable by EPA.
18
-------
Although pollution control enforcement in Bade County had a
better record than the planning effort, there was much poor
performance of that function prior to the initiation of the Enforce-
ment Conference. At the first session of the Conference and at
each succeeding session thereafter Federal reports were presented
(see Proceedings, First, Second & Third Sessions) analyzing the
efficiency of approximately 76 major and minor municipal waste
treatment plants. As of June 1971, only 16 of these plants were
achieving the 90% removal efficiency required by State regulations
(Chapter 17-3) for BOD5 and total suspended solids (TSS). As a
result of these reports, Bade County Pollution Control became
considerably more active in the inspection and prosecution of
of violating sewage treatment plants (see Tables, pp. 1-18-19
Interim Water Quality Management Plan). As a result of this
activity, 15 small and medium-sized sewage treatment plants were
closed, three existing plants expanded, and 21 new plants with
advanced waste treatment were approved. Generally, all plants were
brought up to or near the 90% removal efficiency for BOD5 and TSS.
In addition, Bade County Pollution Control, pursuant to
Conference recommendations relative to septic tanks, imposed building
permit holds on at least seven municipal waste treatment plants for
problems associated with hydraulic overloading or poor operation
and maintenance (see Table 1-18, IWQMP).
-------
Also at each session, Federal reports were presented outlining
the progress of a comprehensive "Industrial Waste Inventory" completed
in September 1971. This report (EPA, SEWL, September 1971) analyzed
36 industries not connected to sewers, 21 discharging to groundwater
by various means, and 15 discharging to surface waters. The report
concluded that industrial wastes were contaminating the inland
waters of Dade County by the addition of oxygen-demanding materials,
petroleum derivatives, coliform bacteria, and toxic substances; that
the industries sampled contributed over half the BOD load discharged
to inland Dade County waters; that pretreatment would be required of
most industries to meet Dade County treatment requirements; that in-
plant changes, recycling and improved housekeeping techniques would
substantially reduce waste discharges; and that a health hazard
was presented by 11 food processing and paper mill industries
discharging inadequately disinfected wastes.
As a result of these reports, Dade County Pollution Control
increased its industrial waste enforcement activities significantly.
By November 1971, Dade County Pollution Control had taken action
against several of the industries listed in the report and only 13
of the original list were still considered a problem.
Pursuant to repeated recommendations of the conferees relating
to the elimination of septic tanks and the control of new septic
tank installations, Dade County Pollution Control proposed a study
to analyze the effects of septic tank effluent on the quality and
quantity of groundwater. This study was initiated in August 1971
20
-------
as a cooperative effort between Pollution Control and the U. S.
Geological Survey. A thorough discussion of the data generated
by this report and the ramifications thereof may be found in the
EIS on Ocean Outfalls and Other Methods of Treated Wastewater
Disposal in Southeast Florida.
Finally, EPA has had some enforcement involvement in
Bade County in addition to the Enforcement Conference. Thirteen
companies were investigated and three were referred to the local
U. S. Attorney for prosecution under the Refuse Act in March and
May 1972. Through the efforts of Bade County Pollution Control,
however, these companies came into compliance and the need for
prosecution was obviated. In addition, the U. S. Attorney
initiated three other cases in cooperation with Pollution Control,
obtaining two convictions for violations of the Refuse Act.
I.E.3. Ocean Outfalls and Other Methods of Treated Wastewater
Bisposal in Southeast Florida
In March 1973 Region IV of the Environmental Protection Agency
published a final environmental impact statement entitled: Ocean
Outfalls and Other Methods of Treated Wastewater Bisposal in
Southeast Florida.* This statement was prepared to consider the
environmental impact of a variety of treatment and disposal techniques
which have been shown to have feasibility in the three-county (Palm
Beach, Broward, and Bade) southeast Florida coastal region. Because
of the similarity in geography, physiography, geology, and hydrology
of the region, the fundamental advantages and disadvantages of each
*Short title - Uast-ptjafpr Disposal Methods will be used throughout
this statement.
21
-------
treatment-disposal technique were evaluated in a general fashion
for application in the three-county region without regard to specific
management needs and limitations which might be dictated by local
conditions. This impact statement should be considered Appendix I.
to the North Bade Impact Statement. However, due to its volume,
only the "Summary Analysis" has been attached in Appendix I.
The Wastewater Disposal Methods impact statement indicates
that. . ."Despite the outward similarities of the three-county area,
enough differences exist to indicate that different disposal methods
or combinations thereof may be desirable. Each effluent disposal
system will be evaluated individually, taking into consideration
the findings of this EIS." The North Dade Environmental Impact
Statement, therefore, will focus upon the specific wastewater manage-
ment needs of the north Dade region and will examine treatment-
disposal alternatives found to be most desirable by the 'Wastewater
Disposal Methods impact statement.
I.C. Inter-relationship with Other Projects
Many agencies of the Federal government, the State of Florida,
Dade County, and cities within Dade County have participated in
programs designed to manage the quality and quantity of resources of
the region. These activities have had a significant impact on the
development of current wastewater management plans in north Dade
County, and have influenced the selection of the proposed construction
program.
22
-------
I.C.I Central and Southern Flood Control Project
One of the most extensive resource management programs in the
region is the Central and Southern Florida Elood Control Project,
constructed by the United States Army Corps of Engineers during
the past 30 years. The Corps is directly responsible for
planning, design, construction, and, in certain cases, operation of
this elaborate system of canals covering an 18-county region of
southeast Florida. Figure 3 shows major elements of the project.
Although the Central and Southern Florida Flood Control Project was
initially envisioned to provide only flood control benefits, the
project has produced benefits in water conservation, saltwater
intrusion control, water supply (both agricultural and domestic),
and recreation.
The operation of flood control structures and pumping sys-
tems has totally modified the natural flow regimen of the region's
surface waters and has significantly modified their assimilative
capacity. The slow movement of waters in the canal system, and
\the minimal opportunity for effective reaeration of these waters
extremely limit the capacity of the canals to accept wastes with-
out violation of water quality standards. It might be possible to
operate the system so as to improve the assimilative capacity of
the canals for treated wastes, such as by augementing flows dur-
ing drought periods, but this would conflict with other objectives,
notably that of water conservation. Hence, it has become the goal
23
-------
Figure 3
LEGEND
COMPLETED OR
UNDER CONSTRUCTION
REMAINDER OF PROJECT
CANA'.
LEVEE
EXISTING LEVEE
TO BE ENLARGED
LEVEE WITH HIGHWAY
ON CROWN
PUMPING STATION
CULVERT
SPILLWAY
SPILLWAY WITH
NAVIGATION LOCK
EXISTING LOCK 8 DAM.
SPILLWAY TO 8E ENLARGED
LOCK. DAM. 8 SPILLWAY
EXISTING HURRICANE GATE
TO BE MODIFIED
EXISTING LOCK
CENTRAL 8 SOUTHERN FLA
FLOOD CONTROL DISTRICT
BOUNDARY
24
CENTRAL AND SOUTHERN FLORIDA
FLOOD CONTROL PROJECT
-------
of Dade County and the Central and Southern Flood Control District
to reduce to the maximum extent practicable all waste discharges to
the canal system.
I.C. 2 Existing Wastewater Collection and Treatment Systems
A considerable proportion of north Dade County presently
receives sewerage service, and essentially all wastewaters collected
in this region receive some degree of treatment. The objective of
the proposed plan is to consolidate these separate collection and
treatment systems to produce greater economy and efficiency of
operation and to insure maintenance of acceptable water quality
standards. The proposed project is designed to supplement and
interconnect existing sewerage facilities rather than replacing them,
thereby reducing both the economic and environmental impact of
regionalizing the system. For example, existing treatment plants
will be converted to pumping stations which will direct waste-
water flows to the proposed North Dade Regional Treatment Plant.
Interceptor mains will be retained in operation, and sewage flows
will be directed through supplemental interceptors when existing
sewers reach full capacity. The majority of the interceptors in-
stalled are force mains and therefore will have maximum flexibility
in meeting future management needs.
25
-------
I.C.3 Proposed County Management System
The north Bade regional management plan is one element of a
fully integrated, countywide water quality management program. The
interim plan was developed in 1972 by the Metropolitan Dade County
Planning Department and was being finalized at the time of the
writing of this Statement.
The plan calls for immediate construction of an 80 mgd treat-
ment facility in north Dade County with a 1976 inflow of approxi-
mately 60 mgd. With consolidation of individual systems into the
regional system, and with population growth in the service area,
it is estimated the treatment plant will reach its full 80 mgd
capacity by the year 1985. At this date, the county plans to change
the direction of flow in some of the main interceptors in the western
portion of the service area, and redirect approximately 15 mgd out
of the North Dade District to the proposed West Dade District. This
flexibility is possible since interceptor mains are being sized to
carry this projected flow, and pumps are being strategically located
to conform to both present and future needs. Once this volume is
diverted away from the north Dade regional facility, the unused
plant capacity will be made available for growth in the north Dade
service area until about the year 2000, when the 80 mgd capacity of
the plant will again be reached. (See Figure 5)
The plan proposed for Dade County has provided for maximum
flexibility for future options. Some of the future configurations
-------
for regional management which are compatible with the proposed north
Bade management plan are shown in Figure 4. The plan provides for
future reclamation of at least part of north Dade's wastewater flow,
should the county's water demand exceed available supplies, and
should treatment technology progress to the point that dependable
reclamation and reuse become economically feasible.
I.C.4 Land Use
The proposed projects will affect a wide variety of decisions
regarding public investment in highway construction, public housing
construction, recreational open space procurement and development,
school construction, etc. Their primary effect will be to channel
growth into areas which have been designated growth centers and to
discourage the blighting effects of over-saturation and "urban
sprawl." The resulting population distribution will in turn have
a significant impact on local, State and Federal investments
designed to provide community services.
In 1965, Dade County adopted a land use plan (General Land Use
Metropolitan Plan) delineating projected areas of residential,
commercial, industrial, and public land use. This plan has been
updated continuously to reflect changes in planning perspective
since 1965, and a new plan is being readied for publication later
this year. The proposed projects have been designed to conform
with projections based on the land use plan and should complement
its overall objectives. This should minimize the possibility of
27
-------
Figure 4
D2
1985-2000
Gl
1975-1985
1985-2000
E3
1985-2000
1985-2000
GREELEY AND HANSEN
CONNELL ASSOCIATES
ENGINEERS
DADE COUNTY, FLORIDA
ALTERNATE DEVELOPMENT
28 PATTERNS
-------
Figure 5
O
O
I
O
_J
u.
100
140
120
100
80
60
VIRGINIA
KEY
1970
LEGEND
PLANT CAPACITY
ESTIMATED FLOW
GREELEY AND HANSEN
CONNELL ASSOCIATES
ENGINEERS
1980
1990
2000
YEAR
DADE COUNTY, FLORIDA
WASTEWATER TREATMENT PLANT
29 FLOW CURVES
-------
expending public funds to promote or support competing community
development objectives, as well as ensuring efficient and timely
expenditure of public funds.
I. D. Physical Description
I. D. 1. Physical Geography
Bade County lies at the southeastern tip of Florida and is
bounded on the north by Broward County and on the west by Collier
and Monroe Counties. It covers an area of approximately 2,350
square miles, about 350 of which are covered by water. Development
is currently precluded in about one-half of the land area since
650 square miles, part of the Everglades National Park, and 350 square
miles, part of Water Conservation Area 3, are owned or leased by the
Federal government or the State of Florida.
The North Service Area, which is roughly the northeastern part
of the county, is the most densely populated. The proposed boundaries
of this service area include about 10 percent of the total land area
in Dade County.
I. D. 2 Climate
Dade County's climate is subtropical with temperature variations
around an annual 75°F average of 828F in summer and 68°F in winter.
Relative humidity averages about 70 percent, and winds are light
to moderate except during thunderstorms and hurricanes, which also
strongly affect rainfall distribution. Rainfall averages about 59
inches per year and ranges from approximately 40 to 85 inches. Since
30
-------
1940, five droughts have occurred when annual rainfall was 45 inches
or less. About 20 inches of annual average rainfall (about 34 percent)
never reaches the water table, but evaporates or runs off as surface
drainage. Light rainshowers of short duration are largely lost to
the water table in this manner. Heavier and more sustained rainfall
is the largest contributor to groundwater recharge. Of the 39 inches
of rainfall reaching the water table, about 15 are discharged to salt-
water bodies - either the bay or ocean through the canal system; an
additional three inches returns as consumptive water use; five inches
are seepage losses; and the remaining 16 inches of average rainfall
are assumed to re-enter the cycle through agricultural irrigation,
evapotranspiration, and uses from privately operated wells.
Table 2 also shows the equivalent flows in mgd of the inches
of rainfall.
I. D. 3. Physiography
The county's topography is flat with low elevations except for
a relatively higher ridge along the coast (Atlantic Coastal Ridge).
Most of the present development is in this ridge area since some of
the remainder of the county is periodically inundated. The coastal
ridge, roughly five to ten miles wide, varies in elevation from
eight to a little over 20 feet and lies close to the shore in the
northern part of the county. From there it fans out to the southwest.
The ridge is cut frequently by natural and man-made drainage systems.
31
-------
Table 2
SUMMARY OF WATER BALANCE
Equivalent
Inches iFj.ow
Average Rainfall 59 3,240 mgd
Evaporated before
reaching water table -19 -1,040
Surface runoff -1 - 60
Reaching water table 39 2,140 mgd
Groundwater discharged to
Bay and Ocean via canals -15 - 820 mgd
Consumptive water uses
including sewage discharged
to sea - 3 - 165
Seepage losses - 5 - 275
Irrigation, evapotrans-
piration, and private wells -16 - 880
Balance 0 0 mgd
Source: Interim Water Quality Management Plan for
Metropolitan Dade County
32
-------
Bade County has an extensive system of canals which provide
drainage for the developed areas. The main canal systems in the
North Service Area include the Snake Creek Canal, the Biscayne Canal
and the Little River Canal. The Miami River Canal lies on the area's
western boundary.
I.D.4 Natural Resources
The most important natural resource of north Bade County is
its climate, which makes the area a major tourist, retirement and
recreation center for the nation. The comparatively mild winters,
permitting outdoor recreation throughout the year, are an important
attraction for tourists and occasional residents. Agricultural land,
though declining in total acreage, remains an important resource.
The Everglades Park is a major factor in the hydrologic cycle of
Dade County and is nationally known as a unique tourist attraction.
The water resources, particularly the coastal waters of the
north Dade area, represent an important natural resource of the
region. The beaches of this area attract a large tourist population
each year; and fishing, both commercial and sport, is the basis for
one of the most important industries in the area.
The coastal waters in the vicinity of the proposed project support a
diverse aquatic community. Some of the most important pelagic
species include the reef fish, such as snapper, grouper and yellowtail-
and a variety of migratory fish species, including sailfish, tarpon,
marlin (both blue and white), tuna, mackeral, kingfish, pompano, blurfish
33
-------
and mullet. The spiney lobster is also a species native to
this region.
Although detailed studies of benthic animals in the project area
have not yet been completed, studies in the coastal waters adjacent
to Broward County probably provide a fairly accurate description of
conditions in the north Dade area. These studies indicate a predomi-
nance of alcyonarians, gorgonians, sponges, stoney corals and sea
urchins. In general, the coastal waters adjacent to northern Dade
County are considered to be of good quality and support a high quality
fishery of significant economic as well as ecological value.
I.D.5 Ground and Surface Waters
A generalized hydrogeologic cross-section along the Tamiami Canal
is shown in Figure 6. The groundwater resources consist of the extremely
productive Biscayne Aquifer overlying the confined Floridan Aquifer.
The Biscayne Aquifer is composed mostly of limestone and sand and
has a generally high porosity. It responds quickly to slight differ-
ences in the water table, producing the following results:
• The water table is relatively flat
• The yields of wells are large
• The ground and surface water regions have an uncommonly
high interrelationship
• The water table reacts quickly to rainfall. There is a high
rate of rainfall penetration and surface water infiltration
with relatively little runoff as compared with other locales
34
-------
COASTAL RIDGE—\
WATER TABLE-
ATLANTIC OCEAN
-BISCAYNE BAY
ANy
y /
O m
O UJ
55
O Q
FLORIDAN AQUICLUDE
I— 1500
GREELEY AND HANSEN
CONNELL ASSOCIATES
ENGINEERS
DADE COUNTY, FLORIDA
GENERALIZED HYDROGEOLOGIC
CROSS-SECTION ALONG
THE TAMIAMI CANAL
-------
The coastal areas, which are exposed to Biscayne Bay and
the Atlantic Ocean, are highly susceptible to saltwater
intrusion.
The Biscayne Aquifer is wedge- shaped with depth varying from
about zero near the western border of the county to between 100 and
200 feet along Biscayne Bay. The water table, which is close to sea
level, generally resides in the Miami oolite, a porous limestone which
forms the top "crust" of the aquifer. The extent and base of this
aquifer are shown in Figure 7.
The Floridan Aquifer is about 2,300 feet thick, the upper part
of which is from 800 to 1900 feet below sea level. The lower part,
referred to as the boulder zone, begins about 1200 feet below sea
level. The two parts are separated by an impermeable formation. This
aquifer is recharged in an area about 200 miles northwest of the
county.
The water resources of Dade County are integrally related with
Lake Okeechobee on the north and the Everglades on the west. Initial
water management efforts, primarily for reclamation and flood control,
tended at times to overdrain the Everglades and the Biscayne Aquifer.
A lack of control on canal water discharge during dry periods allowed
the water table to lower, increasing saltwater intrusion along the
coast. Some municipal water supplies were jeopardized by salt con-
tamination by the late 1930's. The county has constructed salinity
36
-------
D A//D/E!/ ^
LEGEND
WELL USED IN DRAWING CONTOURS
CONTOUR LINtS REPRESENT
APPROXIMATELY THE BASE.
OF THE BISCAYNE AQUIFER
IN FEET 8ELOW SEA LEVEL
CONTOUR INTERVAL 10 FEET
AFTER SCHROEDER, KLEIN ft
HOY, USGS-1958
UPDATED BY ADDITIONAL
INFORMATION
DADE COUNTY, FLORIDA
GREELEY AND HANSEN
CONNELL ASSOCIATES
ENGINEERS
37
EXTENT AND BASE OF
THE BISCAYNE AQUIFER
-------
control dams for use during dry periods while allowing wet period
excessive flows to pass out to sea.
The availability of water to satisfy future demands in Bade
County represents a major water resource problem. Present water
use in the county is approximately 400 million gallons per day (mgd)
This demand is projected to increase to 670 mgd by 1990 and 780 mgd
by the year 2000. Water shortages have already begun to occur, and
unless additional resources can be made available within the next
decade, these shortages will likely become more frequent and more
critical. It is apparent that these shortages are not the result of
a lack of adequate water supply, but rather a lack of ability to
effectively manage available resources to get water to where it can
be used.
Several alternatives have been proposed to more effectively
manage the existing water supply in Bade County. These include:
• Backpumping of canal waters at points west of presently
populated regions to the water conservation areas in the
western portion of the county to increase the yield of the
Biscayne Aquifer;
• Injection of storm water to the upper zone of the Floridan
Aquifer for recovery and reuse during periods'of drought;
• Besalinization of sea water; and
• Recycling of wastewaters after advanced waste treatment.
38
-------
The desalinization proposal would require tremendous financial
investments and would be appropriate only if no other alternative
could be employed. Wastewater reclamation is still unproven on a
scale required in Bade County and must be approached cautiously,
although any proposal for wastewater disposal in the county should
provide options for future reclamation and reuse of wastewaters to
supplement existing freshwater supplies. Injection of storm water,
while apparently a feasible approach, has not yet been proven to be
a practical water management technique. The least expensive and most
attractive proposal is the backpumping scheme. However, more exten-
sive studies must be performed to identify the environmental impact
of this alternative.
The prudent approach would appear to be to proceed with ongoing
research and development programs and to provide maximum flexibility
to meet future water demands which will be compatible with present
water resource and water quality management objectives.
I.D.6. Existing Treatment Systems
Approximately 98 wastewater treatment installations are currently
operating in Bade County and are classified as either major or minor
systems, with the division being made at a plant capacity of approxi-
mately 0.15 mgd. Of these wastewater treatment plants, 28 are con-
sidered major systems serving an estimated 800,000 persons, or
roughtly 60 percent of the total county population. Seventeen of the
39
-------
2$ major treatment facilities are privately owned and the remaining
11 are owned by city, county or Federal governmental units.
The 70 minor wastewater disposal systems served a combined
population of about 23,000 in 1971 and have a total capacity of
approximately 2.30 mgd. Of the total, 56 are privately owned, nine
Federally owned, three municipally owned, and two county owned. A
majority of these plants serve single installations such as shopping
centers, industrial plants, or recreational areas.
Countywide treatment facilities have an installed capacity of
120 mgd. Twenty-one systems, having a combined flow of 25 mgd, dis-
charge treated effluent into the inland canal system. The largest
systems in the north Bade County area, which will be incorporated
into the north Bade regional system, include the cities of North
Miami, North Miami Beach, Hialeah and Sunny Isles. Wastes from
these municipal systems are presently discharged to the Atlantic Ocean
by way of a 10,000-foot, 48-inch diameter outfall. The only treat-
ment provided prior to discharge to the ocean is skimming of floatable
solids. Segments of the North Miami outfall system have recently
approached their hydraulic capacity, preventing any significant
increase in wastewater collection in these areas.
Groundwater infiltration is a serious problem in many of the
existing collection systems which will be consolidated into the North
Bade Regional System. Since saltwater intrusion has occurred into
40
-------
the Biscayne Aquifer in coastal areas, sewer infiltration has resulted
in extremely high chloride levels in wastewaters collected in these
zones. The initial phase of the project will include consolidation
of existing collection systems which have been infiltrated with
brackish groundwater to the extent that chloride concentrations are
expected to range well above 1,000 mg/1. (Public Health Service
recommended standards for potable water supply suggest a maximum of
250 mg/1 of chlorides.) Several communities and utilities in north
Dade County and the Miami-Bade Water and Sewer Authority have initiated
a rigorous infiltration abatement program which has included repairing
or replacing damaged portions of the system. However, it is estimated
that much of the infiltration in these older systems is occurring at
individual service connections and would be extremely difficult to
eliminate.
I. D. 7. Settlement Patterns
In the North Service Area, the population is concentrated in
the eastern part, with somewhat higher densities in the southern
part of the area. The settlement remains relatively dense up to
the Palmetto Expressway after which it drops off rapidly. The western
part of this service area is currently sparsely populated relative
to the eastern section but this thrust of expansion is westward.
A detailed discussion of future settlement patterns and population
projections in north Dade County is contained in Appendix IX.
41
-------
I. D. 8. Water Quality
Practically all bodies of water in north Dade County have
been degraded directly, or indirectly, as a result of wastes pro-
duced by man's activities. This includes the inland canal system,
the subsurface groundwaters of the Biscayne Aquifer, and the
coastal estaurine waters of Biscayne Bay. Degradation has occurred
as a result of direct discharges from treatment plants, seepage
from septic tanks and seepage ponds, and from runoff of rainwaters
which carry wastes into the canal system of the area.
Major canals in the North Dade Service Region include the Snake Creek,
Biscayne, Little River and Miami River Canals. The water quality of major
portions of the canal system in eastern north Dade County can be typified as
follows:
• Biochemical oxygen demands (BOD) elevated in the range
of 2.0 to 5.0 mg/1;
• Dissolved oxygen concentrations usually less than 3.0 mg/1
and often as low as 1.0 mg/1 (except Biscayne Canal which
is usually above 4.0 mg/1);
• Total coliform levels which are generally above 1,000
MPN/100 ml and, in some reaches, exceeding 25,000 MPN/100
ml;
• Sludge accumulation in Miami River and Little River up to
3 inches deep.
42
-------
An additional indicator of pollution is the prolific growth
of aquatic weeds in some canals, notably behind salinity barriers,
which indicate over-enrichment by growth-stimulating nutrients
(carbon, nitrogen and phosphorus) may be occurring. Taken collectively,
these indicators suggest that major segments of the north Dade
canal system have been severely polluted.
Because of the salinity structures, flows in the canal system
prevent normal drainage of contaminated inland waters and intensify
the effects of pollution. As a result, the assimilative capacity
of the canal system for organic wastes is extremely limited, and
in some reaches, approaches zero. Recreational activities have
been sharply reduced throughout the inland waterway system.
Portions of Biscayne Bay occasionally contain high fecal
coliform levels, indicating the possible presence of pathogenic
bacteria and viruses. These include samples collected in the
vicinity of Dinner Key, Miamarina, and Haulover Marina an(j ±n the
Bakers Haulover plume. Other regions of the bay which have been
adversely affected by the discharge of inadequately treated wastes are
Sunny Isles, near the mouth of the Oleta River (which has excessive
coliform and depressed dissolved oxygen levels), and regions in the
Intracoastal Waterway (in which coliform densities exceed water quality
standards).
43
-------
II. ENVIRONMENTAL IMPACT OF PROPOSED FACILITIES
The proposed project will include construction of publicly-
owned regional facilities for the collection, treatment, and dis-
posal of wastewaters in north Dade County. The proposed facilities
include pipelines and pumping stations for wastewater transmission,
wastewater treatment facilities and sludge disposal systems.
Proposed pipeline routes, pump stations, and treatment plant sites
were previously identified in Section I.A. of this Statement.
The environmental aspects of the proposed plan and associated
facilities are divided into primary and secondary impact classifi-
cations. Both beneficial and detrimental environmental impacts may
result from the construction of the proposed project.
II.A. Beneficial Impacts
The beneficial effects of the water quality management program
proposed for north Dade County are summarized as follows:
The elimination of small wastewater treatment plants,
which currently discharge inadequately treated wastewater
to inland canals and bays, will reduce health hazards and
enhance water quality in the vicinity of the current dis-
charges. Any existing nuisances such as odors, noise, and
unsightly conditions in these locations will be eliminated.
Existing treatment facilities which will be eliminated by con-
struction of the north Dade regional wastewater management
system are shown in Table 3.
44
-------
TABLE 3
ELIMINATION OF INLAND WASTEWATER DISCHARGES
NORTH DADE WASTEWATER MANAGEMENT DISTRICT
Treatment Plant to Be Flow
Eliminated by Proposed Action MGD
1. Andover 1.71
2. Carol City 2.03
3. Riverdale 0.36
4. Golden Isles 0.64
5. Palm Springs North 0.45
6. Seaboard Industrial Park 0.12
TOTAL 5.31
Inland Waterway To Be
Enhanced
Snake Creek Canal
Snake Creek Canal
Snake Creek Canal
Oleta River
Snake Creek Canal
Little River Canal
45
-------
The reduction of individual septic tank systems will reduce
potential health hazards and avoid potential groundwater
pollution in localized areas.
The proposed regional treatment facilities will achieve
treatment on a consistent and dependable basis with no
objectionable odors and noise.
The discharge of adequately treated effluent to the ocean
at the edge of the Florida current (rather than the present
discharge of raw and partially treated wastewater into shallower
water closer to the shore) will result in improvement of ocean
water quality, protection of marine life, enhancement of
beaches, and reduction of health hazards.
The provision for future flexibility in the north Bade
management plan may make effluents available for recycle or
reuse to supplement the water resources in the future.
The disposal of sludge which, after treatment and land
application, may be reclaimed as dried cake will provide
material for landfill or soil conditioning.
46
-------
II. B. Adverse Impacts
Although the beneficial environmental impacts related to the
construction and operation of the proposed project will outweigh
the adverse impacts of the project, there will be some detri-
mental effects which may result. These include adverse effects
on the land, water, and air resources of the region. These
impacts are identified and discussed in the following paragraphs,
along with a discussion of actions proposed to minimize these
adverse impacts.
II. B.I. Impact on Land Resources
The construction and operation of recommended facilities may
affect land resources of north Bade County in one or more of the
following ways:
Water or wind erosion of surficial materials resulting
from excavation and spoil disposal;
Changes in structural stability and water carrying
capacity of the bedrock resulting from excavation and
spoil disposal;
Reduction of land available for other uses;
Damage to areas of geographical or historical interest
or of archeological value; and
Disruption of the overall ecology of the region or
localized ecological communities within it.
47
-------
Impact of Surficial Features
The topography and geology of north Dade County do not
lend themselves to severe water erosion. The county is flat
and the ground is porous; therefore, fast moving or lengthy
runs of overland flow are not likely to occur. Accordingly,
water-caused erosion may be of concern only where construction
is carried out near surface waters.
Wind-caused erosion will be given careful consideration during
construction. Although some erosion is unavoidable, proper
supervision by the county's consultant engineer will minimize both
water and wind-caused erosion.
Pipelines will be laid in or beside roads, parallel to canals,
and through existing public rights-of-way in areas which are not
built up. Construction procedures will be specified to inhibit
both water and wind erosion from excavated areas and to minimize
siltation of surface waters or excessive dust from excavated
material. General practices to be followed are listed as follows:
• Trenches will be backfilled continuously to minimize the
length of open trench.
• All surplus excavated material from trenching operations
will be removed by the contractor and hauled to disposal areas away
from the canals.
• All disturbed surface areas will be restored to their previous
condition as soon as possible.
48
-------
• When the construction route parallels a canal or waterway,
excavated soil will be placed on the side of the trench away from
the water's edge.
• Adequate distance will be left between the excavation and
the edge of the waterway where sufficient rights-of-way can be
obtained.
• Dust control measures will be instituted during construction
on dry days.
Effect on Bedrock
The bedrock in Dade County is fairly close to the surface,
particularly in the coastal ridge areas. Construction of pipelines,
pump stations, and treatment plant elements will require excavation
into bedrock. Bedrock is normally soft limestone> therefore,
blasting generally will not be required, and excavation can be
carried on without damaging the overall bedrock. Only negligible
amounts of bedrock will be removed to accommodate pipe, pumping
stations, and plant elements.
Effect of Land Requirements
Pipelines will be constructed in existing rights-of-way and will
not take land out of service. The proposed treatment and sludge dis-
posal facilities will initially require a total of 100 acres of land
(40 acres at Interama to be used for treatment plant construction and
60 acres at Virginia Key to be used initially for sludge disposal) which
49
-------
will be removed from other possibly productive activity. Construction
of the overland portion of the ocean outfall will temporarily remove
a narrow pathway from other productive purposes, but after construction
this land will be available for limited use. The location of the
collection, treatment and disposal facilities is compatible with pre-
sent and proposed land use purposes as defined in the Bade County
land use plan.
Effect on Areas of Archeological, Historical or Geographical Value
Projected pipeline routes, treatment plant sites, sludge disposal
areas, borrow areas, and access routes have been reviewed by the
State of Florida, Department of Archives, History and Records Manage-
ment and are not considered to be of archeological, historical or
geographical value. More intensive examination of routes and sites
will be undertaken during final design to ensure that no valuable
areas are affected.
When the proposed 90-inch ocean outfall is constructed, plans
call for the outfall to traverse the northern portion of Haulover Park,
north of Bal Harbour. The portion of the park property which will be
traversed is presently undeveloped; therefore, the construction of the
outfall would have little impact on the park facilities or on use of
the park either during construction or during operation of the outfall.
However, a narrow band of the park area would be temporarily disturbed
during and immediately after construction.
50
-------
Effect on Ecological Communities
Although Bade County has several rare and valuable ecological
communities, none are directly affected by the proposed project.
The Everglades system in the west and the Biscayne Monument area and
the estuarine salt marshes in the east support most of the more
valuable elements of Dade County's ecological resources.
Most of the required wastewater interceptors will be located in
existing public rights-of-way. There may be limited routing of pipe-
lines through undeveloped areas which have been disturbed previously
by adjoining development activities. These areas are characterized
by marly soils of low nutritive value (typical of northern Dade
County) and support, for the most part, only wasteland species of
shrubs and trees.
The site selected for construction of the north Dade treatment
plant, recently purchased by Dade County, is an 80-acre site located
in the Interama land tract (within the 200-acre tract shown in Figure
8 as site 6C) which supports a diverse plant community and about 30
acres of mixed mangrove. Approximately 40 acres of the site will
have to be cleared and graded to provide for construction of the treat-
ment facilities. The existing flora and fauna of the site were surveyed
by qualified ecologist and representatives of the Department of the
Interior and the Environmental Protection Agency in July 1973. The
findings of this survey are discussed in Appendix V of this statement.
-------
The predominant plant communities which will be adversely affected
by clearing and grading of the plant site are described as follows:
• About 15 acres of predominantly white mangrove,Laguncularla
racemosa, with occasional buttonwood and red and black man-
grove. The habitat characteristics vary from dry, grey marl
to flushed areas of loose, black peat.
• About one acre of oak-palmetto hammock dominated by oaks,
Quercus laurifolia and Quercus virginiana, with other scattered
hardwood. Species composition includes a variety of trees
such as gumbo limbo, strangler fig, sweet acacia, cabbage
palm, coral bean, red mulberry, black bead, myrsine and wild
tamarind. Groundcover is principally composed of saw palmettos
with scattered ferns and shrubs.
• About 8 acres of scrub palmetto characterized by low, dense
groundcover and scattered shrubs. The dominant species are
oaks, Quercus sp., and saw palmetto, Serenoa repens. A number
of species typical of this habitat are present including
waxmyrtle, rusty lyonia, slash pine, muscadine grape and
coontie.
• About 2 acres of lowland with a ^dense covering of sea ox-eye
daisy, Borrichia frutescens, with a few clumps of sawgrass,
cordgrass or Isolated specimens of groundsel distributed
throughout the area.
• About 14 acres of disturbed area dominated by Brazilian pepper,
52
-------
Schinus terebinttiif olius. Some open areas support low grasses
with sparse Brazilian pepper and groundsel with occasional
clumps of lantana. Various other species are scattered through-
out this area.
The location of these plant communities are shown on the diagram
attached to Appendix V of this statement. Although the site does
contain a highly productive red mangrove grouping, Rhizophora mangle,
the treatment plant site has been selected to avoid this area and
the coupled estuarine-mangrove system along the Oleta River. The loss
of the white mangrove area on the plant site represents a regrettable,
but unavoidable, environmental impact but should not adversely affect
the productivity of the remaining mangrove area. Wherever possible,
the existing flora will be preserved in its native state and serve as
part of the visual buffer to the facilities, or as part of the land-
scaping plan. The red mangrove area will be preserved in its native
state.
The proposed construction site and its surrounding area apparently
support a diverse community of wildlife, including song birds, wading
birds, invertebrates and possibly some small game. While the habitat
for these creatures will be eliminated as a result of the plant con-
struction, appropriate wildlife habitat will be preserved along the
Oleta River adjacent to the site, where displaced animals can seek
refuge.
53
-------
Two plant species, the wisk fern, Psilotum nudum, and the coonite,
Zamia pumilia, were erroneously identified in comments submitted on
the draft EIS (and attached to this statement) as being "rare or
nearly extinct." These plants are species native to the southeast
Florida region which have been protected by State legislative action
(Appendix III), but they are neither rare nor endangered. State law
does allow the destruction or taking of these and several other
designated plants (including the cabbage palm) with the written per-
mission of the owner of the property upon which they grow. However,
in order to fulfill the spirit of the legislative act, the wisk fern
and the coonite plants on the site will be located and transplanted
in a suitable environment prior to construction. Wherever appropriate
coonite (or Florida arrowroot) plants will be preserved on the site
and utilized in the landscaping scheme.
The proposed ocean outfall will travel from the treatment plant
at Interama in an generally easterly direction across the site to the
edge of Biscayne Bay. It is presently designed to traverse two small
areas of predominantly white mangrove, the first of which is located
along the Oleta River- The 30-foot permanent and additional 30-foot
construction right-of-way will pass along the edge of the existing
mangrove grouping and may result in the destruction of a strip of
mangrove approximately 20 to 30 feet at its inland edge.
The outfall will also traverse a strip of mangrove currently
growing at the edge of Biscayne Bay in Haulover Park estimated to be
54
-------
approximately 250 feet wide. The construction of the pipeline will
destroy a 60-foot wide path of the natural mangrove area. The total
area of mangrove which will be affected is estimated to be less than
one acre.
The mangrove areas which are affected during the construction of
the outfall will be allowed to revert to their original configuration
after the outfall is buried after general maintenance of the construc-
tion site. Other areas of the Interama site which will be traversed
by the pipeline are of relatively low ecological value or have already
been disturbed as a result of development. These will be restored,
insofar as is possible, to their original configuration after con-
struction. The proposed route of the ocean outfall through the Interama
site is shown in Figure 10.
No adverse ecological impacts are anticipated to occur as a
result of sludge disposal on Virginia Key, since proposed disposal
sites have been utilized as landfill or sludge drying sites for many
years by the city of Miami.
II.B.2 Impact on Water Resources
Although the possible environmental impacts of various
disposal techniques were thoroughly assessed in EPA's
Wastewater Disposal Methods EIS, this statement will briefly summarize
some of the most significant environmental effects which might be
expected should the proposed ocean outfall system be used for disposal
of treated wastewater. In addition to the impact of disposing of
55
-------
treated wastewaters, some additional adverse effects to water resources
of the region may be observed due to the construction and operation
of the proposed collection, treatment and disposal facilities. These
effects are described in the following paragraphs.
Atlantic Ocean
The Continental Shelf of the Atlantic Ocean is used primarily
for commercial and sport fishing and recreational purposes such as
boating, skin-diving, fishing and bathing.
Implementation of the proposed plan will involve constructing a
new ocean outfall in the North Bade District as described in Section
I.A of this statement.
When the new outfall is constructed, it will be buried beneath the
land surface as it passes over land, through Biscayne Bay and the
Intracoastal Waterway and through most of its length of travel beneath
the Atlantic Ocean. In shallower ocean areas, where wave action
could affect the stability of the outfall line, the pipe will be buried
about four feet beneath the ocean bottom. The amount of bottom
surface which will be disturbed, including the trenching and the
placement of spoil, is estimated to be approximately 60 feet along
the centerline of the outfall. Spoil will be replaced in the
right-of-way and will likely be scattered by wave action. In
deeper areas, the pipe will be partially buried (to its spring
line) and the excavated material piled at the edge of the pipe in
56
-------
rick-rack fashion. In other outfall installations, this has
produced a desirable fish habitat.
Trenching through rock will be performed by mechanical
crushing of rock with removal of the spoil by use of a "clam shell"
dredge. Very little, if any, blasting should be required.
Studies will be performed along the proposed route of the
pipeline by experts in undersea ecology to ensure that the
detrimental impact on the ocean bottom and on the offshore reef,
resulting from the outfall construction, will be minimized.
Soundings have indicated that a low point, or possibly a complete
break in the reef, may exist east of the Interama site. This
"break" will be located by divers and selected for the point of
crossing of the outfall to the open water beyond. Under no
circumstances will blasting be utilized to penetrate the reef.
The maximum extent of damage to the reef is estimated to be along
a 40-to-50-foot path along the centerline of the outfall.
The effect of outfall construction on the beach and surf
areas, due mainly to the necessary trenching operations, will be
minor and temporary. Tidal and storm action should obliterate
the evidence of construction quickly.
During construction, adverse effects will be minimized by
implementation of the following precautionary measures:
• All construction and storage of materials will be
accomplished within the right-of-way.
57
-------
• All surplus excavated material will be removed by the
contractor and hauled to a site for disposal in a
manner compatible with the environment.
• Measures will be taken to prevent erosion or silting of
adjacent areas, such as the temporary installation of
cofferdams or shoring, to localize the disturbance.
This will probably be necessary only in the surf zone. In
the deeper water, where the danger of storm wave action is
minimal, it will not be necessary to completely bury the
pipeline. Limiting excavation will minimize benthic
disturbance. Although there will be some destruction of
the benthic biota along the immediate route of the line,
it is anticipated that these will soon be restored to
background level through natural reproduction from the
undisturbed adjacent area.
No discernible disturbance or damage of the ocean waters is
anticipated during construction, except for some localized and
short-term turbidity.
There has been scientific study of the effect of existing
outfalls on ocean water Quality and the ecology of the Continental
Shelf. Such ocean studies substantiate the conclusion that discharge
58
-------
of secondary effluent to the edge of the Gulf Stream, as recommended
in this statement, should involve only minimal risk of pathogenic
infection or ecological damage. (Please note recent studies performed
in the coastal waters of Dade County, reported in Appendix IV.) A
more detailed description of environmental effects associated with
discharge of treated wastes to the Atlantic Ocean is continued in the
Wastewater Disposal EIS.
The proposed north Dade ocean outfall will be monitored as part
of a comprehensive surveillance program which will be initiated in
conjunction with the construction of this and other outfalls in the
three-county southeast Florida region. The objective of this program
will be to seek out, identify and quantify any adverse environmental
effects associated with the discharge of wastewaters to the offshore
coastal waters of the region.
The scope of the proposed monitoring had not been definitely
defined at the time of publication of this statement, but some of
the studies which are proposed are reported as follows:
Routine analysis of ocean waters and sediments for consti-
tuents which may be present in wastewaters and which repre-
sent- a hazard to the delicate ecology of the ocean environ-
ment. These may include analysis for biochemical and chemical
oxygen demand, nitrogen, phosphorus, turbidity and suspended
solids, heavy metals, pesticides and herbicides, halogenated
hydrocarbons, fecal coliform and selected bacterial and
viral studies, etc.
59
-------
Analysis of the effects of wind, tide and current on the
diffusion pattern of chemical and microbiological contami-
nants discharged to the ocean through ocean outfalls. In
particular, information will be sought to determine the
magnitude, duration and frequency of the mixing and flushing
eddies and their effect on diffusion and advection characteris-
tics in the coastal shelf zone.
Various bioassay studies are proposed, such as growth studies
on native aquatic organisms such as alcyonarians, stony
corals, and sponges. Growth rates of these animals could
be measured at varying distances from outfalls and compared
with growth rates observed in areas outside of the influence
of wastewater discharges. The microalgae community should
be analyzed, both as to relative quantity and distribution
of species in the vicinity of ocean outfalls and compared to
populations outside of the zone of influence of wastewater
discharges. An investigation should be made of the incidence
of the sea urchin Diadama antillarum (which has been observed
to reside in greater populations in environmental stressed
areas) to reveal the extent and magnitude of impact or. the
ocean bottom due to the discharge of wastewaters. Field and
laboratory bioassay studies of southeast Florida reef fish to
determine effects of discharges.
60
-------
Preparation of mathematical models to define the extent of
travel, stratification, dilution, die-off and biodegradation
of wastewater contaminants in the southeast Florida coastal
environment.
These and similar studies could be employed to identify both
immediate, direct impacts and cumulative, long-term impacts which
may have gone undetected in other, less definitive studies by the
Environmental Protection Agency and others which have been performed
to date in the southeast Florida coastal shelf zone.
Although preliminary discussions have been held with a number of
agencies (both public and private), no final selection has been made
concerning the execution of the monitoring program. However, only
those agencies which possess demonstrated capability, including
technical expertise and resources, and which will be able to produce
a comprehensive, unbiased environmental assessment will be considered
for the surveillance responsibility- The findings of the monitoring
program will be assessed by local, State and Federal agencies, includ-
ing EPA.
The estimated cost of the surveillance program is approximately
$800,000 to $1,000,000 annually, which is equivalent to less than
1.0 per 1,000 gallons of wastewater discharged via outfalls in the
three-county area (about 37 per capita per year) . The duration of
the monitoring program is expected to be at least three years.
61
-------
Financial requirements will depend largely upon the selection of the
contracting agency and possible cost sharing arrangements which may
be obtained. But under any circumstances, the cost to the people
of the three-county area should be minimal.
If any significant environmental impact is detected, which
threatens to disturb the sensitive ecological balance of the south-
east Florida coastal shelf environment, action will be promptly taken
to rectify the problem, such as by the installation of additional
treatment to wastewaters prior to their discharge to the ocean,
extension of the outfall, etc.
Inland Surface Waters
The major inland surface waters are the lakes and canals which
were built to provide drainage and obtain borrow material. The lakes
and canals are used extensively for recreational boating, swimming
and fishing.
There will be some siltation of inland waterways during the
construction of the proposed project. This will be minimized by
application of the construction procedures outlined earlier in this
section.
Pipeline construction will be in trenches in the waterway beds,
or in the case of short crossing of non-navigable waters, on bridges
across the canals. Where necessary to lay pipes in the waterway
beds, construction may produce a short-term increase in turbidity.
62
-------
This will not significantly increase the silt content of the canals
and should have no effect on the canal inhabitants.
Biscayne Aquifer
Construction of pipelines will require some excavation into the
top of the aquifer, but this will have no effect on its structural
stability or water-carrying capacity.
The North Bade District Wastewater Treatment Plant will be
designed to permit future installation of additional facilities for
treating and pumping highly-treated effluent into the lower reaches
of canals for salinity control or directly into the Biscayne Aquifer
west of the salt front to act as a barrier against saltwater intrusion.
Disposal of treated sludge may have a minor and highly localized
impact on the water quality of the surface aquifer of Virginia Key.
However, action discussed later in this statement will be taken to
minimize this impact.
II.B.3 Impact on Air Resources
Factors which might affect the air resources of Dade County
include:
a. Particulate matter (resulting from airborne dust and stack
emissions).
b. Odors (resulting from release of fumes and gases).
c. Noise (resulting from equipment and vehicles).
All of the above will occur during the construction of the
facilities (short-term impact) and after the facilities are placed
63
-------
in operation (long-term impact). All activities associated with
land clearing, construction and operation of the facilities, which
might result in air pollutants to be raised to the atmosphere, will
be accomplished in accordance with State and local pollution control
regulations. However, it is judged that implementation of the pro-
posed project will not have any significant adverse effect on the air
resources of Bade County. The reasons for this judgment are outlined
in the following sections.
Particulate Matter
Some dust will be generated during construction of the proposed
facilities. Dust control procedures, implemented throughout the
construction phase, will keep this within acceptable limits. All
areas disturbed during the construction period will be restored and
seeded over.
Odors
Odors originating in the collection system are the result of
organic matter decomposing in the wastewater. The decomposition
and attendant production of gases is accelerated by the long travel
periods and high temperatures commonly experienced in the Bade
County collection system. The most common odor causing gas produced
under such conditions is hydrogen sulfide. This gas is generally
released from solution at points of turbulence in the system such as
pump stations and inlet works of treatment plants. The odors will
64
-------
be minimized by incorporating appropriate design features, including
the addition of strong oxidizing agents to the wastewater. In
addition, all primary clarifier tanks and reactor tanks will be covered,
producing a treatment system which will be closed to the atmosphere
and esentially odor free.
The generation of odors within the treatment plants will be
further controlled by proper design and operation of the facilities
and, if necessary, through the use of auxiliary odor control devices.
Odors emanating from sludge disposal sites will be minimal since
sludge processing methods will reduce the organic content of the
sludge to a point where it is no longer putrescible.
Noise
A recent noise survey of the proposed plant sites showed noise
levels for suburban residential areas which are generally considered
to be acceptable (U.S. Dept. H.U.D., 1971). The ambient noise level
in Dade County generally results from noise emanating from motor
vehicles or aircraft.
Implementation of the proposed plan will result in increased
noise levels during construction of the facilities. The severity
of the impact cannot be accurately predicted -but will depend upon the
proximity of the construction activity. In any event, it will be
short term.
Operation of the completed facilities may also result in a
slight increase over ambient noise levels. Potential sources of noise
65
-------
include process equipment such as pumps and blowers and the traffic
associated with operation of the facilities. The Occupational Safety
and Health Act of 1970 imposes strict requirements on noise emission
of plant equipment to protect plant workers. As a result, noise will
be held to a minimum within the plant buildings through proper design
and selection of equipment. The impact of the proposed facilities
on noise levels in nearby residential areas would range from slight
to none.
I.n summary, a short-term adverse impact on noise levels will
> r
Oc^ur during construction of the facilities. Little, if any, long-
j
-." ' *''*
term adverse effects are expected once the facilities have been com-
pleted and placed in operation.
-II.B.4 Impact on Socio-Economic Resources
Impact on Land Use
No change in the residential growth patterns north of the Interama
tract is expected to result since proper buffer areas will be an
integral part of the North Bade District Plant. General public use
of the Interama area is projected to include exhibitions, tourist
attractions, and recreation facilities. The North Bade District
Plant will be constructed so that it will be compatible with these
general public uses.
The location of sewer lines in underdeveloped areas could have
an impact on land use patterns, which could, in turn, have secondary
environmental impacts on the natural resource base of the region.
66
-------
Since sewer service is essential to land development and population
growth, it is reasonable to assume that the presence of interceptors
will act as a stimulant to growth in those areas where- sewers become
available. Interceptors which are identified as part of this pCo3,ec.t
are designed primarily to- alleviate existing pollution gcpbl^is, to*
allow abandonment^,6j}_ treatment facilities which are not presently
>•-' -\ _"' ' , '
meeting water quality and/or effluent standards, and to provide for -«
the diminution oi: septic tanks in urbanized-areas. The proposed system
will have only a minimal effect on land .use in the region, and'more-
over, has been designed to conform to land use projections developed'
by Bade County.
The overall impact of the proposed project on recreation in the
region should be beneficial. As noted in the previous section, water
quality should be improved in both inland andT coastal waters,- and,
", ^ ' f /
as a result, recreational activities such as boating, fishing and
swimming should be improved.
As previously noted, the proposed 90-inch outfall would traverse
an undeveloped portion of Haulover Park, but this should in no way
diminish the value of the park as a recreational facility.
Construction of the proposed facilities will have a short-term
visual impact, resulting from the presence of construction equipment,
excavation and dredging operations, general building construction
and storage of materials and equipment on the sites.
67
-------
The complete facilities will be designed to avoid adverse visual
impact; most of'the buildings and treatment units will be low profile
structures.
All areas overlying buried facilities such as sewers and pipelines
will be restored to their original condition. Pump stations and treat-
ment plant sites will be suitably landscaped with a buffer zone of
trees and plantings around them to screen the facilities from public
view. The nearest highway from the plant site will be approximately
1,000 feet away, and the nearest residence will be about 2,000 feet
from the site.
68
-------
III. ADVERSE IMPACTS WHICH CANNOT BE AVOIDED SHOULD THE PROJECT
BE IMPLEMENTED
Although all reasonable efforts will be made to reduce the
adverse environmental impacts of the proposed project, there will
be some unavoidable effects from the construction and operation of
the proposed system. These will include both long-term and short-
term impacts on land, water, air and social resources of north Dade
County. The following discussion summarizes these unavoidable
impacts.
III. A. Unavoidable Impacts Resulting from Construction and
Operation of the Proposed Treatment Facilities
"Site 6C" in the Interama Tract (See Figure 8) has been
selected for the north Dade treatment facility. The site is
situated west of Biscayne Boulevard along the eastern edge of the
right-of-way proposed for an expressway. The plant will occupy
about 40 acres of an 80-acre tract southwest of the Oleta River.
The plant will be a secondary level treatment facility of the
activated sludge type. Sludge will be pumped from the treatment
site and will be stabilized and disposed of by application to the
land surface in a solid waste landfill area on Virginia Key. Treated
effluent will be discharged to an outfall for disposal to the
Atlantic Ocean.
About 40 acres of land will be removed from other possibly
productive activities for the life of the treatment facility.
69
-------
o
(a
P-
O
O
C
3
cn
CD
(T>
cn
cn
g
fD
ft>
CD
3
CO
ft)
"d
rt
CD
ft)
ft
EXISTJNG
48" 0
OUTFALL
BISCAYNE
BLVD.
C31LINS AVE.
AIA
NORTH MIAMI
GOLF COURSE
LAND
N E
EXISTING
NORTH MIAMI
48" PI PELINE
TO OCEAN
W. DIXIE
H IG H WAY
FLORIDA EAST
COAST R.R.
ITE PLAN
NORTH BABE TREATMENT PLANT
-------
This land use may increase if it is determined that more advanced
treatment is required at the north Bade plant. However, the total
80-acre parcel of property should provide adequate space for future
plant expansion, if necessary. The treatment works will be partially
visible from the proposed expressway. However, the existence of
railroad tracts, gas works, and other industrial facilities has
already dictated a commercial character to the area. An exposition
center and golf course are proposed for the Interama site, but
these land uses should not be significantly affected by the operation
of the North Bade Treatment Plant.
Residential development has occurred west of Eiscayne
Boulevard and north of Sunny Isles Boulevard within view of the
proposed facilities; however, the facilities will be designed in
"low profile" and landscaped to reduce their non-aesthetic impact.
Occasional odors may be observed in adjacent residential areas
during initial plant operation or in the event of system breakdown,
but these should not be detectable during normal plant operations.
As previously noted, the ecology of the treatment plant
site will be modified as a result of grading and clearing of the
site. Unavoidable destruction of portions of existing white mangrove
stands, and the accompanying elimination of wildlife habitat, will
result from construction of the project. Native biota will be
replaced with cultivated plants, grass, etc as part of the proposed
landscaping program. Approximately half of the land area has been
71
-------
subjected to previous development and has partially reverted to a
wild state, while the remainder of the site is still in a native
state. Construction will be primarily in disturbed areas.
Siltation may occur in streams on and near the construction site
during grading, with possible short-term adverse impact on the Oleta
River during rain storms. After grading and construction is completed,
the site will be planted with grass, trees, and shrubs to stabilize
the soil. The site also supports a freshwater marsh which may be
adversely affected temporarily by siltation during construction but
will be preserved in its present form and should not be adversely
affected by operation of the facility. Short-term effects should
not impair the long-term productivity of the marsh area.
Disposal of sludge on land surfaces may have an adverse impact
on groundwater due to drainage and leaching into the ground surface.
Present plans call for piping of sludge and supernatant to a 60-acre
site adjacent to the existing Virginia Key Sewage Treatment Plant.
The site will be located in the central northeastern portion of the
island. At this location, the sludge mixture will be combined with
raw sludge generated at the central Bade (Virginia Key) plant to be
digested biologically, then heat treated and stabilized using either
the "Zimpro" or "Porteous" techniques. Both of these processes
-utilize high heat (over 350°F) and elevated pressures to stabilize
and sterilize the sludge, and to effect separation of solids and
supernatant liquid.
72
-------
The solids fraction will be consolidated and "dewatered"
using either a vacuum filtration or centrifuging process, reducing
the liquid portion of the sludge to approximately 25 percent. The
dewatered solids will be applied to a diked area of the land surface
adjacent to the facilities where exposure to air and sunlight will
complete the drying process, producing an inert, sterile sludge cake.
Supernatant will be retained in the sludge digesters and returned to
the Virginia Key plant to be reintroduced to the process stream for
treatment and subsequent disposal by way of the proposed central Dade
ocean outfall.
A small amount of liquid supernatant may drain, or be leached
into the surface aquifer of Virginia Key. This aquifer is already
permeated with saltwater and is not usable as a source of water supply.
Therefore, no significant adverse impact would be associated with
drainage to this groundwater. To insure that contamination does
not spread to the coastal waters of Virginia Key, a monitoring
program will be initiated. If any contamination is detected, action
will be taken to prevent the degredation of water quality of the
coastal waters.
The dried solids may be combined with solid waste and soil at
remote sites to reclaim nonproductive land areas. Once dried, sludge
should be totally innocuous and may be beneficial as a soil conditioner
and fill.
73
-------
Future plans may call for expansion of the sludge disposal
site. The county is committed to purchase an additional
60 acres adjacent to the plant site, and will also utilize a nearby
100-acre sanitary landfill site on Virginia Key. If operated in the
manner described above, no significant additional impact should occur
The construction and operation of the treatment facilities at
both the Interama site and at Virginia Key will also require the
irretrievable commitment of building materials such as concrete,
steel, etc. The operation of these facilities will require large
quantities of chemicals, especially chlorine, lime, and electrical
power. The production of these materials may result in unavoidable
environmental impacts at locations remote from the plant site and
from the north Bade region.
III. B. Unavoidable Impacts Resulting from Construction and
Operation of Proposed Ocean Outfall Disposal Facilities
Under the disposal plan being proposed, treated wastewater
will be discharged via an ocean outfall to the Atlantic Ocean.
The proposed new ocean outfall would be 90 inches in diameter
and 22,850 feet long, and would run from the treatment facility
across the Interama site to the ocean's edge, and then along the
ocean bed to its termination approximately three miles from shore.
The termination of the outfall will be beyond the offshore reef
and will be within the zone of influence of the Gulf current.
-------
Although, the western edge of the Gulf stream meanders from one to
five miles from shore in southern Florida, its movement should
provide a dependable source of advection and dispersion near the
outfall terminus.
There will be unavoidable environmental impacts from the
installation of these facilities. Earth movement will be required
to provide a trench through the Interama site in which the pipe will
be placed. The trench will have to be a minimum of 15 feet deep
and approximately 30 feet wide at the ground surface in order to
accommodate the 90-inch interceptor. This will require extensive
excavation and may produce disruption of the natural ecology along
the planned route of travel, and siltation to streams, canals, and
inlets in the event of rainstorms during the construction phase of
the project. Siltation will be kept to a minimum by observing
good construction practices such as phasing excavation to match
pipe-laying schedules, trucking of excess soils from the site as soon
as is practicable and covering installed segments with earth, and
reseeding disturbed areas as quickly as possible. The impact on
important ecological communities on Interama has been minimized by
selecting a route which avoids, to the maximum extent possible,
areas of known ecological significance, following routes which
have already been developed.
75
-------
Although soil cover appears to be adequate along the planned
route of the new outfall, blasting of bedrock may be necessary to
provide the necessary trench area. Blasting will be employed only
when no other construction alternative (e.g., air hammers, etc.)
exists. The effect of subsurface, low-yield detonations should
not produce a significant impact on residents of the area. The
effect on the structural integrity of the bedrock should in no
way be affected.
Installation of the outfall along the ocean bed surface will
also produce some unavoidable impacts. The major ecological effect
will be the elimination of the natural benthic community in a strip
about 60 feet wide and three miles long (equal to approximately
eight acres). Since this effect will be distributed over a large area
of bottom surface, the impact should not be significant. It is
expected that much of the natural bottom ecology will eventually
be restored .
Since the outfall may traverse natural offshore coral reef,
some short-term and long-term damage to this irreplaceable natural
resource may occur. Penetration of this reef may be required to
provide access through the reef to the open water beyond.
The alternative to this action, which would call for terminating
the outfall prior to reaching the reef (or in the reef area) , was
discarded since circulation of seawater within the reef zone is
76
-------
greatly reduced. Also, greater damage might occur to the reef if
secondary treated wastewater were released near the reef. Damage
should be limited to a 40-to 50-foot zone along the centerline of
the pipeline path. Once the outfall is in place, no additional
damage to the reef is anticipated. Damage to the reef may eventually
be repaired as a result of natural regrowth around the excavation
area.
The discharge of treated wastewater to the ocean through the
proposed outfalls is expected to have some localized adverse water
quality impacts. A detailed discussion of possible water quality
effects associated with discharge through ocean outfalls is con-
tained in EPA's Wastewater Disposal Methods environmental impact
statement. This Statement will summarize some of the most signifi-
cant impacts.
Solids removal at the treatment facility should reduce the
effect of sludge accumulation from that observed at other locations
employing a lesser degree of treatment. However, a small accumulation
of sludge and "grit" may be observed on the ocean floor around the
end of the outfall. This will have an adverse effect upon the
natural ecology within this extremely small zone of influence
(probably less than one acre).
Proposed waste treatment facilities will remove about 90 percent
of the biochemical oxygen demand prior to discharge to the outfall.
77
-------
This, coupled with the massive circulation of ocean water, should
prevent any measurable depletion of oxygen resources. Nitrogen
and phosphorus compounds will be discharged through the outfall to
the Atlantic Ocean, along with trace concentrations of compounds
containing iron, copper, lead, mercury, zinc, nickel, and other
elements commonly found in domestic sewage. However, the dilution
effect of the Gulf Stream will quickly disperse these to undetectable
levels. The long-term impact of discharging these compounds to the
ocean is not fully known, but based upon a lack of any evidence to
demonstrate any cumulative adverse effects, it is considered to be
inconsequential. Waste treatment, including disinfection with
chlorine and the large distance provided between the proposed dis-
charge point and the nearest point on shore, should provide a wide
margin of safety to prevent human contact with pathogenic bacteria
or viruses. Model studies have indicated that dieoff of bacteria
will have occurred even under the most adverse conditions (such as
failure of chlorination equipment) to such an extent that any
significant human contact with these organisms will be prevented
at the shoreline. In order to insure that discharge of treated
wastewater will not have an unacceptable impact on the ocean
environment of southeast Florida, an extensive monitoring program,
as previously described, will be initiated.
78
-------
A final adverse impact associated with discharge via ocean
outfalls is the loss of potentially recycleable wastewater. While
this is a loss of potentially vital resource to the region, other
more desirable and less expensive sources of water supply are
available and should be utilized before turning to reuse of waste-
waters. However, should it become necessary to utilize recycled
wastewaters to meet future demands, the overall management system
has been designed to allow higher treatment levels at the proposed
site.
III1 C. Construction and Operation of the Proposed Collection
System
The proposed north Bade project calls for the installation of
eleven force interceptor mains totaling 178,000 feet (34.2 miles)
ranging from 24 to 90 inches in diameter, and twelve individual
pumping stations. Proposed interceptor line and pump station loca-
tion are shown in Figure 1. The collection system will be designed
to reroute wastewater flows from individual treatment facilities,
many of which are presently operating in violation of Federal-State
standards to the north Bade regional wastewater treatment facility.
Other elements are designed to expand the collection capacity of
the existing interceptor system, particularly in the vicinity of
the proposed treatment plant, to provide for the consolidation and
growth of the system.
79
-------
The short-term impact of installation of the collection system
will be similar to that described for the overland installation of the
ocean outfall. Major unavoidable impacts will include:
• Possible siltation of streams, canals, and inlets during
excavation in the event of heavy rainfall;
• Noise and dust resulting from operation of earth moving
equipment;
• Temporary loss of earth cover such as grass, shrubs,
trees, etc. This effect will be minimal since all
proposed sewers will follow established public rights-of-
way and the sites will be restored to their original
appearance;
• Short-term disruption of traffic patterns may be expected
on certain well traveled routes.
A major unavoidable environmental impact pertains to the
effect the proposed facilities may have on settlement patterns in
north Dade County. Most interceptors included in the initial phase
of the project have been planned for portions of the urbanized North
Miami-Hileah area and have been designed to accommodate wastewater
flows projected for the year 2000. These sewers should have little,
if any significant impact upon land use in this area.
80
-------
Project 12 (interceptor to the area north of North Miami
Beach( and Project 7 (interceptor to areas north of Hialeah and
west of 57th Avenue) are designed to serve portions of the county
which are not extensively developed at this time. The impact of
placing interceptor mains in these zones may be to provide the
necessary conditions for additional settlement in these areas
prior to other areas which do not have sewer facilities. This may
in turn be expected to have unavoidable impacts on the ecological,
social, and economic environment of these regions. However, it
should be noted that these interceptors have been planned for early
construction to connect existing treatment systems, which discharge
to surface waters of the region, with the north Bade regional system,
thereby eliminating critical pollution problems. Futhermore,
interceptors have been designed in recognition of population growth
patterns as defined in the county's General Land Use Plan. Rather
than encouraging growth, the system may be viewed as providing the
necessary means through which growth can occur in an efficient
manner, with adequate environmental protection.
The pipeline designed to transmit raw sludge from Interama
to Virginia Key will follow a route southerly along Highway U. S. 1
and west over the Rickenbacker Causeway. This route will obviate
any need to lay the pipeline across Biscayne Bay. A duel line will
be installed in the northern portion of the route. Each pipe of
81
-------
the duel system will have the capacity to carry the full sludge
load, with one pipe serving as an emergency standby. The standby
pipe will be connected to the central Bade interceptor system so
that sludge can be pumped to the central Dade plant, even if a
malfunction of the primary system should occur.
The construction of the sludge transmission system, and of
the interceptor system may produce short-term traffic problems along
heavily traveled traffic routes, and may result in inconveniences
to residents of the area. These inconveniences will be kept to a
minimum by performing work on these systems during off-peak traffic
periods.
-------
IV. ALTERNATIVES TO THE PROPOSED ACTION
A variety of alternatives were considered in the final selec-
tion of the proposed wastewater collection,treatment and disposal
system for north Bade County. Alternative treatment techniques were
evaluated in conjunction with several effluent disposal schemes,
A number of treatment sites were studied, considering both compati-
bility with the planned management system and the impact of the
construction and operation of the proposed treatment plant on the
natural and social environment of the area. Several wastewater
collection schemes were evaluated, and interceptor lines were des-
ignated to achieve maximum economy while promoting the objectives
of orderly growth in the region. Finally, several sludge treat-
ment and disposal techniques were considered as alternatives to
the proposed plan. These alternatives are discussed in the following
sections, and evaluated in comparison to the system proposed for
construction. Tabled provides a brief summary of some of the
alternatives evaluated and discussed in this Statement.
IV.A. Wastewater Treatment
Wastewater treatment requirements are primarily a function of
three criteria. The minimum treatment required of all waste sources
is considered to be secondary treatment as defined in Title 40,
Code of Federal Regulations, Part 133 and puolisnea in the Federal
Register on August 17, 1973. These criteria aescnoe tne miiiiuium
level of effluent quality to be achieved for the following parameters
a) BOD (five-day) - 30 mg/1 arithmetic mean in 30 consecutive da^s
45 mg/1 arithmetic mean in 7 consecutive days
83
-------
Table 4
Management Alternatives Evaluated
A. Wastewater Treatment Techniques
1. Secondary Treatment
a. Activated Sludge
b. Physical-Chemical
2. Tertiary Treatment
a. Physical-Chemical
b. Biological-Physical-Chemical
B. Receiving Waters for Effluent Disposal
1. Canals
2. Atlantic Ocean
3. Everglades
4. Groundwater
a. Biscayne Aquifer
b. Floridan Aquifer (Boulder Zone)
C. Scope of Plan
1. Reduced Scope Plan
2. Eliminate North Dade Treatment Plant
a. Diversion to West Dade Plant
b. Diversion to Central Dade Plant
3. Reduced Service Area Plan
4. Construct an 80 mgd Tertiary Treatment Plant With Discharge
to the Canal System
5. Construct a Tri-county Management System
D. Sludge Disposal
1. Ocean Disposal
2. Application to Land Surface
3. Landfill
4. Subsurface Disposal
5. Incineration
6. Miscellaneous Methods
a. Protein Source
b. Building Material
c. Composting
84
-------
E. Site Opportunities
1. Site 1 (East of 1-95)
2. Site 2 (West of N.E. 2nd Ave.)
3. Site 3 (South of 205 Terrance)
4. Site 4 (County Line @ Biscayne Boulevard)
5. Site 5 (Maule Lake)
6. Site 6 (Interama)
85
-------
b) SiigEgmlpd Solids - :3Q mzJl arithmetic mean in. 30 consecutive days
45 ms/1 arithmetic mean in 7 consecutive days
c") Fecal Coliform - ?.nn/inn ml geometric mean in 30 consecutive days
400/100 ml geometric, mean in 7 consecutive days
The .second criterion established for treatment of wastewaters,
concerns the ability of the receiving water body to assimilate
treated wastewaters without significantly affecting the ability of
the receiving water to maintain its natural productivity. In those
cases where State water quality standards have been established
reflecting the water bodies most productive use, waste treatment
was defined to meet'these standards. Where water quality standards
have not been promulgated, a desire to prevent any significant de-
terioration of water quality or preclude present or future uses of t'ie
water bodies was set as the basic objective
The third criterion considered in the establishment of treat-
ment requirements concerns the ability of the treated wastewater to
meet secondary objectives through reclamation. Considering the
predicted shortage of fresh water in Dade County, the ability of
wastewaters to be reclaimed to produce secondary benefits is of
great concern to the people of the region. Secondary objectives
which might be met with reclaimed wastewaters include:
• Recharge of the Biscayne Aquifer.
• Salinity control to prevent further encroachment of saline
water in the Biscayne Aquifer.
86
-------
• Direct reuse, such as by industry or agriculture.
Treatment requirements to meet water quality standards and
reclamation objectives were, in some instances, found to exceed the
capabilities of secondary treatment and demand utilization of ad-
vanced waste treatment technology which will be herein referred to
as "tertiary" treatment. Tertiary systems may be designed to remove
more than 95% of the BOD, suspended solids, total nitrogen and phos-
phorus and achieve essentially 100% elimination of bacteria in
effluent wastewaters.
The treatment systems considered for the north Dade regional
treatment plant are briefly discussed in the following sections.
IV.A.I. Secondary Treatment
Secondary treatment removal efficiencies can be achieved by
a variety of different processes, but can generally be considered
as one of two methods: 1) biological treatment; or, 2) physical-
chemical treatment.
In biological treatment, the primary treated effluent usually
contains about 45-50 percent of the original organic waste load of
the raw sewage. This organic waste is then contacted with a biomass
(either the activated sludge floes, or the slimes developed on a
trickling filter media) and removed from the wastewater by 1) a
rapid adsorption and flocculation of the suspended colloidal matter
and some of the soluble organics, and 2) by progressive oxidation
and synthesis of the adsorbed organics. The variations of the
87
-------
biological treatment process are associated with variations in the
contacted method between the waste organics and the biomass, i.e.,
trickling filter or activated sludge, and by the manner and location
in which oxidation and synthesis is effected, i.e., conventional
activated sludge, contact stabilization, step aeration, extended
aeration, or pure oxygen aeration.
Direct physical-chemical treatment entails preliminary treat-
ment for the removal of gross solids followed by the removal of sus-
pended and colloidal solids by chemical flocculation and sedimenta-
tion. The chemical coagulant used depends on whether phosphorus
removal is desired, the plant size under consideration, and the
characteristics of the waste to be treated. The removal of the
suspended and colloidal solids will also remove approximately 70
percent of the original BOD load with the remaining BOD being pri-
marily in the soluble form. The chemical separation and filtration
steps are therefore followed by the use of activated carbon for the
removal of the soluble BOD by adsorption. The adsorption process is
by contact with either powdered or granular activated carbon. At
present, the use of a granular carbon contactor is preferred because
of the relative ease with which the granular carbon can be regenerated.
IV.A.2. Tertiary Treatment
Tertiary treatment herein refers to 95 percent, or greater, re-
moval of phosphorus and nitrogen nutrient, BOD, and suspended solids.
Although many individual processes have been developed and marketed
88
-------
in recent years to meet some or all of the above removal efficien-
cies, the basic tertiary treatment sequence considered will be one
of the processes described below.
Secondary Plus Physical-Chemical
Secondary plus physical-chemical treatment is a typical se-
condary (biological) treatment plant, followed by the physical-
chemical unit treatment processes listed below, and is very similar
to the treatment processes used at South Lake Tahoe.
1. Chemical coagulation and flocculation with lime as the
coagulant.
2. Ammonia stripping tower.
3. Activated carbon adsorption.
4. Mixed media filtration.
5. Activated carbon regeneration.
6. Lime recalcination.
The unit process performs the treatment steps described as
follows:
Nutrient Removal: Chemical coagulation by lime for phosphorus
reduction, including recalcination and ammonia stripping towers for
nitrogen removal.
Soluble BOD Removal: Activated carbon adsorption columns.
Colloidal Suspended Solids Removal: Chemical coagulation plus
mixed media filtration.
Advanced Biological Plus Physical-Chemical
An alternative to the complete use of physical-chemical tertiary
89
-------
treatment unit process (as described above) is the incorporation of
nutrient removal processes into the biological treatment plant. The
removal of phosphorus can be achieved by introducing any of a number
of chemical precipitants such as lime, alum, ferric chloride, and
polymers into the secondary treatment plant at one of several pos-
sible stages. An increase in the clarification and sludge-handling
facilities that follow the point of chemical introduction would also
be needed to accommodate the chemical sludges produced.
The reduction of nitrogen nutrient would be achieved in a two-
step biological process after the normal biological carbonations
BOD removal step. The first stage, or nitrification step, is the
conversion of ammonia and nitrite nitrogen to nitrate under aerobic
conditions. It may be possible, by careful design, to combine the
first stage-nitrifying step and the normal carbonaceous BOD step
of the secondary treatment plant into a single step by increasing
the aeration period in the secondary plant so that nitrification
is achieved. The second stage, or denitrification step, is the
conversion of nitrate nitrogen to free nitrogen gas (N2> under
anaerobic conditions. So that the denitrification step can be
effected in a reasonable period of time a source of carbon is
added, normally methyl alcohol.
The removal of most of the remaining soluble BOD and suspended
solids can then be effected by the use of carbon columns and mixed
media filter similar to those described under physical-chemical
secondary treatment. The results of recent pilot studies indicate
90
-------
that the use of powdered activated carbon, introduced into the
aeration tank of typical activated sludge treatment plants, may
also be effective in increasing the BOD removal above normal
secondary treatment levels.
Direct Physical-Chemical
Tertiary treatment removal efficiencies have been demonstrated
by pilot studies, by direct physical-chemical methods. The direct
physical-chemical treatment process for tertiary treatment differs
from secondary physical-chemical treatment in only two respects:
1) It introduces an ammonia stripping tower, and 2) the amount of
carbon column contact time is doubled from 30 to 60 minutes to
achieve the 95 percent BOD removal.
IV.A.3 Recommended System
The treatment level required at the north Dade regional plant
was determined through an examination of the assimilative capacity
of potential receiving water bodies to which treated wastewaters
might be discharged. The Wastewater Disposal Methods EIS published
by EPA in March 1973, indicates four treatment disposal techniques
which appear to meet all environmental objectives. These are:
• Disposal of secondary treated wastewaters to the Atlantic
Ocean (beyond the seaward reef) by way of an ocean outfall.
• Disposal of secondary treated wastewaters to the Boulder
Zone of the Floridan Aquifer by way of deep well injection.
• Disposal of tertiary treated wastewaters incorporating a
91
-------
spray irrigation system by land surface application to the
Biscayne Aquifer.
• Disposal of tertiary treated wastewaters (as part of a
closely monitored pilot sutdy) to the coastal waters of
the region.
The statement indicates that, due to the inability of avail-
able tertiary systems to demonstrate dependable destruction of
bacteria and inactivation of viruses, disposal to inland sur-
face waters is not desirable and that other alternatives that mini-
mize contact with man should be utilized. Due to the extremely high
recreational value of the coastal waters of the North Miami area, it
would appear prudent to avoid discharge to the coastal area, even
after application of tertiary treatment. Avoidance of this approach
would futher eliminate any concern regarding possible system mal-
function which might result in discharging untreated or inadequately
treated wastewaters to the coastal area.
The Wastewater Disposal Methods EIS further indicates that the
physiography and groundwater hydrology of the region present severe
limitation to land application alternatives. The lack of adequate
land resources and the inherent difficulties, in controlling and main-
taining a land application system represent additional limitations.
Therefore, it would appear to be most prudent to pursue either
the ocean outfall or deep well disposal approach (both of which re-
quire the installation of secondary wastewater facilities) while
92
-------
providing for flexibility in the treatment process to allow future
upgrading to the tertiary level when operating limitations can be
overcome,and if it can be shown to be of necessity. The construction
of a secondary plant at this time would be compatible with this
future objective since secondary systems are normally (as previously
described) the initial step in the tertiary treatment process. Ade-
quate space for expansion to tertiary treatment was a prerequisite
of all sites explored for the north Bade facility, and will be avail-
able at the Interama site proposed in this statement.
The methods available for secondary treatment are essentially
1) trickling filters, 2) activated sludge variations, and 3) physical-
chemical. Although the trickling filter process can achieve 90 percent
removal of BOD and suspended solids if carefully designed and operated,
it is not considered to be an acceptable treatment alternate because
of the difficulty of maintaining this removal efficiency on a continuous
basis and because of the large site requirements. Therefore, construc-
tion and operating costs were developed for secondary treatment by both
the activated sludge process and a physical-chemical process and for
the> teriary treatment processes discussed. A comparison of treat-
ment alternatives is presented in Table 5. Economic analysis indi-
cated that a direct physical-chemical secondary plant for north Bade
County would be less expensive to construct than an activated sludge
treatment plant, and a direct physical-chemical tertiary plant would
be less expensive to construct and operate than a combined biological-
physical- chemical plant. However, the cost difference is not significant
93
-------
Table 5
Comparison of Treatment Alternatives
Treatment
Process
Activated
Sludge
Carbonacious
BOD Removal
Efficiency
Approx. 90%
Nitrogenous
BOD Removal
Efficiency
25-75%
Nutrient
Removal
(Nitrogen &
Phosphorus)
20-30%
AEstimated
Construction
Cost (80 mgd)
$44.8 million
Advantages
Dependability
East of opera-
Disadvantages
Space requirement
Subject to upset by
Secondary Approx. 90%
Level Physical-
Chemical
Combined Over 95%
Activated
Sludge & Physical-
Chemical
Tertiary Over 95%
Level
Physical-Chemical
Less than 50% N - Less than
25%
P - 90%
43.3 million
Over 95%
Over 95%
89.8 million
Over 95%
Over 95%
65.9 million
* Includes cost of sludge disposal,
site preparation, landscaping, etc,
tion shock loads
Flexibility
Low cost of
operation
Requires about Requires close surveillance
50% space Large chemical demand
required by High cost of operation
activated (nearly twice activated
sludge sludge)
Most dependable High initial and operat-
tertiary system ing costs
Easily expanded Techniques still experi-
system mental
Difficult to control
effluent quality
High quality
effluent
Moderate
initial
investment
Techniquess still experi-
mental
Cost of operation nearly
three times that of
activated sludge system
Extremely large chemical
and power demands
-------
relative to the overall cost of the project. This is especially
true of secondary treatment levels, considering the lack of any
full-size plant data with regards to actual cost and performance of
physical-chemical plants. An activated sludge treatment facility
is also considerably less expensive and difficult to maintain and
operate than a physical-chemical treatment plant and in the long
run would provide a significant cost savings.
Potential site location also has a bearing on the treatment
process to be used. Sites near highly developed residential areas,
or lacking rail delivery potential, may not be as adaptable to a
physical-chemical process requiring deliveries of large quantities
of chemicals, nor to a process requiring reclamation or regeneration
of chemicals on site. The potential for sludge disposal was also a
significant factor in the selection of the treatment process proposed,
Physical-chemical systems generally produce a greater volume of
waste sludge increasing sludge handling costs and intensifying the
environmental problems associated with sludge disposal.
In considering the similarity of costs of the activated sludge
and physical-chemical processes capable of achieving similar levels
of treatment, the selection of the treatment process for north Dade
County was based on the primary factors which would limit or enhance
operational efficiency at the site selected. In recognition of the
demonstrated dependability, low operating and maintenance cost, ease
95
-------
'of operation and control, and the less detrimental environmental
impact of the activated sludge treatment process, this treatment
technique was selected for the north Bade regional treatment facility
in conjunction with the proposed ocean outfall disposal system.
IV. B. Alternatives to the Proposed Sludge Disposal Plan
Sludge is a mixture of water and solids which were either
originally present in the wastewater or which were generated as a
by-product of the treatment process used. Non-processed sludge is
predominatly water (95% to 99% by weight). After processing to a
sludge cake, the water content is 60 percent to 80 percent of the
total weight. Thus, consideration must be given to both the
liquid and solid fractions of the sludge in selecting a disposal
method.
Methods of final sludge disposal are limited to the following:
• Ocean disposal
* Application to land surface
• Landfill
0 Subsurface disposal
• Incineration
The acceptability of the above disposal methods and the use of
sludge for various purposes are directly related to the sludge
quality characteristics described below.
Many of the environmental problems which can arise from sludge
disposal are similar to those caused by the discharge of untreated
96
-------
wastewater to the environment. Characteristics of untreated sludge
and their potential impact on the environment are described below,
grouped under the three major elements of sludge: organic fraction,
inorganic fraction, and microorganisms.
- Organic Material
The organic material in sludge consists of organic carbon
compounds, proteins, fats, carbohydrates, pesticides, and other
substances. Most of these compounds can be decomposed by bacteria
which are normally present in soil and water. In the presence of
oxygen, the decomposition produces innocuous carbon dioxide (CCL)
and water. If sufficient oxygen is not available, decomposition
of organic matter produces methane, hydrogen sulfide, and other
compounds which can produce odors and.-other nuisance conditions.
- Inorganic Material
Inorganic material in sludge is made up primarily of silica,
heavy metal oxides, nitrates, phosphates, and sulphates. The presence
of nitrogen, phosphorus, and some of the trace metals makes the
sludge potentially useful as low-grade fertilizer. In water, however,
these same compounds can stimulate undesirable or excess algal
growths. The heavy metals and nitrates can also be toxic in high
concentrations, resulting in a potential hazard to plants, animals,
and humans. Chlorides can occur at high levels in sludge, depending
on the source of the wastewater and the method of concentrating the
sludge.
97
-------
- Pathogenic Microorganisms
Sludge includes bacteria, viruses, and other microorganisms
normally found in wastewater, some of which are pathogenic. Sludge
use and disposal systems must be properly planned to prevent the
sludge from serving as a vector to transmit disease to man through
direct contact, water supplies, or foods.
Before disposal, the sludge is generally conditioned by one or
more of the following steps:
e Stabilization or digestion, either aerobic or anerobic,
which breaks down organic solids and renders the sludge less
putrescible.
• Disinfection, which eliminates health hazards by killing
pathogenic organisms.
e Concentration, which reduces the liquid volume of the sludge
and makes it easier to handle.
e Incineration, which achieves nearly total destruction of
organic matter and pathogenic organisms and leaves an inert, steri-
lized ash for disposal.
Selection of the appropriate sludge conditioning process or
processes is a function of both the cost and the process's ability
to modity the sludge characteristics to the degree necessary for
disposal.
The two methods of sludge disposal considered were selected
because they are economical and can result in a beneficial product
for use on land.
98
-------
IV. B. 1. Application to Land Surface
This method entails the spreading of liquid sludge or sludge
cake directly to land surfaces to act as a fertilizer or soil con-
tioner for land reclamation, soil enhancement, fertilization of grass
and shrubs, etc.
Prior to application to £he ground, the sludge must be stabilized.
Further, sludge must be dewatered and dried if it is to be handled
as a solid or sold commercially as a soil fertilizer-conditioner.
The advantages of land surface disposal of sludge are low cost,
simplicity of operation, and beneficial soil effects. Disadvantages
may include the large land area needed, limited demand for sludge
due to its low nutritional value compared to inorganic fertilizers,
adverse effect of wet weather on spreading and drying operations,
possibility of groundwater contamination, and potential health hazards,
Several States have adopted regulations prohibiting or controlling
application where crops are used for human consumption.
IV. B. 2. Land Fill
This method consists of disposing of treated sludge on land to
a depth of several feet, a method commonly practiced throughout the
country. The sludge is generally stabilized by digestion or heat
treatment and then dewatered to produce a cake.
Advantages include low cost and simplicity of operation. Disad-
vantages include the land area needed (although the required land
area is less than that required for application to land surface) and
99
-------
potential contamination of ground and surface waters by leaching
of the sludge liquid. Soluble organic and inorganic material, if
not used by the vegetation, can appear in the leachate from areas
where sludge is applied.
The following alternative methods of sluge disposal were con-
sidered for the North Bade County Wastewater Treatment Plant and
rejected for the reasons described below.
IV.B.3 Ocean Disposal
This method of sludge disposal consists of piping or barging
digested sludge to the sea and dispersing it in such a manner as
to obtain dilution of the sludge by seawater. An advantage of
this method is its economy for cities along the coastline. Disad-
vantages of ocean disposal are the potential long-term effects on
the marine evnironment, aesthetic considerations, and adverse public
reaction.
Several states, including the State of Florida, and the EPA
have ruled this form of sludge disposal as unacceptable. For these
reasons, ocean disposal was rejected.
IV.B.4 Subsurface Disposal
This method consists of injecting sludge via well systems into
underground caverns or subsurface strata. While used for disposal
of concentrated industrial wastewater, there are few applications
of this method for sludge disposal. The advantages of the method
100
-------
lies in its lew cost and minimal land surface requirements. Dis-
advantages include possible plugging of the injection system, the
need for suitable geological formations, and the possible contamina-
tion of any groundwater occurring in the strata. For these reasons,
subsurface disposal was rejected.
IV.B.5 Incineration
Incineration is actually a conditioning process designed to
reduce sludge volume before disposal. Advantages of sludge incinera-
tion are its compactness and its ability to achieve a large volume
reduction leaving a sterile ash for disposal. Disadvantages
include high cost; potential air pollution, unless stacks are
equipped with elaborate air pollution control devices; and the
need for auxiliary fuel to achieve good combustion. In addition,
it does not provide an ultimate means of sludge disposal because
some means must be devised to dispose of the ash residue. The
recommended landfill method is considered more desirable than sludge
incineration as long as land is available. As sludge volumes
increase, the existing sludge incinerator at Virginia Key may be
renovated and reactivated.
101
-------
IV.B.6. Miscellaneous Methods
Several additional methods of sludge disposal, which have
been rejected for full-scale application, may be used in the future
if the methods become proven.
Protein Source
Sludge may be potentially useful as a food supplement for
livestock and poultry. This has been confirmed experimentally in
the United States and Russia, but the process has not yet been
developed on a sufficiently large scale to permit practical
evaluation.
Building Material
Sludge ash might be used for soil stabilization and as a
component in asphalt paving mixes, cinder blocks, and lightweight
concrete. The process is considered uneconomical.
Composting
Conversion of sludge to humus having fertilizer value roughly
equivalent to cattle manure is technologically feasible and practiced
to some extent in Europe. Compost is more expensive then chemical
fertilizer commercially available and generally needs to be forti-
fied with additional chemical nutrients.
102
-------
IV.B.7 Alternative Sites
Two sludge disposal sites were investigated for the north. Bade
wastewater management system. The first alternative, initially
proposed in the North Bade Draft EIS, called for utilization of an
existing landfill area in the western portion of the service area
near 58th Street to stabilize and dispose of sludge from the north
Bade region. The second alternative, finally adopted in this state-
ment, calls for pumping sludge to Virginia Key for treatment and
disposal. The reasons for selecting the Virginia Key site are as
follows:
• The use of the Virginia Key site would reduce the cost of
sludge transmission. The transmission route to Virginia
Key is approximately one-half mile shorter than to the 58th
Street landfill and would require considerably less pumping.
• The availability of a major wastewater interceptor running
north from the central Dade plant along U.S. 1 allows a
stand-by system much of the way between the two plant sites
which could be employed on an emergency basis, to convey
sludge to the Virginia Key treatment site from the Interama
plant.
• North and central Dade sludge treatment and disposal facilities
can be immediately combined to gain greater economy of scale
and better administrative control under the second alternative
proposal.
103
-------
• The sludge supernatant can be conveniently returned to the
Virginia Key plant for clarification and discharge to the
ocean without a long force main system from the 58fch Street
landfill area.
• To protect groundwater quality at the 58th Street site, a
system of underdrains and an impervious shield would be
required to prevent supernatant and sludge leachate from con-
taminating the water supply well fields near Hialeah. These
protective measures would not be required at Virginia Key
since the groundwater in this area is heavily infiltrated
with seawater and unfit for water Hupply.
• Disposal of sludge at the 58th Street landfill could potentially
contaminate the area's water supply should the system fail
to operate as designed. The Virginia Key site poses no such
problem.
As described earlier in this statement, raw sludge collected at
the north Dade plant will be piped via a duel transmission system to
Virginia Key, where it will be combined with sludge collected at the
central Dade plant and submitted to biological (anerobic) treatment.
Both transmission and treatment will be in closed systems which should
prevent any production of odors either at the site or along the, route
1
of travel. The stabilized sludge will next be subjected to a heat
treatment process under elevated pressure to further stabilize and
104
-------
sterilize the sludge. The solids portion of the sludge will be sepa-
rated from the liquid supernatant by means of centrifuge or vacuum
filtration and applied to diked drying beds adjacent to the plant,
while the supernatant will be directed to the head of the wastewater
treatment process at the central Dade plant. Dried sludge will be
periodically removed from the site and used at parks, golf courses and
for landfill by the county.
IV.C. Effluent Disposal
In March 1973 the Environmental Protection Agency published a
Final Environmental Impact Statement entitled Ocean Outfalls and
Other Methods of Treated Wastewater Disposal in Southeast Florida.
This statement assessed alternative effluent disposal techniques
in the three-county (Dade, Broward, and Palm Beach) Florida coastal
region. The Disposal Methods EIS in its entirety should be considered
an appendix to this statement. The "Summary Analysis" of this
impact statement is included in Appendix I. Some of the major
advantages and disadvantages of possible wastewater disposal sites
are tabulated in Table g.
The Disposal Methods EIS concluded that "the disposal of
(secondary treated) wastewater to the ocean via outfalls is a viable
method of disposal for southeast Florida." It further concluded that
"disposal of secondary treated disinfected effluent by well injection
into the cavernous 'boulder zone' of the Floridan Aquifer is a viable
105
-------
Table 6
EFFLUENT DISPOSAL ALTERNATIVES
IN SOUTHEAST FLORIDA
1. OCEAN OUTFALLS
ADVANTAGES
1. The assimilative capacity of ocean
is large.
2. The discharge point is remote.
3. Operation of outfall is reliable
hydraulically.
4. An outfall could be used as standby
means of disposal should plant
become unoperable.
DISADVANTAGES
1. The total long range effects
are not well documented.
2. There are some construction
damages, including damages to
reef. This reef is unique on
East Coast.
3. A larger initial capital outlay
is required.
4. Extensive piping is required if
site is inland.
-------
2. CANALS AND STREAMS
ADVANTAGES
1. Reduces need for extensive piping
system.
2. Effluent waters are available for
possible reuse such as protection against
salt water intrusion by creation of a
subsurface salinity barrier.
3. Augmentation of surface water flow
aids in Biscayne Aquifer recharge.
DISADVANTAGES
1. Limited assinilative capacity
requires a level of advanced
treatment, now not available,
before disposal into freshwater
sections.
2. Free exchange between surface
aquifers and canal system may
jeopardize water supply.
3. System provides no remote point
of discharge in case of plant
breakdown.
3. DEEP WELL DISPOSAL
ADVANTAGES
1. The effluent is removed from man's
immediate environment.
2. The receiving aquifer consists of saline
water and therefore is not a suitable
water source for domestic uses.
3. It may be possible to reclaim the
injected effluent in the future.
DISADVANTAGES
Construction techniques must be
controlled so as not to contaminate
fresh water aquifer.
Total long range experience is not
as extensive as other means of
disposal.
-------
o
oo
ADVANTAGES
Extensive piping networks can be
reduced.
Modular construction is made possible
which matches construction of treat-
ment capacity and disposal with flow.
3. DEEP WELL DISPOSAL (Cont.)
DISADVANTAGES
3.
A significant operation and
maintenance program is required
due to sophisticated controls.
4. Even for very small effluent
volumes, a minimum investment
of $1 million for a disposal
system is required irrespective
of flow.
4. LAND SURFACE APPLICATIONS I/
ADVANTAGES
DISADVANTAGES
If properly done, no contaminated
water will leave site.
Nutrients can be recycled into pro-
ductive crop.
Water in excess of crop needs will
be available for other uses.
1. Overloading may cause surface or
subsurface rapid runoff.
2. Large land area needed.
3. Soil may be rendered permanently
unfit for other uses through
buildup of toxicants.
4. Crop control required.
_!/ For additional comments concerning pumping wastewater (raw or treated) from the
Central Broward County area long distances to a remote location for land surface
application as an alternative, see Appendix L.
-------
5. SEPTIC TANKS
ADVANTAGES DISADVANTAGES
1. Eliminates need for extensive 1. Effluent not disinfected.
piping.
2. Drain fields will clog if not
2. Helps recharge groundwater. periodically pumped out.
3. Simple system. 3. Large land area per capita needed.
4. Household chemicals enter ground-
water.
5. Difficult to regulate.
6. SHALLOW WELLS
ADVANTAGES DISADVANTAGES
1. Helps to recharge groundwater. 1. Possible degradation of potable
water supply by toxicants and
pathogens.
-------
7. EVERGLADES
ADVANTAGES
Recharge to surface of aquifer
effectively increases local
water yield.
Everglades biota will perform
additional treatment.
DISADVANTAGES
1. Movement in surface water
aquifers requires treatment to
drinking water standards.
2. May cause adverse ecological
changes.
3. Chlorides in salt water infiltrated
sewage would be harmful.
4. Extensive land area requirement for
effluent application.
-------
method of wastewater disposal for the study area." The Disposal
Methods EIS does indicate that land spreading or discharge of tertiary
treated wastewaters to the region's coastal waters represent
potentially acceptable alternatives to the outfall and deep well
approaches. However, because of the lack of demonstrated dependability
to meet water quality requirements, their relatively high cost of
construction, inherent difficulties in operation and maintenance,
etc., the application of these systems in the three-county
southeast Florida region is not recommended at this time.
It is the finding of EPA that deep well disposal and ocean dis-
posal preceded by secondary level treatment will not only meet all
environmental criteria in the respective receiving waters, but will
also provide the widest possible margin of safety to the people
residing in this region.
For a more detailed discussion, the reader is referred to the
Disposal Methods Environmental Impact Statement.
Several factors were taken into consideration in the selection
of the proposed treatment and disposal techniques for north Bade
County. These include the following:
• Initial capital cost
• Ultimate capital cost
• Average annual cost
o Flexibility to meet future objectives
• Relative recycle potential
e Compatibility with present construction programs
111
-------
• Feasibility of initial pollution abatement programs
0 Positive community development potential
• Compatibility with metropolitan plans.
These criteria are briefly discussed in the following paragraphs.
IV.C.I Capital and Operating Costs
The total construction cost of an ocean outfall for the north
Dade region, including the construction of the necessary pumping
station and appurtenances, is estimated to be approximately $14.925
million. An alternative proposal described in the North Dade draft
EIS,which called for extending the existing North Miami ocean outfall
and installing a deep well disposal system to produce a combined capa-
city similar to that of the ocean outfall system (80 mgd) was estimated
to cost approximately $12.688 million. While a savings of $2.237
million could ultimately be realized through the construction of the
deep well system, an even more significant savings could be achieved
during the initial construction phase of the project. It is estimated
that constructing a new ocean outfall from the Interama plant site
to beyond the seaward reef would require an immediate investment of
the entire $14.925, while the North Miami outfall-deep well disposal
alternative could be initiated for a cost of $9.918 million, a savings
of over $5.0 million. This assumes, in both cases, that the construc-
tion of interceptor sewers will be phased over a period of approximately
three to five years. The immediate cost savings attributable to the
deep well disposal scheme results from the ability to phase installa-
tion of the injection system to match the increase in inflow, therby
delaying the investment in construction.
Although the investment required to construct the deep well
112
-------
disposal system is considerably less than that to construct the
outfall system, the cost of operating and maintaining the injection
system is considerably more expensive than that required for the
ocean outfall disposal plan. The average annual cost of operation
and maintenance for the first 25 years for the approach calling for
disposing of treated wastewater via the existing North Miami outfall
and to injection wells is estimated to be approximately $340,000,
while operating and maintaining a new ocean outfall would require
an average annual investment of approximately $120,000. Considering
all costs, over the next 25 years, the present worth of investments
(at 7% per annum) are computed as follows:
Alternative 1 (New ocean outfall) $16.335
Alternative 2 (Phased deep wells & North Miami Outfall)— 16.383
These costs have assumed that the installation of the deep
well system would require acquisition of an additional
parcel of land upon which to place future injection and monitoring
wells and would require additional distribution lines from the treat-
ment plant site to injection and backup wells.
IV. C. 2. Flexibility
Both systems offer flexibility in meeting future objectives.
The injection system could be readily expanded to meet increasing
flow requirements, thereby enabling delay of initial investment and
also providing flexibility to treat future flows, should they
significantly exceed 80 mgd. New wells could be driven when a need
was identified to handle 10 to 20 mgd increments while construction
113
-------
of the outfall could not be phased and could not readily be
modified should future disposal requirements significantly exceed
its design capacity. However, interceptor systems and pumping
stations have been designed to allow reversal of flow, which would
enable inter-connection with the adjacent West or Central Dade
Districts. This provides adequate insurance that wastewater flows
can be kept within the initial design capacity of the proposed
ocean outfall for at least the next 25 years of operation. There-
fore, the major advantage in flexibility which could be gained
through the installation of a deep well system concerns the immediate
savings of construction funds.
IV. C. 3. Relative Recycle Potential
It has been hypothesized that treated wastewaters injected to
the boulder zone of the Floridan Aquifer may be retained in a
"bubble" of fresh water within this otherwise saltwater aquifer.
It is further hypothesized that this reservoir of fresh water could
be tapped at a future date to provide for a variety of demands which
might not otherwise be satisfied. Wastewater flows discharged
through ocean outfalls will, of course, be lost for any reuse
potential.
Assuming the possibility of reuse of injected wastewaters to
exist, it still may be shown to be economically less desirable to
reclaim treated wastewaters than to utilize available surface water
resources which are presently being wasted via canals to the ocean.
114
-------
This surface water supply is also considered far more plentiful in
quantity and has a quality superior to wastewaters, even if treated
to the tertiary level.
In addition to the usual contaminants present in sanitary waste-
water, many collection systems in north Bade County are subject to
excessive salt water infiltration due to the high water table in
this region of the county. This condition is especially true of
the system currently operated by North Miami Beach, which will pro-
vide 12.8 of the initial 40 mgd to be treated at the North Bade
regional treatment plant. The average per capita flow into the
North Miami system is approximately 256 gallons per capita per day.
Wastewater collection in other portions of the county not subject
to significant infiltration average from 80-90 gpd. From this, it
is estimated that as much as 65 percent of the wastewater received
from this system will be brackish infiltrate. If the future re-
cycling of the wastewater treated at the north Bade facility from
deep aquifers was planned, then one of the following would have to
be initiated:
* Extensive repair and replacement of all collection systems
subject to infiltration (major sources of infiltration are
thought to be at service connections);
* Systematic separation of uncontaminated wastewaters from
systems subject to salt water infiltration; and
8 Treatment of wastewaters to remove chlorides.
115
-------
An extensive infiltration abatement program is planned in the
North Miami Beach, area which may be successful in significantly reduc-
ing the chloride level of wastewaters collected in this area. An
inflow/infiltration analysis will be required of the north Bade region
under paragraph 201(g)(3) of Public Law 92-500 and in conformance
with EPA proposed guidelines published March 19, 1973. This may
better identify possible corrective actions which could reduce the
present rate of infiltration into the existing sewer system. However,
even optimistic estimates suggest that chloride levels in current
infiltration problem zones will likely remain well above drinking
water standards (250 mg/1). After blending with wastewaters scheduled
to be collected in the western portion of the north Dade service area,
chloride levels should average less than 500 mg/1.
Treatment to remove chlorides would be extremely expensive if
it could be accomplished at all, on a scale required at the north
Dade plant. It would be clearly less expensive to desalinate unpol-
luted seawater than to remove chlorides and reclaim wastewater if
future demands exceed available supplies.
Separation of saline infiltrated from non-infiltrated wastewater
is an action which could be accomplished by the north Dade system.
Most of the wastewaters which will be immediately intercepted and
treated at the north Dade plant will be high in chloride content, but
as new collection and interceptor systems are constructed in the
western portion of the service area, the opportunity to segregate non-
infiltrated wastewaters will improve. It is estimated that 40 mgd of
116
-------
this wastewater could be segregated, having a chloride content of
approximately 170 mg/1, and could be reclaimed for limited reuse.
The north Bade treatment plant is being designed to accomplish
segregated treatment of "fresh" and "salty" wastewaters.
Regardless of whether a deep well or ocean outfall system is
constructed, both will be available as a backup "safety valve" if,
in the future, more advanced systems to accomplish recycle are installed.
In case of breakdown of these future systems, an outlet will be
available to prevent a crisis to the natural environment of the
coastal area. Therefore, both systems are compatible with the objec-
tive of recycle and reuse.
IV.C.4 Compatibility with Present Construction Program
Both alternatives are equally compatible with the present water
quality management program. The deep well injection proposal does
have greater flexibility since injection wells could be located
practically anywhere in the service area with no significant addi-
tional costs incurred, while the economy of an ocean outfall system
depends upon the location of the treatment facility relative to the
coastline. However, since the centroid of the population to be
served by the proposed north Bade plant is very near the coastline,
the most desirable location for the plant would not be significantly
influenced by the disposal technique selected. In either case, the
best site location for the treatment facility would be as close to
the coast as economically feasible. The treatment capacity of the
facility has been determined by an analysis of possible service area
configurations, and the program proposed has been shown to be the
117
-------
most cost-effective approach to wastewater management for the region.
IV. C. 5. Feasibility of Initial Pollution Abatement Program
The program proposed should produce the greatest improvement in
water quality in the least amount of time. The plant location and
disposal technique are compatible with the region's existing collec-
tion system and will require a minimum additional investment to
achieve a major reduction of wastewater discharges to the surface
waters of the region. The EPA Wastewater Disposal Statement indi-
cates that pre-testing of specific sites and the acceptance of these
sites in accordance with rigid geological and hydrological standards
will be a prerequisite to permitting the operation of a deep well
injection system. This might delay the projected completion date for
the north Bade system if the injection alternative is adopted if anv
nrnhlems were identified as a result of this testing. However, anv delav
should not exceed the neriod expected for construction of the facilities.
IV. C. 6. Positive Community Development
It is the objective of the Dade County Metropolitan Planning
Department to encourage an orderly development of undeveloped lands
in the area. At present, the most heavily urbanized areas of the
region are located along the coast; the county is generally less
densely populated as one travels west from the coast. In order to
minimize the costs of public services (e.g., sewer, water, police,
education, etc.) it is apparent that planned development of available
space in the corridor surrounding the urbanized areas should be the
most rational course of action. The phases of installation of inter-
ceptors, and the proposed location of the treatment and disposal
118
-------
facilities, have been planned to meet this basic ob-jective. Capacity
in these facilities has provided for ample population growth, but
has been designed to channel this growth in an attempt to promote
positive community development.
IV.C.7 Compatibility with Metropolitan Plan
Both the ocean outfall and deep well injection disposal alterna-
tives will be compatible with the proposed Dade County Water Quality
Management Plan. Both will result in removing essentially all point
source waste discharges and eventually eliminating all septic tank
facilities from the surface and near-surface groundwaters of the
North Dade District. Both will meet all management objectives insofar
as providing for the maintenance of both adequate quality and
quantity of usable water resources in the region. Both will provide
an economically feasible and technologically achievable solution to
the water pollution problems identified in north Dade County.
IV.C.8 Recommended Disposal Technique
It is apparent that either a deep well disposal system or an
ocean outfall could be satisfactorily employed to dispose of waste-
waters treated at the north Dade treatment plant. The ocean outfall
approach was selected on the following bases:
• In the long run both techniques are equally expensive. However,
a deep well disposal system would require considerably more
electrical power and require closer surveillance.
119
-------
« The deep well disposal approach, would require field testing
prior to installation. While the possibility is thought to
be remote, any problems identified during field testing could
possibly delay completion of the system.
• Considerably more experience exists regarding the operation
of ocean outfalls than injection wells, especially in the
range of wastewater volumes anticipated in north Dade County.
• Installation of an injection system of adequate capacity to
serve north Dade would require acquisition of additional
property, either at Interama or at a remote location. Such
additional property, within a reasonable distance from the
plant site, would be difficult to purchase. Additional
environmental impact would be incurred at such a site(s)
along the route(s) of the necessary transmission lines from
the plant to the disposal site(s)-
• The State of Florida Department of Pollution Control and the
Miami-Dade Water and Sewer Authority have both strongly sup-
ported the installation of an ocean outfall system for north
Dade County (see letters attached).
IV.D. Alternative Management Plans for North Dade County
A number of alternative management plans were considered prior
to the selection of the proposed plan. Other alternatives which were
also considered called for either collecting only part of the total
volume of wastewater generated in the district for treatment and dis-
posal at regional facilities; exporting the wastewater for treatment
120
-------
and disposal at proposed facilities located in adjacent districts; or
significantly modifying the proposed treatment and disposal plan-
These alternatives are discussed in the following section.
IV.D.I Reduce the Scope of the Interim Water Quality Management Plan
Numerous possibilities exist for reducing the scope of the
proposed plan. One was selected for illustrative purposes and was
based on the assumption that smaller regional systems would be built
and that only minimal provisions would be made to handle future flows.
The reduced plan would result in the following:
• Septic tank disposal systems would not be eliminated
• Treated effluent from existing plants would continue to be
discharged into the inland canal system; and wastewater dis-
charged to the ocean would receive secondary treatment and
disinfection.
The reduced plan differs from the proposed plan primarily in the
capacity of the facilities proposed. In addition to upgrading some
existing local plants and constructing additional transmission systems
in the North Bade District, the plan for the district would include
a 30 mgd secondary treatment plant at the Interama site, which would
utilize the existing North Miami outfall.
The alternative of reducing the scope of the plan was rejected
for the following reasons:
121
-------
• Continued discharge of treated wastewater to inland waterways
would result in the continued degradation of canal water
quality. Increased septic tank discharges to the Biscayne
Aquifer would pose a potential health hazard due to possible
contamination of potable water supplies.
• A general decline in the recreational and aesthetic environ-
ment could result. Such a decline could adversely affect the
tourist industry.
IV. D. 2. Eliminate North Dade Plant and Immediately Build West Bade
The primary difference between this plan and the recommended
plan would be elimination of the North Dade District Plant. Under
this plan, wastewater from the North Dade District would be diverted
to both the Central Dade District Plant at Virginia Key and to a
•new West Dade District Plant.
Projected plant capacities for each of the districts would be
as follows:
Design Capacity - mgd
Plant Location 1975-19-95 1985-2000
North Dade District 0 0
Central Dade District 160 160
South Dade District 50 50
West Dade District 30 115
Total 240 325
122
-------
In addition to new transmission systems for all districts, major
first stage facilities would include:
• A pump station and transmission line from the North District
to the Virginia Key Plant, and a new line across Biscayne
Bay
• Expansion of the Virginia Key Treatment Plant to provide
secondary treatment for 160 mgd from the North and Central
Bade Districts and increase the length and the hydraulic
capacity of the Virginia Key outfall
• A 50 mgd secondary treatment plant for the South Dade District,
in the Goulds-Perrine vicinity, with an associated deep well
injection system
• A 30 mgd secondary treatment plant for the West Dade District
with an associated deep well injection system.
In 1985 as flows increase due to growth, additional transmission
facilities would be constructed in west Dade and the capacity of
the West Dade District Plant would be increased to 115 mgd. The
initial plant capacity in the South and Central Dade Districts would
be adequate until 2000.
This alternate plan is rejected for the following reasons:
• Failure of the West Dade District Plant or the deep well
injection system could pose a public health risk since the
effluent would contaminate municipal water supply wells.
123
-------
• Construction of a new transmission line across Biscayne Bay
to the Central Dade District Plant would result in increased
turbidity in the Bay and would destroy the existing bottom
life in the vicinity of the construction.
• The 50 mgd of North Dade District wastewater pumped to the
Central Dade District Plant for treatment would not be avail-
able for salt water intrusion barrier recharge if such a
future need arises.
• If and when additional water supplies are needed, other
sources superior to wastewater effluents should be used for
supplementing the fresh water in the county.
• The capital costs of the initial facilities to be constructed
under this alternate plan would be more than for the recom-
mended plan.
• Premature urban development pressures would be generated in the
west Dade area.
IV.D.3. Eliminate North Dade Treatment Plant and Pump All North
District Wastewater To Virginia Key (Expanded Central
Plant Plan)
Under this plan, no North Dade District Plant would be con-
structed and wastewater from the North Dade District would be treated
at the Central Dade District Plant at Virginia Key. The South and
West Dade District Facilities would be the same as in the recommended
plan.
124
-------
Projected plant capacities would be as follows:
Design Capacity - mgd
Plant Location 1975-1985 1985-2000
North Dade 0 0
Virginia Key 190 190
South Dade 50 50
West Dade 0 85
Total 240 325
Besides the necessary transmission facilities in all districts,
major first stage facilities would include:
• A pump station and transmission line from the North Dade
District to the Virginia Key Plant, including a new line
across Biscayne Bay.
• Expansion of the Virginia Key Treatment Plant to provide
secondary treatment for 190 mgd from the North and Central
Dade Districts and increasing the length and hydraulic
capacity of the Virginia Key outfall.
• A 50 mgd secondary treatment plant for south Dade on the
Goulds-Perrine vicinity, with an associated deep well in-
jection system.
In 1985, new transmission facilities and an 85 mgd treatment
plant would be constructed in the West Dade District. The initial
capacity of the Central and South Dade District. Plants would be
adequate until the year 2000.
125
-------
This alternate plan is rejected for the following reasons:
• Construction of a new transmission line across Biscayne Bay
to the Central Bade Plant would result in increased turbidity
in the Bay and would destroy the existing Bay bottom life in
the vicinity of the construction.
• The 50 mgd of North Dade District wastewater pumped to the
Central Dade District for treatment would not be available
for salt water intrusion barrier recharge if such a future
need arises.
• The capital costs of the initial facilities to be constructed
under this alternate plan would be more than for the recom-
mended plan.
• The proposal would tend to stimulate growth in the presently
undeveloped western area of the county and conflict with
adopted land use plans.
IV.D.4. Reduce the Size of the North Dade District Plant and
Immediately Build 85 mgd West District Plant
This plan is alternate Plan C of the Interim Water Quality
Management Plan and differs from the recommended plan in that the
North Dade District Plant would be limited in size to the capacity
of the existing outfall, and a West Dade District Plant with a
capacity of 85 mgd would be constructed immediately.
Projected plant capacities for each of the districts would be:
126
-------
Design Capacity - mgd
Plant Location 1975-1985 1985-2000
1975-1985
North Bade 30 30
Central Bade 100 100
South Bade 25 55
West Bade 85 140
Total 240 325
In addition to new transmission systems in all four districts,
major first stage facilities would include:
• A 30 mgd secondary treatment plant at the Interama site and
an extended ocean outfall for the North Bade Bistrict. (Most
of the North Bade Bistrict wastewater having a high chloride
content would be handled by these facilities).
• Expansion of the Virginia Key Treatment Plant to provide
secondary treatment for 100 mgd from the Central Bade Bistrict.
The length and the hydraulic capacity of the Virginig Key out-
fall would be increased to handle flows from both the West and
Central Bade Bistrict Plants.
• A 25 mgd secondary treatment plant for the South Bade Bistrict
in the Goulds-Perrine vicinity with an associated deep well
injection system.
• An 85 mgd secondary treatment plant for the West Bade Bistrict
located west of the Miami International Airport. A pump station
and pipeline crossing Biscayne Bay would deliver treated efflent
127
-------
from the West Bade District Plant to the Central Bade District
Plant at Virginia Key where it would be repumped and discharged
through the Virginia Key outfall.
In 1985, additional transmission facilities would be required in
the West Dade District and the capacity of the West Dade Plant would
be increased to 140 mgd. In addition, the South Dade District Plant
would be expanded to 55 mgd. The initial capacity of the North and
Central Dade District Plants would be adequate until the year 2000.
Plan C is rejected for the following reasons:
• Malfunction of the treatment plant or effluent pipeline with re-
sultant discharge of incoming wastewater to the West Dade
District Plant inland to the Tamiami Canal would pose a
potential threat to the potable water supply in the nearby
well field.
• Future alternate methods of effluent disposal involving water
reuse by pumping to the conservation area would be more ex-
pensive than under other plans because of the easterly location
of the proposed plant site.
* Construction of a new transmission line across Biscayne Bay
to the Central Dade Plant would result in increased turbidity
in the bay and would destroy the existing bay bottom life in
the vicinity of construction.
• Staffing and operation of four treatment plants would be
required in the initial stage. This would entail higher
128
-------
operating costs than the recommended plan which includes only
three initial plants.
• The capital costs of the initial facilities to be constructed
under this plan would be more than for the recommended plan.
IV.D.5. Construct an 80 mgd Tertiary Waste Treatment Plant with
Discharge to the Canal System
This plan would call for the construction of an 80 mgd tertiary
waste treatment plant at the Interama site with discharge to the in-
land canal system to serve as salinity control. The plan would call
for the following project elements:
• An 80 mgd tertiary wastewater treatment plant to be con-
structed at the Interama site.
* A pump station and outfall line from the treatment facility
to a region west of the line of salinity control dams in the
county with discharge to one or more canals on the "fresh"
water side of the structures.
* Construction of the Central, South, and West collection,
treatment and disposal systems as described in the Dade
County Interim Water Quality Management Plan.
This plan was rejected for the following reasons:
• The Treated Wastewater Disposal EIS, published by EPA, cautions
against disposal of wastewaters, (even after treatment to the
tertiary level) to the inland surface waters of the region.
The lack of demonstrated dependable destruction of bacteria
and inactivation of viruses by available tertiary systems
129
-------
suggests this approach, would not totally eliminate the po-
tential public health hazard resulting from contamination of
the canal system.
• The chloride level of wastewaters reaching the north Bade
plant during the early phases of the project is expected to
range over 1,000 mg/1. Since chlorides will not be removed
by tertiary treatment, these excessive concentrations will
by retained in the treated effluent. Disposal to inland
canals would increase the chloride level of these water
bodies and, through infiltration to the groundwater aquifer,
could contaminate domestic water supplies. There is some
question as to whether chloride levels can be reduced to the
degree that all the wastewaters treated at the north Dade
plant could be recycled.
• This proposal provides no margin on safety, should the ter-
tiary system fail to operate satisfactorily. A system break-
down would result in discharging untreated, or partially
treated wastewater to the inalnd surface waters, or coastal
waters of the area.
* The cost of this proposal is excessive, when compared with
alternative ocean outfall and deep well injection systems
requiring only secondary treatment. Unless immediate direct
reuse benefits could be obtained, the use of tertiary systems
cannot be justified at this time.
130
-------
• Other alternatives to disposal of tertiary treated wastewater
to the inland canals were also rejected for the following
reasons:
Land application in the western portion of the county -
High chlorinity would prevent use for agricultural pur-
poses and would increase the salinity of groundwaters in
the Biscayne Aquifer.
Disposal to coastal waters - This would result in no bene-
ficial reuse of treated wastewaters and could not be eco-
nomically justified. System malfunction might result in
contamination of the county's beaches.
Disposal to the ocean - This would result in no beneficial
reuse of treated wastewaters and could not be economically
justified. Studies have shown that secondary treatment is
adequate for ocean disposal.
Disposal to the boulder zone- Studies have shown that
secondary treatment is adequate for wastewater injected
to the boulder zone.
• While immediate installation of the tertiary facilities to
treat all wastewaters at the north Bade plant was judged
inappropriate at this time, if chloride infiltrated waste-
waters can be separated and if more dependable treatment
systems can be developed, part of the north Bade wastewaters
could be recycled at a future date. The proposed wastewater
management system is compatible with this future objective.
131
-------
IV.D.6 "Tri-county Management System
This approach, advocated by some local environmental interests,
would call for collecting all wastewaters over a three-county region
(Bade, Broward and Palm Beach) and pumping them collectively to a
treatment facility located west of the urbanized coastal area (pos-
sibly in Monroe County) with effluent disposal by land application.
Advocates of this scheme have indicated that by returning wastewaters
to the surface aquifer a constant recharge of the groundwater supply
can be attained. Two treatment-disposal alternatives could be envisioned
to accomodate this scheme which would result in adequate protection
of the groundwater quality:
« Secondary treatment with effluent application to a carefully
controlled and harvested system of pasture land. In order to
insure adequate reduction of nitrates in the effluent returned
to the groundwater through vegetative uptake, application
rates could not exceed two inches per week. Therefore, land
requirements will equal approximately 120 acres per mgd
disposed.
0 Wastewater receiving tertiary treatment, which reduces total
nitrogen content to approximately 3.0 mg/1, could be applied
to the land surface at a much higher rate (possibly six inches
per week), thus requiring about one-third as much land for
irrigation.
132
-------
Assuming land availability not to be a critical factor and that
land can be acquired at a reasonable cost, it would appear to be
more economical to adopt the first alternative plan. Adoption of
this plan would require the following facilities:
9 Immediate construction of a 300 mgd facility west of the
urban coastal area of southeast Florida. The facility must
be expandable to approximately 1,000 mgd by the year 2000.
• Construction of interceptor sewers and pumping facilities,
running from the Atlantic coast in Broward County inland
for at least 25 miles and approximately 140 miles along the
Atlantic coast from Jupiter, in Palm Beach County, to Homestead,
in Bade County (several alternative collection schemes could
also be envisioned).
This plan was rejected for the following reasons:
9 Adoption of this plan would result in one of the most momentous
construction programs ever envisioned in the region (with
the possible exception of the Florida Flood Control System,
which has been constructed over the past 30 years) and would
necessitate abandonment of several million dollars worth of
pollution abatement equipment presently in use in the three-
county area.
• Land requirements would equal 36,000 acres (approximately 56
square miles) now, increasing to 120,000 acres ( 168 square
miles) by the year 2000.
133
-------
• Much, of the land available for effluent disposal is subject
to high, water table conditions. This might severely limit
disposal activities during portions of the year subject to
high rainfall and would necessitate storage facilities
adjacent to the site to hold treated effluent until disposal
could be accomplished. If storage of one month's accumulation
of wastewater were required, then a reservoir with a capacity
of approximately 100,000 acre-feet would have to be constructed
(e.g., A teirfoot-deep reservoir would require 10,000 acres
to hold secondary treated wastewater.)
• If the accumulated sludge were also disposed of by application
to the land surface for natural air drying, this would
necessitate extensive preparation of a site (such as installa-
tion of an underdrain collection system, provision of an
impervious shield to prevent leaching into the groundwater,
etc.) It is estimated that approximately 150,000 cubic feet
of sludge would have to be disposed of each day under present
conditions, growing to nearly 500,000 cubic feet/day by the
year 2000. If this were applied to the land surface at a
rate of one inch per week, the minimum land required for sludge
disposal would be 3,000 acres.
134
-------
• The environmental impact associated with installing nearly
200 miles of interceptor sewer, ranging up to eight feet in
diameter, would be very great and would necessitate replacing
many miles of highway, extensive disruption of normal community
activity, etc., and major impacts on the area ecological
resources.
• The environmental impact of discharging 300 to 1,000 million
gallons per day of wastewater to the surface aquifers of
southeast Florida is hot known. It might be expected to
significantly alter the natural geo-hydrological pattern of
the entire region and could have an adverse impact on the
sensitive ecology of the Everglades. An approach which might
have such far-reaching and potentially damaging environmental
impacts would certainly require extensive evaluation before
action could be taken. (Please note additional comment in
Appendix VI)
• Periodic harvesting of pasture crops would necessitate an
extensive agricultural effort encompassing ultimately 12,000
acres. Disposal of harvested plants could pose a problem
since they would not be suitable for human consumption and
would have to be disposed of in such a manner that they would
not result in secondary environmental impacts.
These are not necessarily unsolvable problems, but they do suggest
that the tri-county concept is at least several years from reality.
135
-------
It should be noted that the proposed north Bade facility is not
incompatible with such a concept and that, should a plan of this
nature be adopted in the future, treated wastewater could be
delivered to a western facility for disposal by land irrigation.
IV.E. Alternate Site Location
Of all the sites selected in Bade County, the North Dade Treat-
ment Plant site has received the most intensive study due to its
proximity to a highly developed residential and commercial area.
Thus, a separate report was prepared to consider possible sites in
the north Dade area. It was the conclusion of that report (a summary
of which follows) that the Interama site presented the best location
for the north Dade regional treatment plant.
Since wastewater collected in the North Dade District (under both
disposal alternatives under consideration) is to be treated and dis-
posed of to the Atlantic Ocean, and the present existing facilities
are also designed and operated in this manner, the most logical and
economical location for the treatment plant is at the eastern end of
the collection system. In addition to greater construction and opera-
tional costs, construction of a treatment facility in the western half
of the service area would have a greater adverse impact on the area as
a result of increased disruption and relocation caused by the construc-
tion of the facility. Therefore, the area considered for the location
of the northeast Dade treatment plant was limited to sites east of
N.W. 2nd Avenue.
The selection criteria were basically that the site: 1) must
contain at least 40 acres of land and preferably 70-80 acres to allow
1 "Site Analysis for North Dade Regional Wastewater Treatment Facility"
by Metropolitan Dade County Planning Department, August 1971.
136
-------
for adequate buffer areas around the treatment facilities, and be
under single ownership to expedite site acquisition; 2) be compati-
ble with both existing and planned land uses; 3) not be excessively
expensive to obtain and develop; and 4) minimize the environmental
impact on the surrounding area as a result of construction and opera-
tion of a wastewater treatment plant.
Using the above criteria, tracts larger than 40 acrea under single
ownership were delineated and mapped for analysis. Many of the pos-
sible tracts had to be eliminated as urban development (largely
residential) has already occurred or is proceeding on them. An
example is the huge Aventura tract adjoining the Intracoastal Water-
way. Two other tracts, Greynolds and Haulover Parks, were dropped
from consideration due to the shortage of park facilities in the
county. The remaining undeveloped tracts of over 40 acres plus acres
under one ownership are listed below and shown on Figure 9.
Site 1. A rectuangular tract just east of Interstate 95 between
N.E. 215 Street and N.E. 208 Terrace, located in the unincor-
porated county.
Site 2. An irregular tract between N.E. 2nd Avenue, and N,E. 10
Avenue, and N.E. 215 Street and N.E. 205 Terrace, located in^the
unincorporated county.
Site 3. A rectangular tract just south of N.E. 205 Terrace ad-
jacent to the previous tract, located in the unincorporated
county.
137
-------
tTT . V i-i-L!—. i ^ »•_. ur —rrx L— - f ^t •* -*-.?•--' •
C i t • •• J f1-JJ-T'>' --lr
GREELEY AND HANSrN
CONNELL ASSOCIATES
ENGINEERS 138
DADE COUNTY, FLORIDA
NORTH EAST DADE
TREATMENT PLANT LOCATIONS
-------
Site 4. An irregular tract adjacent to the Dade-Broward County
line just east of Biscayne Boulevard, located in the unincor-
porated county.
Site 5. Maule Lake between Biscayne Boulevard and the Eastern
Shores subdivision, partially in the unincorporated county and
partially in North Miami Beach.
Site 6. The Interama site, including the privately owned Interama
site, partially in the unincorporated county and partially in
North Miami Beach.
The six sites shown on Figure 9 were then further analyzed with
regard to: 1) their present land use; 2) their proposed future land
use; and 3) the estimated acquisition cost; and are compared in Table
7. Based on the information presented in Table 7 t Sites 2 and 3
have been eliminated as being unfeasible (as Site 2 is presently used
as an antennae field and Site 3 is a rock pit and quarry). The four
remaining sites are considered to be of equal feasibility with regard
to land acquisition, and hence the preferred site is dependent upon:
1) compatability with surrounded adjacent land uses; 2) sewerage
system economics, i.e., the least cost incurred as a result of addi-
tional sewerage facilities required to utilize the site selected;
and 3) minimal adverse impact on the environment.
The above "final selection criteria" are discussed in detail in
the previously referenced Bade County Planning Department report and
the relative ranking of the four sites is shown in Table Q
139
-------
Table 7
NORTH DADE WASTEWATER TREATMENT SITE COMPARISON
SITE
PRESENT LAND USE
PROPOSED LAND USE
SITE ACQUISITION COST/DOLLARS PER ACRE
This tract is bordered on the east and south
by single-family residences on the north by
garden apartments and on the west by Inter-
state 95. The area west of 1-95 is undeve-
loped as is the tract under consideration.
The land itself is suitable for construc-
tion, but little land would be left for a
necessary buffer from the immediately
adjacent residential uses. Additionally
the plant be visible from Interstate 95.
The antennae farm of Tropical Telephone,
a vital link in our overseas communica-
tions network, occupies this site.
Single-family residences are adjacent
to the north, east and west. A rockpit
and undeveloped land are the neighbors
on the south. This large site would
be suitable for the plant but, as
mentioned previously, there is a
necessity to maintain the present
communications facility at the site.
Since this site is almost completely
used as a rockpit,' no further considera-
tion will be given to it because of the
tremendous cost involved in filling it
in order to facilitate construction.
Site is projected to be developed as multiple-
family residential. Surrounded by single and
multiple-family residential, except on the
north where the proposed county line express-
way is routed.
25,000
Site is projected to have the same usage.
Surrounded by multiple and single-family
residential except on the north where pro-
posed expressway is routed.
12,500
Rockpit and quarry
N. A.
-------
SITE
PRESENT LAND USE
PROPOSED LAND USE
SITE ACQUISTION COST/ DOLLARS PER ACRE
This large, undeveloped tract would allow
sufficient room for buffering the proposed
plant from its surroundings. To the south
is the huge Aventura high density resident-
tial, shopping, golf course development now
under construction. Biscayne Boulevard
borders the tract to the west. The Gulf-
stream Race Track is located to the-north.
Undeveloped land lies to the east with the
exception of a small area of single-family
homes.
Maule Lake is a body of water approximately
10-12 feet deep and surrounded by high
value residential development, including
the Eastern Shores single-family development
to the east. East Greynolds Park is adjacent
to the southwest and a marina is adjacent to
the west. A 40 acre island would have to
be built to construct the sewage treatment
plant; additional fill than that produced
by tank excavations during plant construc-
tion would be required. Although a buffer
distance would be possible to maintain
between the plant and surrounding
residential uses, the plant would be
visible from all sides of the lake.
The Interama site is a 1,700 acre tract
of land primarily reserved as the site
for the Bicentennial program, Inter-
American Center, a Florida International
Site is projected to be developed as multiple-
family residential, surrounding by like uses,
except where adjacent to the proposed Interama
Expressway.
40,000
Site is projected to have the same usage. Con-
tinuation of existing development; park-usage on
the west, single-family residential to the east
and south, and multiple-family residential to
the north.
2,500 + cost of backfill material and
average depth of 10 feet.
Site will be developed as "Century Center" with 30,000
the proposed Interama Expressway and proposed
rapid transit traversing the tract. Strip com-
mercial uses will be developed along the north
-------
SITE PRESENT LAND USE PROPOSED LAND USE SITE ACQUISTION/DOLLARS PER ACRE
Site 6 continued
University campus, an amusement area, the side of Sunny Isles Causeway, single-family
North Miami recreation area, and other and apartment uses further north, single-
public uses. An exception is the pri- family residential to the south, and multlple-
vately-owned Terama tract used as a family and Haulover Park east of the Intra-
marina, on the northern edge of the c.oastal Waterway.
site.
The Interama tract is bordered on the
east by the Intracoastal Waterway,
with Haulover Park and high-and low-
density residential uses just across
the channel. Single-family residential
areas and Biscayne Bay border the site
on the south, the Biscayne Boulevard
commercial area to the west, and Sunny
Isles Causeway to the north. North of
the Causeway are a few commercial and
*J high-rise residential uses and East
Greynolds Park. A large percentage
of the site has been filled in anti-
cipation of development as outlined
in the Research Group/Hammer, Greene,
Silver Associates report. Much of
the remainder of the site is covered
with mangroves, especially the area
adjacent to the Oleta River.
Fill material produced by the tank
excavations for the treatment plant
would be sufficient to provide a
foundation for the facility.
-------
TABLE 8
FINAL SITE SELECTION CRITERIA
Site
1
4
5
6
Compat ability
with
Surrounding
Land Uses
3
3
2
1
System
Economics
4
3
1
1
Minimum
Adverse
Environmental
Impact
1
1
3
3
Based on the above comparison, it was concluded that Site 6, the
Interama tract, be selected as the site of the north Bade regional
wastewater treatment plant, with the optimum site location within the
Interama tract being the result of a separate independent study.
Further, due to the extensive size of the Interama site, 1700 acres,
and the relatively small treatment plant site requirments, 20-40
acres, sufficient latitude is available in selection of the exact
treatment plant site so as to minimize or eliminate the potential
adverse effects on the "red mangrove" area of the tract.
Siting of the ocean outfall also involved doing as little damage
as possible to the natural environment of the area. A number of
alternative routings for the proposed ocean outfall were investigated
to determine the best means of conveying treated wastewater from
the north Dade treatment plant to the Atlantic Ocean. The route
finally accepted is shown in Figure 10. This route has been slightly
modified from that proposed in the draft EIS to avoid as much of
the native mangrove as possible and to follow, as closely as possible,
existing access roads in the Interama site. Only one leg of the
143
-------
-------
outfall route will result in destruction of mangrove on Interama.
This will be the portion of the pipeline traveling south from the
r
plant and that which skirts the southern edge of the existing white
mangrove area as the line turns in an easterly direction. As previously
noted, this should not adversely affect the productivity of the
mangrove system.
A stretch of mangrove along the Atlantic coast will also have
to be traversed in Haulover Park. The alignment shown in Figure 10
was chosen since the pipeline will pass through a dump area (appearing
on the aerial diagram as a light path) and will have to pass through
only a relatively narrow stretch of white mangrove.
Much of the land area on the Interama site south of the proposed out-
fall alignment is scheduled for development for the bi-centenial
exposition and for other activities. This eliminated the possibility
of laying more of the outfall along established access roads. However,
most of the remaining portion of the outfall (other than that previously
described) will traverse regions which have already been stripped of
their native cover and have reverted to scrub pines, low quality
vegetation or cultivated plants.
In addition to the several routes investigated passing through
Interama, an alternative route running north along the route of
Biscayne Boulevard to Sunny Isles Causeway and then easterly along
the causeway to the edge of Biscayne was considered.
145
-------
The proposed outfall route was adopted for the following reasons:
• The proposed route would involve the least amount of overland
construction and minimize the environmental impact associated
with trenching, blasting and other measures that provide the
pipeline right-of-way; this would also result in an economic
savings.
• The proposed route would produce an optimal alignment with
the "low point" of the coral reef and would ultimately result
in the least undesirable impact on this unique and ecologically
sensitive resource. If the outfall were to be routed by way
of Sunny Isles, additional excavation and additional cost
would be required to reach this low point, with associated
additional impact on the water quality of Biscayne Bay and
the Atlantic Ocean during and following the construction
phase.
• The proposed route would have a minimal social impact during
construction. Construction of the alternative proposal might
be expected to disturb traffic patterns on busy Biscayne
Boulevard and Sunny Isles Causeway and to be a nuisance to
residents fronting on these highways.
These problems would be entirely avoided by adoption of the
proposed routing.
146
-------
V, RELATIONSHIP BETWEEN LOCAL SHORT-TERM USES OF MAE'S
ENVIRONMENT AND THE MAINTENANCE AM) ENHANCEMENT OF
LONG-TERM PRODUCTIVITY
It is apparent that all alternatives available for disposal of
wastewaters from the north Bade region would result in some undesire-
able environmental effects. Regardless of the financial investment,
the task of disposing of human wastes will ultimately produce inevitable
burdens on the natural environment, either direct or indirect, local or
remote. This is true, and will almost certainly continue to be true,
as long as people continue to settle in urban areas.
The construction and operation of treatment and disposal
facilities may be viewed as a social or environmental "overhead",
a price which must be paid as the cost of living in urban America.
The search for the "best" wastewater management plan is, therefore,
a matter of identifying all the environmental costs associated with
each alternative and selecting the approach which is least
environmentally expensive. While these environmental costs are
certainly present in the proposed project, it is believed that this
project will produce the "least costly" solution of all options
available.
The long-term benefits which will result from the proposed
action, measured in improved water quality and recreation potential
and reduced risk to the public health, will far outweigh the short-
term disruption to the local environment and commitment of resources
required in the construction of the system. The collection, treatment,
147
-------
and disposal system will provide for the removal of the majority of
discharges from inland waterways in the north Bade region and result
in discharge of treated and disinfected wastewater to the Atlantic
Ocean. Future plans call for expansion of the proposed collection
system to remove essentially all waste discharges to inland waterways
in the region. The project has the flexibility to meet a variety
of future objectives such as providing a higher degree of treatment
or providing recycleable wastewater for possible reuse.
Studies of existing ocean outfall systems in the southeast
Florida coastal area, which provide a lesser degree of treatment
than that proposed for the North Dade Treatment Plant, have revealed
no cumulative effects associated with this disposal technique. Small
sludge accumulations near the outfall terminus have been observed.
However, with the removal of approximately 90 percent of the suspended
solids, and essentially 100 percent removal of settleable and floating
solid material at the north Dade plant, this condition should be
minimized.
Both field and model studies (See Appendix IV) have supported
the conclusion that, with proper disinfection, bacterial and viral
levels in the recreational coastal waters adjacent to Dade County
will be well within specified State and Federal water quality standards.
All chemical and physical indicators should be substantially the same
as those detected in natural, uncontaminated seawater within a distance
148
-------
of less than a mile from the outfall discharge point. The long-term
cumulative effect of discharging minute quantities of inorganic, or
non-biodegradable, components to the ocean is not fully known, but
with the diluting effect of the Gulf Stream, estimated to be over
seven million times the proposed north Bade plant rate of flow, no
serious effect is anticipated.
The proposed north Bade ocean outfall system is only one of
several ocean outfalls, either operating or proposed, designed to
discharge to the Gulf Stream. Nine individual outfalls presently
discharge from the three-county (Dade, Broward, and Palm Beach)
southeast Florida coastal area alone, for a total of 130.3 million
gallons per day. Consolidation and enlargement of these systems as
presently proposed would result in more than tripling this volume
by the year 1990. While the use of more efficient wastewater treat-
ment techniques will result in significantly reducing the quantities
of many wastewater constituents, those not efficiently removed by
secondary waste treatment will be discharged to the Gulf Stream in
increasing quantities. For this reason, a long-term monitoring
program will be carried out to study in detail any possible impacts
associated with ocean discharge, and future system flexibility pro-
vided to insure that if measurable deterioration of ocean waters is
detected, alternative options will be available to prevent irreparable
harm to the environment.
149
-------
In the long-term, it is anticipated that the availability of
collection sewers will have an impact on the distribution of settle-
ment in north Bade County. The continued expansion and urbanization
of this region will, in turn, have an impact on the natural resource
base of the region. These effects will include a reduction in open
space; an increase in the use of heating fuels and automobile usage
with attendant impact on air quality; and, in general, a change in
the characteristic land use pattern from rural to suburban, eventually
to urban type settlement.
The growth of population in northeast Bade County during the
past three decades has occurred at such a phenomenal rate that it has
often preceded the availability of community services, such as sewage
collection and adequate waste treatment, and has resulted in a variety
of environmental insults. It is apparent that, although the availability
of centralized sewer systems can be a positive factor in channeling
growth, the lack of such systems will not necessarily prevent continued
urbanization of the region, and the environmental deterioration which
has often accompanied such growth. It may be concluded that if growth
is to occur, it is preferable that it be directed and planned, and
that adequate provision be made to preserve the environmental values
of the urbanized region, including the provision of adequate sewerage
service.
The proposed wastewater management plan for north Dade County
has been developed in recognition of existing land use plans which
150
-------
consider settlement patterns, traffic, recreation, and open space
needs and may contribute to the goal of insuring that continued
urbanization in the north Bade region will occur without sacrificing
fundamental environmental values.
It has been suggested that ocean outfalls which disposed of
recycleable wastewater should not be installed in southeast Florida,
since this approach represents a shortsighted solution to one problem
which may ultimately aggravate another problem - that of possible water
supply shortage. Previous sections of this statement have already
indicated that other sources of supply of higher quality are available
to satisfy future demands and could be utilized at a fraction of the
cost of recycling treated wastewaters. In general, these techniques
focus on reducing the loss of storm water presently discharged to
Biscayne Bay during periods of overabundance, such as by backpumping
of canal waters west of the urban coastal areas to groundwater conser-
vation zones, injection to deeper acquifers, for storage in underground
caverns, etc. However, it should be further noted that when viewed
on a countywide basis, the water quality management plan, of which
the north Bade system is an element, is not incompatible with the
concept of recycling and reuse of treated wastewaters. Two facilities,
the south Bade regional system, scheduled to be in operation by 1977,
and the west Bade system, to be in operation by 1985, both will
dispose of treated wastewaters in such a way that reuse of these waters
151
-------
could be accomplished. In addition, the north Dade system may be
modified to provide for the future advanced waste treatment and
reuse of some or all of the wastewaters reaching this facility, if
this should become necessary.
Infiltration of brackish groundwater into existing collection
systems which will be incorporated into the north Dade regional
system may account for a significant proportion of the total waste
flow in some regional interceptors during the early phase of the
management program. The Miami-Bade Sewer and Water Authority has
embarked upon a program to identify and replace defective elements
of local collection systems to reduce the rate of groundwater infiltra-
tion. However, it is probable that much of the wastewaters collected
in the North Miami area will continue to have excessive chloride
levels (greater than 1,000 mg/1) even after infiltration control
programs are initiated.
In order to provide for possible reuse of some or all of the
wastewaters treated at the North Dade Treatment Plant, the system
is being designed in such a way that it may be modified to provide
reusable wastewater in either of two ways:
Up to 50 mgd may be delivered to the treatment plant, primarily
from the western portion of the service area, which will have received
only limited chloride infiltration (less than 250 mg/1). One future
alternative calls for keeping this waste flow separate during the
treatment process and providing a higher degree of treatment to this
152
-------
portion of the wastewater. This portion could then be returned for
limited reuse such as recharging the groundwater aquifer, industrial
water supply, salinity control, irrigation, etc.
Estimates indicate that, with an effective infiltration control
program, the maximum chloride level of all wastewaters reaching the
north Dade plant could be maintained below 500 mg/1. Space is
available at the Interama site to expand the facility to treat all
of the wastewater from the north region to a tertiary level. This
treated wastewater having chloride levels ranging from 250 to 500 mg/1
could be utilized for salinity control in the canal system or for
some limited irrigation purposes.
Table 9 shows the possible allocation of wastewaters which
could be made, utilizing facilities proposed for construction in
Dade County, including the north Dade collection, treatment, and
disposal system assuming reuse of 30 mgd of the north Dade wastewater
flow. Of the total 321 mgd of wastewater projected to be available
by the year 2000, 160 mgd could be reused, employing systems proposed
in the Dade County Water Quality Management Plan. This could provide
for over 40 percent of the increase in water demand projected to
occur between the year 2000 and the present, and could satisfy many
of the non-consumptive water demand requirements such as salinity
control, agriculture, and industrial use.
153
-------
On
-C-
Table 9
WASTEWATER DISPOSAL
DADE COUNTY
Year
1970
1975
1980
1990
2000
Total
154
184
215
272
321
Blscayne
Aquifer
(Septic Tanks)
42
15
5
5
0
QUANTI
DISPO
Inland
Canals
& Bay
27
0
0
0
0
TY - MGD
3AL TO
Ocean
85
157
180
233
271
Boulder
Zone
0
12
30
35
50
Amount Available for Reuse!)
0
42
70
130
160
1) Amount o*f additipnal treatment beyond secondary treatment would depend on the duration, magnitude,
location and type of reuse application.
-------
The final aspect of the proposed north Bade wastewater manage-
ment plan, which may have significant impact on the long-term pro-
ductivity of the natural environment of the region, is the disposal
technique adopted for sludge produced at the proposed treatment
facility. An estimated 67 tons of sludge per day (dry weight) will
be produced at the north Dade treatment facility when operating at
full capacity. This sludge, plus supernatant liquid, will be piped
to a disposal site on Virginia Key where it will be treated, and
then the solids fraction will be applied to the soil surface and
allowed to dry.
When dry, the sewage sludge will be odorless and essentially
free of pathogenic bacteria and viruses and will have the consistency
of cakes of sand. It will have adequate nitrogen and phosphorus
content to enable it to support a normal growth of vegetation. Sewage
sludge has often been utilized as a soil conditioner and fill which
have later resulted in restoration of low quality lands for such
purposes as parks and golf courses. The north Dade management plan
will retain this valuable resource and put it to a useful, constructive
purpose.
155
-------
VI. IRREVERSIBLE COMMITMENT OF RESOURCES WHICH WOULD BE INVOLVED
IN THE PROPOSED ACTION
If the proposed wastewater collection, treatment and disposal
plan is implemented, resources will have to be committed irreversibly
and irretrievably in the construction and as a result of the operation
of the system. These resources will consist of the land upon which
the treatment facility will be constructed, including its native cover
and indigenous flora and fauna; the narrow portions of the offshore
reef through which the new ocean outfall will pass; materials required
in the construction of the system; the electricity and chemicals
required to operate the facilities and the treated wastewater which
will be discharged to the ocean and/or Floridan Aquifer.
VI.A Land Resources
The site proposed for the treatment plant, located in the Interama
tract, consists of 80 acres, approximately 30 of which are mixed man-
grove, including about 11 acres which are typified as coupled mangrove-
estuarine association along the western bank of the Oleta River. This
mangrove area, and that which must be traversed by the proposed ocean
outfall at the edge of Biscayne Bay in Haulover Park, must be considered
valuable natural resources. The portion of the site which will be
disturbed as a result of the construction and operation of the proposed
facility will be approximately 40 acres, including about 15 acres of
predominantly white mangrove,with the remainder being reserved in its
156
-------
native state to serve as a buffer. The plant will be situated away
from the highly productive red mangrove area, and will require the
clearing and landscaping of an area considered to be of little social
or historical significance.
VLB Offshore Reef
There is a natural reef located approximately 12,000 feet from,
and running parallel to, the Bade County shoreline, which must be
traversed by the proposed ocean outfall. It will be necessary to
provide a narrow path through the reef for a zone of several yards
on either side of the pipeline. As a result of the necessary con-
struction, irreparable damage may be done to the reef in a narrow
zone of influence. It is expected that no damage outside of this
construction zone should occur, either directly or indirectly, as
a result of the proposed action.
It is possible that, in time, reef-building organisms may
essentially repair the damaged portion of the reef, but in any
event, the amount of damage envisioned is not significant in com-
parison with the total structure of the reef.
VI.C Construction Materials
A large quantity of resources will be required in the construc-
tion of the proposed system. The interceptor system will require
approximately 34.2 miles of iron pipe, ranging from 24 to 90 inches
in diameter, and 12 individual pumping stations. The new ocean
157
-------
outfall is proposed to be a 22,850-foot-long, 90-inch diameter iron
and/or concrete pipe. The treatment plant will consist of covered
primary clarifiers, reactor tanks, contact chambers and digesters
constructed of concrete and pipes, pumps, heaters, etc., requiring
iron and steel construction.
Some of the materials may be reclaimable for use at other loca-
tions should future requirements dictate their removal from the
system. The north Dade system has been designed to incorporate most
of the existing interceptor network. The major abandonment dictated
by adoption of the proposed ocean outfall plan will be the existing 48-
inch outfall presently serving North Miami (10,000 feet). The expense
of lengthening this outfall and laying a parallel outfall to provide
the proposed 80 mgd capacity would be more costly than to abandon
this facility and construct a new 90-inch diameter outfall. The
environmental impact of these two alternatives would be essentially
the same.
VI.D Operation of the Treatment Facility
The operation of the treatment facility will require an annual
expenditure of about 50,000 megawatt-hours of electricity, 1,200
tons of chlorine gas, and an undetermined quantity of other chemicals,
etc., to achieve acceptable treatment of sewage collected in the North
Dade District. This does not include the cost of pumping sewage to
the facility or to the ocean, nor does it include the materials
158
-------
required to maintain the system in operation. These materials will
be essentially unrecoverable,
VI.E Discharge to the Ocean of Treated Wastewater
Operation of the north Bade treatment and disposal system will
result in an irretrievable loss of all or part of an anticipated 80
mgd of potentially recycleable treated wastewater to the ocean or
the Floridan Aquifer. By the year 1990, discharges from Dade County's
two proposed ocean outfall systems (north Dade and central Dade) will
have reached the system capacity of 190 mgd. Demand for water for all
purposes under extreme drought conditions is predicted to have reached
nearly 700 mgd by 1990, and by this date will have surpassed the capa-
city of presently installed systems by slightly over 200 mgd. It
has been suggested that treated wastewater now proposed for ocean
disposal could be better utilized to prevent a water shortage crisis
in Dade County-
Studies have shown that in the drought year 1961-62 a total of
385,000 acre-feet (about 350 mgd) were wasted to the Atlantic Ocean
through the canal system in Dade County. The average annual runoff
loss is close to a billion gallons per day. The Water Quality Management
Plan prepared by the Dade County Planning Commission has suggested
that much of this freshwater runoff could be captured by backpumping
from the canal system to the western conservation area where it would
159
-------
be made available to recharge the Biscayne Aquifer. The cost
of this proposal is estimated in the plan to be approximately
$12 per million gallons. The alternative of providing advanced
treatment for a similar quantity of recycled wastewater is estimated
to be $72 per million gallons.
In view of alternative sources of supply available to Bade
County to satisfy future water demands, the proposed irretrievable
loss of wastewater is not considered to constitute an unacceptable
constraint.
160
-------
VII. PUBLIC COMMENTS
VILA. Response to Comments made at Environmental Impact Statement
Public Hearing, Miami, Florida, May 14, 1973
Mr. R.C. Willits, Chief Engineer, Miami Bade Water and Sewer Authority
Comment 1:
Recommend increasing the initial phase of the north Bade treat-
ment plant from the proposed 40 mgd to a minimum of 60 mgd.
Response:
A review of the anticipated wastewater inflow to the proposed
north Bade treatment facility by the Miami-Bade Water and Sewer
Authority, its consultant, Connell Associates, and EPA, indicates
that an initial 40 mgd capacity would not allow for expected growth
and expansion of the north Bade service area during the initial con-
struction phase. A 60 mgd facility has been recommended in the final
draft.
Comment 2:
An acceptance of the 60 mgd design figure for the plant would
favor the ocean outfall alternative over the deep well disposal
alternative.
Response:
The updated cost estimates for a 60 mgd deep well disposal
facility are presented in Section IV.C. of this statement. It
should be noted that the estimated cost associated with the construc-
tion of an ocean outfall have also been increased from the Braft EIS.
This increase reflects the increase in estimated cost associated
with construction of the North Bade outfall, based upon recent con-
tracts awarded for similar construction work in southeast Florida.
A comparison of the two alternative costs shows that the long-term
investments associated with the two techniques are approximately
equal.
161
-------
Comment 3:
Deep wells cannot receive raw sewage and must await completion
of the treatment plant expected in 1977.
Response:
This is true. However, it is our understanding that a moratorium
imposed by the State of Florida, Department of Pollution Control
would require a special interim permit to increase the waste load
discharge via the ocean outfall until secondary treatment could be
provided.
Comment 4:
Utilization of deep well disposal will require pretesting which
would delay construction of the installation by more than one year.
Response:
The pretesting required would not delay the completion of the
deep well disposal system beyond the expected completion date of the
North Dade Treatment Plant. Therefore, no delay in rectifying the
current problem would result if the deep well proposal was accepted.
Comment 5:
Continued use of the existing 48" North Miami ocean outfall
will provide disposal capacity for only a relatively small proportion
of the anticipated wastewater discharged (i.e., about 17% of the
daily peak flow).
Response:
This is true. This factor was considered in our economic
analysis in Section IV.C. The use of a small retention basin for
treated effluent to equalize hourly flow was considered to make more
efficient use of the outfall under the second alternative proposal
in the draft EIS.
162
-------
Comment 6:
An additional site would be required if deep well disposal is
adopted in an area where land is difficult to acquire.
Response:
This was assumed in our analysis and an additional cost (both
economic and environmental) was included in our discussion of the
alternatives. It was assumed that additional land could be procurred
in northeast Dade County in the general area of Aventura, which
be compatible with the deep well disposal requirements.
Comment 7:
Requirements for disinfection of secondary treatment should be
specified. These should be consistent with recently proposed national
standards, Federal Register, Volume 38, Number 82, April 30, 1973.
Response:
This change has been discussed in Section IV.A. of this statement,
Mr. Joseph Moffat, Chairman, Committee for Sane Growth, Miami Beach
Property Owners Association
Comment 1:
"Competent authorities" indicate that the best solution to Dade
County's pollution abatement problems is through a "tri-county"
arrangement.
Response:
A discussion of this alternative has been added to the final
statement in Section IV.D. We do not agree that this approach is
the best way of meeting current wastewater management needs, although
as a long range objective, the tri-county arrangement may represent
an acceptable option. The plan proposed in the statement may be
viewed as an incremental step toward a fully integrated, inter-county
regional arrangement and is in no way incompatible with this objective.
163
-------
Comment 2:
The tri-county approach, involving the use of treated waste-
waters applied to the land surface, would solve wastewater treat-
ment problems, help to replenish the fresh water supply, and replace
disappearing soil.
Response:
This may be true. However, many environmental effects associated
with this approach are ,as of now, only poorly understood. It would
require extensive study, including scientific analysis and demonstra-
tion programs, before the full impact of such a proposal could be
defined. Such delays cannot be tolerated in a situation as critical
as that presently exhibited in north Dade County. Please note Appendix VI
Comment 3:
The proposed plan is "outdated" in that it disposes of a national
resource by "throwing it away".
Response:
The wastewater to be disposed of by discharge to the ocean during
the initial phase of the project is expected to be heavily infiltrated
with salt water. Flows reaching the plant from the western portion
of the North DadeRegion will be separated from the salt contaminated
wastewaters and will be available for reuse (after additional treat-
ment) if it becomes necessary to do so. The statement covers this
issue in some detail.
Comment 4:
If the heavy sludge can be piped from east to west, as described
in the impact statement, then the entire effluent could be collected
in the west, the sludge removed and used, and treated effluent piped
to the east, temporarily to the ocean outfall line.
Response:
This is true. However, the reverse is also true. That is,
wastewaters collected in the east could be piped westward for reuse
if this becomes necessary in the future. Since wastewaters collected
during the initial phase of the project have no practical reuse po-
tential, it is more logical to discharge them to the ocean from an
easterly plant location, while retaining flexibility for a western
pumping system in the future.
164
-------
Comment 5:
The statement that the north Dade plant is located at the
"downstream end" of the collection system is in error.
Response:
The term "downstream end" was used figuratively in the draft
statement and was somewhat ambiguous. This has been corrected. The
comment was meant to indicate that the proposed plant location is
near the optimal collection point for the system of existing and
proposed interceptors in the region. Since the interceptor system
will operate under pressure, rather than gravity flow, wastewater
could be pumped in either direction.
Comment 6:
The Interama site was selected solely on the basis of "funneling"
funds to the Interama Authority.
Response:
The Interama site was selected based upon at least three major
criteria:
(1) The site was available at a relatively low cost ($30,000
per acre)
(2) The site is situated at a location such that maximum
use of the existing interceptor system could be made,
and a minimum additional investment of time and money
would be required to complete the north Dade system
(3) The site, along with several other sites, was visited
by both professional and citizens groups, and found to
be most compatible with the proposed facilities' re-
quirements, including size, accessibility and environ-
mental impact.
Comment 7:
Mr. Moffat indicates those he represents accept an ogean outfall
as a temporary solution, to be available as a "safety valve", but
does not accept this approach as an "ultimate" solution.
165
-------
Response:
This is the same view as that accepted by EPA (note Chapter 3,
"Summary Analysis," Wastewater Disposal Methods EIS in Appendix I
of this statement). When it can be shown that treated wastewaters
cannot only economically but safely be utilized to augment the
county's water supply requirements, than as much as 40 mgd or more
could be diverted away from the outfall for reuse.
Mr. Colin Morrissey, Director, Bade County Pollution Control
Department
Comment 1:
The use of deep wells for wastewater disposal has several
associated risks. This technique has not been employed on a scale
proposed for north Dade County and would require extensive testing.
Response:
EPA has expressed a belief that the likelihood of success of
deep well disposal systems in southeast Florida is very great and
that this technique should pose no unacceptable level of risk to
the natural environment of the region.
Mr. Neil M. Goldman, Federal M. D. T. A. Wastewater Treatment Opera-
tion Program, Opa-Locka, Florida
Comment 1:
Mr. Goldman expresses confusion concerning the statement that
it has been found that there is no damage resulting from current
outfall lines which convey raw wastewater to the ocean.
Response:
This is not correct. The draft statement indicated that there
had been detectable deterioration of the ocean ecology near the
effluent point of outfalls dischargin raw sewage, but no discernible
change outside of a rather small zone of influence. The proposed
166
-------
.project will result in eliminating raw sewage discharges from
northern Dade County, please note the outfall studies in Appendix y.
Comment 2:
There is no proof that harmful bacteria could survive and build
up over a period after discharge through the proposed ocean outfall,
and possibly be harmful to tourists that swim in the ocean.
Response:
Since bacteria (and viruses) have a relatively short survival
life in sea water, there is no danger of a "build up" over time. A
very high degree of disinfection will be required of the discharged
wastewaters, such that seawaters should meet State water quality
criteria for contact recreation within a few yards of the outfall
terminus, even under the most adverse conditions. Again note Appendix V
Comment 3:
The city of North Miami has no plans to construct new facilities,
or upgrade existing facilities to the 90% BOD removal, secondary
treatment level.
Response:
The proposed north Dade regional treatment and disposal system
will obviate the need for these facilities. Wastewaters collected
in North Miami will be pumped to the county-owned and operated North
Dade Treatment Plant, and disposed of to the ocean.
Comment 4:
Dischargers in north Dade County are going to continue to re-
lease inadequately treated wastes until the "Sewerama" Plant is
complete, which may not occur until 1985 or 1990.
Response:
The north Dade plant is expected to be under construction
during 1974 and in operation in 1977. The State has imposed a mora-
torium on the waste load which can be discharged through the existing
North Miami outfall which should result in preventing any additional
damage until the new plant and outfall are complete.
167
-------
Mr. James Redford, Jr., President of Izaak Walton League, and member
of the Florida Pollution Control Board
Comment 1:
Deep well disposal of secondary treated wastewaters at the pro-
posed North Dade installation would require time-consuming research
and would be "dilatory", "expensive" and is "not a proven way of
effluent disposal".
Response: •
Deep injection wells could be completed in about the same
amount of time as that required to construct the plant-outfall
systems. Costs for the two systems are presented in Section IV.C.
of this statement and indicate that the two approaches are about
equally expensive. Further information concerning the reliability
of existing deep well disposal systems in southeast Florida is
contained in Appendix I.
Comment 2:
No studies have been performed to determine where wastewaters
will travel after injection to the boulder zone.
Response:
Studies performed to date indicate that wastewaters will not
move vertically between rock strata, and that movement will be
lateral, within aquifer zones. Available information indicates that
movement would take place in all directions, but that the most rapid
movement would be in a southeasterly direction, due to groundwater
pressure gradients.
Comment 3:
It is not known whether a deep well disposal system will work in
this location.
Response:
Data accumulated by the U.S.Geological Survey, the Florida
Geological Survey: the Florida Department of Natural Resources,
and other sources indicate that at least two cavernous zones
should be present to receive wastewaters beneath the'North Dade site.
168
-------
Comment 4:
It is not known how many acres it is going to take to inject
40 to 80 mgd of sewage to the boulder zone.
Response:
Approximately one to two acres would be required for each
disposal site. It is estimated that at least 20 mgd could be injected
at each disposal site.
Comment 5:
Why can an ocean outfall be permitted for discharge of Virginia
Key treatment plant wastewaters, and of Hollywood, but economic
considerations limit its use in north Bade?
Response:
Each case has been independently evaluated by EPA, considering
alternative cost and environmental impact, feasibility of alternative
approaches, population distribution and growth, etc. These factors
can, and do, vary from region to region and must be considered in
determining the "best approach" for each region.
Mr. Randolph Ferguson, Political Science Student, Florida International
University
Comment 1:
What possible effects have been studied concerning stormwater
running into the sewage collection system? Can stormwaters be
separated from wastewaters and returned to the aquifer?
Response:
Infiltration into the wastewater collection system is a major
problem in portions of the north Bade region. As noted in Section
II. C., an infiltration/inflow analysis will be performed by the
Miami-Dade Water and Sewer Authority to fulfill EPA construction
grant guidelines. While infiltrated groundwaters cannot be readily
separated from wastewaters, they can be prevented from entering the
system through proper construction of new interceptors and repair
of existing systems which allow infiltration.
Comment 2:
Can secondary treated wastewaters be used (as in Cocoa Beach
and St. Petersburg) to irrigate golf courses and farm lands in
western Dade County?
169
-------
Response;
The pilot studies being conducted at St. Petersburg and at
Cocoa Beach have dealt with a relatively small quantity of wastewater.
Disposal of 60 million gallons per day would far exceed the irriga-
tion requirements of parks, golf courses, etc., in the county, and
secondary treated wastewater would not be suitable for irrigation of
crops grown for human consumption. Please note comments concerning
pilot studies being preformed in St. Petersburg in Appendix VI.
The high salinity of north Bade wastewaters would pose the additional
problem of potential contamination of the Biscayne Aquifer.
In general, the use of spray irrigation would require extensive
analysis and testing, especially if applied on a scale as required
for north Bade; this would not be an appropriate solution to the
critical pollution problem of the region. However, if spray irrigation
can be shown to be an economically feasible wastewater management
approach in Bade County, this technique could be employed at a
future date as it is compatible with the proposed system.
170
-------
VII. B. Response to Written Comments Received by EPA from
Public and Private Interests
Mr. Forrest W. Howell, Area Director, Region IV, Department of
Housing and Urban Development
Comment 1:
The draft statement indicates treated wastewaters could be
pumped into the Biscayne Aquifer east of the salt front. This
is ambiguous.
Response:
This was erroneous and should read west of the salt front.
Comment 2:
The draft statement indicates that dilution in the ocean
will reduce concentrations of metals and other elements found in
domestic sewage to undetectable levels. The statement continues >.-
that "little if any serious effect is anticipated." The Depart-
ment feels that "a little serious effect is too much." They
recommend these statements be removed, and replaced with facts.
Response:
The draft statement indicates that studies performed to
date have not been able to identify any cumulative effects
associated with ocean discharge. In Section II.B of this state-
ment, it is stated that EPA will require initiation of an
intensive monitoring effort of scientific research to verify
whether any such deleterious effect can be identified on the
ocean ecology resulting from discharge of treated wastes. While
EPA acknowledges that there may be as yet undetermined accumula-
tive effects associated with ocean disposal, the technique
proposed appears to have the least serious potential impact of
all alternatives available. If any serious impact is identified
by the monitoring activities proposed, the treatment level at
the North Dade Plant will be increased.
Comment 3:
Several discussions in the draft were redundent and appeared
under several topic headings. These should be consolidated to
produce a more concise statement.
171
-------
Response:
Your comment is correct. However, several discussions fall
under more than one topic. The basic outline of the EIS is that
which has been proposed by the Council on Environmental Quality.
In striving for completeness and full disclosure, we have
various facets of the same discussion under two or more topics.
Comment 4:
An apparent confusion exists concerning statements that the
wastewaters injected to the aquifer will both "flow toward the
ocean" and "form a dense or bubble of fresh water" in the aquifer.
Response:
Wastewater being less dense than the saline waters in the
receiving formation will tend to form a bubble of wastewater.
Pressures in the formation will force the bubble to grow more rapidly
in a southeasterly direction.
Comment 5:
This is the first EPA statement to present estimated
operating costs for treatment and disposal facilities.
Response:
No comment required.
Comment 6:
The Department urges construction of AWT facilities as a
part of the proposed system, or at the earliest feasible moment.
Response:
It should be noted that the construction of advanced waste
treatment facilities, where they are not needed to meet water
quality requirements, would be unwise, wasteful and environmentally
degrading. The following points should be noted:
1. Only limited funds are available each year for waste-
water treatment facilities. The investment needed to provide AWT
172
-------
at the north Bade plant could double or triple its cost, and delay
rectification of other critical pollution problems in the State of
Florida.
2. AWT facilities require tremendous quantities of chemicals
and electricity as compared with secondary level plants. This could
accelerate the depletion of some of our natural resources and could
have a significant secondary impact related to the provision of these
needs at sites remote from Bade County.
3. The operation of AWT facilities create significant primary
environmental problems beyond those associated with secondary plants.
The disposal of sludge is one problem. The volume of AWT sludge may be
two-three times that of secondary sludges. Some AWT sludges do not
dry readily and are difficult to handle. Chemicals removed from waste-
waters and those added to provide treatment become contaminants of the
sludge, posing difficult disposal problems. However, if it is deter-
mined that a higher degree of treatment is required to prevent undesi-
rable water quality conditions in the Atlantic Ocean, then EPA will
support an upgrading of the treatment level at the north Dade plant.
Mr. Sidney R. Caller, Deputy Assistant Secretary for Environmental
Affairs, U. S. Department of Commerce
Comment 1:
In Section I.D.4 of the EIS, the recreational and commercial
importance of pelagic and benthic organisms in the project area should
be discussed.
Response:
This discussion has been added as per your recommendation in
Section I.D of this EIS.
Comment 2:
A description of the estuarine and oceanographic features and
conditions of the north Dade County coastal area should be provided
to assist in defining the impact of the project on marine life.
Response:
A detailed description of oceanographical features and conditions
of the southeast Florida coastal waters, including prevalent aquatic
life forms, has been presented in Section IV.C and in Appendix A of
173
-------
the Disposal Methods EIS (Appendix I of this statement). The area
of influence of the proposed north Dade ocean outfall is adequately
described by these discussions.
Comment 3:
The comment that "There has been scientific study of the effects
of existing outfalls on water quality and the ecology of the continental
shelf. Such ocean studies substantiate the conclusion that discharge
of secondary effluent to the edge of the Gulf Stream ... should in-
volve only minimal risk of pathogenic infection or ecological damage"
should be documented in the statement.
Response:
Section V.A and the individual studies cited and referenced in
Section V.A. and Appendices A and B of the Disposal Methods EIS pro-
vide extensive documentation to support this statement. Additional
documentation concerning bacteriological and viral studies on existing
Dade County outfalls has been included in Appendix IV of this statement.
Most studies performed to date have been in the vicinity of untreated
or partially treated wastewater outfall discharges. The provision
of secondary treatment and adequate disinfection should considerably
reduce the undesirable effects which are described as associated with
raw waste discharges.
Comment 4:
Mr. Caller suggests that the final EIS for the north Dade waste-
water management system be revised and expanded to allow the statement
to be considered an essentially self-contained document without having
to depend upon the detailed discussions contained in the Disposal
Methods EIS.
Response:
The Ocean Outfalls and Other Methods of Treated Wastewater Dis-
posal in Southeast Florida EIS is designated as Appendix I to the
North Dade EIS and will be made available to all recipients of the
North Dade statement upon request. Since the contents of the Disposal
Methods EIS are applicable to decisions made concerning at least seven
individual impact statements currently in some stage of preparation
by EPA for southeast Florida projects> It would obviously be a waste
of time, money and manpower to document in detail the technical basis
for policy decisions considered similar for each of these seven cases.
174
-------
The North Bade statement has attempted to provide a complete discussion
in the defense of the actions proposed and has cited the Disposal
Methods EIS only for detailed discussion as a means of providing
scientific documentation.
Comment 5:
Ocean current measurements being made by the National Oceanographic
and Atmospheric Administration should be employed in the siting of the
proposed north Dade ocean outfall.
Response:
This information and any other data which can be made available
to the Environmental Protection Agency is welcomed and will be utilized
in determining the location of the ocean outfall discharge point east
of north Dade County. The precise effluent point will be defined at
the conclusion of anticipated oceanographic studies to be performed
during the preconstruction phase of the project.
Colonel Emmett C. Lee, Jr., Corps of Engineers, Jacksonville District
Engineer
Comment 1:
The statement does not evaluate a definite proposed plan of action.
The environmental impacts from the various choices presented could be
substantially different.
Response:
The final statement does evaluate a definite plan of action
(i.e., 60 mgd plant with ocean outfall disposal).
Comment 2:
Previous comments on Ocean Outfalls and Other Methods of Treated
Wastewater Disposal in Southeast Florida EIS transmitted February 27,
1973 apply to this service.
Response:
These comments were answered in the final environmental impact
statement published on March 19, 1973 which should be
175
-------
considered as Appendix I to this statement. These and other
comments were considered in the preparation of the final draft of
the "Treated Wastewater Disposal Methods" EIS, which served as
the overall policy guide for the North Bade Statement.
Mr. Lawrence E. Lynn, Jr., Assistant Secretary, U.S. Department
of the Interior
Comment 1:
The draft impact statement fails to fully disclose the
extent of the problem relating to water supply shortages in
southeast Florida and to discuss the use of recycled wastewaters
to assist in meeting these future demands.
Response:
The projected water supply shortage in southeast Florida was
discussed in the draft statement in Sections I.D. "Physical
Description;" III.B. "Construction and Operation of Proposed
Ocean Outfall Disposal Facility;" IV.C.3. "Relative Recycle
Potential;" IV.D.5. "Advanced Waste Treatment Plan;" V. "Relationship
Between Local Short-term Uses of Man's Environment••.and the Maintenance
and Enhansement of Long-term Productivity;" and VI.E. "Discharge to
the Ocean."
This statement has further elaborated on this issue beyond the
draft statement in response to comments received on the draft EIS.
We have provided responses on the general topic of recycle and reuse
of wastewater to comments presented by Mr. Joseph Moffat,
Mr. Randolph Ferguson, Mr. Forrest W. Howe, Mrs. Anne Ackerman, and
Dr. Hobart T. Feldman.
Comment 2:
Tertiary treatment has been rejected based mainly on economic
criteria rather than for environmental reasons.
Response:
Please note our Response #6 to Mr. Forest W. Howell. While
the provision of advanced waste treatment might "best assure
nondegradation of receiving waters," as previously noted, it
would impose additional indirect environmental burdens in other
locations. Nondegradation is really not an issue here since the
provision of secondary level treatment will result in an overall
improvement of water quality, rather than degradation of ocean
water quality.
176
-------
Comment 3:
The statement does not establish deep well disposal as a viable
disposal method. The description is brief.
Response:
The draft statement refers the reader to the "Wastewater Disposal
Methods EIS" (Appendix I). Over 25 pages of this document were devoted
to a discussion of the acceptability of deep well disposal in south-
east Florida. More than fifty wells have been drilled into the boulder
zone in south Florida. At least ten of these wells are located in
Bade County, Florida. From this data the extent, thickness and
continuity of the boulder zone and the aquicludes have been determined
by the U. S. Geological Survey (Florida District Office), by Florida
Geological Survey, and by several oil companies. Each is in substantial
agreement with the data presented herein by EPA. Several firms have
been successfully injecting wastewaters into the boulder zone in south
Florida for 30 years and in Dade County for three years.
Comment 4:
If deep well disposal is adopted for north Dade, EPA Administrator's
Decision No. 5 should be followed.
Response:
No comment required.
Comment 5:
Cross sections presented in Figures 6 and 7 are in conflict
concerning the depth of the boulder zone. Paragraph 3 on page 40
of the draft statement adds to this confusion.
Response:
It will be noted that Figures 6 and 7 presented in the draft
were for different locations in Dade County (e.g., at Sunset Park
Treatment Plant and at the Tamiami Canal). The depth of the Floridan
Aquifer and its boulder zone below the land surface does vary somewhat
and, at any rate, is not precisely defined in nature. The statement in
the draft EIS was meant to provide a general approximation of the
aquifer depths in the county. Any deep well installation would
177
-------
require preliminary borings to define aquifer depths at the
site. To reduce confusion, one of the two diagrams has been
eliminated from the final EIS.
Comment 6:
The statement presents only a minimal discussion of proposed
construction testing and monitoring requirements.
Response:
Please note discussions in Appendix I, "Wastewater Disposal
Methods EIS," including Appendix D of this document and the
Administrator's Policy Decision #5, regarding deep injection of
wastewaters (attached to this statement as Appendix II) .
Comment 7:
There is a contradiction in the draft EIS concerning whether
or not groundwater quality in the boulder zone would be degraded
as a result of wastewater disposal.
Response:
In the sense that foreign substances would be introduced to
the groundwater contained in the boulder zone, its quality might
be considered to be degraded. However, since this water yould have
no value as a source of water supply, we concur that in fact, no
degradation would take place. The statement has been eliminated
in the final draft.
Comment 8:
The relationship between the physical characteristics of the
'boulder zone" and injection of treated wastewater is not discussed.
Response:
Secondary treated domestic wastewater has been found to be
compatible with the physical, chemical and biological characteristics
of rock formations of the boulder zone.
Comment 9:
Additional comments will be based upon definitive information
concerning this proposal.
178
-------
Response:
The deep well disposal option has not been adopted at the
north Bade location.
Comment 10:
The statement does not describe adequate land provision for
sludge disposal. Incineration is recommended.
Response:
Please note that the plan for sludge disposal has been
modified from that presented in the draft statement. The county
presently owns 60 acres at Virginia Key, owns an option on an addi-
tional adjacent 60-acre parcel which it intends to exercise, 35
acres of which are to be used for sludge disposal, and is adjacent
to a 100-acre existing landfill area on Virginia Key which may also
be utilized for sludge disposal.
The county owns and operates several parks, golf courses, etc.,
and intends to utilize dried sludge as a soil conditioner. Composting
at the landfill area is also a likely possibility. It is expected
that most of the sludge could be productively utilized in this manner.
Incineration of dried sludge would not only deprive the county
of this valuable secondary use, but would also produce other
environmental impacts such as air quality problems and additional
fuel requirements. However, if it becomes apparent that sludge
disposal techniques adopted are not adequate to deal with the
volume of sludge produced, incineration of the excess quantity is
a future possibility.
Comment 11:
The statement did not consider the impact on land resources
associated with deep well disposal.
Response:
The draft statement acknowledged that additional land outside
of the Interama tract might be required if the injection alternative
was adopted. This is further described in this statement and con-
tributed to EPA's decision to select ocean outfall disposal for
the north Dade system.
179
-------
Comment 12:
The adoption of an ocean outfall disposal system with secondary
waste treatment of effluent wastewaters is not consistent with the
goal of maintaining high quality water in the coastal area.
Response:
Ocean outfalls have been successfully operated in southeast
Florida for several years without detectable deterioration of water
quality outside of a localized mixing zone. Most of these facilities
discharge either raw or only partially treated wastewater to the
ocean from outfalls of considerably shorter length than that pro-
posed for north Dade. The provision of secondary treatment and dis-
infection at the north Dade treatment plant should reduce the impact
of wastewater discharge to the ocean to a level such that State and
Federal water quality standards will be protected, and the present
high quality of the region's coastal environment will be preserved.
Comment 13:
The comment that "proper buffer area" will be provided around
the plant is not adequately defined in the statement.
Response:
The proposed location of treatment plant components has been
identified in the site location map included in Appendix V, and a
general site map of the proposed facilities is included in this state-
ment as Figure 12. The buffer around the plant site is planned for
about 200 feet; the site is located nearly 1,000 feet from the nearest
highway and approximately 2,000 feet from the nearest residence.
Comment 14:
The statement that "no change in residential patterns north of
the Interama tract is expected" and "...sewer service. . .will act
as a stimulation to growth in those areas where sewers are not
available" appear to be in conflict.
Response:
The area north of the plant site is already sewered and would
not be in any way affected by the availability of new interceptors
scheduled for construction. The initial statement was meant to
imply that the pattern of development near the
180
-------
Interama plant should not be in any way affected as a result
of the treatment facilities being constructed in this location.
Comment 15:
Maps should be provided to show the projected land use in
the region.
Response:
The sewer construction plans have been designed to provide
for population, industrial, commercial and institutional growth
as dictated in the "General Land Use Master Plan" for Dade County,
adopted in 1965. This is a voluminous document and could not
appropriately be included in this statement. Copies of the
plan may be obtained from the Metropolitan Dade County Planning
Commission in Miami.
Comment 16:
Discussion in Section III.A. of the draft EIS of soil and
vegetative conditions at the proposed plant site is not documented
Response:
A more detailed discussion was presented earlier in the
draft in Section II.B.l., which provides more documentation. The
fact that all of this region has soil of low nutrient quality
has been acknowledged in this discussion. Additional information on
vegetative species in the area has been included in Sec. II.B.l and App. V
Note:
The "Detailed Comments on Environmental Statement" will not
be answered individually, but have been utilized to edit the
content of this statement.
Mr. Donald P. Schiesswohl, Bureau of Environmental Planning and
Evaluation, Florida Department of Pollution Control
Comment 1:
The Department takes the position that an ocean outfall for the
north Dade facility is the most feasible and reliable alternative.
Response:
An ocean outfall for disposal of secondary treated wastewaters
has been recommended in this statement.
181
-------
Comment 2:
The deep well alternative is unproven at this scale in terms
of environmental impact and recycle potential, and extensive pre-
testing required would result in delay of the project.
Response:
utilization of smaller wells has provided the technology
to allow adequate design of a system as large as that proposed
for north Dade County. Please also note our response to comments by
Mr. R. C. Willets.
Comment °>:
Comments concerning south Dade proposal for deep well disposal
apply to the north Dade service area as well.
Response:
This is not the case as the local environmental conditions in
north Dade County are considerably different from those described in
the South Dade EIS which will be affected by the proposed south Dade
treatment and disposal system. The system finally selected in north
Dade will not involve the use of deep well disposal.
Mr. H. E. Wallace, Assistant Director, Florida Game and Fresh Water
Fish Commission
Comment 1: •
The statement rejects tertiary treatment on economic rather than
environmental grounds. The best wastewater treatment should be em-
ployed to assure non-degradation of receiving waters.
Response:
t
Please note our response to question #6, Mr. Forrest W. Howell,
Department of Housing and Urban Development.
Comment 2:
Conclusions reached for not using tertiary treatment conflict
with conclusion reached for using the same degree of treatment at
the Fort Lauderdale, Port Everglades treatment plant.
182
-------
Response:
An ocean outfall is proposed for the north Dade plant; therefore,
secondary treatment Is considered the most appropriate. The Port
Everglades plant, which will treat to beyond the secondary level and
discharges to the Intracoastal Waterway, is much smaller than the north
Dade plant and could better serve as a "pilot study" such as that
discussed in Chapter II, "Summary Analysis" in Appendix I of this
statement. Both the North Dade and Fort Lauderdale statements are
consistent with the conclusions of the Disposal Methods EIS.
Comment 3:
The statement does not adequately describe techniques to be used
to stabilize sludge.
Response:
Sludge collected from the north and central Dade plants will
receive conventional anaerobic digestion followed by heat stabilization
under elevated pressure conditions. The treated sludge will be "de-
watered" by means of the vacuum filtration or centrifuging process
to approximately 25 percent solid content. The stabilized and de-
watered sludge will then be applied to diked drying beds on Virginia
Key.
Comment 4:
Alternative methods of treatment for effluent and sludge handling
during equipment failure should be discussed.
Response:
A duel transmission system is proposed to convey sludge from
Interama to Virginia Key. Should the anaerobic treatment or the
heat stabilization units malfunction, backup units will be available.
The duel design (i.e., both anaerobic digestion and heat treatment)
allows additional flexibility since either process could satisfactorily
stabilize sludge for disposal, should the other process become tempo-
rally inoperable. Should wastewater treatment facilities become
temporarily inoperative, raw sewage could be discharged to the ocean
for a short period of time without irreparable damage.
Comment 5:
Alternative routes for the pipeline between the plant site and
the ocean should be shown on a map with a description of the impact
on ecological communities under each alternative routing.
183
-------
Response:
Alternative on-land routes have been described and discussed
in Section IV of this statement. A map showing the proposed
outfall route and its impact on ecological communities
has.also been shown in Section IV.E.
Mr. L. Ross Morrell, State Archaeologist and Chief, Bureau of
Historic Sites and Properties
Comment 1:
The Bureau recommends an intensive examination relative to
archaeological and historical resources be conducted by professionally
trained archaeologists.
Response:
Your request is acknowledged. The final report on the proposed
sites will be forwarded for review by Mr. Morrell*s office. Dr.
Hemming of the University of Florida has been requested by the Miami -
Dade Water and Sewer Authority to investigate the north Dade plant
site and to prepare a report of his findings.
Mr. Garret Sloan, Director, Miami-Dade Water and Sewer Authority
Comment 1:
In response to a statment in the draft EIS concerning antici-
pated flows in the north Dade system, the following was presented:
(a) Tabulated flow in the existing North Miami outfall,
December 1972 equalled 26.9 mgd
(b) Present flows from treatment plants to be collected into
the north Dade system as soon as the plant is completed
equal 14.2 mgd
(c) Anticipated additional flow resulting from building
permits prior to January 1, 1973 is about 3.0 mgd
(d) The total present flow, based on the above, is 44.1 mgd to
which approximately 1.0 mgd would be added each year as
a result of population growth in presently sewered areas.
184
-------
Response:
This information is acknowledged and appreciated. Based upon
this and other information collected, the initial stage of the pro-
posed north Dade treatment plant has been increased from 40 mgd
capacity to 60 mgd.
Comment 2:
The Department recommends construction initially of a 60 mgd
treatment plant rather than the 40 mgd facility proposed in the
draft statement.
Response:
Please note previous comment. This approach has been adopted.
Comment 3:
Several objections to the use of deep wells for disposal of
treated wastewaters in north Dade were raised:
(a) If the plant capacity is set at 60 mgd (rather than the
proposed 40 mgd), an ocean outfall will be less expensive
to construct and operate
(b) Deep wells cannot receive raw wastes and must await com-
pletion of the north Dade plant in 1977 or later before
providing additional capacity to the presently overtaxed
system.
(c) Necessary pretesting of deep wells could delay rectifica-
tion of the current pollution problem
(d) Continued use of the existing North Miami outfall would
not provide sufficient capacity to dispose of a significant
quantity of the wastewater flow projected
(e) An additional site would be required if deep wells were
utilized.
Response:
Please note our earlier responses to comments presented at the
May 14, 1973 public hearing by Mr. R. C. Willits, Miami-Dade Water
185
-------
and Sewer Authority; Mr. Colin Morrissey, Dade County Pollution
Control; and Mr. James Redford, Jr., Florida Pollution Control
Board.
Comment 4:
Disinfection requirements should be identified, consistent with
EPA guidelines published in the Federal Register, April 30, 1973.
Response:
Please note our response to comment # 7, Mr. R. C. Willits, Miami-
Dade Water and Sewer Authority. The statement has been revised to
reflect this policy change.
Mr. Colin Morrissey, Director, Dade County Pollution Control
Comment 1:
The Department echoes the comments of the Dade Water and Sewer
Authority, calling for a minimum 60 mgd treatment plant capacity,
citing present flow conditions which indicate a 40 mgd plant would
be too small to adequately serve the region's needs.
Response:
Please note our previous comments.
Comment 2:
The Department questions the advisability of disposing of waste-
waters at the north Dade location by use of a deep well injection
system. The Department alludes to various sections of the impact state-
ment on Disposal Methods which indicate that:
(a) The long-term effects of this method of waste disposal are
unknown
(b) It cites discussion of two "well failures" in Florida
(c) It indicates that safe disposal of microogranisms surviving
the sewage treatment process is dependent upon whether the
aquiclude functions as intended
(d) It discusses the possibility of secondary seismic activity
along fault planes which might be produced by injection of
wastes under pressure
186
-------
(e) It indicates the possibility of potable water contamination
through leakage of the well, or through the aquiclude
which requires monitoring of the injection system.
Response:
EPA policy on subsurface emplacement of wastewaters by well
injection in southeast Florida (as expressed in Appendix I) is designed
to protect the Biscayne and upper Floridan Aquifers from pollution or
other environmental hazards attributable to improper injection or to
ill-sited injection wells. One of EPA's goals is to ensure that
engineering and geologic safeguards adequate to protect the excellent
quality of the drinking water in the Biscayne Aquifer and to protect
the integrity of the subsurface environment are adhered to in the
preliminary investigation, design, construction, operation, and
monitoring phases of each injection well project. The EPA will oppose
emplacement of wastewaters and other materials by subsurface injection
in north Bade County and elsewhere, without strict controls and a
clear demonstration that such emplacement will not contaminate
groundwater resources or otherwise damage the environment. It will
be recognized by all concerned that subsurface injection will cease
or be modified at any site when a hazard to the drinking water in
the Biscayne Aquifer, to the surface water resources, to other natural
resources, or to the environment appear imminent.
Mr. Richard Brusuelas, Director of Environmental Health Planning,
Greater Miami Chamber'-of Commerce
Comment 1:
The Chamber also questions the advisability of constructing only
a 40 mgd initial phase facility for the north Dade region.
Response:
Please note our earlier comments.
Comment 2:
In light of the planned Bi-centennial Celebration to be held at
the Interama site, it is hoped that construction can be completed
by 1976.
Response:
It is possible that the plant may not be completed by this date,
although it is EPA's desire that there be as little conflict as
187
-------
possible. Construction of the portion of the outfall traversing the
site will be a high priority project and should be completed before
the celebration. Since the plant site and the site proposed for the
celebration are in different areas of the Interama tract, the pro-
blem, if any, should be small.
Comment 3:
Concern is expressed regarding the electrical energy requirements
of operating a deep well disposal system.
Response:
It is estimated that the electrical energy required to dispose
of wastewaters at the north Dade facility by deep well injection
would be approximately 1,200 kw-hrs per day at maximum capacity
(i.e., 60 mgd).
Comment 4:
Concerning the proposed disinfection practices at the north
Dade plant, it is asked:
(a) What impact will chlorination of the effluent have on the
ocean ecosystem
(b) What precautions will be taken to avoid hazardous situations
involved in shipping and handling of chlorine gas in urban
areas?
Response:
Section V. A. of Appendix I (Disposal Methods EIS) indicates that
since
« "effluent chlorine residuals are normally low on discharge
from sewage treatment plants ( 1 mg/1), and
e discharge through an ocean outfall will provide substantial
immediate dilution,
then the effects on ocean waters would be expected to be very localized
in nature."
The transport of chlorine through urban areas is hazardous, as is the
transport of other toxic, flammable, or explosive commodities such
188
-------
as gasoline, propane, etc., commonly carried through such areas,Truck or
rail delivery of chlorine will require the same types of precautions
and special handling procedures as employed for all hazardous commodi-
ties and would include specially designed and marked tank trucks,
selection of lightly traveled routes, delivery at off-peak traffic
hours, notification of law enforcement agencies of delivery times
and routes, etc. The possibility of generating sodium hypochlorite by
electrolysis of sea water on site was investigated in 1972 by
the Miami-Dade Water and Sewer Authority. However, the process was
not found to be economical and, further, would result in the addition
of chlorides to the treated wastewater. Therefore, this technique
was rejected.
Mrs. Anne Ackerman, Chairperson, "Pollution Revolution," Miami,
Florida
Comment 1:
The Committee objects to the use of the Interama site for the
proposed north Dade treatment plant for the following reasons:
(a) The site has been "set aside" to accommodate cultural and
recreational facilities
(b) The site was chosen to "bail out" financially the Interama
Authority; after a decision was reached, reasons were
developed to support this decision
(c) The site does not lend itself to advanced wastewater treats
ment requirements - where recycling and reuse could be
accomplished.
Response:
Please note our response to Comment # 6 by Mr. Joseph Moffat,
presented at the May 14, 1973 hearing. It should be further noted
that the treatment facilities planned at Interama will be designed
in "low profile" making maximum use of landscaping to shield the
facility from view and to prevent an aesthetically offensive impact
on the Interama site. There is no reason why cultural and recreational
activities cannot be carried out near the site designated for the
treatment plant.
Much study has been directed at locating a site which will be
compatible with future management objectives, including the reuse
189
-------
of all or part of the wastewaters treated. It has been concluded
that, providing sludge treatment and disposal is carried out at
a remote site (as proposed in this statement), the 80-acre Interama
site will be completely compatible with this future goal. The
most likely potential use for recycled wastewater will be for salinity
control to prevent saltwater encroachment westward into the Biscayne
Aquifer, or for industrial purposes. The location of the north Dade
plant would allow convenient use of recycled wastewaters for both
purposes with minimal risk of contaminating domestic water supplies.
Comment 2:
A site in western Dade County is sought immediately because
such a site would lend itself to a sophisticated program. If it is
not constructed now, it may not be constructed in the future.
Response:
A western treatment-disposal system is presently proposed for
1985. This will be the fourth and final plant designed to complete
the Dade County system. It is felt that construction of the north
Dade plant at Interama is completely compatible with any future
program which may be envisioned for wastewater management in southeast
Florida.
Comment 3:
Concern is expressed over the loss of reuseable wastewaters.
Response:
Dade County does not have a water shortage problem; it has a
water management problem. The draft EIS pointed out that a number
of possible actions are under study which can make additional
resources available to meet future demands for at least the next
two decades. These techniques are expected to provide water of
higher and more dependable quality than recycled wastewater at a
fraction of the cost envisioned for reuse of treated wastewaters.
However, if at some future date, recycling becomes a safe and
economical approach to meet the county's growing demand, additional
treatment could be provided to as much as 40 mgd or more of the
north Dade flow to satisfy this demand. The reader is referred to
the Dade County Water Quality Management Plan of the Metropolitan
Dade County Planning Commission.
190
-------
Comment 4:
A smaller plant is recommended at the Interama site using the
existing ocean outfall to dispose of treated effluent. The remain-
der of the effluent should be pumped to a western facility to
receive tertiary treatment prior to disposal.
Response:
This alternative was investigated as an alternative to the
proposed action (see draft EIS and this statement). This approach
was found to be more expensive, would likely delay rectification
of the existing problem, and would seriously conflict with adopted
land use plans. In general it would not be an efficient use of our
limited resources.
Comment 5:
The Committee does not favor deep well disposal of treated wastes.
Response:
No comment required.
Mr. Hobart T. Feldman, M. P., Chairman, Alert Citizens Tri-County
Alliance
Comment 1:
Concerning the use of an ocean outfall to dispose of secondary
treated wastes, this group indicated:
(a) At the terminal point of the proposed outfall, the direction
of the current is definitely shoreward. The Gulf Stream meanders
frequently from one-half to three miles east of this location.
Response:
Since no detectable degradation of water quality is expected
outside a very narrow zone near the outfall terminus, the direction
of the current and proximity of the Gulf Stream will not be essential
factors. Even under the most adverse conditions produced by wind,
tide, current, etc., no violations of the State of Florida Class III
water quality standards are expected outside of the effluent "boil."
Please note the field studies performed in the vicinity of existing
ocean outfalls in Bade County reported in Appendix IV of this statement.
191
-------
(b) Chlorination of the wastewater effluent could have an
adverse effect on the ecology of the ocean waters.
Response:
Please not© our response to question # 4 of Mr. Brusuelas, Greater
Miami Chamber of Commerce.
(c) Comments offered concerning the proposed Palm Beach
ocean outfall system (since rejected) were not considered in the
draft EIS for the north Dade facility.
Response:
These comments were answered in the West Palm Beach EIS. Our
position in that statement and the North Dade Statement is consistent
with Appendix I of this EIS.
(d) The draft statement's comment that water quality will be
improved as a result of construction of the project is in error.
The ocean's quality will be degraded.
Response:
The present discharge of approximately 30 mgd of essentially raw
sewage represents approximately four times the biochemical oxygen
demand and suspended solids load and as much as 100 times the bacterio-
logical load as that expected to be discharged to the ocean in 80
mgd after secondary treatment of these wastewaters. Trace metals
not effectively removed by secondary treatment could increase slightly,
but even these should be significantly reduced in concentration as
a result of effective solids removal.
Comment 2:
Concerning the impact of the outfall construction on the local
mangrove-estaurine association, the group indicates that:
(a) The proposed pipeline would permanently destroy a signifi-
cant portion of an ecologically significant mangrove-estaurine system.
Response:
The extent of the impact of pipeline construction on the mangrove
area has been thoroughly identified and represents only a small pro-
portion of the existing stand of mangroves. Outfall alignment has
been established to minimize this impact. The suggestion that
permanent destruction will occur is overstated.
192
-------
(b) The presence of these mangroves is not listed as a
valuable natural resource.
Response:
The mangrove has been listed as a valuable natural resource in
this statement in Section VI.
(c) Destruction of mangroves would require extensive study and
a permit from Federal and State agencies concerned with the conserva-
tion of mangrove areas.
Response:
The mangrove area will not be destroyed; only small portions of
the existing mangroves will be affected by construction of the plant
and outfall system. The county has applied to the State of Florida
for a permit to construct the outfall.
Comment 3:
Concerning the irretrievable loss of freshwater, the group
indicates:
(a) No suggestion is made to avoid this loss in the draft state-
ment.
Response:
The loss -of saltwater-infiltrated sewage is not thought to be
of signifigant economic or environmental consequence since it has
only limited reuse value. Further, this, loss is not considered of
immediate significance since other sources of water supply of higher
quality are available to satisfy present and future demands at a
cost considerably below that of recycled wastewater.
(b) Backpumping is not a suitable alternative to provide for
future water supply requirements, due to poor water quality.
Response:
Backpumping of canal water, from areas west of populated regions
of the county, is being studied as one means of satisfying future
demands. The quality of this water has not been thoroughly documented.
193
-------
However, according to the Bade County Water quality Management Plan,
preliminary investigations suggest that this water is of such, quality
(both chemically and bacteriologically) that it could be pumped from
canals, such as the Snake Creek and Tamiami Canals west of settled
areas, and applied to the land surface in designated water conserva-
tion areas without danger of adversely affecting existing groundwater
quality. Due to the interconnection of the ground and surface water
systems in Dade County, much of the present recharge of the Biscayne
Aquifer during drought periods is accomplished by infiltration of
canal water into the groundwater system. The recharge proposal would
simply improve the efficiency of this existing recharge phenomenon.
(c) The draft statement notes that "more desirable sources of
water supply [than recycled wastewater] are available" to meet future
demands but fails to describe them.
Response:
Please note our previous comment. While numerous schemes have
been suggested, most focus on more efficiently utilizing the Biscayne
Aquifer groundwater supply and making greater use of the canal waters
of western Dade County. The fact that these sources can be expected
to produce a water resource with lower dissolved solids and viral
counts than recycled wastewater makes them preferable as a source of
general water supply.
Comment 4:
The group expresses several objections to the proposal of in-
jecting secondary treated wastes to the boulder zone.
(a) The hazards associated with injection in north Dade County
were acknowledged but minimized. An example noted was the danger
of leakage near fault zones.
Response:
The Floridan Aquifer system has a 25 to 40 foot above land sur-
face artesian head in Dade County, Florida. Therefore, if any
existing fractures (faults) in the subsurface were open, salty water
from the Floridan Aquifer would be boiling up as a spring or row of
springs along the fracture. No such boils or springs are known to
occur in Dade County,
Pressures necessary to open fractures in the subsurface have
been thoroughly studied by the petroleum industry. Numerous publi-
cations are available. Computations by the EPA and the USGS show
194
-------
that in northern Dade County at a depth of 2500 feet a pressure in
excess of 1500 psi would be required to create a fracture. This
pressure will never be reached because automatic shutoff equipment
installed on each well would stop injection long before the 1500 psi
pressure was reached.
(b) The "immediate" need for recovering these waters was not
considered.
Response:
As previously suggested, the "immediate" need noted here can be
more safely and economically satisfied from sources other than
recycled wastewaters. High chlorinity of wastewaters to be collected
during the initial phase of the project cpuld preclude their use
for most productive purposes, and. therefore, would provide little
"immediate" value even if reclaimed.
(c) The "effluent" is not fit for body contact or ingestion.
Response:
This is true. It is current EPA policy that domestic waste-
waters, no matter what degree of treatment provided, must be
considered unfit for human ingestion. While the plant effluent
itself would not be recommended for body contact, the Coliform
level required at the point of discharge to the ocean by EPA
regulations for secondary treated wastewaters would be such that
it would meet State of Florida bacteriological standards. Mixing
with ocean waters will further reduce this level below body
contact criteria.
(d) The ultimate fate of injected wastewaters is speculated
but not known.
Response:
Please note the response to question #2, Mr. James Redford,
Izaak Walton League and Florida Pollution Control Board.
195
-------
Comment 5:
Objection is expressed concerning the use of the Interama site
for the location of the North Dade Treatment Plant.
(a) The land is expensive, and was not intended for the
installation of treatment facilities.
Response:
See our earlier response to Mr. Joseph Moffat and Mrs. Anne
Ackerman.
(b) The easterly location of the site is not consistent with
objections concerning reuse of wastewaters.
Response:
See our earlier response to Mr. Joseph Moffat and Mrs. Anne
Ackerman.
(c) Dade County's contract with the Interama Authority
specifies that the plant be "odor free." The draft statement
indicates odors may be detectable during plant startup, and in case
of breakdown.
Response:
The periods when odors will be noticeable will be .very few in
number. Much of the plant is to be enclosed. Sludge will not be
processed at the Interama site. Chemicals will be used to oxidize
septic sewage reaching the plant. Standby electrical generation
equipment will be available to protect against temporary power
loss. In short, all reasonable measures will be taken to eliminate
any odor problem at the Interama plant.
(d) Selection of the site was predicated on the assumption
that an ocean outfall would be utilized to dispose of wastewaters.
Response:
This is not necessarily true. The site is also
compatible with deep well disposal alternatives and could, at some
future date, be employed in a system utilizing land application in
western Dade County. The site is also conveniently situated to
accommodate a variety of reuse objectives, such as providing fresh
water for salinity control.
196
-------
Comment 6:
The following objections are raised concerning the discussion
of infiltration into the collection system.
(a) The statement that Bade County "has initiated a rigorous
infiltration abatement program" is untrue.
Response:
Extensive efforts to control infiltration have been underway
for several years by communities in the county. These include
the cities of Miami (which has recently been consolidated with the
county to form the Miami-Bade Water and Sewer Authority),
North Miami, Hialeah, Westwood Lakes Utilities and others. While
these communities are expected to continue their surveillance
of local collection systems, the Water and Sewer Authority will
exercise overall control and guidance concerning the County's
infiltration abatement program.
(b) The volumes of wastewater presented for Bade County are
misleading. They represent the sum of infiltrate flows and those
added by human use.
Response:
This fact was made very clear in the draft statement and is
further discussed in this statement. As previously noted, an
infiltration/inflow analysis will be performed by Bade County as
a condition to receiving EPA construction funds. This study should
help to better define major problem areas and efficient corrective
actions.
(c) An adequate infiltration program "would reduce volumes
to be handled by treatment plants by one-half" This is not economically
sound.
Response:
Inflow/infiltration analysis required by EPA will be utilized
to determine whether it would be more economical to replace "leaky"
systems or to provide additional transmission and treatment capacity
for infiltrated inflows. Under either circumstance, the county will
continue its program of locating, repairing or replacing damaged
systems. While the infiltration rate in some localities may approach
50 percent of the total inflow, infiltration into the entire north
Bade system is expected to be less than 15 percent of the total inflow.
197
-------
(d) The lack of an adequate infiltration/inflow abatement
program should make the'county ineligible for a Federal construction
grant.
Response:
In Section II.D. the EPA requirement to complete this analysis
is noted.
Comment 7:
The type of treatment proposed for the North Bade Plant is
questioned.
(a) The modified activated sludge treatment plant proposed does
not comply with Federal Law 92-500 (1972 Amendments to the Water
Pollution Control Act) since it does not provide for the highest
treatment available for the life of the facility.
Response:
Federal Law 92-500 states no such requirement. Section 101(a)
(2) indicates, "it is the national goal that wherever attainable,
an interim goal of water quality which provides for the protection
and propagation of fish, shellfish and wildlife and provides for
recreation in and on the water be achievable by July 1, 1983."
The proposed program of improvements for north Bade County will
meet this goal. Further, Section 301(b)(l)(B) states that
for "publicly owned treatment works....approved pursuant to
Section 203....prior to June 30, 1974....effluent limitations based
upon secondary treatment..." will be required.
(b) The proposed land application of sludge proposed at the
58th Street landfill has not been adequately field studied and
could result in contamination of drinking water.
Response:
This is true. Based upon this conclusion, it has been decided
to dispose of treated sludge from the North Bade District on Virgina
Key, where no danger of potable water contamination exists.
(c) The split system of effluent sludge treatment at two
different locations would increase the cost of operation.
198
-------
Comment 8;
In the preparation of regional boundaries for water quality
management service areas, county boundaries were imposed - restricting
the possibility of multicounty regional systems.
Response:
The Metropolitan Dade County Planning Commission in developing
its Water Quality Management Plan has considered inter-county arrange-
ments; but, due to the administrative complexity of such arrangements,
coupled with the lack of any demonstrated economic advantage associated
with these alternatives, this approach was ruled out for the immediate
future. If long-range plans appear to make inter-county arrangements
attractive, such as for joint disposal of treated wastewaters, adequate
flexibility exists to accomodate this ultimate objective.
Bruce A. Bell, P. E., Citizen
Comment 1:
High chloride concentrations may prevent present reuse of treated
effluents; however, steps are being taken to reduce chloride levels
and segregate low chloride wastewaters, thus future reuse should be
strongly considered.
Response:
This is essentially the attitude shared by EPA. While it is
questionable whether treated effluent from the north Dade plant would
be suitable for general reuse, it may be possible to reclaim waste-
waters for limited uses, as noted in this statement. The difficulty
with immediately adopting a reuse policy is that
1) utilization of recycled wastewater would be much more expensive
and of lower quality than water supplied from other sources
and should be utilized only if these alternative sources prove
to be inadequate
2) reuse of wastewaters on the scale proposed is untried and could
involve a possible risk to public health
3) an extensive research and field testing program would be required
prior to implementation of a reclamation program. This is not
compatible with immediate abatement needs in Dade County.
199
-------
4) it is still questionable as to how efficient infiltration
control programs will be in eliminating chlorides from the
system.
Research programs are proposed and will hopefully define a means through
which Bade County's current "water shortage" may be alleviated. If
these studies should determine that wastewater recycling is a feasible
and necessary technique, the north Bade project is completely compatible
with this long-range objective and could be modified to accommodate
this goal.
Comment 2:
Physical-chemical secondary treatment would provide advantages
over biological treatment at present.
Response:
At the present time, the state-of-the-art of physical-chemical
systems is still in the exploratory stage. While prototype "p-chem"
systems appear to provide distinct advantages over biological systems,
they are still untried on a scale as proposed in the north Dade area.
Their major disadvantage is the difficulty inherent in operating these
systems and in achieving a dependable effluent quality. They also
require relatively large quantities of electrical power, a commodity
in short supply in southeast Florida.
Comment 3:
Biological, followed by tertiary treatment, is expensive to con-
struct and operate. Physical-chemical treatment facilities constructed
in north Dade County could be inexpensively and efficiently upgraded
to provide tertiary treatment.
Response:
All advanced waste treatment systems are expensive to construct
and operate. To date, biological treatment has been included in nearly
all major AWT systems, although some completely P-chem facilities are
being tested. It is hoped that, by the time a definitive path is
established to meet water resource requirements in Dade County, technology
will have progressed to the point that upgrading of the facility can
proceed in an economically efficient manner. At this point in time,
it is questionable whether a completely P-chem plant could be constructed
and operated any less expensively or more efficiently than a biological
followed by a tertiary treatment system. Given the current popularity
200
-------
of three-stage biological systems in the southeast, it would appear
that a secondary biological treatment plant would be more compatible
with possible future upgrading requirements than a secondary P-chem
facility.
Comment 4:
Cost comparisons presented do not consider systems optimization
for alternatives presented.
Response:
In general cost estimates have been computed from standard cost
curves and modified for such factors as engineering, contingencies,
monitoring, etc. They do not reflect optimization of individual
systems. While the absolute values assigned may be imprecise, the
method of deriving the figures was consistent in all cases. Considering
fluctuations in the cost of construction, the estimates provided are
probably as close as can be achieved.
Comment 5:
The hazard from viruses appears to be overstated.
Response:
Please note discussions in this statement, the Disposal Methods
EIS, references cited therein, and Appendix VI of this report. When
dealing with a projected 80 million gallons per day of wastewater,
and with a geo-hydrological system as sensitive as that in northern
Bade County, a prudent approach would appear to be most logical. Since
it is apparent that a considerable amount of debate still continues
in the scientific community over the effectiveness of wastewater
treatment systems to deactivate viruses on a long-term and consistent
basis, it is believed that the most prudent approach calls for disposal
via ocean outfall. Even advocates of wastewater reclamation have
urged the use of standby "safety valve" systems, so the investment in
the proposed ocean outfall will play a continuing role even if a reuse
policy is adopted at some later date.
201
-------
REFERENCES
American Water Works Association, "AWWM Policy Statement on the
Use of Reclaimed Wastewaters as a Public Water-Supply Source,"
Journal, American Water Works Association, Vol. 63, No. 10,
October 1971.
Bechtel Corporation, "Bulk Transport of Waste Slurries to Inland
and Ocean Disposal Sites - Summary Report," Federal Water Pollution
Control Administration, Department of the Interior, December 1969.
Berg, G. , "Integrated Approach to Problems of Viruses in Water,"
Journal of Sanitary Engineering, Division of ASCE, 6, pp. 867-882,
December 1971.
Bishop, E. W. and N. C. Landrum, 1960, "Control of Salt Water In-
trusion in Dade County for Protection of the Biscayne Aquifer,"
Engineering Report prepared for W. Turner Wallis and Assoc., Re-
printed 1963 by Division of Water Resources and Conservation, State
Board of Conservation, Tallahassee, 1963.
Black, A. P. et al, "Chemical Character of Florida's Waters, 1951,"
Water Survey and Research Paper //6, Florida State Board of Conserva-
tion, 1931.
Black, Crow and Eidsness, Inc., Engineering Report, "Drilling and
Testing of Waste Disposal Well No. 1 - Furfural Plant - Sugar Cane
Growers Cooperative of Florida, " Gainesville, Florida, 1965.
Burns, R. W. and 0. J. Sproul, "Vircuidal Effects of Chlorine in
Wastewater," Journal of Water Pollution Control Federation, Volume
39, No. 11, pp. 1834 - 1849, November 1967.
Chambers, C. W., "Chlorination for Control of Bacteria and Viruses
in Treatment Plant Effluents," Journal of Water Pollution Control
Federation, Volume 43, No. 2, pp. 228-241, February 1971.
Chitty, N. and C. W. Davis, "The Effects of the Discharge of
Secondary Treated Sewage Effluent into the Everglades Ecosystem,"
Sea Grant Special Bulletin No. 6, University of Miami, Miami,
Florida, February 1972.
202
-------
Donaldson, Erie C., and Aldo F. Bayazerd, "Reuse and Subsurface
Injection of Municipal Sewage Effluent - Two Case Histories," USDI,
Bureau of Mines Information Circular 8522, 1971.
Eilers, Richard, "Condensed One Page Cost Estimates for Wastewater
Treatment," EPA, AWT Research Laboratory, Cincinnati, Ohio, November
1970.
Environmental Protection Agency, "Limitations and Effects of Waste
Disposal on an Ocean Shelf," (Florida Ocean 'Sciences Institute),
U.S. Government Printing Office, Publication 16070EFG 12/71,
December 1971.
Environmental Protection Agency, Region IV, "Ocean Outfalls and
Other Methods of Treated Wastewater Disposal in Southeast Florida:
Final Environmental Impact Statement," Atlanta, Georgia, March 19,
1973.
Feldman, Milten H., "Trace Materials in Waste Disposal to Coastal.
Waters - Fates, Mechanisms and Ecological Guidance and Control,"
Working Paper No. 78, Federal Water Quality Agency, Northwestern
Region, 1970.
Garcia-Bengochea, J. I. and R. 0. Vernon, "Deep Well Disposal of
Wastewaters in Saline Aquifers of South Florida," Water Resources
Research, Volume 6, No. 5, 1970.
Greeley and Hansen-Connel Associates, Inc., "Interim Water Quality
Management Plan for Metropolitan Dade County," prepared for the
Metropolitan Dade County Planning Department, Dade County, Florida,
June 25, 1972.
Highway Research Board, "Highway Noise: A Design Guide for Highway
Engineers," NCHRP Report 117, 1971.
Hull, J. E., "Hydrologic Conditions During 1970 in Dade County,
Florida," U.S. Geological Survey, 1972.
Johannes, R. E., "Coral Reefs and Pollution," in press, 1972.
203
-------
Kohout, F. A., "Flow Pattern of Fresh and Salt Water in the Biscayne
Aquifer of the Miami Area, Florida," International Assoc. Sci.
Hydrol. Cotran. Subter. Waters, Publication 52: 440-448, 1960.
Leach, S. D., Howard Klein, and E. R. Hampton, "Hydrologic Effects of
Water Control and Management of Southeast Florida," Florida Geo-
logical Survey Report of Investigations, No. 60.
Metropolitan Bade County Planning Department, "Site Analysis for
North Dade Regional Wastewater Treatment Facility;" Miami, Florida,
August 1971.
Metropolitan Dade County Pollution Control, Special Water Pollu-
tion Control Survey, Effluent Point of Miami Beach Outfall, July 28,
1970.
Meyer, F. W. , (U.S. Geological Survey), "Preliminary Evaluation'of
the Hydrologic Effects of Implementing Water and Sewerage Plans,
Dade County, Florida," 1971.
Parker, G. G. , "Geologic and Hydrologic Factors in the Perennial
Yield of the Biscayne Aquifer," Journal, American Water Works
Association, Volume 43, p. 817-834, 1951.
Parker, G. G., et al, "Water Resources of Southeastern Florida with
Special Reference to the Geology and Groundwater of the Miami Area,"
U.S. Geological Survey Water Supply Paper 1255, 1955.
Post, Buckley, Schuh and Jernigan, Inc., and Hazen and Sawer, for
the Metropolitan Dade County Water and Sewer Authority, "Environ-
mental Assessment of the Interim Water Quality Management Plan,"
September 1972.
Smith. Robert, "Cost and Performance Estimates for Tertiary Waste-
water Treating Processes," Federal Water Pollution Control Administration,
AWT Research Laboratory, Cincinnati, Ohio, June 1969.
Sowder, W. T., Director, Florida Division of Health, "Ocean Outfalls
Pose No Virus Disease Threat," J. Florida MA/June 1972.
205
-------
U.S. Department of the Interior, "Conference in the Matter of Pollu-
tion of the Navigable Waters of Dade County, Florida and Tributaries,
Erabayments and Coastal Waters," Miami, Florida, in three volumes:
First Session, October 20-22, 1970
Second Session, February 18-19. 1971
Third Session, July 2-3, 1971.
Vernon, R. 0., "The Geology and Hydrology Associated with a Zone
of High Permeability (Boulder Zone) in Florida," Soc. of Mining
Engineers, AIME, Preprint No. 69-AG-12, 1969.
206
-------
APPENDICES
207
-------
APPENDIX I
Summary Analysis of OCEAN OUTFALLS AND
OTHER METHODS OF TREATED WASTEWATER DISPOSAL
IN SOUTHEAST FLORIDA
208
-------
CHAPTER III
SUMMARY ANALYSIS
The basic consideration in the treatment and disposal of wastewater
is protection of public health and the environment. Federal law requires
that wastewater receive secondary treatment prior to discharge into the
nation's waters. For the purpose of this Environmental Impact Statement,
secondary treatment is defined as:
a. 100% floatable and settleable solids removal.
b. 9Q% five-day biochemical oxygen demand (BOD) reduction.
c. 90% suspended solids (SS) reduction.
d. Disinfection to reduce fecal coliform to a monthly average
of less than 200 per 100 ml and viruses by 99%.
Secondary treatment plus disinfection, and selected disposal of
effluent to provide separation from man by both time and distance,
will protect the public health. With regard to pathogenic organisms,
EPA is fully cognizant of the state-of-the art of epidemiology, and
the reliability and effectiveness of sewage treatment processes for
pathogenic inactivation, including advanced waste treatment technology.
It is not clear at the present time what benefits would be derived from
plete elimination of pathogenic organisms from sewage effluent to
offset the costs required to achieve such a high goal. Even the
most advanced form of sewage treatment cannot achieve 100% inactivation
of pathogenic organisms 100% of the time. Nonetheless, EPA encourages
209
-------
the application of advanced waste treatment methodology, providing the
goals are clearly defined and the risks of not meeting the goals on a
continuous basis at the additional expense are acceptable.
OCEAN OUTFALLS
The disposal of wastewater to the ocean via outfalls is a viable
method of disposal for southeast Florida. Diversion of wastewater
from inland surface waters to ocean outfalls will substantially and
immediately improve the quality of those surface waters and will con-
tribute to the long-term enhancement of inland surface water quality.
Conditions under which the ocean outfall method of disposal may be
used are:
• Alignment of the outfalls will be established to minimize
disturbance of the reefs. A physical and biological site
survey will be required to establish that alignment.
• The outfalls will end beyond the last reef such that, under
maximum shoreward current conditions, the boil will not
overshadow the reef.
• A continuous monitoring program will be initiated to detect
any unforeseen changes in the marine environment and should
such changes occur, alternate disposal methods will be
required.
Secondary sewage treatment followed by adequate disinfection
provides substantial reduction of disease-causing organisms, and
9 210
-------
additional inactivation is obtained by exposure of organisms to ocean
waters. Dilution of residual pollutant matter, including pathogenic
organisms, and the separation of the effluent from the general popula-
tion provided by ocean outfalls, will protect the public health.
Ocean outfalls have been used to dispose of untreated and partially
treated sanitary sewage from the populated areas of southeast Florida
for over 30 years. Based on recent studies, it was found that there
are no detectable adverse effects beyond the small zone at the end of the
outfall pipe. Neither is there any evidence of cumulative adverse effects
resulting from the long-term discharges of untreated wastes. This,
however, does not eliminate the possibility that changes are occurring
which may be so subtle as to be undetectable by short-term observation.
Ocean water chemistry data confirm that the Gulf Stream and coastal
waters are nutrient-poor. Upgrading existing treatment facilities,
which utilize ocean outfalls for effluent disposal, to secondary treat-
ment, in addition to construction of the North Broward and West Palm
Beach systems and their ocean outfalls as proposed, would result in a
net reduction of 96,940 pounds/day suspended solids (SS)- and 88,940
pounds/day BOD from present discharge levels. Even if outfall systems
were to be used until the year 2000, loadings of BOD and SS only would
be approximately 60% of what they are today.
It is the policy of EPA, as reflected in the goals in the Federal
Water Pollution Control Act Amendments of 1972, to eliminate discharge
to the nation's navigable waters. Ocean outfalls are considered an
10
-------
interim solution to total wastewater disposal until reuse and reclama-
tion methods are identified, developed, and reliably implemented. At
that time, outfalls will become a secondary method of wastewater disposal
which will provide a safety valve during times of human error, mechanical
failure, or adverse natural conditions.
CANAL OR INTRACOASTAL WATERWAY DISPOSAL
The freshwater canal systems and inland tidal waters of southeast
Florida have long been used for the disposal of wastewaters because they
are convenient. The surface waters of Dade, Broward, and Palm Beach
Counties are classified almost exclusively for recreation and/or fish
and wildlife uses, both of which permit direct human contact with these
waters. Since disposal of treated wastewater effluents into these surface
waters would present the immediate hazard of direct contact with man,
protection of public health is of critical concern. The freshwater
canals recharge the Biscayne Aquifer during dry periods, and the possi-
bility of contaminating this potable water supply also exists. The
uncertainties connected with the continuous complete destruction of
pathogenic bacteria and removal or inactivation of viruses by standard
secondary sewage treatment processes, even with adequate effluent dis-
infection, suggest that other alternative forms of effluent disposal
which minimize contact with man should be used.
The use of freshwater canals for treated effluent disposal would
provide freshwater for groundwater recharge and protection against
212
-------
saltwater intrusion during dry periods. However, many of the surface
waters of the three-county area are already degraded because of existing
discharge of treated and inadequately treated municipal and industrial
wastewaters. The use of large regional wastewater collection and secondary
treatment systems, while removing the pollutional load from presently
affected areas, would concentrate it in others. The freshwater canals have
a limited assimilative capacity, particularly during periods of drought,
and could not assimilate these large treated wastewater volumes. Since
secondary treatment does not significantly remove nitrogen and phosphorus,
nutrient enrichment and resulting nuisance algal and aquatic weed growths,
in addition to biodegradation of residual organic matter from secondary
effluents, would undoubtedly result in anoxic conditions and subsequent
damage to desirable aquatic life forms. Nutrient concentrations in
much of the Intracoastal Waterway are also high, and the discharge of
secondary effluents into these waters would result in nutrient over-
enrichment.
Since the freshwater canals receive nutrients from other sources
such as agricultural operations and urban runoff and already have signi-
ficant quantities in them, it seems apparent that present AWT techniques
for nutrient removal would not reduce nutrient levels in wastewater to
a level such as to preclude over-enrichment. The saline reaches of
the canals present a different situation regarding assimilative capacity
and in some situations would present the opportunity for a pilot study
on the discharge of a wastewater subject to AWT for nutrient removal.
I,
213
-------
The use of chlorine for the disinfection of secondary treated waste-
waters results in the possible formation of toxic chlorine-nitrogen
compounds which adversely affect fish and other aquatic life. The
confined canals or portions of the Intracoastal Waterway present con-
ditions conducive to danger from such toxic compounds and suggest that
other disinfection methods be investigated when considering this method
of disposal.
DEEP WELL DISPOSAL
Disposal of secondary treated disinfected effluent by well
injection into the cavernous "boulder zone" of the Floridan Aquifer is
a viable method of wastewater disposal for the study area. Use of this
disposal method will, under proper construction and operation practices,
effectively separate from man pathogens surviving the treatment process
and other residual pollutants. Diversion of wastewaters from surface
waters to deep wells will substantially and immediately improve the
quality of those surface waters and will contribute to the long-term
enhancement of surface water quality.
The long-term effects of this disposal method in the disposal zone
are not known. Careful construction, inspection, and monitoring, as
required by Florida's Disposal Well Permit Policy, will assure protec-
tion of the overlying aquifer by detecting leaks or failures in time to
allow effective corrective measures to be taken.
J Z 214
-------
Water in the cavities below 2,500 feet is of a quality similar to
seawater. Displacement of this water by a secondary treated effluent will
lead to the formation of a freshwater layer within the caverns. Based
upon the assumption discussed in Chapter V.C.,growth of this layer is
estimated at a rate of about four square miles per year per 100 mgd of
discharge. Wastewaters stored in this way could, under controlled con-
ditions, possibly be retrieved during droughts and used as a source of
freshwater for irrigation, for prevention of saltwater intrustion into
the surface canal systems, or for other uses which would justify costs
of reclaiming the stored water. Retrievable injected wastewaters would
have to be evaluated for possible additional treatment according to
the intended use.
LAND DISPOSAL
Presently, in Dade, Broward, and Palm Beach Counties there are 92
small sanitary waste treatment plants and 13 industries utilizing local
land disposal systems to dispose of 5.66 mgd of liquid wastes. Environ-
mental effects of these disposal systems are not known.
Land disposal of treated wastewater can provide additional water
purification (after waste treatment), conserve freshwater, and utilize
nutrients and other constituents for productive purposes when applied
to crops. Studies on the health risks of land disposal indicate a
continuing concern,while still drawing the general conclusion that it
is safe and acceptable practice if soil, hydrologic, and climatic conditions
215
-------
are favorable. However, this method of wastewater disposal has limited
application in southeast Florida because of the high groundwater table
and the unsuitability of the soil of some available unurbanized land.
Large-scale utilization of conventional land disposal systems in
southeast Florida will require:
% Large land areas for effective disposal (approximately 20,000
acres per 100 mgd for crop irrigation).
• Separation of high saline wastewaters from coastal areas from
the "fresher" wastewater from the western areas.
• For utilization of existing farm land, either direct govern-
mental control through purchase or condemnation of legal
controls over private enterprise farm practices.
• For conversion of undeveloped land.
Replacement of natural vegetation with year-round
harvestable crops which cannot be used for direct human
consumption.
Provisions for disposal of the natural vegetation and
harvested crop in such a manner as not to violate water or
air quality standards.
Control of the water table to permit hydraulic loading and
survival of the cover crop.
The conversion of wet-lands to dry-lands to prevent ground-
water contamination.
216
-------
« Provisions for storage of excess wastewater during wet seasons
and harvest times.
• Provisions for disposal of excess reclaimed irrigation water.
All of the requirements impose secondary ecological stresses
on the area.
SEPTIC TANK DISPOSAL
In south Florida during, the past 25 years, the demand for housing
has exceeded the ability and desire to supply wastewater collection and
treatment facilities in all areas. In many cases, this shortcoming
has been met by constructing individual household septic tanks. Presently,
approximately 275,000 septic tank systems serving an estimated 962,000
people are in use within the three-county-area. However, continued
widespread use of septic tanks within areas of low population density
may be considered as a viable temporary method of wastewater disposal
until additional wastewater collection and treatment systems are
provided.
Increased use of septic tanks for disposal of the area's waste-
waters reduces the margin of safety for south Florida's invaluable
groundwater supply. The probable contamination of the Biscayne Aquifer
with nutrients, toxic metals, trace organic chemicals, pathogenic
bacteria, and viruses by the discharge from improperly operated and
maintained septic tank systems cannot be avoided. Failures of individual
septic tank systems is a known public health hazard.
217
-------
SHALLOW WELL DISPOSAL
The disposal of wastewaters through shallow (less than 200 feet deep)
injection wells into the permeable limestones of the Biscayne Aquifer
has limited application. The use of shallow well disposal would provide
for recharge of the Biscayne Aquifer and for protection against saltwater
intrusion during drought periods but at considerable risk of groundwater
contamination.
It is not environmentally acceptable to dispose of or store treated
wastewaters by subsurface injection through shallow disposal wells where
such wastewater may interfere with present or potential uses of these
subsurface waters, or otherwise degrade water quality. Since the
introduction of secondary treated wastewaters into the Biscayne Aquifer
could adversely affect use of the aquifer as the principal local water
supply, the Environmental Protection Agency does not consider shallow
well injection as a viable alternative method for disposal of treated
wastewaters in southeast Florida.
Wastewaters injected into the porous Biscayne Aquifer would move
rapidly toward the intakes of nearby water supply wells. Since the
secondary sewage treatment does not completely remove pathogenic
organisms, disposal of wastewaters to shallow wells would introduce
pathogenic organisms into the Biscayne Aquifer.
Wastewaters from some treatment plants in the study area have
chlorides exceeding 1000 mg/1 from the seepage of seawater into sewage
lines located near the coast. Chlorides, along with other residual
218
1 f
-------
wastewater contaminants, could reduce the chemical quality of the Biscayne
Aquifer waters below acceptable drinking water standards.
DISCHARGE TO THE FLORIDA EVERGLADES
The importance of the Everglades marshlands has long been recognized
in the hydrological, climatological and ecological makeup of southern
Florida. The existing environmental relationships are extremely complex
and are difficult to qualify or quantify. The natural conditions of
the Everglades region is manifested by a wet-dry hydrologic fluctuation known
as the "hydroperiod".
A perplexing problem in managing the Everglades is the regulation of
canal water replenishment schedules to comply with the natural hydro-
period of the Everglades. Regulated discharge of treated wastewater to
the Everglades could supplement flow during low water conditions and
optimize water level changes which are more accentuated now than they
were under natural conditions in the past.
The discharge of treated wastewater would introduce additional
nutrients to the Everglades. Scientists believe that maintenance of
historic nutrient levels is crucial to the preservation of the present
ecosystems intact, as well as to the biological well-being of
the Everglades National Park.
With the present state of knowledge, the effects of the discharge of
treated wastes on the Everglades are unpredictable, although current
studies suggest that any increases in nutrients would sufficiently alter
1 219
-------
the unique Everglades ecosystem to the extent that changes would not
be reversible. Such irreversible changes must be avoided.
NO ACTION
Continued present policies and practices of wastewater disposal
will result in the gradual degradation of environmental quality of
southeast Florida.
WATER MANAGEMENT
The key to a healthy and productive environment in southeast Florida
lies in overall water management. The solutions to the water problems
of the area should provide an optimum balance between the needs of man
and the needs of his environment.
The potential for water shortages exists. As recently as the
Spring of 1971, some areas of the urban-suburban three-county area
were rationed potable water. The Corps of Engineers reports that the
freshwater resources presently available for all uses can be exceeded
by the demand for all uses by 1976, after completion of all works
authorized by Congress prior to 1968.
An authorized proposal for the construction of new works should,
when implemented, satisfy most water demands for agriculture, Everglades
National Park, and urban needs under normal conditions. However, it is
agreed by Federal, State, and local governments that water shortages will
occur in the future during severe droughts.
, - 220
J •/
-------
The Ad Hoc Technical Committee on Wastewater Reuse in Southeast
Florida has published a plan of study to develop alternative decisions
required to implement wastewater reuse and storm water conservation.
This plan is a logical approach to arrive at the needed answers and
achieve water conservation goals. It is incumbent upon all levels of
government to recognize that ocean outfalls are not the ultimate solution
to disposal of treated wastewater but are an interim measure to meet the
immediate pollution abatement needs,and to provide a "safety valve" in the
future, and the "no discharge" goal for 1985, which has been adopted in
the 1972 FWPCA Amendments, is an understood mandate to not rely on ocean
outfalls for a long time into the future.
Abandonment of existing plans is not in the interest of good water
quality management as severe environmental degradation exists today.
While correction of existing problems is occurring, however, there
must be an accelerated program for developing wastewater management and
reuse systems for southeast Florida. Any waste treatment and disposal
schemes implemented today must meet the basic criteria of flexibility
so as not to preclude or otherwise deter reuse considerations for the
future when study and research allow it.
PALM BEACH PROJECTS
The following is the course of action regarding method of disposal
approved for the Palm Beach projects:
221
-------
1. Construct a test well for the purpose of obtaining the required
information to determine if deep well disposal of secondary effluent
is feasible at the site. This is estimated to take nine months. If
the test well proves successful, construction will proceed for comp-
letion of the deep disposal wells with appropriate backup and
monitoring equipment consistent with EPA and State of Florida
regulations.
2. If the test disposal well is unsuccessful, the applicant will
proceed with the construction of the proposed approximately 6000-
foot outfall with the addition of multi-media filtration.
In the event the implementation of the above course of action
proceeds to step two» there is a possibility that the treatment plant
could be finished before the ocean outfall. This would mean that
secondary disinfected effluent from the new plant may be discharged to
Lake Worth, a part of the Intracoastal Waterway, for a period of a
few months, until completion of the ocean outfall.
222
-------
APPENDIX II
ADMINISTRATOR'S DECISION STATEMENT NO. 5
EPA POLICY ON SUBSURFACE EMPLACEMENT OF
FLUIDS BY TOLL INJECTION
223
-------
1 UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
~V ,fct/ WASHINGTON, D.C. 20460
THE ADMINISTRATOR
FEB 6 1973
ADMINISTRATOR'S DECISION STATEMENT N0> 5
SUBJECT: EPA POLICY ON SUBSURFACE EMPLACEMENT OP FLUIDS BY
WELL INJECTION
This ADS records the EPA's position on injection wells
and subsurface emplacement of fluids by well injection, and
supersedes the Federal Water Quality Administration's order
COM 50^0.10 of October 15, 1970.
GOALS
The EPA Policy on Subsurface Emplacement of Fluids by
Well Injection is designed to:
1. Protect the subsurface from pollution or other
environmental hazards attributable to improper
injection or ill-sited injection wells.
2. Ensure that engineering and geological safeguards
adequate to protect the integrity of the
subsurface environment are adhered to in the
preliminary investigation, design, construction,
operation, monitoring and abandonment phasea of
injection well projects.
3. Encourage development of alternative means of
disposal which afford greater environmental
protection.
224
-------
PRINCIPAL FINDINGS AND POLICY RATIONALE
The available evidence concerning injection wells and
subsurface emplacement of fluids indicates that:
1. The emplacement of fluids by subsurface injection
often is considered by government and private
agencies as an attractive mechanism for final
disposal or storage owing to: (1) the diminishing
capabilities of surface waters to receive
effluents without violation of quality standards,
and (2) the apparent lower costs of this method of
disposal or storage over conventional and advanced
waste management techniques. Subsurface storage
capacity is a natural resource of considerable
value and like any other natural resource its use
must be conserved for maximal benefits to all
people.
2. Improper injection of municipal or industrial
wastes or injection of other fluids for storage or
disposal to the subsurface environment could
result in serious pollution of water supplies or
other environmental hazards.
3. The effects of subsurface injection and the fate
of injected materials are uncertain with today's
knowledge and could result in serious pollution or
environmental damage requiring complex and costly
solutions on a long-term basis.
POLICY AND PROGRAM GUIDANCE
To ensure accomplishment of the subsurface protection
goals established above it is the policy of the
Environmental Protection Agency that:
1. The EPA will oppose emplacement of materials by
subsurface injection without strict controls and a
clear demonstration that such emplacement will not
interfere with present or potential uae of the
subsurface environment;, contaminate pround water
resources or otherwise damage the environment.
225
-------
2. All proposals for subsurface injection should be
critically evaluated to determine that:
(a) All reasonable alternative measures have been
explored and found less satisfactory in terms of
environmental protection;
(b) Adequate preinjection tests have been made for
predicting the fate of materials injected;
(c) There is conclusive technical evidence to
demonstrate that such injection will not interfere
with present or potential use of water resources
nor result in other environmental hazards;
(d) The subsurface injection system has been
designed and constructed to provide maximal
environmental protection.
(e) Provisions have been made for monitoring both
the injection operation and the resulting effects
on the environment;
(f) Contingency plans that will obviate any
environmental degradation have been prepared to
cope with all well shut-ins or any well failures;
(g) Provision will be made for plugging injection
wells when abandoned and for monitoring plugs to
ensure their adequacy in providing continuous
environmental protection.
3. Where subsurface injection is practiced for waste
disposal, it will be recognized as a temporary
means of disposal until new technology becomes
available enabling more assured environmental
protection.
4. Where subsurface injection is practiced for
underground storage or for recycling of natural
fluids, it will be recognized that such practice
will cease or be modified when a hazard to natural
resources or the environment appears imminent.
226
-------
5. The EPA will apply this policy to the extent of
its authorities in conducting all program
activities, including regulatory activities,
research and development, technical assistance to
the States, and the administration of the
construction grants, State program grants, and
basin planning grants programs and control of
pollution at Federal facilities in accordance with
Executive Order 11507*
William D. Huckelshaus
Administrator
Attachment
Recommended Data Requirements for Environmental
Evaluation of Subsurface Emplacement of Fluids
by Well Injection
227
-------
RECOMMENDED DATA REQUIREMENTS FOR ENVIRONMENTAL EVALUATION
OF SUBSURFACE EMPLACEMENT OF FLUIDS BY WELL INJECTION
The Administrator's Decision Statement No. 5 on
subsurface emplacement of fluids by well injection has been
prepared to establish the Agency's position on the use of
this disposal and storage technique. To aid in
implementation of the policy a recommended data base for
environmental evaluation has been developed.
The following parameters describe the information which
should be provided by the injector and are designed to
provide regulatory agencies sufficient information to
evaluate the environmental acceptability of any proposed
well injection.
(a) An accurate plat showing location and surface
elevation of proposed injection well site, surface features,
property boundaries, and surface and mineral ownership at an
approved scale.
(b) Maps indicating location of water wells and all
other wells, mines or artificial penetrations, including but
not limited to oil and gas wells and exploratory or test
wells, showing depths, elevations and the deepest formation
penetrated within twice the calculated zone of influence of
the proposed project. Plugging and abandonment records for
all oil and gas tests, and water wells should accompany the
map.
(c) Maps indicating vertical and lateral limits of
potable water supplies which would Include both short-and
long-term variations in surface water supplies and
subsurface aquifers containing water with less than 10,000
mg/1 total dissolved solids. Available amounts and present
and potential uses of these waters, as well as projections
of public water supply requirements must be considered.
(d) Descriptions of mineral resources present or
believed to be present in area of project and the effect of
this project on present or potential mineral resources In
the area.
(e) Maps and cross sections at approved scales
illustrating; detailed geologic structure and a stratigraphic
section (including formations, lithology, and physical
characteristics) for the local arec., and generalized maps
and cross sections illustrating the regional geolotrlc
setting of the project.
228
-------
(f) Description of chemical, physical, and biological
properties and characteristics of the fluids to be injected.
(g) Potentiometric maps at approved scales and isopleth
Intervals of the proposed injection horizon and of those
aquifers immediately above and below the injection horizon,
with copies of all drill-stem test charts, extrapolations,
and data used in compiling such maps.
(h) Description of the location and nature of present
or potentially useable minerals from the zone of influence.
(1) Volume, rate, and injection pressure of the fluid,
(J) The following geological and physical
characteristics of the injection interval and the overlying
and underlying impermeable barriers should be determined and
submitted:
(1) Thickness;
(2) areal extent;
(3) lithology;
(M grain mineralogy;
(5) type and mineralogy of matrix;
(6) clay content;
(7) clay mineralogy;
(8) effective porosity (including an explanation
of how determined);
(9) permeability (including an explanation of how
determined);
(10) coefficient of aquifer storage;
(11) amount and extent of natural fracturing
(12) location^ extent, and effec-ca of known or
suspected faulting indicating whether faults are
sealed, or fractured avenues for fluid movement.
(13) extent and effects of natural solution
channels
229
-------
(11) degree of fluid saturation;
(15) formation fluid chemistry (including local
and regional variations);
(16) temperature of formation (including an
explanation of how determined);
(17) formation and fluid pressure (including
original and modifications resulting from fluid
withdrawal or injection);
(18) fracturing gradients;
(19) diffusion and dispersion characteristics of
the waste and the formation fluid including effect
of gravity segregation;
(20) compatibility of injected waste with the
physical, chemical and biological characteristics
of the reservoir; and
(21) injectivity profiles.
(k) The following engineering data should be supplied:
(1) Diameter of hole and total depth of well;
(2) type, size, weight, and strength, of all
surfacet intermediate, and injection casing
strings;
(3) specifications and proposed installation of
tubing and packers;
(4) proposed cementing procedures and type of
cement
(5) proposed coring program;
(6) proposed formation testing program;
(7) proposed logging program;
(8) proposed artificial fracturing or stimulation
program;
(9) proponed injection procedurej
230
-------
(10) plans of the surface and subsurface
construction details of the system including
engineering drawings and specifications of the
system (including but not limited to pumps, well
head construction, and casing depth);
(11) plans for monitoring including a multi-point
fluid pressure monitoring system constructed to
monitor pressures above as well as within the
injection zones; and description of annular fluid;
(12) expected changes in pressure, rate of native
fluid displacement by injected fluid, directions
of dispersion and zone affected by the project;
(13) contingency plans to cope with all shut-ins
or well failures in a manner that; will obviate any
environmental degradation*
(1) Preparation of a report thoroughly investigating
the effects of the proposed subsurface injection well should
be a prerequisite for evaluation of a project. Such a
statement should include a thorough assessment of: 1) the
alternative disposal schemes in terms of maximum
environmental protection; 2) projection of fluid pressure
response with time both in the injection zones and overlying
formations, with particular attention to aquifers which may
be used for fresh water supplies in the future; and 3)
problems associated with possible chemical interactions
between injected wastes, formation fluids, and mineralogical
constituents.
231
-------
APPENDIX III
865.06 PRESERVATION OF WILD TREES, SHRUBS AND PLANTS; PENALTY
232
-------
COPY
865.06 Preservation of Wild Trees, Shrubs and Plants; Penalty
(1) It is unlawful for any person to:
(a) Willfully pick, pull up, tear up, dig up, cut, break, injure or
destroy trees, shrubs, vines, flowers, ferns and mosses which are
hereinafter named in paragraph (b) growing upon t^e iand Of another,
or uponthe land reserved, set aside or maintained by the state as
a public park, or as a game preserve, or sanctuary for trees, plants,
wild animals, birds or fish, without having previously obtained
permission from the owner or person lawfully occupying such land or
his representative or the superintendent or custodian of such park,
refuge or sanctuary.
(b) Transport, carry or convey on any public highway, or sell or
offer for sale in any place the following plants:
1. Bromeliads - all species of the bromeliad family, sometimes
known as air plants, or wild pines, native to the state except
Tillandsia usneoides, the Spanish moss, which is specifically ex-
cluded from this law.
2. Orchids - all species of the orchid family, both epiphytic
and terrestrial, native to the state.
3. Ferns - all species of the fern families, native to the state,
except the following: All Acrostichum (leather swamp fern), Blechnum
(swamp fern), Nephrolepsis (Boston fern), Osmunda (cinnamon and
royal fern), and Polypodium; Dryopteris normalis; Dryopteris thelypteris
233
-------
(marsh fern) and Pteris cretica (small brachen fern) which are
specifically excluded from this law.
4. Palms - all species of the palm family native to the state,
except the Sabal palmetto (cabbage palm) which is specifically
excluded from this law.
5. Peperomia - all species native to the state;
6. Sarracenia - all species native to the state (pitcher plants);
7- Zamia - all species native to the state (coontie);
8. Cercis canadensis (redbud);
9. Epigaca repens (trailing arbutus);
10. Erythrina arborea (Cherokee or coral bean);
11. Eugenia confusa and E. simpsonii (redberry and Simpson
eugenia);
12. Gelsemium sempervirens (yellow Jasmine);
13. Gordonia lasianthus (loblolly-bay);
14. Guaiacum sanctum (roughbark lignum vitae);
15. Guilandina crista (nicker bean);
16. Ilex cassine, I. Myrtifolia and I. opaca (dahoon, myrtle-
leaved and American holly);
17. Kalmia latifolia (mountain laurel);
18. Jacquinia keyensis (joewood);
19. Lobelia cardinalis (cardinal flower);
20. Nemastylis floridana (eelestial lily);
234
-------
21. Rhododendron austrinum and R, caneseens (wild azaleas);
22. Pinckneya pubens (fevertree);
23. Salpingostylis coelestina (Bartram's syixia);
24. Sophora tomentosa (necklace-pod);
25. Taxus floridana (Florida yew);
26. Tetrazygia bicolor (tetrazygla);
27. Torreya taxifolia (Florida torreya);
28. Tournefortia gnaphalodes (sea lavender);
29. Vierna baldwinii (dwarf clematis);
30. Cornus Florida and Cornus alternifolia (dogwood);
which have been gathered, picked, pulled up, torn up, dug up, cut
or broken in violation of this law.
(c) A review and possible revision of this list shall be made at
ten (10) year intervals by a committee from the Florida federation
of garden clubs, inc., and the Florida nurseymen and growers association,
inc., to keep it up to date as changing conditions within the state
decree.
(2) (a) In any prosecution under this section it shall be a defense
that plants, or the flowers, roots, bulbs or other parts thereof
transported, carried or conveyed or sold or offered for sale by the
party were grown under cultivation, or were taken from his own land
or land under lease by him or were taken from the land of another
with written permission by the other or his representative or were
legally imported from another country.
235
-------
(b) Licensed, certified nurseymen who grow any of the native plants
listed in subsection (l)(b) from seeds or by vegetative propagation
are specifically permitted to sell these commercially grown plants
and shall not be in violation of this section of the law if they do
so, as it is the intent of the law to preserve and encourage the
growth of these native plants which are rapidly disappearing from
the state.
(3) Any person who willfully does any act made unlawful under this
section is guilty of a misdemeanor of the second degree, punishable
as provided in Section 775.082.
(a) Nothing in this section applies to public utility company duties
or to authorized personnel of colleges and scientific institutions
collecting for educational and scientific research purposes, or to
persons engaged in the collection of limited amounts of seeds for
propagation purposes.
(b) All prosecutions under this section shall be commenced within
six (6) months from the time such offense was committed and ,not
afterwards.
(4) Plant inspectors of the department of agriculture and consumer
services shall, as part of their regular inspection of nurseries and
roadside stands, be on the alert for any of the above native plants
appearing suddenly in a given nursery in a mature stage or a stage
236
-------
showing several years of growth, and are empowered to request proof
of where and how the plants were obtained.
Amended by Laws 1965, c, 65-426, Sec. 1, eff. June 25, 1965; Laws
1969, c. 69-106, Sec. 14, 35, eff. July 1, 1969; Laws 1971, c. 71-
136, Sec. 1118, eff. Jan. 1, 1972.
237
-------
APPENDIX IV
OUTFALL DATA
238
-------
BLACK & VEATCH and H. J. ROSS ASSOCIATES, INC.
A Joint Venture
2660 Brickel! Avenue, Miami, Florida 33129
Miami Kan$as CitV
(305)854-1900 December 19, 1972 (816)361-7005
Dr. Richard Stringer
Environmental Protection Agency
1421 Peachtree Street., N.E.
Atlanta, Georgia 30309
Dear Dr. Stringer:
In accordance with your expressed desire to receive all available data concerning
the results of our ongoing research on pollution in and near the ocean outfalls of
Dade County, we take pleasure in sending you herewith two reports:
1 - Final report of Dr. R. F. McAllister of Florida Atlantic
University summarizing his ocean sampling program.
2 - Interim report of Dr. Michael Sigel, of the University of
Miami, giving his findings to date regarding the presence
of viruses in and near the outfalls.
All samples were taken at the surface, though some are identified by the depth
of the water at the point where they were taken. To provide background data
for a future monitoring program, samples were taken at the intended sites of the
planned new outfalls.
As you know, the North Miami and Miami Beach outfalls discharge completely
raw domestic waste water, while at Virginia Key the product receives about 60%
treatment, including pre- and post-chlorination at and 8 ppm, respectively.
We regard it as significant that, whereas virus tests are positive in the untreated
boils, even where the outfall discharges at a depth of 140 feet, no viruses have
been found in the treated boil, where the outfall is very shallow (18-foot depth).
We trust you will find these reports of use in your work. We will keep you in-
formed regarding further progress in the program.
Very truly yours,
H. J. ROSS ASSOCIATES, INC.
Robert V . Dorwart
RVD:kt Project Manager
Enclosures
239
-------
Miami-Metro Offshore Sampling Program
December 12, 1972
Introduction
In spite of analytical difficulties, the program described below gave a good picture
of the viruses of the three major outfalls of the Miami area, and some valuable
additional information regarding total and fecal coliforms, water chemistry, and
temperature and water clarity. None of the analytical difficulties reported herein
had any bearing upon the quality of the virus samples.
The commercial laboratory chosen to make determinations for total and fecal coliforms
salinity, nitrates and phosphates had difficulties from the start. Coliforms seemed unreasonable
low in the outfall boils, and salinities were so high as to be oceanographically impossible.
Naturally, then, the nutrient determinations were also suspect. After several
conversations and reviews of the data and procedures, a control sample was inserted in
the batch delivered to the commercial lab. After it proved unsatisfactory in all respects,
coliform analysis was shifted to the Department of Biological Sciences at Florida
Atlantic University, and salinities were determined by C. J. Assoc. After some time,
during which no laboratory was found which could surely be depended upon, the
Environmental Protection Agency, through the good offices of Dave Hopkins, arranged
to perform the nutrient analyses on the last three sets of samples, which had been stored
in the dark in a refrigerated cabinet. All of the changes were made with the concurrence o
of the H0 J. Ross Associates representative, Mr. Robert Dorwart. The F. A. U. micro-
biologists further recommended that a small amount of sodiun thiosulfate be added to
all future coliform sampling bottles to depress activity of residual chlorine and of
chloramines present in any chlorinated sewage sample.
A suggested handling procedure for salt water samples taken for coliform studies is
included below.
Narrative
H. J. Ross Associates, hired C, J. Assoc of Pompany Beach, Florida to sample at the present
and proposed outfall locations for the North Miami and Virginia Key outfalls, fhe present
Miami Beach outfall, and several sites adjacent to them, including the Baker's Haulover
Inlet, the Safety Valve just south of Key Biscayne, and a location just upcurrent of the
Virginia Key outfall which proves to be in the Bear Cut Inlet to Biscayne Bay most
of the time. Water samples were taken in sterile bottles for coliform analysis, in non-
sterile but clean bottles for water chemistry, and with the exception of the first sampling,
made before the virologist at the University of Miami was ready, in five gallon sterile
bottles for virus studies. All samples were delivered as rapidly as possible to the
various laboratories each sampling day,, The objective of the study was to determine the
quantities of pollutants in the various boils, and in the bodies of water contributing
or potentially contributing to water quality in the vicinity of the proposed outfall termini.
240
-------
-2-
On each run a temperature profile was taken at an offshore station to see if major
thermoclines existed, which might affect dilution of the rising effluent. Secchi
disk readings were taken at many of these points to give us some feeling for the
water clarity near the proposed outfalls, prior to discharge „
Samplings were made from 28 June thru 29 September, with considerable weather
difficulty toward the end of the summer. A summary of the sampling dates, sites
and results is found in the table of results at the end of this report „ Viruses are
reported upon separately by Dr» Mike Sigel and/or Mrs „ Frances Parsons of the
University of Miami Virology Lab, to whom the virus samples were delivered.
After 29 September it was concluded that more could be gained by expending the
remaining funds in the sampling budget for continuation of the virus studies than
for the general background studies. Accordingly this is a final report on the gen-
eral program now concluded „
Sampling Procedure
Coliforms: Both total and fecal coliforms were determined by the mi lie-
pore filtration method, plated on endo- and MF media,, Samples were taken in
the most active portion of the outfall boils and in other designated locations, in
sterile bottles, and held in the shade in an ice chest, covered with ice, until
delivery to the laboratory, usually within 2 to 4 hours.
When the coliform counts in the first two sets of samples appeared too low, the
laboratory was requested to check their procedures „ Shortly thereafter, the
sample analysis was transferred to FALL Even then some low counts were found,
particularly when samples taken in the boils early in the day were not delivered,
because of weather or boat problems, until that evening „ Several sets of sample
bottles had sodium thiosulfate added before sampling to eliminate free chlorine
whether directly present or resulting from chloramine breakdown. In one case
residual chlorine was found two days after sampling!,
Salinity; Samples for salinity determination were taken in clean non-
sterile bottles and analyzed by argentometric titration initially. End point-
determination was a serious problem, and even when correct procedures were
explained to the laboratory, results were undependable, some duplicate samples
giving different results, and some results well above possible salinities for this
area of the ocean. After several attempts to clarify the problem, Co J „ Assoc.
had the remaining salinities determined by their people on an induction salino-
meter capable of giving results to ,,003 o/oo. Checks against a seawarer stan-
dard, Eau-de-Mer Normale, insured accuracy -
Nitrates and Phosphates; Nutrients were initially analyzed in a com-
mercial lab^r^to7>TEy~standararrnethods „ When the results of several other types
of water analysis became suspect, a control sample containing 5 parts per million
241
-------
-3-
(ppm) of phosphate in 20 0/00 Nad was introduced„ It appeared in the tabulation
as 1 ,,45 ppm, and helped us decide to change laboratories. When FAU would not
undertake nutrient analysis, the samples were held in a cold box, in the dark, until
the Environmental Protection Agency laboratory, on the EPA barge at Fort Lauderdale,
could analyze them,, They did this under the agreement that no charge would be made
by C. Jo Assoc „ or by H. J o Ross Assoc. for this part of the sample analysis. EPA
uses 'a Technicon Autoanalyzer and really gives nitrite-nitrate (assumed to be essen-
tially all nitrate after storage in the dark for two months) and phosphate to at least
.005 mg/1, essentially ppm,,
Temperature: A Yellow Springs Recording Thermometer was used to take the
temperature profiles. In view of the time constant of several seconds, and of the
slow change in temperature with depth, readings were taken every 10 feet near the
proposed outfall termini. No significant thermocline appeared during these profiles,
although such pronounced thermoclines have been recorded on the continental shelf
of Southeast Florida a number of times in the past,
One temperature section, consisting of temperature profiles at regular intervals from
the outfall to the nearshore area, was made along the North Miami outfall pipeline.
These profiles and the section are presented at the end of the report.
Visibility-Water Clarity: A.ten-inch white Secchi disk was used to deter-
mine visibility vertically at the offshore locations and occasionally at other sites.
When bottom could be seen with the naked eye, the disk was not needed. During
rough water and squalls, the disk could not be used effectively.
Viruses: Virus samples were taken in the most active part of the outfall
boils and at other specified locations, in sterile five-gallon bottles supplied by the
University of Miami Virology Laboratory. They were delivered to the laboratory no
later than 5:00 P.Mo on the day of sampling. All samples were flocculated with
polyelectrolyte and the floes preserved in refrigerated storage until innoculated
into rhesus monkey kidney tissue (RMKT). When no significant pathological effects
were observed in RMKT, several modifications of the procedure were tried, and
human embryo tissue was substituted 0 It proved to be the required host tissue.
Pathological changes in such tissue have been reported from one boil and from
Bakers Haulover outflow at the time of writing of this report. Further virus reports,
like those preceding this report, will be made directly to H. Jo Ross Assoc.
Interpretation
Generally the various biological, chemical and physical characteristics of the
waters away from the outfalls and from the outflow of inland waters show levels of
the various indicators which are characteristic of the Gulf Stream in this part of
the world,, Salinity varies around 35 to 36 0/00, with values above 36 0/00 almost
certainly due to analytical errors. Nitrates and phosphates are very low, to the
point of extreme poverty of nutrients. Values less than 0015 ppm of phosphate and
242
-------
-4-
usually of 0006 ppm or less of nitrate are characteristic. The background of
coliforms is essentially zero. Viruses in the offshore waters, out of the immediate
influence of outfalls or inland waters appear to be at near zero levels too.
Inland waters, whether from sewage discharge via outfalls, or from the Bay, dis-
charged thru Bakers Haulover, Bear Cut, The Safety Valve, Morris or Government
Cut, typically have some higher levels of one or all of these parameters. Salinities
will be either higher or lower depending upon evaporation and precipitation in the
rainshed feeding Biscayne Bay o The outfalls discharging in less than 140 feet of
water have salinities which vary with mixing (currents, wave height, volume of
flow, etc.), but the Miami Beach outfall is very nearly at background salinity,
probably because of the superb mixing at 140 feet of depth.
Coliforms are high to very high in the boil of the untreated sewage at North Miami
and Miami Beach, but are low throughout the study in the partially treated Virginia
Key effluent. Coliforms in Bakers Haulover and occasionally in the Safety Valve
reflect sewage discharge into Biscayne Bay at times „
The situation above generally appears to apply to viruses as well .
Nitrates and phosphates, the primary nutrients, are low offshore but, particularly
phosphate, reach high values in the outfall boils., Some apparent increase was
found in the outflow from Biscayne Bay, known to have substantially higher nutrient
levels at times of high agricultural and cultivated land runoff, with associated
fertility-
Temperatures during this study are routinely a few degrees higher at the surface
than at 60 to 140 feet, and often one to three degrees lower in the boil, reflecting
both possible effluent temperature and entrainment of salt water from deeper levels
during mixing. No sharp fhermoclines were detected although such abrupt tempera-
ture changes have been seen on the Southeast Florida continental shelf in the past.
Visibility,, generally very good in the Gulf Stream, where 1-200 feet is not uncom-
mon, varies on the shelf with the complex interaction of various land-derived
drainage flowing onto the shelf „ In the area of study it has varied from 2-3 feet to
more than 90 feet. Typically in the outfall boils and Bakers Haulover outflow, the
visibility was a few feet at best „ Under conditions existing now, it is my judgment
that an enormous quantity of secondarily treated effluent will be required to make
a significant change in the shelf water clarity or visibility, until inland waters no
longer contribute their suspended debris, much of it organic, and nutrients into the
shelf water „
Suggested Marine Coliform Sampling Procedure:
1 - Sterile sample bottles containing a very small amount of sodium thio-
sulfate should be used.
243
-------
-5-
2» Samples must be taken so as not to lose the thiosulfate, sealed, and
placed into a refrigerated container, preferably at 32° or lower„ (The best
arrangement is, of course, to filter and plate the samples at sea.)
3. Keep the sample iced and return to the laboratory at the earliest time
for filtration and culturing»
40 Analyze as usual „
Using this procedure, the rapid death of coliforms from chlorine or chloramines
can be prevented, and the effects of salt water contact die-off minimized,, There
is no substitute for the earliest possible processing of salt water samples, however.
Table of Results
Abbreviations used below:
MBB - Miami Beach Boil
UMBB - Upstream of Miami Beach Boil
NMB - North Miami Boil
ONMB - Offshore of North Miami Boil
UNMB - Upstream of North Miami Boil
HST - High Spring Tide (+ listed hrs. or min.)
1ST - Low Spring Tide (+listed hrs. or min.)
T C - Total Coliforms
F C - Fecal Coliforms
BHP - Bakers Haulover Plume
VKB - Virginia Key Boil
UVKB - Upstream of Virginia Key Boil
VKPT - Virginia Key Proposed Terminus
SV#8 - Safety Valve - Marker #8
BB#26 - Biscayne Bay - Marker #26
244
-------
.SAMPLE
#
6/28/7
1
2
I
i
ftn.d.j_y L
7/11/72
1
2
3
4
6
7
Analyz
7/27/72
1
2
4
6
Analyz
/9/72
1
2
5
6
7
nalyz
ontro
vi
.p-
LOCATION
UNMB
NMB
ONMB
MBB
UNMB
BHP
VK~B
UVKE
VKPT
SV#8
BB#26
\NKE
VKPT
iftg agency-
UNMB
NMB
MBB
UMBB
UNMB
BHP
g agency-
UVKB
VK~B
VKPf
SV#8
SV#8
VKPT
UVKB
ng agency:
sample -2 C
TIDE
HST-1 hr
HST-1 hr
HST-i hr
HSTfl hr
HST4-4I hr
HST 4»45
Discount
HST+i hr
H^T1 4- 1 hr>
HST -h 1 hr
HST-f l:45hi
HST-»-5i hr
LST
LST-f 1 hr
Discoun"
HST-i hr
HST-i hr
HST-*- 2 hr
HST"*- 2 hr
HST-f-^- hr
HST 1-5 hr
Salinit:
HST -L 45 m
HST-f-1 hr
HST*li hr
HST + 2 hr
LST
LST ^20 m
LST-f 1 nr0
o/oo NaCl,
T C
col./lOO nil
1
163,000
«; i
< i
< i
i
all salinit'
1,200
1
<.!
^i
T5m DhosTDr
F G
col o/lOO ml
<1
9,000
< 1
y values- gi
iJ-0
15,000
320,000
300
<1
60
•ocedure are
1190
190,000
500
500
600
1,200
2,200
ate, in sterj
SAL.
o/oo
48.4-0
44o79
43.16
^7c50
44 061
^3.35
P , t •: ',
SS &&£4
49.85
47.14
47.50
45.88
42o99
45.16
49.31
oss err
36085
35o9
36031
36.85
37o57
30.72
better
35»95
31.98
23.86
37.03
37o21
38.11
37.21
le disl
N0yn
mg/Jl
-------
SAMPLE
#
9/1 V7
1
2
3
4
2
Anal
^22/72
1
2
4
1
Anal
LOCATION
>
WBB
UMBB
ONMB
NMB
ONMB
BMP
/•zing agen<
UVKB
VKB
VKPT
SV#8
VKPT
UVKB
yzine: ae-enc
TIDE
HST
HST
HST-f 1 hr
HST+li hr
HST + lJ hi
HST + 2 hr
y
HST+ 1 hr
HST -Hi hr1
HST »• 1 1 45
HST4-2J hr
HSTt-5 hr
LST- 1 hr
y
T C
col./lOO ml
180,000
0
390
2,060,000
6,360
0
— PAU
9
6000
590
156
14-9
183
FAU
F G
col./lOO ml
81,000
0
36
1, 150,000
^•30
0
__PAU
0
2000
20
0
0
5
FAU
SAL.
o/oo
35.88
35.89
35.11
32.84
34.68
33.85
-C • J • — •
35.29
28.19
36.11
34.89
36.05
35.1?
•C.J.
NO-
mg/1
,006
<.005
<.oo5
.005
<.oo5
<.oo5
-EPA—
.009
.0*44
.011
.005
.006
.006
-EPA--
POj^,
me/1
,04?
.023
.210
.850
.300
.020
-EPA—
.017
.850
.014
.014
.017
.014
-EPA—
VISIB.
ft.
2
30
3
30
3
3-5
13
TEMP,
OF
86
85
85
REMARKS
. ___ __—_______-.______—___—__
9/29/72
1
2
4
6
Analyz
MBB HST
UMBB HST
ONMB HST
NMB HST
ONMB HST
BHP y HST
ing agencies
+ 45
+ 50
+ it
+ 2
m
m
^5
hr
99,000
18
8
930,000
0
10
FAU—
20,000
2
1
125,000
0
0
FAU—
35-
35-
35-
35°
— c!
95
99
94
18
98
82
J.
.010
.006
.005
.008
.005
.030
.014
.014
.246
.014
<.005 »017
—EPA— EPA
3
60 83
60
4
5
(Tv
-------
ULVIBB
6/28/72
Depth
8 ft.
10
20
30
40
50
60
70
80
90
100
110
120
Temp
83oF
82.5
82
81.5
81
80
78.5
78
77
76
75
75
73
Temperature Profiles
NMB 9V#8 VK.PT
6/28/72 7/11/72 7/11/72
Depth Temp Depth Temp Depth Temp
0 ft 82o5°F 0 ft 84°F 0 ft 84°F
10
20
30
40
50
60
82.5 10
82 14
81
81
80.5
80
84 10
84 20
30
40
50
60
70
80
90
84
83-5
83
82.5
82o5
82
80
79
78
ONMB
7/27/72
Depth Temp
0 ft 83°F
10
20
30
40
50
60
70
80
90
83
83
82.5
82.5
82o5
82«5
82
82
82
MBB
7/27/72
VKPT
8/9/72
8/9/72
VKPT
8/9/72
OVKB
8/9/72
Depth
0 ft
10
20
30
40
50
60
70
80
90
100
Ternp
84°F
83-5
83
82.5
82.5
82.5
82.5
82.5
82
82
82
Depth
0 ft
10
20
30
4o
50
60
70
80
90
Temp
8 5 °F
85
85
84.5
84
83.5
83.5
83
82.5
82
Depth
9 ft
10
13
Temp
87-5°F
87c5
87^5
Depth
0 ft
10
20
30
40
50
60
70
80
90
Temp
87°F
86
85
84.5
84
84
83-5
83-5
83-5
83
Depth Temp
0 ft 90°F
18 89
UNMB
9/14/72
Depth
0 ft
10
20
30
40
50
60
70
80
90
100
110
120
130
Temp
86°F
86
35-5
85
84.5
84
83-5
83-5
83
83
82.5
82.
82
81.5
VKPT
9/22/72
Depth
0 ft
10
20
30
40
50
60
70
80
90
100
Temp
85°F
84.5
84.5
84
83.5
83-5
83
83
82.5
82.5
82
SV#8
9/22/72
Depth Temp
0 ft 85°F
10 85
12 85
ONMB
9/29/72
Depth
0 ft
10
20
30
40
50
60
70
80
90
100
110
Temp
83°F
83
8205
82.5
82.5
82
82
82
82
82
81.5
81.5
247
-------
Temperature Section
North Miami Pipeline
6/28/72
Depth
at
temp f
taken
0
10
20
30
40
50
60
prof
15
83
83
~^\
lie i'
20
84
82*
82*
1
21
r
84
83i
22
£T
84*
82*
82
— *"
18
M
84~
821
82
.-—
20
P
84*
82
81*
33
84*
82
81*
811
38
o
84
82
81*
^~\
P
83*
88
81 1
Sii!
^^•» ' — .
45
84
81*
814
81
81
— \
51
84
82
81 a
81
80*
80
58
,
84
Qpi
0^2
82
£*
Hn i
SOg-
56 in jrhe boll
8205
82*
82
81
81
80*
80^
248
-------
UNIVERSITY OF MIAMI
MIAMI, FLORIDA 33155
December 15, 1972
Mailing Address:
LABORATORY OF VIROLOGY
DEPARTMENT OF MICROBIOLOGY
SCHOOL OF MEDICINE
P. O. BOX 7278
Mr. R. V. Dorwart
H. J. Ross Associates Inc.
Consulting Engineers
2660 Brickell Avenue
Miami, Florida 33129
Dear Mr. Dorwart:
The enclosed tables contain detailed information on the viro-
logical surveys performed during the months of July, August
and September 1972. The samples were collected by Dr.
McAllister and were surface samples.
The following conclusions appear to be warranted at this time.
1. No viruses have been demonstrated at the outfall or in the
vicinity of the Outfall of the Virginia Key plant.
2. Viruses were isolated from three samples (two different
dates), collected in the vicinity of North Miami Outfall.
One of the isolations has been identified as echo virus
type 24. In addition, two samples (two different dates)
taken from the Baker's Haulover Plume have yielded virus,
as yet unidentified.
3. Two positive virus isolations were made from samples taken
at the Miami Beach Outfall. One of these has been identi-
fied as echo virus type 12.
4. Echo viruses cause infection of the human intestinal tract.
In many instances these infections are inapparent but the
asymptomatic carrier can transmit the virus to the environ-
ment or to other persons. Some of the echo virus infections
have been associated with paralytic disease, meningitis,
diarrhea, undifferentiated febrile illness and rashes.
249
A private, independent international university
An equal opportunity employer
-------
Mr= R. V. Dorwart Page 2 December 14, 1972
5. Further work is being continued utilizing human cells
(HEK and HEL) which appear to be more sensitive to virus
isolation then the monkey kidney cells (vero and MK)
which were used earlier in. the investigation.
Sincerely,
y
.
. /
M. Michael Sigel, Ph.D.
Professor
MMS:fs
250
-------
Ocean Outfall
Sewage Treatment Plant
City of Miami, Florida
at
Virginia Key
Sample
Date Site
7-11-72 Outside Boil
Boil
90 depth,
Incoming Tide
Safety Hatch,
Incoming Tide
90' depth,
Outgoing Tide
Safety Hatch,
Outgoing Tide
Negative Control
8-10-72 Outside Boil
Boil
Virological
Finding
Negative
Negative
Negative
Negative
Negative
Negative
Negative
Negative
Negative
Cells Coliforms,
Used Chlorine Remarks
Vero
MK
Vero
MK
Vero
MK
Vero
MK
Vero
MK
Vero
MK
Vero
MK
MK
MK 1 ppm residual
chlorine reported
-------
Virginia Key - 2
Date
8-10-72
9-22-72
Sample
Site
90' depth,
Incoming Tide
Safety Hatch,
Incoming Tide
90' depth,
Outgoing Tide
Safety Hatch,
Outgoing Tide
Negative control
Outside Boil
Boil
90' depth,
Virological
Finding
Negative
Negative
Negative
Negative
Negative
Atypical
Negative
Atypical
Cells Coliforms,
Used Chlorine Remarks
MK
MK
MK
MK
MK
HEL, HEK
HEL, HEK
HEL, HEK
Incoming Tide
Safety Hatch,
Incoming Tide
90' depth,
Outgoing tide
Safety Hatch,
Outgoing Tide
Negative
Negative
Negative
HEL, HEK
HEL, HEK
HEL, HEK
Vero - Cell line derived from African Green monkey kidney
MK - Primary Rhesus monkey cells
HEL - Primary Human Embryo Lung cells; HEK - Primary Human Embryo Kidney cells
Positive - Refers to positive isolation but virus not yet identified
-------
Ocean- Outfall
Miami Beach, Florida
Date
7-27-72
9-14-72
9-28-72
Sample
Site
Boil
Upcurrent
Boil
Upcurrent
Boil
Outside Boil
Virological
Finding
Negative
Negative
Echo virus type
12 isolated
Negative
Positive
No definite
Cells Coliforms,
Used Chlorine Remarks
MK
MK
HEL, HEK 92,000/100 ml
HEK, HEK
HEK, HEL
HEK, HEL
isolation;
atypical
Vero - Cell line derived from African Green monkey kidney
MK - Primary Rhesus monkey cells
HEL - Primary Human Embryo Lung cells
HEK - Primary Human Embryo Kidney cells
Positive - refers to positive isolation but virus not yet identified
-------
Ocean Outfall
North Miami, Florida
r-o
ui
Date
7-27-72
9/14-72
Sample
Site
Upcurrent of Boil
Boil
Gulf stream
Baker ' s Haulover
Inside
Ocean, 2 miles out
140' depth,
Outgoing Tide
Boil
140' depth,
Baker ' s Haulover
Virological
Finding
Negative
Negative
Negative
Negative
Negative
Pos itive
Echo virus type
24 isolated
Positive
Positive
Cells
Used
MK
MK
MK
MK
MK
HEK, HEL
HEL, HEK
HEK, HEL
HEK, HEL
Coliforms,
Chlorine Remarks
45 Coliforms/ Questio
100 ml sample
from Bo
240,000+/100 ml
Plume
-------
North Miami, Florida - 2
Ui
Date
9-28-72
Sample
Site
140' depth,
Incoming Tide
Boil
140' depth,
Virological
Finding
Negative
Positive
Negative
Cells Coliforms,
Used Chlorine Remarks
HEL, HEK
HEL, HEK
HEL, HEK
Outgoing Tide
Baker's Haulover
Plume
Positive
HEL, HEK
Vero - Cell line derived from African Green monkey kidney
MK - Primary Rhesus monkey cells
HEL - Primary Human Embryo Lung cells
HEK - Primary Human Embryo Kidney cells
Positive - Refers to positive isolation but virus not yet identified
-------
APPENDIX V
INTERAMA SEWAGE TREATMENT SITE
VEGETATION SURVEY
256
-------
A PINT
VENTURE
POST, BUCKLEY. SCHUH & JERNIGAN, INC.
reply to: 7500 northwest 52nd street
miami, florida 33166
telephone: 305/885-9101
HAZEN AND SAWYER
new york, new york
August 2, 1973
Mr. Jack Ravan
Region Administrator
Region IV
Environmental Protection Agency
1421 Peachtree Street, N. E.
Atlanta, Georgia 30309
Attn: Mr. Paul Wagner
Gentlemen:
Re: EIS on C120375
North Dade, Florida
In response to your request for additional information
relative to the comments received on the referenced Draft
Environmental Impact Statement, we are submitting herewith a
report on existing vegetation. The report identifies plant
species on the proposed site of the treatment plant and pro-
posals for safeguarding or relocating protected species. A
map accompanies the report and indicates the general treatment
plant arrangement.
We believe the information provided will enable your
Agency to complete its final EIS and allow this project to move
forward. If additional questions arise, please contact us.
Very truly yours,
POST, BUCKLEY, SCHUH
HAZEN $ SAWYER
JERNIGAN, INC
WWR:md
Enclosures/2 sets
William W. Randolph, P.E.
cc: Mr. Garrett Sloan
Miami-Bade Water $ Sewer Authority
027-72-020.00
257
-------
INTERAMA SEWAGE TREATMENT SITE
VEGETATION SURVEY
A vegetation survey was conducted on July 19, and 20,
1973. Plant communities were identified by a combination of
infra-red aerial photography and ground truth. Identification of
common and scientific plant names is according to A Flora of
Tropical Florida by Robert W. Long and Olga Lakela.
Six plant communities have been identified as
follows:
Scrub palmetto/oak
Hammock
Lowland
Disturbed area
White mangrove
Red mangrove
Scrub Palmetto/Oak
This plant community is characterized by low dense ground
cover and scattered shrubs. The dominant species are oaks, Quercus sp.,
and saw palmettos, Serenoa repens. Numerous species typical of this
habitat are conspicuous, including the following: wax myrtle, rusty
lyonia, slash pine, muscadine grape, and coontie.
258
-------
Hammock
Two well defined hammock communities are located in the
north eastern portion of the property. A third hammock is located
on an area of high ground in the north central area. Transition
from hammock communities to other vegetation communities (mangrove,
scrub palmetto/oak, disturbed area) is abrupt. The hammocks are
dominated by oaks, Quercus laurifilia and Quercus virginiana, with
other hardwood species scattered throughout the hammock. Character-
istic species composition includes a variety of trees such as gumbo
limbo, strangler fig, sweet acacia, cabbage palm, coral bean, red
mulberry, black bead, myrsine and wild tamarind. The ground cover
is principally composed of saw palmettos, with scattered ferns and
shrubs. Coontie, Zamia pumilia is a common component of the ground
cover. The forest floor varies from bare black sand to a
characteristic covering of leaf litter. In the cool moist portions
of the hammock, various epiphytes are prevalent principally on the
trunks and branches of oak trees or cabbage palms.
Lowland
A dense ground covering of the sea ox-eye daisy, Borrichia
frutescens, characterizes the lowland area. A few clumps of saw
grass, cord grass, or isolated specimens of groundsel are sparsely
distributed throughout the area. The ground is light grey marl.
259
-------
Disturbed Area
The vegetation of the disturbed area is dominated by the
exotic Brazilian pepper, Schinus.terebinthifolius. However, some
open areas support low grasses with sparse Brazilian pepper and
groundsel. Large areas support almost exclusively a low, dense
covering of Brazilian pepper. Along the edges of a Brazilian
pepper stand are occasional guava and dense clumps of lantana.
Two clumps of whisk fern, Psilitum nudum, containing 64 and 18
specimens, were found beneath Brazilian pepper trees. A few
isolated individual specimens of whisk fern were sparsely
scattered in the vicinity of these two clumps. No other whisk
ferns were found on the property. One coontie, Zamia pinni lia,
was found in this area. Various other species as identified on the
plant list are sporadically scattered throughout this area.
White Mangrove
The majority of the mangrove forest on the site is
dominated by a community of white mangroves, Lagunculoria racemosa,
with an occasional buttonwood, and red and black mangrove. An
understory of red mangrove occurs in the north eastern portion of
the swamp in an area gradual transition to a red mangrove community.
Isolated specimens of black mangrove are located throughout the
forest. The habitat characteristics vary from dry, grey marl to
flushed areas of loose, black peat.
ocn
-------
Areas of grey marl generally support either dense stands
of straight boled trees or widely spaced white mangroves with
multiple and somewhat recumbent trunks. These white mangroves
range in height from 10' - 25'. In some areas, the rubber vine,
Rhabdadenia biflora, is very common. Very little or no leaf litter
was encountered in this area. In contrast, flushed areas of loose
or firm black peat support straight boled trees reaching maximum
heights of 40' with maximum diameters at breast height (DBH or 4 1/2"
above ground) of 12". Abundant leaf litter is present in this
area.
Red Mangrove
The northeastern portion of the mangrove swamp is dominated
by the red mangrove, Rhizophora mangle, community. The soil in this
appearantly tidal area is composed of firm to loose black peat with
an abundance of leaf litter. In the transition zone between red
and white mangrove communities, red mangroves form an understory
beneath taller white mangroves. The numbers of white mangroves
gradually diminish in the transition area toward an almost ex-
clusively red mangrove community. These red mangroves range in
height from approximately 25' - 35'.
261
-------
Characteristic Terrestrial Plants and Associations
(not an exhaustive list)
SCRUB PALMETTO
Groundsel
Beauty berry
Sawgrass
Rusty lyonia
Wax myrtle
Slash pine
Bracken fern
Laurel oak
Myrtle oak
Live oak
Shining sumac
Cabbage Palm
Brazilian pepper
Saw palmetto
Cord grass
Florida trema
Muscadine grape
Coontie
Baccharis halimifolia
Callicarpa ameficana
Cladium jamaicensis
Lyonia ferruginea
Myrica cerifera
Pinus elliottii var. densa
Pteridium aquilinum var. caudatum
Quercus laurifolia
Quercus myrtifolia
Quercus virginiana
Rhus copallina
Sabal palmetto
Schinus terebinthifolius
Serrenoa repens
Spartina sp.
Trema micrantha
Vitus rotundifolia
Zamia pumilia
262
-------
HAM4QCK
Sweet acacia
Leather fern
Marlberry
Blechnum fern
Gumbo limbo
Sawgrass
Butterfly orchid
Coral bean
Strangler fig
Dahoon holly
Wild tamarind
Red mulberry
Waxmyrtle
Myrsine
Virginia creeper
Black bead
Resurrection fern
Guava
Coffee
Laurel oak
Live oak
Cabbage palm
Saw palmetto
Acacia farnesiana
Acrostichum dariaeaefolium
Ardisia escalloriioides
Blechnum serrulatum
Busera simaruba
Caldium jamaicensus
Encyclia tampense
Erythrina herbacea
Ficus aureum
IIlex cassine
Lysiloma latisiliqua
Morus rubra
Myrica cerifera
Myrsine guianensis
Parthenocissus quinquefblia
Pithecellobiiim guadelupense
Polypodium polypodioides
Psidium guajava
Psycotria undata
Quercus laurifolia
Quercus yirginiana
Sabal palmetto
Serrenoa repens
263
-------
Greenbriar
Cord grass
Poison Ivy
Air pine
Shoe string fern
Muscadine grape
Coontie
LOWLAND
Salt wort
Sea-oxeye daisy
Saw grass
White mangrove
Cord grass
WHITE MANGROVE
Leather fern
Black mangrove
Salt wort
Sea-ox-eye daisy
White mangrove
Rubber vine
Red mangrove
Smilax sp.
Spartina sp.
Taxicodendron radicans
Tillandsia fasiculata
Vittaria lineata
Vitus rotundifolia
Zamia pumilia
Batis maritima
Borrichia frutescens
Cladium jamaicensus
Laguncularia racemosa
Spartina sp.
Acrosticum danaeaefolium
Avicennia germinans
Batis maritima
Borrichia frutescens
Laguncularia racemosa
Rhabdadenia biflora
Rhizophora mangle
264
-------
RED MANGROVE
Black mangrove
White mangrove
Red mangrove
DISTURBED AREA
Leather fern
Groundsel
Groundsel
Rattlebox
Lantana
Wax myrtle
Virginia creeper
Slash pine
Guava
Whisk fern
Bracken fern
Shining sumac
Cabbage palm
Willow
Brazilian pepper
Saw palmetto
Avicennia germinans
Laguncularia racemosa
Rhizophora mangle
Acrostichum danaeaefolium
Baccharis angustifolia
Baccharis hamlimifolia
Crotolaria spectabilis
Lantana involucrata
Myrica cerifera
Parthenocissus quiriquefolia
Pinus elliottii var. densa
Psi,dium guaj ava
Psilotum nudum
Pteridium aquilinum var. caudatum
Rhus copallina
Sabal palmetto
Salix caroliniana
Schinus terebinthifblius
Serenoa fepens
265
-------
Poison Ivy Taxicodendron radicans
Coontie Zamia pumilia
266
-------
WILDLIFE
Wildlife was not formally surveyed or measured. The
following discussion lists the species which were observed and
identified during July 19 and 20th, 1973.
Invertebrates
Throughout the mangrove forest, a tree climbing crab,
Aratrus pisonii, is abundant. Fiddler crabs, Uca sp. inhabit
mangroves and lowland areas, but not in large numbers. Evidence
of land crabs, Cardisoma guanhumi, was found in dry areas of
the white mangrove forest, lowlands, and disturbed areas supporting
a cover of Brazilian pepper. Coffee bean snails, Melampus coffeus,
were found singly or clustered in groups on the lower portions of
mangrove trunks and prop roots. These snails were most often ob-
served in moist or wet areas.
Birds
Song birds such as the cardinal, blue jay, mocking bird,
etc. were identified throughout the property. Along mosquito ditches
and in the apparently red mangrove area, a few wading birds were
observed as follows: green heron, Butorides viresens, common egret,
Casmerodius albus, and the white ibis, Guara alba. The red-bellied
woodpecker, Centurus carolinus, was found in all mangrove areas.
267
-------
Mammals
No mammals or tracks were observed. However, holes were
found in hammocks and some disturbed areas which may have been dug
by either armadillos or racoons.
268
-------
SEWAGE TREATMENT PLANT PROPOSED DEVELOPMENT
As illustrated on the accompanying map, the proposed
sewage treatment plant will occupy the southern portion of the
property. The northeastern portion of the site will be preserved
in its natural state. This area contains the greatest variety
of plant species and offers the most ecologically diverse habitats,
Vegetation communities contained in this area include scrub
palmetto/oak, white mangrove, red mangrove, and the hammocks. Due
to its probable high ecological value, this area has been selected
for preservation.
The two hammocks located in the preservation area are
well developed. The larger hammock on the eastern extremity of
the property supports the greatest variety of characteristic
hammock vegetation. Among the species present are numerous
epiphytes including the butterfly orchid, resurrection fern, shoe
string fern, and various bromeliads. The smaller hammock to the
west also supports resurrection fern and various bromeliads, but
no epiphytes were found in the hammock located within the proposed
construction site.
A narrow tidal creek meanders south for a short distance
through the red and white mangrove communities. Tidal flushing
occurs through a large portion of the northeastern mangrove area.
269
-------
It has recently been established that flushing action in mangrove
swamps is responsible for distributing a major nutrient supply to
the marine food chain. Development of the sewage treatment
facilities well not impair this natural flushing process. Runoff
from the developed site will not enter the creek system.
The nearest residential development is Fulford Heights,
located approximately 2000' west of the site on NE 9th Place and
NE 159th Street.
Construction of the treatment plant will require the
raising of the existing ground to elevation of 9 feet. Barriers
will be erected to present erosion of fill into adjacent natural
areas. No runoff from the sewage treatment will flow into adjacent
natural areas. Whisk fern, coontie and various desirable trees will
be transplanted for preservation.
Coontie, Zamia pumilia, occurs principally in scrub
palmetto/oak and hammock communities. However, no coonties were
found in the hammock located within the proposed construction area.
Consequently, the majority of coonties will be preserved in their
natural state, but those plants which occur in the southern
portion of the scrub palmetto/oak community will be preserved in
landscaping. These hardy plants are commonly found throughout
most of Florida in a variety of environmental conditions. Coontie
-------
is useful in landscaping as a foundation, border, edging or entrance
plant and as ground cover.
The whisk fern, Psilotum nudum, occurs in one area be-
neath a cover of Brazilian pepper. As this area must 'be filled,
the whisk ferns will be removed and planted in a suitable en-
vironment. The whisk fern commonly occurs throughout Florida in
moist shaded woods. Prefering humus conditions, whisk fern
usually grows around the base of trees, on well rotted logs or in
humus-filled cavities of trees.
271
-------
REFERENCES
Bush, Charles S., Florida Shrubs and Trees for Florida Homes,
Florida Dept. of Agriculture, Bulletin #195,
October 1969, pg. 120.
Craighead, Frank C. Orchids and Other Air Plants of the Everglades
National Park, University of Miami Press, Coral Gables,
Florida, 1963, pg. 36.
Long, Robert W and Lakela, Olga, A Flora of Tropical Florida,
University of Miami Press, Coral Gables, Florida, 1971.
272
-------
MF.
V
I
W „-
0- OAK/ PAlMtr"HAMMOCK
P-- SCRUB PALMETTO "
B- BRAZILIAN 'ptPPCMDENs'E)
S- BORRICKIA^ISEA-OXEIC DAISY I
: '
amfh) )* tcancrci) throu«hox,ir«
pl«d "0* and >P Oni Zo^nia was
UV ( Whisk F«rn ) *o\ found in
to 'o«t« Oru. of- tit 8'ozi'ioo P*ppef
location )
.If *V
/••:^--
uf:'.'
-------
APPENDIX VI
ST. PETERSBURG WASTEWATER EFFLUENT SPRAY IRRIGATION PROJECT
-------
oTATK OF
REUBiN 0-0. ASKEW
OOVCIHOM
Fl.OHIDA
EMMETT 6
scent
DEPARTMENT of HEALTH and REHABILITATIVE SERVICES
EPIDEMIOLOGY RESEARCH CEN,T|n
4001 TAM*A B»V BOULCVAHD
TAMPA. FLOHIOA
DIVISION OF HEALTH
WILSON T. BOWOER, M.O., M.P.H., DINCCTOft
February 5, 1973
Mr. William E. Dunn
Board of County Commissioners
315 Haven Street
Clearwater, Florida
Dear Mr. Dunn:
In response to questions posed during your visit on January 24th re-
garding the hazards to public health of secondary effluent spray irrigation,
I must admit that there is no hard data to support my contention that this
is a potentially dangerous procedure. However, the following data is pre*-
sented in support of my opinion.
As you may know, we have been working, with the City of St. Petersburg
on their wastewater effluent spray irrigation project for the past year.
Our findings clearly indicate that secondary wastewater treatment, including
both pre- and post-chlorination, is not sufficient to inactivate entero-
viruses present in the influent. We have routinely isolated from 1-25
enteroviruses from approximately three liters of finished effluent. I think
you would agree that this demonstrates gross viral contamination considering
the small sample size. To date, we have isolated Polio, type 1, 2, and 3,
Coxsackie B2, and ECHO 8, all of which have the potential of causing severe
and possibly crippling disease in man.
In addition to enteroviruses, represented by roughly 70 different types,
adeno, reo and hepatitis viruses are excreted into the sewerage system by
man. Of these, hepatitis is the most resistant to treatment and probably
survives longer than do the enteroviruses. Unfortunately, at present there
is no laboratory system available for demonstrating hepatitis A virus.
Even so, many outbreaks of hepatitis A have been traced epidemiologically
to sewage contaminated water. Although viruses cannot replicate outside a
living cell, they are protected from adverse conditions by proteinaceous
materials and they are capable of producing infection in man when ingested
in very small numbers. Studies have indicated that one or two polio virions
can produce infection. When this potential is considered, the creation of
virus laden aerosols through secondary wastewater spraying appears to me to
be courting trouble.
We still do not know the fate of virus during soil percolation. The
probability exists that the virions would attach to soil particles and thvs,
be removed from the percolating waters. However, such attachments are not
stable since a change in pH can elute the attached particles and permit
C. COIEMAN BREWER, PH.O., Mcmbtr
J. M. COHEN, O.O., Mtmtxr
275
ADVISORY COUNCIL
>o*<
EUGENE G. PEEK, Jr., M.D., Pntld.nl
WILLIAM FREDERICK LINDSEV, M.O., M.mb.r
WILLIAM J. WEBER, O.V.M.. Mrtrfbfl
bit
-------
Mr. William E. Dunn -2- January 5, 1973
passage of the agents to deeper areas. Also, there is competition for
attachment sites among proteins and viruses. Since attachment sites are
limited in number ; it follows that over time as these sites are tied up,
viruses should penetrate deeper and deeper into the soil and should
eventually reach the underground aquifers. Data accrued by the U. S.
Geological Survey staff, which was included in the Environmental Assess-
ment Report for the Northwest Service Area of Pinellas County, clearly
indicates coliform contamination of wells varying in depth from 85 feet
to 135 feet, all in the Floridan aquifer. If these represent fecal coli-
forms, the probability of virus contamination of the Floridan aquifer due
to percolation must be considered. We are at present conducting tests on
effluents which haye percolated through the soil at various depths. Our
findings over time will, hopefully, give us some of the answers we
desperately need.
Certainly, if the end product of wastewater treatment can be shown to
be free of virus, the use of such effluents for irrigation and/or deep well
injection would be advantageous for water conservation. Even so, such use
of wastewater would be limited during heavy rainfall periods necessitating
an alternative disposal method. Additionally, as a safety precaution
against operational breakdowns, an outflow system would appear to be
indicated.
In summary then, I do believe that using secondary wastewater for spray
irrigation, except under rigidly controlled conditions, is a threat to public
health not only through aerosol infection of man but also through virus
contamination of the aquifer. Therefore, only virus free wastewater
effluents should be used for spray irrigation with careful monitoring of the
treatment system. If even minor breakdowns should occur, an alternative
disposal method, preferably an outfall pipe into the Gulf, should be available,
As additional research results become available, hopefully, more
definitive answers will be forthcoming. However, until that time, we must
approach wastewater spray irrigation very cautiously in my opinion.
Sincerely,
Flora Mae Weldings, Sc.D.
Administrator
FMW:ms
276
-------
APPENDIX VII
WRITTEN COMMENTS
277
-------
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
*° JACKSONVILLE AREA OFFICE
PENINSULAR PLAZA
661 RIVERSIDE AVENUE
REGION IV JACKSONVILLE, FLORIDA 32204
Peachtree—Seventh Building in^O
50 Seventh Street, N.E. JUUG I, ±9(5 IN REPLY REFER TO;-
Atlanta, Georgia 30323
U.6 PPG
Mr. Sheppard D. Moore
Chief, EES Staff
11+21 Peachtree Street, N. E.
Atlanta, Georgia 30309
Dear Mr. Moore:
Subject: Draft Environmental Impact Statement
Worth Dade County Regional Collection,
Treatment and Disposal System
The following questions and statements were raised during our
review of the subject Environmental Impact Statement (EES).
1. On page 72 the statement is made that highly
treated effluent may be pumped "into the Biscayne
Aquifer east of the salt front" to act as a barrier
to salt water intrusion. The area described as
"salt front" is ambiguous. The statement seems to
say that the treated effluent would be pumped into
a salt water area east of salt water - fresh water
interface.
2. The statement on page 86 that "the dilution effect
of the Gulf Stream will quickly disperse these (iron,
copper, lead, mercury, zinc, and other elements commonly
found in domestic sewage) to undetectable levels" sounds
reminiscent of the thoughts that the first settlers on
the Miami River must have had about their waste disposal.
On page lljli the same belief is expressed with the state-
ment "the diluting effect of the Gulf Stream (is) estim-
ated to be over seven million times the proposed North
Dade plant rate of flow." A warning is sounded in the
very next clause of that sentence: "little, if any,
serious effect is anticipated".
¥e believe that even a "little serious effect" is too
much. This plant is only one of six to eight treatment
plants of similar capacity in the Southeast Florida area
that propose to discharge effluent into the Gulf Stream*
Well planned, well documented, thorough studies should
be carried out before the project is undertaken so that
statements like: "The long-term cumulative effect of
discharging minute quantities of inorganic, or non-bio-
degradable components to the ocean is not fully known,
(P. llil;)" and "little, if any, serious effect is antici-
27«
-------
pated." can be eliminated from Environmental Impact
Statements and be replaced with facts.
3. Several places in the EIS the following information is
repeated under different topics or headings:.
Pages 87, 120 and lit? all contain discussions of the
relative merits of highly treating wastewater with
the objective of reuse vs. other presently non-tapped
sources of water.
Pages 89 and Ili5>-llj.6 contain parallel discussions of the
problems inherent in deep well disposal.
Pages 108 and 1!?1 contain similar descriptions of sludge
treatment processes.
These passages and others, most notably the several
discussions of construction techniques and amount of
materials needed on pages 83-85 and 15>5, should be con-
solidated to produce a more concise and understandable EIS.
k* On pages 87-88 the EIS states that wastewater injected into
the Floridan Aquifers will probably flow with the water
flow in the aquifer. On page 1^6 the EIS states that the
injected wastewater will probably form a lens or a bubble
of less dense water in the Floridan Aquifer. This is con-
fusing and should be resolved.
£. On page 117 there is discussion of the long term yearly
operating costs of the deep well injection disposal vs.
the ocean outfall system. This is the first EIS of the
six quite similar EIS's we have already reviewed, con-
cerned with wastewater effluent disposal in Southeast
Florida that has discussed that point.
6. In light of the questions raised in Section 2. of this
letter, we would like to once again urge the Environmental
Protection Agency to adopt a policy of recommending Advanced
Wastewater Treatment (AWT) facilities to be an integral part
of all new wastewater treatment facilities construction, or
to plan for addition of AWT at the earliest feasible moment.
If we can be of any further assistance, please feel free to contact
our office.
irrest W. Howell
ea Director
279
-------
OFFICE OF THE ASSISTANT SECRETARY OF COMMERCE
Washington, D.C. 20230
June 12, 1973
Mr. Sheppard N. Moore
Chief, EIS Staff
Region IV, Environmental Protection
Agency
1421 Peachtree Street, N.E.
Atlanta, Georgia 30309
Dear Mr. Moore:
The draft environmental impact statement for North Bade
County, Florida, which accompanied Mr. Ravan's letter
of April 30, 1973, has been received by the Department
of Commerce for review and comment.
The statement has been reviewed and the following
comments are offered for your consideration:
Section I. D. 4, Natural Resources, refers to climate,
beaches, water-based recreation, agricultural land, and
the Everglades National Park. We suggest that the final
environmental impact statement also specifically mention
the various living marine resources in the project area,
including especially those pelagic and benthic organisms
that are of recreational or commercial importance. In
addition, a description of estuarine and oceanographic
features and conditions off the north Dade County coast
would enhance the quality of the final environmental state-
ment by providing information that would assist the reader
in comprehending and evaluating the probable impact of the
project on marine life.
Section II. B. 2, Impact on Water Resources - Atlantic
Ocean, should specifically document the following state-
ments: "There has been scientific study of the effect of*
existing outfalls on water quality and the ecology of the
-------
- 2 -
Continental Shelf. Such ocean studies substantiate
the conclusion that discharge of secondary effluent
to the edge of the Gulf Stream . . . should involve
only minimal risk of pathogenic infection or ecologi-
cal damage."
In addition, we note (page 71) that this draft environ-
mental impact statement, relies on the "Treated Waste-
water Disposal" environmental impact statement for "A more
detailed description of environmental effects associated
with discharge of treated wastes to the Atlantic Ocean
. . .". We suggest that the final environmental impact
statement for this project be revised and expanded to
include sufficient information to allow the environmental
impact statement to be considered an essentially self-
contained document, capable of being understood and evalu-
ated by the reader without having to depend on detailed
discussion contained in another environmental impact state-
ment. Alternatively, each reviewer should be provided with
the referenced document containing information the reviewer
requires to understand and evaluate the impact of ocean
outfalls on marine life.
National Oceanic and Atmospheric Administration's Atlantic
Oceanographic and Meteorological Laboratories in conjunc-
tion with the University of Miami have been obtaining
current measurements seaward of Miami Beach utilizing
continuous recording current meters for a period of several
months. These data when processed and analyzed can be made
available to EPA, and should be considered during the design
phase for either the Interama outfall or for the extension.
of the existing North Miami outfall. The available current
data do not extend to the proposed seaward ends of either
of the proposed outfall sites. In order to insure optimum
location of the seaward end of the outfall as well as
avoiding the possibility of criticism in the future, an
effort should be made to obtain time-series measurements
of the variation in oceanic circulation at any potential
outfall terminus.
281
-------
- 3 -
Thank you for giving us an opportunity to provide these
comments, which we hope will be of assistance to you.
We would appreciate receiving a copy of the final state-
ment.
Sincerely,
'Sidney R.' Gal\eJ
Deputy Assistant Secretary
for Environmental Affairs
282
-------
DEPARTMENT OF THE ARMY
JACKSONVILLE DISTRICT. CORPS OF ENGINEERS
P. O. BOX 4970
JACKSONVILLE, FLORIDA 322O1
SAO WE
5 June 1973'.
Mr. Sheppard N. Moore
Chief, EIS Staff
Environmental Protection Agency
1421 Peachtree Street, N.E.
Atlanta, Georgia 30309
Dear Mr. Moore:
In response to your letter of 30 April and attached Draft Environ-
mental Impact Statement, North Dade County Regional Collection,
Treatment and Disposal System, the following comments are offered.
1. This draft EIS does not appear to be fully responsive
to the requirements of NEPA in that it does not evaluate a
definite proposed plan of action. Numerous decisions are still
to be made on the plan, and potential environmental impacts from
the various choices of system flexibility could be substantially
different.
2. Our comments on the Wastewater Disposal EIS previously
transmitted by SADYN letter dated 27 February 1973, as they apply
to this service area, are still applicable.
3. Our comments on the South Dade County Draft EIS, dated
11 May 1973, pertaining to deep well disposal methods also apply
to this statement.
This also constitutes reply to your letter of 30 April, same subject,
addressed to Colonel J.B. Newman, Office, Chief of Engineers, which
was forwarded to this office for reply.
We appreciate the opportunity to review the statement.
Sincerely yours,
EMMETT I
Colonel, Corps of Engineers
District Engineer
283
-------
United States Department of the Interior
OFFICE OF THE SECRETARY
WASHINGTON, B.C. 20240
ER-73/646 JUL 9 1973
Dear Mr. Ravan:
This Department has reviewed the draft environmental impact statement
on the North Dade County Regional Collection, Treatment and Disposal
System. Within the areas of our concern, we believe that there are
several aspects of the statement which warrant further consideration
and revision.
Geology and Hydrology
Our concerns in this geographic area include an unpolluted ocean eco-
system surrounding Biscayne National Monument and for a natural flow
of ground water into Everglades National Park. In these regards, al-
though either ocean outfall or deep-well disposal of treated waste-
water would be superior to methods currently in use, neither of these
choices permits beneficial re-utilization of wastewater. In view of
the critical shortage of water predicted for Florida in 1980 or 2000,
the section on re-utilization of wastewater (A42-43), although recog-
nizing the problem, falls short of being a full discussion. Many uses
do not require water of the highest quality and such re-use of sewage
effluent could be an important factor in forestalling future shortages.
Although the statement evaluates the alternative of tertiary treatment,-
it rejects its use mainly for economic reasons, rather than environmental
reasons. We believe that the statement should point out that the utili-
zation of alternative tertiary or advanced wastewater treatment would
best assure nondegradation of receiving waters.
284
-------
Ltr. to Mr. Jack E. Ravan, EPA, Atlanta, Ga., Subj: North Bade County
Waste System-
We do not believe that it has been established by the statement that
deep-well disposal is a viable method. The description relating to ge-
ology and hydrology is brief and gives the unjustified impression that
subsurface conditions are well known. In view of the few holes that
have been drilled into the boulder zone, the extent, thickness, and con-
tinuity of the boulder zone and the aquicludes are not known. It should
be recognized that the effects of deep-well disposal are not known and
will not be for many years.
If the decision is made to utilize deep-well injection, then every ef-
fort should be made to meet the requirements set forth.in the EPA
Administrator's Decision Statement No. 5 on subsurface emplacement of
fluids by well injection. The cross sections presented in the report
(figures 6 and 7) indicate that there is some confusion in defining the
depths of deep aquifers. The top of the "boulder zone" of figure 7 ap-
pears to be nearly 1800 feet deeper than the top of the "boulder zone"
of figure 6. Paragraph 3 on page 40 adds to the confusion. The state-
ment presents only a minimum of detail on the construction testing and
monitoring of a deep-well injection system. We believe much more de-
tail is warranted. In our view, the site would be ideal for implementing
a comprehensive investigation of the deep-well injection method.
There is an apparent contradiction between page 87 and page 146. Page
87, paragraph 3, says, "the quality of the resident fluid in the boulder
zone will be degraded," whereas page 146, paragraph 2, says, "injection
of wastewater treated at the north Bade plant is not expected to have
any adverse impact on water quality in the receiving waters of the
boulder zone." In a sense, the native water may be considered improved
in quality because of the recognized possibility that the injected
wastewater can be recovered as an auxiliary fresh-water supply, whereas
the native salt water is presently considered unusable.
The relationship between the physical characteristics of the cavernous
"boulder zone" of the Floridan aquifer and the proposed injection of
treated effluent (p. 164) should be discussed in the environmental state-
ment. An assessment of this relationship is required by the EPA's Policy
on Subsurface Emplacement of Fluids by Well Injection (Appendix II, p.
180, item j.20, draft environmental statement).
We find little basis for additional comment on the deep-well injection
plan until more definitive information is presented. For example, the
last item on page 72 indicates that EPA will require a standby injection
well "leading to a separate level of the boulder zone." This is a
285
-------
Ltr. to Mr. Jack E. Ravan, EPA, Atlanta, Ga., Subj: North Dade County
Waste System
requirement that needs some elaboration, as do other basic items relative
to a deep-well injection plan.
Land Use and Recreation
The proposed facilities are required because of the rapid population
growth and economic development of South Florida. Based upon our re-
view we feel that the document does not adequately address the future
needs of the County as they relate to the predicted growth of the area,
particularly for the need of additional lands to dispose of the sludge
resulting from a wastewater plant, as well as the type of treatment.
For example, on page 111, reference is made to the fact that as "sludge
volumes increase, the existing sludge incinerator at Virginia Key may
be renovated and reactivated." On page 109, mention is made that "If
the demand for sludge as a soil conditioner matches the quantity of
sludge being produced, all of the plants will probably use this method."
We assume that EPA means the sludge will be used as a soil conditioner.
In light of the fact that "... several States have adopted regulations
prohibiting or controlling application (of sludge) where crops are used
for human consumption . . . ," we suggest that EPA consider complete in-
cineration for all of the sludge as the primary disposal method. Such
a treatment appears to be needed for the anticipated volume increase in
sludge. Additionally, we fear that North Dade County will experience
great difficulty in disposing of sterilized sludge (p. 81) that has
low nutritional value (p. 108); therefore, we further suggest the need
for additional land to dispose of the sludge be required and addressed
now by EPA.
The Geological Survey has recently begun a cooperative study with Dade
County on the effects of the northwest Dade landfill on ground-water
quality. The results of this study should provide background data on
the quality of the leachate and its effect on the water resources.
We note that che draft environmental statement has not considered the
impact of the lands (1.5 acres per well site) needed if the deep-well
disposal alternative is adopted (p. 154, paragraph 1).
If the ocean outfall method is used, it seems to us that such use would
not be in concert with the statement which appears on page 101, paragraph
1, particularly as only secondary treatment is proposed: "Due to the ex-
tremely high recreational value of the coastal water of the North Miami
area (which is similar to the project area), it would appear prudent to .
avoid discharge to the coastal areas, even after application of tertiary I
286
-------
Ltr. to Mr. Jack E. Ravan, EPA, Atlanta, Ga., Subj: North Bade County
Waste System
treatment." We also note that "... adequate space for expansion to ter-
tiary treatment was a prerequisite of all sites explored for the North
Dade facility, and will be available at the Interama site . . ." (p. 102).
We urge that the "proper buffer areas" mentioned on page 76 be shown on a
map to clarify that "no change in residential growth patterns north of the
Interama tract is expected." This appears to be necessary as this state-
ment is not in concert with paragraph 2, second sentence, page 76, which
reads: "Since sewer service is essential to land development and popula-
tion growth, it is reasonable to assume that the presence of interceptors
will act as a stimulant to growth in those areas where sewers are avail-
able." Further, we suggest that the last sentence of this same paragraph
be clarified and documented. The sentence reads: "The proposed system
will have only minimal effect on land use in the region, and moreover,
has been designed to conform to land use projections developed by Dade
County." Clarification may be possible by including maps showing existing
and projected land uses for North Dade County.
Finally, we suggest that paragraph 3 on page 80 be clarified and documented
or deleted as most of the soils and vegetation of North Dade County are of
low nutrient value and low quality, respectively. Paragraph 3 is somewhat
misleading as is evidenced by the recreational opportunities, etc., natural
and manmade, which have been developed in the area.
A brief list of additional and more detailed comments is enclosed.
We appreciate the opportunity to have reviewed this statement and hope that
our comments will be of value in the preparation of the final statement.
Sincere
Assistant
Enclosure
Mr. Jack E. Ravan
Regional Administrator
Environmental Protection Agency
1421 Peachtree Street, N. W.
Atlanta, Georgia 30309
287
-------
(ER-73/646)
Detailed Comments on Environmental Statement
The environmental statement would be greatly improved and easier to
understand if the document contained a series of maps for the following
discussions: Physical Geography (p. 34); Effect on Ecological Communi-
ties (p. 64), particularly for the Interama Treatment Site, such maps
should include detailed descriptions showing the vegetation, soils,
topography, and geology for the proposed site; Projected Population
trends in the North Dade District (p. 50); and the locations of the
sites listed on pages 13 and 94 and the pipeline location mentioned on
page 64.
Page 31: We suggest that the reference to the use of the existing North
Miami outfall in connection with deep-well disposal be rephrased as this
outfall would be extended if this method were to be used.
Page 34, Physical Geography paragraph: It should be pointed out that
Conservation Area 3 is not owned by the Federal Government or the State
of Florida. Most of the land is controlled by the State of Florida by
an easement.
Page 56, paragraph 1: Proposed treatment plant sites should be identi-
fied in Section l.A.
Page 61: It is presumed that the last line should read "country," not
"county." If not corrected, the apparent error could lead to serious
misunderstanding.
Page 64, paragraph 1: The shrubs and trees designated as wasteland
species should be better described and listed. The community should be
described as far as habitat value and what species of wildlife utilize
this area.
Page 64, paragraph 2: The statement that the Interama land tract sup-
ports a diverse plant community and about 70 acres of mixed mangroves
is very vague and needs additional coverage. The area provides habitat
for small game, such as rabbits, squirrels, dove, and quail, as well as
numerous nongame mammals, songbirds, and other animals, which play a
role in this diverse community. The amount of each type of wildlife
habitat to be lost should be specified, along with the different species
of wildlife found in those different areas.
288
-------
Also there are two plant species found on Site 6C that are protected by
the State of Florida; these are whisk fern (Psilotum nudum) and Florida
arrowroot (Zamia pumila). These upland species are rare or nearly ex-
tinct and should be considered in this statement.
Page 80, paragraph 3: The loss of native vegetation should be identi-
fied and a description of its importance to the ecosystem added. The
Bureau of Sport Fisheries and Wildlife believes that the loss of native
vegetation in this area of south Florida where very little wildlife
habitat remains is significant.
Page 142: We note that the size of the Interama site is reported as
1,700 acres, whereas 200 acres is the size reported throughout the
rest of the document. We suggest that this be clarified in the final
statement.
289
-------
PETER P. BAUJET
SXECUTIVE DIRECTOR
letter was recei
to the attachments for SAI 73-1190-E.
STATE OF FLORIDA
DEPARTMENT OF POLLUTION CONTROL
2562 EXECUTIVE CENTER CIRCLE, EAST
MONTGOMERY BUILDING.TALLAHASSEE. FLORIDA 32301
June 12, 1973
EVIN
Mr. E, E, Moroney, Chief
Bureau of Intergovernmental Relations
Division of State Planning
Department of Administration
725 South Bronough Street
Tallahassee, Florida 32304
RE: Draft Environmental Impact
Statement, North Dade County
SAI - 73-1190-E
Dear Mr. Moroney:
The Department of Pollution Control has reviewed the Draft
Environmental Impact Statement for North Dade County and makes
the following comments:
1. The statement is generally in accord with DPC
and objectives for Dade County.
programs
2. The statement does not take a definite position on the
method of disposal for North Dade and leaves the question
as to ocean outfall or deep well injection unanswered.
The Department takes the position that an ocean outfall
for this particular facility is the most feasible and
reliable alternative. The injection well alternative is
unproven at this scale in terms of environmental impact
and recycle potential and would result in some delay of
the project. Long term cost savings would be minimal.
In view of this review, the Department of Pollution Control
requests that in the development of the Final Environmental
Impact Statement for North Dade County a firm recommendation
and commitment be made to an ocean outfall means of disposal.
If there is a need for any further information concerning
this project, please contact Don Beevers at 488-3379.
\tery truly yours,
DPS:bll
cc: H. Rhodes;
Donald P. Schiesswo'hl, Chief
Bureau of Environmental Planning
and Evaluation
SE Regional Consultant; Metro-Dade
290
JOHN R. MIDDLEMAS
BOARD MEMBER
GEORGE RUPFEL
BOARD MEMBER
JAMES F. REDFORD. JR.
A, D. VINCEN
-------
FLORIDA GAME AND FRESH WATER FISH COMMISSION
(WARD DOOM, Chairman
Marianna
OGDEN M. PHIPPS, Vice Chairman
Miami
E. P. "Sonny" BURNETT
Tampa
O. L. PEACOCK. JR.
Ft. Pierce
JAMES B. WINDHAM
Jacksonville
DR. O. E. FRYE, JR., Director
H. E. WALLACE. Assistant Director
FARRIS BRYANT BUILDING
620 South Meridian Street
Tallahassee, Florida 32304
May 30, 1973
Mr. E. E. Maroney, Chief
Bureau of Intergovernmental Relations
Department of Administration
725 South Bronough
Tallahassee, Florida 32304
Re: SAI #73-1190-E, Draft Environmental Impact Statement, North Dade County
Regional Collection Treatment and Disposal System
Dear Mr. Maroney:
The Environmental Protection Section of the Florida Game and Fresh Water Fish
Commission has reviewed the above referenced project and offers the following com-
ments.
Although this impact statement evaluates the alternative of tertiary treat-
ment, it rejects its use mainly for economic reasons, rather than environmental
reasons. We would recommend that the best alternatives, tertiary or advanced
wastewater treatment, be utilized to assure non-degradation of receiving waters.
The alternative of tertiary treatment with discharge to saline waters was not
evaluated for environmental impacts. Conclusions reached for not using tertiary
treatment for north Dade are contradictory to conclusions reached for using the
same degree of treatment at the Port Everglades wastewater treatment plant.
(Draft EIS, Ft. Lauderdale).
The impact statement does not clearly state what type of treatment will be
used to stabilize the sludge, but does have one reference made to heat treatment
(p. 81). We would recommend that heat treatment be utilized on the sludge, if
it is not already proposed, so that adverse impacts on public health and water
quality will be minimal.
Alternate methods of treatment for effluent and sludge during equipment
failure should be discussed; none were discovered in this statement. Alternate
routes for the pipeline between the plant site and the ocean should be shown
on a map having existing ecological communities, and what each route's environ-
mental impact would be. The environmental impact of the proposed facilities on
each of the potential sites is not discussed in this draft environmental impact
statement, and should be covered in the final statement.
291
-------
Mr. E. E. Maroney
Page Two
May 30, 1973*
Thank you for the opportunity to comment on this project. If we may be of
further assistance, please feel free to contact us.
Sincerely,
H. E. Wallace
Assistant Director
HEW/BJ/ra
292
-------
STATE OF FLORIDA
Of
THE CAPITOI
TAUAHASSEE 32304
ROBERT WILLIAMS, DIRECTOR
DIVISION OF ARCHIVES HISTORY. AND
REC
DIViSiOH CF STATE PLANNING,
(9Od) 488-I48O
Bj.-ea-.; Of
MAY 29 1973
SAI NO.
RICHARD (DICK) STONE
SECRETARY OF STATE
Mr. E. E. Maroney, Chief
Bureau of Intergovernmental Relations
Division of State Planning
Department of Administration
725 S. Brenough
Tallahassee, Florida 32304
Re: S.A.I. f73-1190-E (E.P.A. North Dade County Regional
Collection, Treatment and Disposal System.)
Dear Mr. Maroney:
In reference to the above project, we find that archaeological
and historical values have been considered on pages 59, 62, and
63. On pages 62 and 63, the D.E.I.S. reads:" More intensive
examination of routes and sites will be undertaken during final
design to ensure that no valuable areas (i.e. archaeological,
historical, and geological) are affected". We would like J_o
strongly recommend that this "intensive examination", relative
to archaeological and historical resources, be conducted by
professionally-trained archaeologists. This will insure the validity
of the subsequent assessment.
Sincer
L. Ross Mo IT'•"•e 11,-
State Archaeologist and Chief,
Bureau of Historic Sites
and Properties
LRM/epg
293
-------
MIAMI-DADE WATER AND SEWER AUTHORITY
P. O. BOX 316 3575 S. LeJeune Road
MIAM., FLORIDA 33133 Telephone 665-7471
May 11, 1973
Mr. Jack Ravan
Regional Administrator
U.S. Environmental Protection Agency
Region IV
1421 Peachtree Street N.E.
Atlanta, Georgia 30309
Re : Public Hearing for the Drafts of
Environmental Impact Statements
For Regional Wastewater Treatment
Plants: in Dade County,, Florida
Dear Mr. Ravan:
Our comments on the drafts of North, .Central and South Dade
District Environmental Impact Statements (E.I.S.) are presented below
in summary form. They are the product of the independent study of
each Environmental Impact Statement by both our staff and the consult-
ing engineering firm assigned to the specific project and to the over-
all Water Quality Management Plan.
I. General Cotmnents
The three E.I.S.'s generally follow the projects recommended
in the latest draft of the Water Quality Management Plan (W.Q.M.P.) of
Metropolitan Dade County, Florida, which we support. Two of the E.I.S.'s
feature important alternatives which should be considered because of
limitations on the availability of funds during the initial stages of
the large scale projects. In addition each E.I.S.. considers alterna-
tive^ to the W.Q.M.P. which have been raised previously by local citi-
zens at public hearings conducted during the summer of 1972 when the
Environment Assessment Statement was in preparation. Thus, a serious
effort has been made to continue to reexamine citizen objections and
questions right up until the issuance of the final draft of each E.I.S.
II. North Dade District E.I.S.
A. Initial Capacity of Wastewater Treatment Plant.
The initial capacity of the wastewater treatment plant is
reduced from 80 to 40 million gallons per day (mgd) as a first stage
with a remaining stage to be constructed at a future date to provide
a total of 80 mgd in the future. However, recognition is given to the
possibility of increasing the size of the initial wastewater treatment
plant in the E.I.S. as follows : "If it can be shown that this capacity
will not be adequate to meet local management needs, the initial capa-
city of the treatment facility may be expanded" (page 13). Another
important reference is Figure 3 on page 33 of the E.I.S. It shows an
295
-------
Mr. Jack Ravan
May 11, 1973
Page 2
initial average daily wastewater flow of 60 mgd for 1976-7 increasing to
80 mgd by 1985. As a result of our review of this matter, it is recom-
mended that the North Bade District Wastewater Treatment Plant have an
initial capacity of 60 mgd rather than 40 mgd, and that basic capacity of
80 mgd be completed before 1985.
B. Alternative Methods of Disposal of Treated Wastewater.
The first, an ocean outfall, is placed at a disadvantage by
economic comparison because it cannot be constructed in increments to
conserve the expenditure of funds at an early stage of the project. Con-
sideration of the need by the Environmental Protection Agency' for conserv-
ing of funds is directly linked to the recommendation for constructing an
initial Wastewater treatment plant of 40 mgd capacity rather than any
larger. An acceptance of an initial 60 mgd capacity for the wastewater
treatment plant, and its larger volumes of treated wastewater, would favor
the ocean outfall alternative from an economic standpoint.
The second alternative for disposal of treated wastewater is
the combined use of the existing ocean outfall extended beyond the third
reef and deep wells. Our objections to this alternative are as follows:
(a) It will not be of significantly lower initial -cost
if the initial wastewater treatment plant capacity is
60 mgd.
(b) The deep wells cannot receive raw sewage and must
await completion of the wastewater treatment plant in
1977 or later before providing additional capacity to
the existing overtaxed North Dade Interceptor and ocean
outfall.
(c) The adoption of deep wells for treated wastewater
disposal, requires that a test well be drilled to con-
firm geologic formations at the site and this will delay
construction of the installation of the full capacity
units by more than one year, based upon local experience.
A deep well of 3,000 feet depth, of 24 inch or larger
diameter, is a major project.
(d) The companion project extension of the existing
ocean outfall some 1,100 feet to a depth of 90 feet and
the installation of diffusers beyond the third reef will
decrease its hydraulic capacity to approximately 30 mgd.
This flow is rather small by comparison to the total
peak flow for the project which is in excess of 175.5
mgd. The quality of construction of the existing out-
fall facility has been subject to question so that the
investment of large expenditures to extend it for long
term service is not clearly supported.
296
-------
Mr. Jack Ravan
May 11, 1973
Page 3
(e) An additional site for deep wells would be required
in an area where land is difficult to acquire.
It is our recommendation that an ocean outfall be installed
to serve the North Dade District wastewater plant of sufficient capacity
to meet peak flows from that plant.
C. Disinfection
Requirements for, or definitions of, secondary treatment have
been cited differently with respect to disinfection in the Impact State-
ments relating to Dade County. These should be superseded to conform to
the recently proposed national standard as stated by EPA in the Federal
Register (Vol. 38, No. 82, April 30, 1973). Details of these differences
are somewhat technical for presentation at this hearing.
III. Central Dade District E.I.S.
This E.I.S. draft is in complete agreement with the Water
Quality Management Plan for Metropolitan Dade County, Florida and its
approval is recommended.
IV. South Dade District E.I.S.
A. Initial Capacity of Wastewater Treatment Plant.
It is recommended that the wastewater treatment plant be con-
structed initially of 30 mgd capacity instead of the 50 mgd recommended
by the W.QJJI.P. If the initial plant size were limited to 30. mgd, it
would not be possible to receive sewage from the Kendall area until
1985 when it is to be rerouted to the future West Dade District waste-
water treatment plant. It is recognized that it is not desirable to
continue operation of the two Kendall area wastewater treatment plants
owned and operated by General Water Works Corporation after construction
of the South Dade District regional wastewater treatment plant. However,
it is probably the more economical alternative, especially since Kendall
area wastes are permanently designated for discharge to the West Dade
District wastewater treatment plant. Therefore, by continuation of op-
eration of the two Kendall plants after its.completion, the initial capa-
city of the South Dade District regional plant can be established at
30 mgd, for future enlargement to 50 mgd capacity.
B. Location of Deep Disposal Wells.
»•
The requirement to install the proposed deep disposal wells,
east of "Salt line", or 1,000 ppm isochlor at the base of the Biscayne
acquifer, has been questioned in the E.I.S. for reasons of economy.
297
-------
Mr. Jack Bavan
May 11, 1973
Page 4
It would save some estimated $2,850,000, if the deep wells could be in-
stalled on the wastewater treatment plant site by elimination of a pipe
line.
The Miami-Dade Water and Sewer Authority has a dual responsi-
bility to the community. The protection of the water resources of Dade
County are of vital importance, also. South Dade County, in the vicini-
ty of the South Dade District wastewater treatment plant site is wholly
dependent for its fresh water supply on the Biscayne acquifer. No pub-
lic water utilities have mains in the area so that wells are the source
of supply for domestic and irrigation water. Any damage to this re-
source would be of extreme concern to all interests in the area.
During the summer of 1971, it was found that brackish water
resulting from drilling of the Sunset Park wastewater plant deep dis-
posal well had reached the Authority's Alexander Orr Water Treatment
Plant supply wells, some 1.5 miles distant. Again, during 1972, the
drilling of the second deep well at the Kendale Lakes wastewater
treatment plant produced high chloride concentrations in the Biscayne
acquifer at the well which were drawn toward the Southwest Well Field
of the Authority, approximately two miles distant. Fortunately, pro-
tective measures by General Waterworks, ordered by the Florida Depart-
ment of Pollution Control, and changes in pumping schedules by the
Authority prevented either of these "salt spills" from impairing the
public water supply, but it was a warning of what could happen. In
retrospect, each of the two deep wells drilled for treated wastewater
effluent disposal produced a serious hazard to our water resources.
As a result of these two incidents, the Dade County Health
Department, the Florida Department of Health and Rehabilitation Ser-
vices, the Florida Department of Pollution Control, the Metropolitan
Dade County Pollution Control Department, and the Authority jointly
adopted an informal policy urging that future deep wells be limited
to areas east of the "salt line" where "salt spills" resulting from
drilling, could cause no damage to the fresh water in the Biscayne
Acquifer.
For the reasons stated above, the Authority staff will vig-
orously oppose the drilling of deep wells on the South Dade District
wastewater treatment plant site. However, the installation of the
deep wells east of the "salt line" or 1,000 ppm isochlor, will be
supported.
298
-------
Mr. Jack Ravan
May 11, 1973
Page 5
V. Conclusions
The preparation of the three Environmental Impact Statements
for wastewater treatment in Dade County, Florida, was a most difficult
project for your staff, because of the wide range of problems to be
resolved. The quality and detail presented in each Statement are
appreciated and will serve as valuable reference data. Certainly no-
thing of importance was overlooked. We will make every effort to
support your Statements, subject to the comments presented herein.
Very truly yours,
Garrett Sloan
Director
GS:ew
299
-------
METROPOLITAN DADE COUNTY* FLORIDA
864 N. Wr 23lb STREET
33127
£ _ tELEPJfONE: 635-7524
DADE COUNTY POLLUTION CONTROL
May 23, 1973
N. Moore
E.I.S. Staff
-U2l'peachtree St., N. E.
Atlanta, Georgia 30309
Dear Mr. Moore:
This refers to Mr. Ravan's letters dated Apri I 13 and 27,
1973 with which were forwarded copies of Environmental Impact
Statements on Dade County, Florida.
Regarding these documents, the following are our comments list-
ed in order of importance insofar as they concern this office:
1. On page 13 of the Draft E.I.S. on North Dade County
the proposal is made to construct the Interama
sewage treatment plant in two 40 mgd increments over
the next three to five years. However, on page 30 of
the same E.I.S. it is stated that the countywide water
quality management plan calls for i mmed i ate construc-
tion of an 80 mgd treatment facility in North Dade
County. We wish to point out that an 80 mgd or, at
the very least a 60 mgd capacity plant should be plan-
ned for as the initial stage for the following reasons.
The present flow generated by the area under consider-
ation is approximately 23.6 mgd. The flow from cur-
rently operating municipal and private package plants
which are to be diverted into the North Dade regional
plant as soon as possible amounts to some 14.2 mgd.
To this should be added the estimated additional
flow to be expected from building for which building
permits have been approved, in the North Dade Area.
but which have not yet received Certificates of
Occupancy. This figure amounts to approximately
3.0 mgd.
These figures total to some 40.8 mgd. Roughly account-
ing for the population growth forecast, in three years
the sewage flow to be handled could easily reach 42.9
mgd thus making a 40 mgd treatment plant inadequate at
the start of operation.
300
-------
Mr. Sheppard N. Moore
May 23, 1973
Page Two
2. We would take issue with the location of deep wells
at the plant site for disposal of treated effluent
from the regional treatment plant serving South
Dade County, as advocated in paragraph IV.B.I, page
95, in order to cut costs. We consider that a con-
cern for public health would take precedence over
cost when determining location of the disposal
wells. It is obvious that location of the wells
east of the 1,000 ppm isochlor line should be of
major concern in protecting our drinking water
supplies. The isochlor line is located approximately
three miles to the east of the plant. This viewpoint
is also shared by the U. S. Geological Survey, the
County Water and Sewer Authority and the Dade County
Health Department. The basis for this stand is dis-
cussed below.
3. We also question the advisability of disposing of
treated wastewater, in excess of the capacity of the
ocean outfall, into deep wells as proposed as an
alternate on page 2 of the summary sheet for the
E. I. S. on North Dade County.
The two foregoing objections regarding the manner proposed for
the use of deep disposal wells, when not an absolute necessity,
are based on the still questionable factors and certain doubts
regarding the dependability of deep disposal wells in general.
Justification for exercising caution in the use of such wells
is expressed at several points throughout part V c of the final
E.I.S. 'Ocean Outfalls and other Methods of Treated Wastewater
Disposal in Southeast Florida". These include the accounts of
two well failures in Florida in 1965 and 1969 mentioned on
pages 184 and 185 of the E.I.S. The statement is made on pages
187 and 188 that the use of deep wells for disposal of wastewaters
in the study area (Southeast Florida) would remove some 197
million gallons a day of wastewaters from man's immediate environ-
ment with less potential for health hazard than other methods of
disposal, as long as reuse for Immediate consumption is not
considered. However, this statement is immediately followed by
a comment cautioning that the long-term effects of this method
of waste disposal are not known.
301
-------
Mr. Sheppard N. Moore
May 23, 1973
Page Three
Also, on page 188 the comment is made that the safe
disposal of any microorganisms surviving the sewage treat-
ment process is dependent upon whether the aquicludes
function as intended, in which case the surviving bacteria
should no longer constitute a hazard to the health of man.
It is further noted that E.P.A. recommends on page 188
that precautions be taken to provide for automatic stop-
ping of injection pumps when a predetermined pressure
i ncrease occurs.
Reference is made on page 199 of the same E.I.S. to second-
ary seismic activity along fault planes being caused by
injection of wastes at high pressure in certain other
areas of the United States. Although the possibility
of such occurrences in Southeastern Florida are said to be
minimal, the existence of a fault zone in the study area
is described, which was mapped in 1965. Further, special
precautionary monitoring measures are recommended to protect
the property owners and potable water supply if any deep
disposal wells are constructed in that area. Although the
fault zone lies in Martin and Palm Beach Counties, the
possible existence of a fault in Dade County cannot be
positively ruled out.
Considering the various observations mentioned above con-
cerning deep disposal wells, we feel that at the present
time they should by no means be considered a foolproof
method for disposal of wastewater.
Although we seriously question the desirability of using
deep disposal wells in the vicinity of the proposed North
Dade Interama sewage treatment plant, the circumstances
concerning disposal of treated wastewater from the South
Dade regional sewage treatment plant pose an entirely
different problem. These circumstances make the use of
deep disposal wells preferable to an ocean outfall at the
South Dade plant and discussed below:
1. Whereas the existing ocean outfalls in Southeast
Florida vary from 4,600 to 12,000 feet in length,
an outfall to serve the proposed South Dade sewage
treatment plant would have to cover a distance
302
-------
Mr. Sheppard N. Moore
May 23, 1973
Page Four
of some eighteen (18) miles, approximately
thirteen (13) miles of which would be under water,
in order to traverse Biscayne Bay, the coastal
reefs and reach a nominal water depth of 90 ft.
in the ocean. The cost involved would be prohibitive,
2. Furthermore, this facil.ity would be just north of
the Biscayne National Monument and not far from
the John Pennekamp Coral Reef State Park. The
establishment of these preserves attest to the high
regard in which this entire area is held as a most
productive and valuable underwater preserve.
3. To excavate the necessary trenches for an ocean
outfall line across the widest part of Biscayne
Bay and eastward of the coastal reefs would
cause siltation and increased turbidity.
We wish to invite your attention to certain errors in the
list of sewage treatment plants which will eventually dis-
continue operation when expansions to the regional plant
serving Central Dade County is complete. These are listed
on page 40 of the Draft E.i.S. on Central Dade County.
Eastern Shores and Sunny Isles should be omitted as they
are located in the North Dade District. The Veteran's
Administration Hospital is out of service and should also
be omitted, while the Kendale Lakes Plant should be added
since it is considered as one of the major plants in the
Central Dade District.
Ve ry truIy yours ,
Co I in Morrissey
Di rector
CM/JPS:bI
303
-------
RE:
Addendum to Chamber's Position Taken
at May 15 EPA Hearing on Dade County's
Interim Water Quality Management Plan.
The Greater Miami Chamber of Commerce
1200 BISCAYNE BOULEVARD. MfAMI. FLORIDA 33I3Z. (3OS) 377-4711
May 24, 1973
RICHARD BRUSUELAS
DIRECTOR OF ENVIRONMENTAL
HEALTH PLANNING
Mr. Sheppard N. Moore
Chief, EIS Staff
1421 Peachtree Street, NE
Atlanta, Georgia 30309
Dear Mr. Moore:
In further review of the draft Environmental Impact statements we would like to address
the following points and include them in the record as part of our presentation.
In our concern for North Dade we again would like to question the feasibility of building
these facilities in stages of 40 million gallons per day. By the time the initial 40 mil-
liuii ydllon pei day uriii ia completed it would be at capacity and the North petit .uf Dade
County will again be faced with the dilemma of building moratoriums or making variances
for package treatment plants, septic tanks or other modes of treatment until the second
unit can be completed. Good community planning in North Dade will depend on the
completion of a total package, giving us 80 million gallons per day capacity. Therefore,
we feel that it is imperative that we construct an initial 80 million gallon per day sewage
treatment facility.
In light of the fact that there will be a Bi-centennial Celebration at the Interama site, we
would hope that all construction will be completed"before the exposition opens.
We are further concerned with the operation of deep well injection systems because of the
energy or power requirements which are considerably higher as compared to ocean outfalls.
In light of South Florida's electrical demands and nation wide fuel shortages it would seem
the best and least environmentally damaging approach to use ocean outfalls.
Because of our interest in the total environmental health of Dade County, we would like to
request a consideration of the impact of disinfection procedures which would be required
of all our ocean outfalls. We understand that large quantities of chlorine will be required
to meet proposed EPA standards for disinfection. Our questions are in two parts, 1)
what the impact of chlorine will be on the ocean ecosystems, and 2) what precautions will
be taken to avoid extremely hazardous situations involved in shipping and handling large
quantities of chlorine gas in a heavily urbanized area. Possibly, another ramification of
this question would be: can this chlorine gas be provided and can we as a community cope
with the hazard and potential danger to human life posed by the transportation and handling
of large quantities of toxic and corrosive substances such as chlorine.
304
continued....
-------
Mr. Sheppard N. Moore
May 24, 1973
Page Two
Appreciate your handling these items mentioned above as an addendum to our presente-
tion.
truly yours,
Richard Brusuelas
Director of Environmental
Health Planning
RB/omt
305
-------
R*E*V*0*L*U*T*I*0*N" Campaign
Anne Ackerman (Mrs. I.)
Chairperson, "Pollution Revolution"
3010 Marcos Drive, #R401
North Miami Beach, Florida 33160
Telephone number,305- 931- 3890
J
Sheppard N. Moore
Chief, EIS Staff
1421 Peachtree Street, NE
Atlanta, Georgia 30309
Dear Mr. Moore,
As Chairperson of the "Pollution Revolution" Campaign of North Dade
County, Florida, I am submitting the following statement re: Draft
Environmental Impact Statement, North Dade County.
I feel like an actor in a three act play making my final curtain
speech,— since I allready testified before E.P.A. in Palm Beach
County, then in Dade County, and now, in writing, directly to you
in Atlanta. 1 was ill the day— May 14, 1973— the final public
hearing was held in Miami.
History
The "Pollution Revolution" Campaign of North Dade County was organized
in November ,1970 with two objectives;—(1) To obtain a phosphate-ban
in detergents & cleaning agents for Dade County as a first step in
the retardation of the eutriphication of our waters: and (2) to
bring to South Florida, and particularly Dade County an effective,
sophisticated,advanced water treatment sewage program aimed toward
the re-use of our waters.
The first of these objectives was met within a year, altho' we had
to overcome the opposition of the major producers in the cleaning
agent industry,--namely, Proctor-Gamble; Colgate; & Lever House.
We were able to accomplish this because our local governnrt»at -
The "Metro" Commission of Dade County- gave us unqualified support.
The second objectivefunfortunai:«ljty is another matter. Altho* we h ave
appeared time and time again before every group empowered to develop,
approve, and implement a proposed plan, — all that has happened is
the tentative approval of an archaic plan that seeks no more than
secondary ( 90% ) treatment of sewage and an ocean outfall. All
plans proposed by us, and others, that would point toward advanced
waste-water treatment (tertiary with phqphate removal at plant site))
and the re-use of our most precious resource,-- our water— have been
discarded.
We have pointed out time and again that,— (1) we object to the site,
Interama; (2) we »eek a site in the west end of Dade County, because
such a site would lend itself to a sophisticated program; (3) we
cannot afford to lose all our water thru1 an ocean outfall; (4) we
sought a compromise plan that would utilize a smaller plant at
Interama together with the ocean outfall available now, provided that
at the same time, a western site plant for tertiary treatment would
be Included.
It must be stated at this point ±*at the plan now being proposed does
-------
not include the Last stated (4) compromise plan, or we would have
endorsed it,
Our objection to --
(1) The Interama Site was based on the fact that it would place a
sewage plant in the site that had been set aside for the most
highly developed cultural and recreational facility in the
entire area;-- that the site was chosen in order to bale out
the Interama Authority from financial difficulties, and only
then were the reasons developed for its desireability as a
sewage plant site;-- that it does not lend itself to a place
where advanced waste-water treatment and recycling could be
done. Yet, we were willing to accept it, if it were a small
part of the over-all adopted plan.
(2) It is imperative that a west Dade site be obtained now for a
plant that could be developed for tertiary treatment and the
reuse of our waters. Unless it is done now , it will not be
made available in the future. It has taken 13 years for the
1960 plan to be partially implemented, and we know that if
the plan contained in the Impact Statement is implemented now
we will not be able to obtain the other at any future date
in our lifetime.
(3) Enclosed herewith is a newspaper article that appeared in the
Miami Herald, dated May 23, 1973, that is self explanatory,
Our precious water supply cannot at this time even take care
of our current population, and growth will take place. Unless
we use every advanced method known now to reuse our water, we
will desecrate this entire area. Most of us who came here to
live have come out of cities that have been destroyed ecologies
and we refuse to see this happen here*
(4) We will support a plan that will include an advanced waste-
wajrer treatment plant in western Dade now, together with the
smaller plant at Interama with the ocean out-fall that is
presently in use, or one that may be needed to augment it,
Altho1 deep well injection has been proposed, we do not think that
is the answer. The proposals contained in the"impact staement"
call for 2-40 Million Gallon plants at Interama. If only one such
plant is built for Ocean Outfall, and the other started now, •*»**
even on a smaller scale for advanced waste-water treatment with
various methods tried for water re-use then within a short period
of time that western Dade plant could give us definitive results
for water reuse in this area , and point the way for the kind of
program we envision. The Interama plant and outfall can the» be
used as a back up or alternative plant as needed.
We would support such a program . The saving of our water is imper-
ative, We can support no program that does not have this objective,,
Please excuse the typographical errors,— this is not my area of
competence. Nevertheless, we urge you to give full consideration
to our recommendations.
Sincerely yours,
^~ N
-------
Ban Is
Necessary'
By MIKE TONER
Herald Environment Writer
Dade County has out-
grown its supply of fresh
water and should prevent
any new building on 169,000
acres of undeveloped land
remaining between the urban
area and the Everglades, the
county's most active conser-
vation organization said
Tuesday.
A moratorium covering
most of Dade's remaining
undeveloped' land is neces-
sary to preserve it for re-
charging the underground
water supply of the county's
1.3 million people, Izaak
Walton League officials said.
"GOVERNMENT MUST
face the growth issue and
seek any and all means to
contain it within the capabili-
t i e s of our natural re-
sources," IWL chapter Presi-
dent James Redford said,
releasing a six-month study
of the county's water re-
sources made at the Univer-
sity of Miami's Center for
Urban Studies.
The study, financed under
a $10,000 grant from the
IWL and the Miami-based
foundation of vacuum
cleaner millionaire Herbert
Hoover, concludes that:
• The Miami area has al-
ready run short of water
once — with a six billion
gallon deficit during tna
spring drought of 1971.
• Existing supply is not
only inadequate, but is being
seriously threatened with
contamination by sewage,
pesticides, industrial wastes
and infiltration from the sea.
• Future population
growth will force increasing
numbers of people to share
the same amount of water —
compelling as much as" a 40
per cent reduction in individ-
ual use during future
droughts. 208
• Areas earmarked for fu-
ture development — includ-
ing parcels of land now being
sold adjacent to Everglades
swi the jetfiort
-------
Water Supply Outgrown, Study Says
Frorri Page TB,
site be'ng considered in
North Dade — should be left
unsaved because they are
water-carrying B i s c a y n e
Aquife-.
• And so-called "exotic"
means of getting additional
water — like piped-in water,
desalinization and b a c k-
pumping of urban runoff —
are not only expensive, but
would reqQire vast amounts
of another resource in limit-
ed supply, energy.
IN ADDITION to the
moratorium on undeveloped
lands, Redford urged:
• A halt to all rezoning of
existing open areas now
zoned for agriculture or
general use.
• .Cessation of all
drainage canal construction
within the lower portion of
the Central and Southern
Florida Flood Control
District — stretching from
the Kissimmee River in
central Florida to the tip of
the peninsula.
• Active discouragement
of all new diversions of fresh
water from the Miami Canal,
Dade's, "pipeline" to ' the
fresh water reservoir of Lake
Okeechobee — a recommen-
dation that could effect
water for farming and
industrial use.
Redford said the moratori-
ums ought to remain in
effect "until we are able to
assure that we will have the
services needed for any fu-
ture increases in population."
"WE CANNOT support
ourselves on the water we
get from the aquifer now
during times of drought.
"So to the extent that the
people of Dade County be-
lieve that water is neccessary
to their quality of life; any
the man-made Miami Canal
that continued to recharge
the Biscayne Aquifer during
the advanced stages of the
drought.
Without water creeping
' down the canal from the
nearly dry Lake Okeechobee,
the UM team concluded, the
intrusion of sea water into
the fresh water aquifer
would have been even
greater than it was.
They pointed out that
North Miami Beach wells
suffered considerable salt
contamination — at times
yielding water with three
times the salt level deemed
safe by public health of-
ficials.
But the' water supply of
the shallow lake is also the
major surface reservoir for
growing populations, agricul^
ture, industry — and even
power plants — in the fast/
growing coastal areas nortH
of Dade County.
'THE AMOUNT of water
we have is finite; it is one
pot with a predictable bot-
tom," Redford said.
He warned that future
growth in the Florida Keys
— expected to triple its de-
mand for fresh water —
would add to the competition
for water.
About half of the Keys
water supply is pumped out
of the ground in South Dade
and piped southward along
the chain of islands.
The UM study is also the
first attempt in South Florida
to link what is becoming
known as the water crisis to
what is already known as the
energy crisis.
But Hartwell who worked
for the U.S. Geological
Survey for 30 years, says
that all "new technologies"
for increasing the water sup-
ply would require "increas-
ded costs, increased demands
for energy and accompanying
environmental tradeoffs 7- a
nice way of saying that more
natural values will be lost."
"The FCD is having trou-
ble getting diesel fuel for its
pumps," Redford pointed out.
"WHAT WOULD happen
if we grew so populous that
we had to depend on back-
pumping of runoff waters
and there was no fuel for the
pump?"
And Redford cautioned
that backpumping — dispos-
al of water washing off the'
urban areas into the
Everglades — would be the
equivalent of disposing of
• treated sewage into pristine
wetlands.
The UM study concludes
that many areas of the
Miami urban area already
unsuitable for wellfields
because they are located too
close to sewage treatment
plants or areas with a high
concentration of septic tanks.
In fact, Hartwell concludes
that only about 50 per cent
of the county's surface is
now available for recharge
very to the aquifer —the
areas now being eyed for fu-
ture development.
Covering those areas with
homes, roads and shopping
centers would reduce even
further the amount of water
seeping Into the aquifer from
the surface, he said.
"The destruction of these
resources can be likened to a
pensioner whO' consumes his
principal along with the
interest," he said.
"Some Monday morning he
will w.ake up broke,"
Study Propose? Moratorium for Shaded Arep
... 169,000 acres now largely undeveloped
309
-------
J»LERT CITIZENS |RI-COUNTY!ILLIANCE
AN AFFILIATION OF CITIZENS GROUPS OF
DADE, BROWARD, PALM BEACH AND NEIGHBORING COUNTIES OF SOUTH FLORIDA
Headquarter*
13085 ORTEGA LANE CITIZENS GROUPS OF:
NORTH MIAMI, FLORIDA 33161 May 27 » 1973 CORAL GABLES
Telephone: MIAMI
305) 891-1183 or 947-8411 NORTH MIAMI
NORTH MIAMI BEACH
C Hai'rmsn HIALEAH
HOBARTT. FELDMAN, M.D. MIAMI BEACH
HALLANDALE
SeoRETARy MIRAMAR
BEN MARKS HOLLYWOOD
Mr. Jack Ravan
Regional Administrator PALM BEACH
Region IV - EPA OTHER COMMUNITIES
1421 Peachtree Street NE
Atlanta, Georgia
RE: DEIS North Bade County Regional Collection, Treatment, & Disposal
System
Dear Mr. Ravan:
The following comments are submitted, herewith, for inclusion in the
records, regarding EPA's DEIS of the North Dade System referred to above:
I. RE: Ocean outfall disposal of 90% treated effluent:
A. Effects on ocean eco-system
1 . Depth at distal end of outfall
a. At 90 ft. depth, current is definitely toward the shore
(Personal communication, Dr. Don Hanson- NOAA - Miami)
b. Edge of Gulf Stream meanders, frequently £-3 miles east
of proposed location.
2. Hazards of recommended chlorination levels on marine organ-
Isms emphasized by EPA's Gentile and Brung. (PB DEIS May, '72)
3. Warnings by Drs. Betz, Hoffmann, Corcoran, Lane, Voss, Lee,
et cetera not mentioned, & apparently ignored (PB DEIS,
May 22, '72; P.B. DEIS Jan 24, 1973)
4. EPA's statement of resulting Improvement in quality of
ocean water is erroneous. The quality is degraded. P58.
B. Destruction of Mangrove- estuarlne association
1 . Proposed pipe line would permanently destroy a significant
portion of an ecologically-significant Mangrove- estuarine
system. P 65
2. Presence of these mangrove-estuarine associations not listed
as a valuable natural resource. P37
3. Destruction of mangroves in submerged, and wetlands areas
for laying of pipe would require extensive study and permit
from other Federal and State agencies concerned with conser-
vation of mangrove areas.
C. Irreversible and irretrievable loss of fresh water to the ocean
1 . No suggestions offered as bow to avoid this in DEIS by EPA
2. Water shortages acknowledged. P 41
-------
Mr. Jack Ravan May 27, 1973
3. EPA's preference of backpumping storm water run-off should
not be permitted because of poor quality of water P 4y
4. DEIS mentions "More desirable sources are available," but
does not identify these "sources". P 87
II. RE: Deep well injection of 90% treated effluent
A. EPA acknowledges hazards but minimizes them P72
B. EPA minimizes major danger of fault zone leakage P 88
C. Immediate need for recover ing water not considered by EPA
D. Effluent not fit for body contact, or ingestion.
E. Fate of injected water speculated, not known.
Ill RE: Plant site location on Interama
A. Expensive land, not originally intended for sewage treatment plant
B. Not condusive to use of treated effluent in present or future
because of easterly location.
C. Dade County's contract with Interama specifies odor-free plant.
This is not guaranteed, according to DEIS P 74, 80
D. Selection predicated on continued use of ocean outfall because of
1. Salt infiltration
2. Limited state-of-the-art, alleged, to provide AWT
IV. RE: Salt infiltration
A. Statement by EPA that "the county has initiated a rigorous
infiltration abatement program" (p44) la completely untrue.
(Dade County has no over-all program underway for infiltration
control at this time.)
B. Volumes of effluent in Dade County are misleading, and represent
infiltrated water in system added to human use.
C. Adequate infiltration abatement program would reduce volumes
to be handled by treatment plants by one half.
D. Lack of adequate infiltration abatement program by county should
make county ineligible for federal grant. (P.L. 92-500}_
E. Extravagant overbuilding of plant to accommodate excess water
from infiltration not economically sound.
V. RE: Type Treatment Plant and Quality Effluent
A. Modified activated sludge plant proposed does not comply with
92-500 because it would not provide for the highest treatment
available for the life of the works.
B. Sludge produced must be separated from the plant and pumped
westward for treatment. No studies have been performed to de-
termine possibilities of contamination of near-by well fields.
C. Split system of effluent-sludge treatment at different locations
would Increase cost of operation.
D. No cost-factor analysis studies performed comparing plants at
east and westerly locations.
E. EPA states there is Inability of tertiary systems to demonstrate
dependable destruction of bacteria and inactlvatlon of virus (p10l)
1. EPA ignores proven TAHOE and similar systems in successful
operation for years.
2. EPA ignores repeated comments from Corp of Engineers, and
Dr. John Sheaffer, Chief Environmental Expert, Undersecretary
of the Army concerning feasibility of advanced systems, etc.
(DEIS - Ocean Outfalls - Mar 19, 73, p. F 8)
3. EPA has approved at least 35 advanced treatment facilities
in Florida, with recycling through spray irrigation. Similar
projects have been approved by EPA in otherparts of U.S.
4. None of above were mentioned in present DEIS. Impression by
EPA is that no advanced or tertiary system provides acceptable
effluent.
F. Synergistlc use of effluent with electric generating plant not
mentioned, although such plants are now being considered in west.
-------
Mr. Jac* Ravan
G. Imposed limits of county lines are contrary to concepts of
regional, multicounty system essentdil in SE Florida, and in-
dicate obsolete planning.
The above outline summarizes major criticisms of Dade County's Interim
Water Quality Management Plan And EPA Region IV1 s DEIS of that plan.
Most of the comments, except for the site selection, are equally appli-
cable to Central and South Dade regions. The mangrove- estuarine assoc-
iation may also be applicable primarily to the North district.
In February, 1972, the Alert Citizens Committee of North Miami submitted
proposals for alternative plans. Receipt was never acknowledged by
EPA, nor were the plans referred to in any subsequent DEIS. The plans
basically called for the Immediate construction of advanced treatment
plant in northwest Dade adjacent to a proposed electric generating plant,
with syng~istic use of effluent and heat generated by the electric plant
to dehydrates, the sludge. The other plan called for several pumping
stations to propel secondarily-treated effluent northward into Palm
Beach County, for spray irrigation on a living filter type arrangement,
on high elevation, with 5-12 feet of sand beneath appropriate soil.
Browarek and Palm Beach Counties were to have contributed to the flow.
On April 4 and 5, 1973, documented Information was presented to a special
conference of members of the House and Senate Public Works Committees,
in Washington, concerning Dade County's plan. Included in that presen-
tation was evidence that Dade County deliberately ignored a viable,
properly-executed application for a plan to upgrade the City of North
Miami's two pumping stations to secondary treatment for a cost of $3
million. The application by North Miami was supported by assurance
of the consulting engineer for the city that this could be done. The
same engineer, having received a contract from the County to design
the plant at Interama, and to prepare the Environmental Assessment of
the County's plan, completely ignored the possibility of North Miami's
proposal, which would have produced 90% treated effluent, without the
need for a new plant and outfall, wlthln9-12 months. The savings
would have been §97 million dollars, and the plan would have served
satisfactorily as a short-term solution, while a new plant were being
constructed in northwest Dade County.
The Alert Citizens Trl-County Alliance is on record as opposing ocean
outfalls to dispose of 90% treated effluent. And because of the reasons
mentioned, deep well injection is not satisfactory. The most impor-
tant consideration, which EPA is overlooking, is the critical water
shortage facing South Florida. The Corp's backpumping suggestion^ of
the 1966' s is no longer applicable because of the poor quality of the
water. The only other source of water which could be used for
recharge, through ground infiltration, is properly treated wastewater.
••j\
Since no engineer in Florida or EPA has any better suggestions as to
where to get the water to re-use, ACTA humbly suggests EPA and the
State of Florida immediately consult with the Corp's Washington office,
and through the provisions of the Chiles Resolution, determine the
best of many alternatives for the present and future water and waste
water requirements of Southeast Florida.
£ uc —
Hobart T. Feldman, M.D
Chairman, A.C.T.A
HTF/ms
312
-------
Mr. Jack Ravan
May 27, 1973
COPIES TO:
David Levin, Esq. Dept. Pollution Control 2562 Exec .Ctr Circle, E
Tallahassee, Florida 32301
Hon. Richard Stone, Secretary of State, Tallahassee, Fla.
Ron Jack Orr, Mayor, Metropolitan Dade County, Miami, Florida
Ron Wilson, Esq. N.R.D.A. 1600 20th St N.W. Washington, D.C 20009
Hon Russell Train Council on Environmnetla Quality
722 Jackson PI. N.W. Washington, D.C. 20006
Hon. Dante Fascell Committee on Governmental Operations
U.S. House of Representatives; Washington, D.C.
Hon. Guy Van der Jagt - Committee on Governmental Operations
U. S. House of Representatives
Hon Henry Reuss - Committee on Governmental Operations-US. House Repr.
Hon Gilbert Gude - Committee on Governmental Operations " " "
Hon Leo J. Ryan " " " "
Mike Toner, Miami Herald
Morton^Lucoff, Miami News
Miss Cpndy Rose Ft. Lauderdale News
Michael Mclntosh 170 Okeechobee Road, West Palm Beach, Fla.
Board of County Commissioners, Court House, Miami, Florida
Mr. Sal Drago 200 S. E. 6th Street, Fort Lauderdale, Fla. (IITF)
-------
New York University
School of Engineering and Science
Department of Civil Engineering
University Heights
Bronx, N.Y. 10453
Telephone: (212) 584-0700
May 29, 1973
Environmental Protection Agency
Region IV
lU21 Peachtree Street
Atlanta, Georgia 30309
Gentlemen:
Enclosed please find my comments on the draft environmental
impact statement entitled: "North Dade County Regional Collection,
Treatment and Disposal System."
Very truly yours,
Bruce A. Bell
Senior Science Advisor
Natural Resourses Defense Council
314
-------
Comments
on
Environmental Impact Statement - Draft,
"Korth Bade County Regional Collection, Treatment and Disposal System"
Prepared by
Environmental Protection Agency
Region IV
Atlanta, Georgia
Dated: April 27, 1973
by
Bruce A. Bell P.E.
315
-------
Comments
The draft Environmental Impact Statement (l) recommends the use of
secondary treatment, with effluent disposal by either ocean outfall
or deep veil injection. Sludge disposal is to be by landfill preceded
by digestion and heat treatment. While the bulk of the statement is to
be commended, there are a number of items and conclusions in the
statement with which I would disagree.
In any area, where present and future water needs threaten to
limit both economic and population growth, much more serious consideration
must be given to both present and future wastewater reuse. Many of
the commments which I could make in this regard have already been made
in comments (2) submitted on the Environmental Impact Statement
entitled "Ocean Outfalls and Other Methods of Treated Wastewater Disposal
in Southeast Florida" (3)- ID this statement while future reuse
considerations are stressed, the methods proposed make future wastewater
reuse considerably more difficult and expensive than if alternative
methods of wastewater treatment and sludge handling were used.
The use of biological secondary treatment followed by tertiary
treatment is, by far, the most expensive method of achieving an effluent
of sufficiently high quality for reuse (l, ^, 5). Further, if later
reuse is to be contemplated, sludge disposal must be considered in terms
of the future sludge handling problems. Digestion, heat treatment and
land disposal will be affected strongly if chemical sludge is added to
the biological and primary sludges which would result from the project
as presently proposed.
316
-------
2.
There are four general areas on which I would like to comment:
1. The effect of chlorides resulting fron infiltration on
the decision to use a biological treatment system.
2. The effect of the choice of the proposed project on
present and future reuse possibilities.
3- The cost comparisons used in the decision making process.
k. The public health aspect of wastewater reuse.
Effect of Chlorides
Infiltration of salt water into sewer systems is a common problem
in coastal areas.. It is true that high levels of chlorides in the
wastewater will make reuse impractical. However, as noted in the
Environmental Impact Statement (l) steps are being taken to reduce
the infiltration and therefore the chloride content of the wastewater.
In addition, segregation of that portion of the wastewater low in
chlorides is being considered. In any event, it is stressed throughout
the statement that future reuse is to be strongly considered. Thus,
the choice of treatment methods should be based on future as well as
present considerations and the effects of the high chloride concentrations
should be considered temporary.
Present and Future Reuse
The c hoice of secondary treatment rules out the possibility of
reuse at present. This choice, may to some extent, be justified by
the present high levels of chlorides in the wastewaters. The choice of
treatment and sludge disposal methods, however, influence not only present
but future reuse possibilities as well. Biological treatment followed
by chemical-physical treatment will give an effluent of high quality
317
-------
3-
suitable for reuse in a number of ways. However, the cost of such
methods are high (l, k, 5). Sludge treatment and disposal would also
be affected by the addition of chemical-physical treatment.
In a paper presented at the N.Y. Technology Transfer Design
Seminar (6) EPA has concluded that lime would be the coagulant of choice
in most chemical-physical processes. One of the major reasons for the
choice of lime is that lime can be recalcined and recovered by the
incineration of sludge. If future reuse is contemplated then sludge
handling and disposal methods implemented should consider future
handling of chemical sludges.
Physical-chemical treatment at the secondary treatment level with
incineration of sludge would provide the basis for a future upgrading
to reuse quality effluent. Effluent disposal by deep well injection would
provide the backup disposal method needed, if for any reason, standards
for reuse were not temporarily met by the future plant. If upgrading
was needed in the near future, substantial savings might be realized
by not having to construct the entire deep well injection capacity.
A physical-chemical secondary treatment plant could be upgraded to supply
a high quality effluent for reuse more quickly: and with much less
expense than a biological secondary treatment plant (4).
Cost Comparisons
The cost comparisons presented in Table 9 of the Environmental Inpact
Statement (l), do not appear to have considered fully the alternatives.
The cost of such alternative should be compared on the basis of the
optimum combination of treatment and sludge disposal. For exanjile,
physical-chemical treatment will have considerably different operating
318
-------
costs if chemical regeneration by incineration is used than if the sludge
is disposed of by landfill and no recovery of chemicals is realized.
It may be noted that EPA (6) has estimated cost of physical chemical
treatment for a 100 MOD plant to be 9.5 to 1^.5 cents/1000 gals, for
a level of treatment slightly better than secondary. These figures
compare favorably -with normally accepted secondary treatment costs.
Physical-Chemical Secondary Treatment
The advantages of physical-chemical treatment over biological
treatment have been clearly stated by EPA's Kugelman and Cohen (6).
Their conclusions are presented as Table 1.
TABLE 1
Advantages of Physical-Chemical Treatment vs. Conventional
Primary and Secondary (5)
1. Less area requirements - 1/2 to 1/k
2. Lower sensitivity to diurnal variation
3. Not affected by toxic substances
k. Potential for significant heavy metal removal
5. Superior removal of P compounds
6. Greater flexibility in design and operation
T. Superior organic removal
Public Health Aspects
A great deal has been said in both this Environmental Impact Statement
(l) and in the consideration of disposal methods (2) on the dangers of
virus in the effluent from advanced or tertiary wastevater treatment systems
319
-------
Comments have been previously submitted on this subject (2). However,
it should again be emphasized that previous successful experience has
been ignored (7-12) and EPA is willing to claim that "tertiary effluent
will be free of viruses and coliform bacteria ..." (13) for a land
treatment system not even yet constructed.
Summary
The choice of biological treatment and landfill after digestion
and heat treatment does not consider fully either present or future
reuse potential: Reuse of wastewater would provide an additional
water resource, valuable in a water short region. Chemical-physical
secondary level treatment would offer both present and future advantages
over biological treatment.
In general, my comments may be summarized as follows:
1. High chloride concentrations may prevent present reuse of
treated effluents, however, steps are being taken to reduce
chloride levels and segregate low chloride wastewaters, thus
future reuse should be strongly considered.
2* Physical-chemical secondary level treatment would provide
advantages over biological treatment at present.
3. Biological, followed by tertiary treatment is expensive to
construct and operate.
^-. Physical-chemical treatment could be inexpensively and efficiently
upgraded to provide a high quality effluent for reuse.
5- The cost comparisons presented do not appear to reflect the
costs of each alternative when the entire system is optimized
for each method of treatment.
6. The hazard from viruses appears to be overstated.
320
-------
6.
References
1. EPA, "North Bade County Regional Collection, Treatment and Disposal
System/1 Draft Environmental ]inpact Statement (1973).
2. Bell, B.A. , and Cardenas, R.R., Jr., Comments on: "Ocean Outfalls
and Other Methods of Treated Wastewater Disposal in Southeast
Florida," (1973).
3. EPA, "Ocean Outfalls and Other Methods of Treated Wastewater Disposal
in Southeast Florida," Environmental Impact Statement (1973).
k. Zuckerman, M.M., and Molof, A.H., "High Quality Reuse Water by
Chemical-Physical Wastewater Treatment," JWPCF, k2, 3 (1970).
5- Villiers, R.V., Berg, E.L., Brunner, C.A., and Masse, A.N.,
"Treatment of Municipal Wastewater by Lime Clarification and Granular
Carbon," Joint Conference of the Chemical Institute of Canada
with the American Chemical Society (1970).
6. Kugelman, I.J., and Cohen, J.M. "Physical- Chemical Processes,"
Presented at Technology Transfer Design Seminar for Municipal
Wastewater Treatment Facilities, New York, N.Y. (1972).
7- Sander, G.J., and Van Vuuren, L.R.J., "The Reclamation of Potable
Water From Wastewater," JWPCF, ki, 2, 355 (1969).
8. Merrell, J.C., and Katko, A., "Reclaimed Wastewater for Santee
Recreational Lakes," JWPCF, £8, 8, 1310 (1966).
9- Gulp, R.L. , and Roderick, R.E., "The Lake Tahoe Water Reclamation
Plant," JWPCF, 38, 2, iVf (1966).
10. Parkhurst, J.D., and Garrison, W.E., "Whittier Narrows Water Reclamation
Plant--Two Years of Operation," Civil Engineering, 3jf, 9, 60 (1969).
11. Auramy, A., "Wastewater for Groundwater Recharge," JWPCF, 36, 3,
296
12. Peters, J.H., and Cuming, D., "Water Conservation by Barrier Injection,"
Water and Sewage Works, U.k, 2, 63 (1967).
13- Chaiken, E.I. , Poloncsik, S., and Wilson, C.D. , "Muskegon Sprays
Sewage Effluents on Land," Civil Engineering, ^3_, 5, ^9 (1973).
321
-------
STATE OF FLORIDA
0f Atumtntjstratintt
Division of State Planning
Reubin O'D. Askew
725 SOUTH BRONOUGH GOVERNOR
TALLAHASSEE
Earl M. Starnes 32304 L. K. Ireland, jr.
STATE PLANNING DIRECTOR StCRETARY Of ADMINISTRATION
June 15, 1973
Mr. Sheppard N. Moore
Chief, EIS Staff
1421 Peachtree Street, N. E.
Atlanta, Georgia 30309
Dear Mr. Moore:
Functioning as the state planning and development clearinghouse con-
templated in U. S. Office of Management and Budget Circular A-95, we have
reviewed the following draft environmental impact statement:
Environmental Protection Agency: Wastewater Treatment
Facilities - North Bade County. SAI Number 73-1190-E
During our review we referred the environmental impact statement to
the following agencies, which we identified as interested in the statement:
Department of Agriculture and Consumer Services; Board of Trustees of the
Internal Improvement Trust Fund; Department of Community Affairs; Environ-
mental Information Center; Game and Fresh Water Fish Commission; Department
of Health and Rehabilitative Services; Department of Natural Resources; De-
partment of Pollution Control; and Department of State - Division of Archives,
History and Records Management.
Agencies were requested to review the statement and comment on pos-
sible effects that actions contemplated could have on matters of their concern.
Letters of comment on the statement are enclosed from the Game and Fresh
Water Fish Commission; Department of Natural Resources; and Department of
State - Division of Archives, History and Records Management. The Depart-
ment of Agriculture and Consumer Services - Division of Forestry reported
"no adverse comments" by telephone. No further responses were received.
Therefore, it is the position of the state that the project is in accord
with state goals and objectives.
In accordance with the Council on Environmental Quality guidelines
concerning statements on proposed federal actions affecting the environ-
ment, as required by the National 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 the project.
Comments regarding this statement and project attached hereto should be
addressed in the statement.
322
-------
Mr. Sheppard N. Moore
Page Two
June 15, 1973
We request to be forwarded one copy of the final environmental state-
ment prepared on this project.
Sincerely,
?^>^^7
;?
E. E. Maroney, Chief X^
Bureau of Intergovernmental Relations
EEM/Wdp
Enclosures
cc: Mr. Charles Blair
Mr. Randolph Hodges
Mr. Joel Kuperberg
Mr. William Partington
Mr. Emmett S. Roberts
Mr. David Scott
Mr. Charles Shepherd
Mr. H. E. Wallace
Mr. Robert Williams
323
-------
STATE OF FLORIHA
Earl M. Starnes
STATE PLANNING DIRECTOR
TO:
FROM:
SUBJECT:
B?partm*ttt nf AfottuttiBtratinn
Division of State Planning
725 SOUTH BRONOUGH
TALLAHASSEE
32304
'»88-2'»01
Mr. Randolph Hodges, Ex. Dir.
Department of Natural Resources
Tallahassee, Florida
Attn: Mr. James Smith
Bureau of Intergovernmental Relations
SAI: 73-1190-5
Reubin O'D. Askew
GOVE«NO«
L. K. Ireland, Jr,
or
DATE:
MAY 8 1973
DUE DATE: MAY 22 1973
Please review and comment to us on the above draft environmental
impact statement, copy attached. In reviewing the statement, you should
consider possible effects that actions contemplated could have on matters
of concern to your agency.
If you feel that a conference is needed for discussion of the
project or resolution of conflicts, or if you have questions concerning
the statement, please call Mr. Estus Whitfield at (904) 488-2401. Please
check the appropriate box below, attach any comments on your agency's
stationery and return to IGR or telephone "no adverse comments" by the
above due date.
On that date, we intend to consider all review comments received
and develop a state position on the project. In both telephone and written
correspondence please refer to the above SAI number.
Sincerely,
Chief
Bureau of Intergovernmental Relations
Enclosure cc: Mr. William Beckham
TO: Bureau of Intergovernmental Relations
FROM:
SUBJECT: DEIS Review and Comments
1_23 No Comments
L | Comments Attached
Reviewing Agency:
Signature:
Title: ^Administrative Assistant
324
3F STATE PLANNING,
Bi'feou Of
Intern"-! >p.-.-,- , , „ , ,,
' •• t I R- -t.-in?
Date:
-------
UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE
State Office, P. 0. Box 1208, Gainesville, Florida 32601
May 29, 1973
Mr. Sheppard N. Moore
Chief, EIS Staff
1421 Peachtree Street, NE
Atlanta, Georgia 30309
Dear Mr. Moore:
The draft environmental impact statement for "North Dade County
Regional Collection, Treatment and Disposal System" in Dade
County, Florida that was addressed to Mr. Kenneth E. Grant,
Administrator, Soil Conservation Service on April 30, 1973, was
referred to this office for review and comment.
The ocean outfall system as planned for disposal of waste water
is probably the most expedient and least damaging to the environ-
ment.
The Soil Conservation Service would recommend tertiary treatment
meeting Federal and State regulations. The treatment should
provide for the reduction of chlorides so that the waste water
could be reclaimed for irrigation and recharge use. The site
chosen for the treatment plant should permit the use of an
ocean outfall for disposal in case the tertiary system fails to
operate.
A pilot project should be developed utilizing sludge on organic
soils. This would have potential for reducing subsidence of a
valuable agricultural resource.
We appreciate the opportunity to review and comment on this
proposed project.
Sincerely,
u.
-xX_v x ''_,*-
William' E.~Au1itin
State Conservationist
cc: Dr. T. C. Byerly
K. E. Grant
W. B. Forney
Council on Environmental Quality, Wash. DC - 10 copies
325
-------
DEPARTMENT OF HEALTH, EDUCATION, AND WELFARE
REGION IV
50 7TH STREET N.E.
ATLANTA, GEORGIA 30323
May 31, 1973 OFFICE OF THE
REGIONAL DIRECTOR
Re: 283-5-73
Mr- Sheppard N. Moore
Chief, EIS Staff
Environmental Protection Agency
1421 Peachtree Street, N.E.
Atlanta, Georgia 30309
Dear Mr. Sheppard:
Subject: Draft EIS
North Dade County Regional
Collection, Treatment and
Disposal System, Miami, Florida
We have reviewed the Draft Environmental Impact Statement on
the above subject project and find it well prepared. Consequently,
we have no comments to offer.
Very truly yours,
L
^ Frank J. Grqschplle
^—~',u}'\^ Regional Director
Hb
326
-------
DEPARTMENT OF THE NAVY
OFFICE OF THE OCEANOGRAPHER OF THE NAVY >" «EPLY REFER TO
200 STOVALL STREET 659
ALEXANDRIA, VA. 22332 29 May 1973
Mr. Sheppard N. Moore
Chief, Environmental Impact
Statement Staff
Environmental Protection Agency
1421 Peachtree Street, N.E.
Atlanta, Georgia 30309
Dear Mr. Moore:
The draft environmental impact statement on North Dade
County, Florida of 27 April 1973 has been reviewed.
At this time there are no comments. The opportunity to
review the draft is appreciated.
Sincerely,
. i
• f
B. E. STULTZ
Commander, CEC, U. S. Navy
Assistant Chief of Staff
for Environmental Quality
By direction of the
Oceanographer of the Navy
327
-------
UNITED STATES DEPARTMENT OF AGRICULTURE
FOREST SERVICE
Southeastern Area, State and Private Forestry
Atlanta, Georgia 3O3O9
1940 May 25, 1973
Mr. Jack E. Ravan
Regional Administrator
Environmental Protection Agency
Region IV
1421 Peachtree Street, N.E.
Atlanta, Georgia 30309
Dear Mr. Ravan:
The draft environmental impact statement on North Bade County,
Florida, was reviewed by the Resource Use and Management and
the Environmental Protection § Improvement Units of the South-
eastern Area, State § Private Forestry.
The statement is well written and we have no corrections or
additions.
Thank you for the opportunity of reviewing this draft.
/
FREDERICK W. HONING
Area Environmental Coordinator
Enclosure
328
-------
APPENDIX VIII
PUBLIC HEARING
329
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
TRAHSCRIPT OF
PUBLIC BEARING
on the
DRAFT ENVIRONMENTAL IMPACT STATEMENTS
Entitled
"HORTH BADE COtJHTY*
-CENTRAL DADE COUKTY"
"SOOTH BADE
FLORIDA
Dad« county Courthouae
Second Floor
Hiami, Florida
9i00 o'clock, A.M.
Monday, May 14, 1973
Reported by
Howard E. worley
WOR LEY & ASSOCIATES
Court Reporters
62 First National Bank Building oon
DECATUR. GEORGIA nnnnn
-------
SPEAKERS
Richard Brusueles
Environmental Health Planner
Greater Miami Chamber of Commerce
Ms. Florine E. Toller
Federal Grants Coordinator
Homestead, Florida
R. C. Willits
Chief Engineer
Miami-Dade Water and Sewer Authority
Joseph Moffat, Chairman
Committee for Sane Growth
North Miami Beach Property Owners
Association
Colin Morrissey, Director
Bade County Pollution Control
Neil M. Goldman
Federal M. D. T. A.
Waste Water Treatment Operation
Program
Dr. Elton Gissendanner, Chairman
State of Florida Inter-American Center
Authority
John Bergacker
Department of Public Works
James F. Redford, Jr.
President, Izaak Walton League
Member, Florida Pollution Control
Board
Randolph "Ferguson
Political Science Student
Florida International University
331
-------
i I p R Q C E ED INGS
2 OPENING STATEMENT
BY
4 ORIN G. BRIGGS
5
6 MR. BRIGGS: May I call the meeting to order,
7 please.
8 I will ask you to take your seats.
9 I want to thank you all for coning today to
10 the public hearing on the Draft Environmental Impact
n Statements for modification and improvement of the
12 wastewater treatment systems for north, south and
13 central Dade County.
14 I want to introduce the members of the panel
15 to you, which consist of Joe Francmathes on ray left,
lfi who is Director of the Facilities Branch of the Water
lo
17 Program Division for Region IV of EPA.
18 And, on my right, near right, is Alec Little,
19 Director of Surveillance and Analysis Division, Region
20 IV, in charge of our Central Regional Lab.
21 We are also pleased to have with us today
22 Mr. Jack E. Ravan, on my far right, who is the
Regional Administrator of EPA.
2io
24 And, at this time, I would like to ask him*
25 to give us Just a short word of greeting.
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 332
DECATUR, GEORGIA 30030
-------
J. Ravan
JACK E. RAVAN
REGIONAL ADMINISTRATOR
REGION IV, EPA
ATLANTA, GEORGIA
MR. RAVAN: Thank you very much, OrIn.
Ladies and gentlemen, we are privileged
again to be in Dade County and to hear the public
comments and anything else anybody wants to say with
regards to the Draft Environmental Impact Statement.
This is a continuing process as envisioned
under the Water Improvement Act of 1972, whereby the
Environmental Protection Agency not only considers it
a privilege and a policy, but a requirement under the
law to maximize public participation with regard to
our, what might be called public decisions.
We look forward to hearing from you this
morning, and since all of the Statements are avail-
able and may be examined in great detail by our persons
witnesses and others here this morning, I think I
shall not have any further comments at this time.
Or in.
MR. BRIGGSt Thank you, Mr. Ravan.
I am Orin Briggs. I am General Counsel for
WORLEY & ASSOCIATES
Court Reporters
62 Firtt National Bank Building 333
DECATUR, GEORGIA 30030
(404) 378-6239
-------
i O. Briggs
2
the Region in Atlanta.
3
And, at this time, I would like to indicate
4
that the notices of this public hearing were printed
5
in the "Miami Herald', the •Miami News" and the
6
"Greater Miami Journal" on the dates of April 23 and
7
May 13. And, these notices will appear in the Final
8
Impact statement as a part of this record.
9
This public hearing today is being held
10
pursuant to the requirements of the national Environ-
11
mental Policy Act, for the purpose of receiving public
12
comment on the Draft Environmental impact Statements
13
on the proposed sewage treatment programs*
14
The impact statement's primary purpose is
15
to disclose the environmental consequences of the
16
proposed action, thereby alerting the Agency decision-
17
maker, the public and ultimately congress and the
18
President to the unavoidable environmental risks
19
involved in this particular project.
20
The national Environmental Policy Act re-
21
quires that each Federal Agency prepare a statement
22
on environmental impact in advance of every major
23
action which has significant environmental conse-
24
quences.
25
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 334
DECATUR, GEORGIA 30030
(404) 378-6239
-------
O. Briggs
The Draft Statement must assess in detail
the potential environmental impact on a proposed
action and must contain a detailed description of the
proposed action* discussion of the probable impact on
the environment, any adverse environmental effects that
could not be avoidable, alternatives to the proposed
action, and an assessment of the cumulative long-term
effects of the proposed action.
In addition to these requirements, the Final
Statement must also include all comments and objections
received on the Draft, and must indicate how signifi-
cant issues raised during the commenting process have
been resolved.
The Final Impact statement must be made
public at least thirty days before official action is
taken on these projects.
Today, we will call the witnesses in the
order that you have registered, and if there are wit-
nesses here who have not registered yet, we would ask
you to register out at the registration desk*
We will ask you to limit your remarks to
approximately ten minutes on relevant issues which
deal with the subject today.
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building
DECATUR, GEORGIA 30030
(404) 378-6239
-------
o. Briggs
it, we will give you an
while you are speaking the
iffst time, such other time as you need at a
-------
O. Briggs
witnesses, they can do as others and register and
speak for themselves.
We will ask you not to speak more than twice,
and if you are going to make a second speech, as z
indicated after your fifteen minutes, we request that
you wait until everyone has spoken.
When you are called to speak, we would ask
you to submit a copy of your statement, if you have one,
both to me and to the court reporter, and then you
would go to the podium on your right, give us your
name and your address, and the title of any group that
you are associated with.
Just before I call on Mr. Franxmathes to
give us a brief description of the project, 1 would
like to, at this time, recognize two representatives
from your Congressional delegation.
We have Mr. Ted Hanes from senator Dan
Ourney's office. Mr. Banes, he is back here.
We also have Mr. Ellis Bond, who is the
District Representative for Congressman Pepper. Be is
also in the back there, too*
We are glad to have you gentlemen here, and
we appreciate the interest of your bossest and Z know
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 337
DECATUR, GEORGIA 30030
(404) 378-6239
-------
0. Briggs
that they will follow this and keep in touch with us
3
ss these issues are developed.
i
4
At this time, I am going to ask Mr. Joe
Franzmathes to give us a brief description of the
three projects we are having the public hearing on
today.
JOE FRANZMATHES, DIRECTOR
10 i FACILITIES BRANCH, WATER PROGRAM DIVISION
REGION IV, EPA
ATLANTA, GEORGIA
MR. FRANZMATHES: Good morning.
14
Three Environmental Impact Statements for
15 j
Bade County have been prepared in accordance with the
16 I
National Environmental Policy Act of 1969.
17 i
The Act directs the responsible Federal
18
Agency to develop Statements along the guide-lines
ID j
set forth by the Council on Environmental Quality on
20
all major actions which have a significant impact on
21
the quality of the human environment.
j
22
Under the statutory authority of the Federal
23
Water Pollution Control Act Amendments of 1972, the
24
Environmental Protection Agency administers financial
25
WOR LEY & ASSOCIATES
Court Reporters
62 First National Bank Building 338
DECATUR, GEORGIA 30030
(404) 378-6239
-------
J. Franzmathes
2
assistance for the construction of publicly owned
3
wastewater treatment facilities.
4
The Agency will also issue permits to allow
5
the discharge of treated effluent into navigable
6
waters.
7
For purposes of these Acts, the responsible
Agency is the Environmental Protection Agency, Region
IV, 1421 Peachtree Street, Northeast, Atlanta, Georgia,
30309.
The projects which are assisted are noted
in the appropriate Statement.
It should be noted that since Statement
4
publication, an additional 11.25 million dollars for
the ocean outfall extension of Virginia Key and 1.725
c
million dollars for preparation of plans and
specifications for the 55 million gallon a day
secondary expansion at the same facility have been
g
indicated for funding from fiscal '73 funds by the
Florida Department of Pollution Control.
The Agency cannot predict subsequent year
funding, but it expects it to be substantial. To
3 provide treatment and disposal in the county is
4 estimated to cost $152 million.
5
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 338
DECATUR, GEORGIA 30030
(404) 378-6239
-------
J. Franzmathes
Any treatment facility constructed will
3
provide a minimum of secondary treatment aa defined
4
in the Federal Register dated April 30, 1973. This
5
definition supersedes that given in these statements,
6
or the statement entitled "ocean outfalls and other
7
Methods of Treated wastewater Disposal in southeast
8
Florida".
9
Methods of disposal are discussed more fully
10
in that Statement, and it is incorporated by reference
11
into these statements.
12
Despite the outward similarity of all areas
13
of the county, enough differences exist to warrant
14
preparation of three statements which are3 the North
15
District, encompassing the o>rth Miami, Hialeah area;
16
the Central District, encompassing the Miami Springs,
17
Miami, Miami Beach, Coral Gables area? the south
18
District, encompassing Florida City, Homestead,
19
Ooulds-perrine and cutler Ridge area,
20
To facilitate public participation, the
21
Agency is holding one hearing on these three State-
22
ments. The geographic boundaries for each Statement
23
are shown in the Statement.
24 *
For the North District, construction of an
25
WOR LEY & ASSOCIATES
Court Reporters
62 First Nationel Bank Building 339
DECATUR, GEORGIA 30030
(404) 378-6239
-------
J, Franzmathes
80-ragd secondary treatment facility and two 40-mgd
modules at the Interama site is proposed. Ocean or
deep well disposal were considered environmentally
equal to this location.
Other factors will be taken into account.
Some of these are the availability of sites for deep
well disposal within an economical radius of the plant
site and the action to be taken by the State in
allocating funds.
Deep wells minimize initial capital cost;
however, capitalized costs, that is all costs brought
back to present worth, both capital and operating, are
equivalent, A significant benefit of the project will
be the treatment of 25 million gallons per day now
discharged without treatment into the ocean.
The major concern is the location and
commitment of land for the plant site.
For the Central District, construction of
115 million gallon per day secondary treatment
facility with an ocean outfall is proposed. The ocean
outfall would be 18,000 feet in length, terminating in
90 feet of water. It will conform to the criteria
established in the Ocean Outfall Impact Statement.
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 340
DECATUR, GEORGIA 30030
(404) 378-6239
-------
i J» Franzmathes
2
A significsnt benefit will be the provision
3
of adequate treatment at a facility that now provides
4
approximately 60 percent treatment, and discharges
5
4,400 feet from shore in 18 feet of water. It will
6
also eliminate 22 million gallons per day of sewage
7
that is discharged into the ocean without treatment.
8
For the south District, construction of a
9
50 million gallon per day secondary facility is pro-
10
posed with deep well disposal. The agency is pro-
11
posing the facility to be constructed in modules of
12
30 and 20-ragd.
13
A significant benefit will be the removal
14
of 10 million gallons per day of untreated or
15
partially treated wastewater from the canals and the
16
bay. The major concerns are prevention of contami-
17
nation of the Biscayne Aquifer by deep well construc-
ts
tion and the development that may occur as the result
19
of providing a basic utility. All projects will cause
20
pollution related to construction, removal of un-
21
developed land for use as a natural habitat, and
22
removal of vegetation.
23
The projects may have an effect on settlement
24
patterns, population growth rates, and density
25
WORLEY& ASSOCIATES
Court Reporters
62 First National Bank Building OA-J
DECATUR, GEORGIA 30030
(404) 378-6239
-------
13
J. Pranzmathes
distribution.
3
The beneficial impact will be upgrading the
4
surface and estuarine waters, protection of ground
5
water supply, reduction of the public health risk, and
6
improvement of the recreational potential of all waters
in the region. The projects can provide one base for
orderly growth.
The record will remain open for fifteen days
o
following today. Comments should be sent to Mr. Moore
i
at the address previously given.
Thank you.
MR. BRIGGS: Thank you, Mr. Franzmathes.
And, at this time, we will call the first
witness.
6
MR. RAVAEfj Mr. Chairman, if I may, ladies
and gentlemen, I just wanted to point out that peter
Baljet, your State Executive Director for the Pollution
Control Department, had planned to be here this
morning. I have just received a message from Petar
and he says he will not be able to participate due to
some conflicting, but yet very important business
with the Governor in Tallahassee. So, I wanted you to
know this before wo proceed.
WORLEY & ASSOCIATES
Court Reporters
62 First National Bonk Building
DECATUR, GEORGIA 30030
(404) 378-6239
-------
i or,, Ravan
2
Thank you.
3
MR. BRIGGS: Thank you, Mr. Ravan.
4
At this time, we will call the first witness,
5
Mr. Richard Bruaueles, Environmental Health Planner
6
for tha Greater Miami chamber of Commerce.
7
8 RICHARD BRUSUELES
9 ENVIRONMENTAL HEALTH FLANKER
10 GREATER MIAMI CHAMBER OF COMMERCE
11 MIAMI, FLORIDA
12
HR. BRUSUSLESi Good morning*
13
I am here this morning representing the
14
Greater Miami Chamber of Commerce and its Environmental
15
Quality Action Committee and Water and Sewers Action
16
Committee.
17
Both of these Committees have significant
18
interests in the waterways in Dade County*
19
We are well aware of the expenditures of time
20
and dollars that brought us to this point, and are
21
also aware of the pockets of opposition to the i»~
22
plementation of this plan. However, we would like to
23
point out that the plan has been accepted by the
24
County Commissioners who are our elected spokesmen.
25
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building o r o
DECATUR, GEORGIA 30030
-------
15
B. Brusueles
2
strongly urge that today's hearing not serve as a
3
delaying mechanism for cleaning Dide County's waters.
4
The ocean outfall study prepared by EPA (and
5
released six months late) shows that the ocean disposal
6
of secondary treated sewage in the waters of the Gulf
7
Stream at depths of approximately 90 feet should have
no adverse impact on the ocean's ecosystems. More-
over, it is our understanding that the two systems
designed for the North Dade facility will be more
costly and time consuming.
2
We are further concerned that this concept
3
is based more on financial rather than environmental
considerations. If this is the case, then possibly
the intent of the Environmental Impact Statement has
been circumvented.
If ocean outfalls have been cleared by EPA,
what is the alternative for North Dade? Is it to
19
allow phasing as money becomes available via deep well
10
disposal or to be consistent with environmental
considerations by going to an ocean outfall?
The concept of deep well disposal has not
-3
been studied in detail. This has been a long-time
24
concern of the Environmental Quality Action Committee
25
WOR LE Y & ASSOCIATES
Court Reporters
62 First National Bank Building 344
DECATUR, GEORGIA 30030
(404) 378-6239
-------
R. Brusueles
2
as expressed in letter form to the Environmental
3
Protection Agency. We believe that the United States
4
Geological Surveys should conduct studies on existing
deep well disposal. These studies should provide bette
data OK hydraulic pressures and determine if the
aquicludes between the various aquifers below Dade Coun
are continuous and provide an adequate margin of safety
From an environmental point of view, the deep
well disposal in North Miami presents many questions.
We again present the possibility that the proposed
decision for a combined system might be political or
financial rather than environmental in nature.
North Dade currently has a sewage treatment
demand for 40 million gallons per day and will have a
demand of 60 million gallons per day by 1977. There-
fore, the concept of staging in 40 million gallon per
18 \
day increments would not enable us to halt all dis-
19
charge into our surface waters.
20
In view of the recent court action to release
21
funds, should we not proceed with the full package of
80 million gallons per day? The 80 million gallon per
23
day with ocean outfall is the least costly and most
viable alternative. Staging of facilities necessitates
25
WORLEY& ASSOCIATES
Court Reporters
62 First National Bank Building
DECAtUR, GEORGIA 30030
(404) 378-6239
-------
R. Brusueles
additional tax dollars* whereas, early construction
avoids inflation costs.
Delays in sewage treatment capacity works
contrary to good land use planning and protection of
inland water quality. Delays in regional plant con-
struction tend to proliferate package treatment
facilities or septic tanks. A point to make here is
that these additional sources of pollution create
enforcement problems, package treatment plant in-
spection for interim plants alone could cost Dade
County an additional $200,000 per year.
we hope that in the future Dade County will
be able to reclaim the billions of gallons now going
or scheduled for ocean outfall. However, the potential
disruption of Everglades eco-systems or contamination
of the Biscayne Aquifer requires that we extensively
study the problems, problems of nutrient loading and
survival of viral and bacterial pathogens.
The issue at hand is not ocean outfalls,
which offer a valid alternative being compared to deep
well disposal, but that of economics and opposition to
location. No site is ideal. However, the Korth Dade
site provides land area for sufficient buffering.
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building T / /-
DECATUR, GEORGIA 30030 4
(404) 378-6239
-------
4.0
i R. Brusueles
2
in summary, Z would like to say that the
3
time has come to clean up Da da County* a waters, so
4
let's get with it and implement the approved plan.
5
The North Dade facility should be built as
6
one SO million gallon per day facility rather than two
7
40 million gallon per day plants as proposed in the
8
Environmental impact Statement.
9
Three. That the disposal wells for the
10
South Dade facility be put within the salt intruded
11
area east of the salt line*
12
Fourth* That the Environmental impact
13
Statement not be used as an economic timer or a method
14
to satisfy various protesting elements in the corn-
is
aunity. The intent of an Environmental impact State-
16
ment must provide information for rational environ-
17
mental decisions.
18
Five. That we stop talking and begin con-
19
struction towards a cleaner environment for Dade
20
County*
21
MR. BRIGGSi Thank you, sir.
22
At this time, we will call the second witness
23
Ms, Florine E. Toller, Federal Grants Coordinator,
24
City of Homestead.
25
WORLEY& ASSOCIATES
Court Reporters
62 First National Bank Building 347
DECATUR, GEORGIA 30030
(404) 378-6239
-------
P. Toller
MS. FLORINE E. TOLLER
FEDERAL GRANTS COORDINATOR
HOMESTEAD, FLORIDA
MS. TOLLER: I don't have a prepared state-
ment, but I do have a statement that we mailed in
relative to the Environmental impact statement, if you
would care for a copy now.
MR. BRIGOSs Yes, I would. And, the whole
statement will appear in the record as though read.
(Whereupon, the reporter copied into the
record the report above-referred to, the same being
a letter dated May 2, 1973, on the letterhead of the
City of Homestead, Florida, and addressed to Mr.
Sheppard N. Moore, Chief, EIS staff, 1421 peachtree
Street, N.E., Atlanta, Georgia 30309, and signed by
O. R. Pearson, City Manager.)
"In keeping with a communication from
Environmental Protection Agency dated April 13, 1973,
directed to the Honorable William F. Dickinson, Mayor,
Homestead, Florida, the following comments are sub-
mitted for your review, relative to draft, Environmental.
impact Statement, C120377, south Dade county, Florida.
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 343
OECATUR, GEORGIA 3O030
(404) 378-6239
-------
i F. Toller
2
"Generally speaking* as far as the statement
3
is concerned, I find that while the topic of sewage
4
disposal is covered the companion problem is given
5
little or no attention. To me these problems are
6
inseparable and should be considered as such*
7
"In this respect, therefore, it is my
8
opinion that, certain aspects of the program prepared
9
in the Environmental impact statement do not conform
10
with the intent of the Federal Law covering these
11
subjects. Specifically, the city of Homestead objects
12
to areas contained within the report and I shall
13
attempt in what follows to comment on these areas as
14
they appear in the report. This comment will be sub-
is
mitted by page numbert
16
"Page 201
17
'operating results may show it is
18
feasible to recover effluent in the future
19
for one or more uses during drought periods.
20
This possibility will be investigated at
21
the South Dade injection site.'
22
"Concerning this statement, the City of
23
Homestead has been in a position for the past two and
24
one-half years to conduct studies at a much lesser
25
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building
DECATUR, GEORGIA 30030
(404) 378-6239
-------
F. Toller
cost than is noted in the report* that would deter-
mine conclusively the feasibility of recovery from
deep well injection. We have offered this possibil-
ity to county* state and federal agencies and while
a considerable interest has been shown we have been
turned down* primarily by Dade County, and the stated
reason for this rejection has been fear of the county
concerning the annexation policy of this city.
"If you are at all familiar with the
Homestead proposal* it involved deep well injection
and recovery for electric generating cooling water in
a closed circuit operation. We therefore feel the
statement on page 20 has overlooked a less expensive
and more complete method of investigation than is
possible, as outlined in the report.
"Page 22i investigation of Septic Tanks in
Dade County
"in this area, this study was to have been
completed in July, lir 2, To date no information has
been made available by Dade county concerning this
subject. As a matter of fact, Dade County has con-
tinued to issue permits in all areas of the county
wherein septic tanks have been approved. The only
WOR LEY & ASSOCIATES
Court Reporters
62 First National Bank Building
DECATUR, GEORGIA 30030
(404) 378-6239
-------
i F. Toller
2
step taken by Dade county relative to use of septic
3
tanks has been the enlargement of individual property
4
size when septic tanks are contemplated.
5
"page 251 Comment is here made relative to
6
the Homestead proposal to Federal Conferees at a
7
meeting of July 2 and 3, 1971. The second recora-
8
mendation of this third session directed the Dado Count)
9
Commission to give 'special attention to studies
10
conducted and reported to the conferees by the City of
11
Homestead.'
12
"The report continues, noting that in
13
September, 1971,
14
'It became apparent that the Dade County
15
Commissioners would not approve the concept
16
of the City of Homestead constituting a
17
fourth region in the county and that the
18
interim plan would require the wastes of
19
Homestead and the surrounding area to be
20
treated at the Goulds-perrine area plant
21
with disposal by deep well injection.'
22
"At this point let me say that in September
23
of 1971, the Dade County Commission had little if any 4
24
knowledge of the Homestead plan, nor to my
25
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building
DECATUR, GEORGIA 30030
-------
23
P. Toller
recollection had it been presented to the Dade county
Commission, what became clear was that administrative
officials of Dade County did not intend to approve and
gave only cursory review of the Homestead plan and
again the primary reason for this being the fear of
those Dade County officials relative to the expansion
possibilities of the City of Homestead.
"The concept of three as opposed to four
regions in Dade County has never, in my opinion, been
adequately explored and those engineers employed by
the City in this study, have continuously maintained,
contrary to county conditions, that capital costs
and operating costs would be less in the fourth
district than those costs proposed by Dade County.
"page 32i The Environmental impact State-
ment states:
'The use of treated effluent to main-
tain a freshwater block behind control works
near the mouth of drainage canals may be-
come a viable effluent discharge alternative
if and when dry weather supplies of fresh-
water become scarce for other purposes such
as urban and agricultural water supplies.*
WORLEY & ASSOCIATES
Court Reporters
62 Pint National Bank Building 35'
DECATUR, GEORGIA 30030
(404) 378-6239
-------
i F4 Toller
2
"I point out here that this statement appears
3
to be in conflict with the justification carried
4
throughout the report for removal of the same dis-
5
charges from the canal system on the county. If as a
6
matter of fact the treated effluent is now considered
7
to be a pollutant endangering the water supply, the
8
use of this same effluent during periods of drought
9
would be considered an even more dangerous pollutant
10
because of the draw down on the canal water itself
11
during drought periods. This draw down could under
12
these conditions find its way into the fresh water
13
supply.
14
"I point out, in addition, there is no plan
15
submitted within the report for recovery of the
16
treated effluent from deep well injection for the uae
17
contemplated above. This statement is inconsistent
18
with the statement contained on page 34 of the report
19
wherein
20
'The Enforcement Conference recom-
21
mendations preclude the use of inland
22
canals as receiving streams for the dis-
23
charge of treated waste water after January
1, 1973;•
25
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 353
DECATUR, GEORGIA 30030
(404) 378-6239
-------
25
F. Toller
"Page 41; Contained on this page is the
statement that
• metropolitan Dade county is at the
sane time polluter and pollution controller*
prosecutor and defendant, consultant and
iaplementer.'
"This statement is absolutely correct and
bears out the contention of this city that for reasons
other than that of pollution control, Dade County has
consistently blocked all attempts by the City of
Homestead, as well as others, in an attempt to not
only implement sound pollution abatement methods at a
lower cost but has likewise ignored completely the
principle of water conservation. In respect to water
conservation, county, state and federal agencies have
completely ignored the use of fresh water for engine
cooling purposes by the City of Homestead. The impact
of this use upon the acquifer is such that daily there
is being lost a water supply that would handle the
needs of 150,000 to 200,000 people. It was the pro-
gram of the city of Homestead to stop this loss and
to present studies through monitored evaluation of
the validity of recycled waste water for engine
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 354
DECATUR, GEORGIA 30030
(404) 378-6239
-------
i F. Toller
2
cooling purposes. This program would have had appli-
3
cation in similar circumstances throughout the United
4
States. The quoted statement above X think exem-
5
plifies the actions of Dad© county concerning this
6
vital subject.
7
"Page 421 Reference is made on this page to
8
the existing sewage system to the city of Homestead in
9
that it does not measure up to 90% efficiency* This
10
reference is incorrect.
11
"This city has received an operating permit
12
from the state of Florida for a period of seven (7)
13
years* based upon independent tests showing our treat-
14
ment plant does meet the 9Q% requirement.
15
"page 45i Reference is made here, relative
16
to immediate and long range coots, flexibility for
17
future allterations, adaptability for reuse and overall
18
compatability of the county construction program.
19
These factors have been considered by the county in
20
their 'interim water Quality Management Flan for
21
Metropolitan Dade county'* June, 1972.
22
"Here again, the City of Homestead contests
23
the computations of the Dade County engineers, based
24
on the information provided by the consulting
25
WO RLEY& ASSOCIATES
Court Reporters
62 First National Bank Building 355
DECATUR, GEORGIA 30030
(404) 378-6239
-------
^___ 27
1 F. Toller
2
engineers for the city of Homestead, and I maintain
3
that the county concept was conceived within the
4
administrative section of the county government and
0
„ that engineers were employed to substantiate the
original concept.
"I point out here that in light of the
8
Environmental impact Statement and the county plan,
y
that it is the intent of the county to force the Ci.t •••' c
Homestead into utilizing the county system at a coat
in excess of what costs would be incurred were the
2
City of Homestead permitted to handle the area sewage
3
treatment problems.
4
"In support of this condition, I submit that
5
it is the intent of Dade County, expressed by the
6
Water and Sewer Authority Director, to charge the city
7
of Homestead at a rate of 20
-------
i F. Toller
2
city.
3
"In support of my contention relative to the
4
fear of Dade County over the annexation of properties
5
to the city of Homestead, I submit a copy of a letter
6
received by this office from Dade county planning
7
Director, Reginald waiters. I think this letter
8
exemplifies the attitude of Dade County concerning
9
growth, not only of this community but of other com-
ic
munitiea in Dade County. It is the position of this
11
writer that this attitude has carried over into the
12
engineering thinking of the officials of Dade County
13
and has resulted in a program that is not in the best
14
interests of the citizens of this county.
15
"page 47i The statement that 'The area
16
south and west of the city of Homestead is generally
17
undeveloped except for farming.', is at the moment
18
reasonably accurate, however, land economies, the
19
advent of the South Dade expressway, the availability
20
of land for development, the high cost of farming,
21
etc., will make this statement unsound within the next
22
three to five years. I point out that there is now
23
under single ownership in the very area referred to,
*
24
some 12,000 acres of land that is anticipated to be
25
WORLEY& ASSOCIATES
Court Reporter!
62 First National Bank Building
DECATUR, GEORGIA 30030
-------
29
1 F. Toller
2
developed by the owner aa soon as possible. This
3
fact, along with development presently under way and
4
that planned by others in this area* completely dis-
5
counts the population tables shown on Page 57 wherein
6
the 1980 population is shown at 16,800 and the popu-
7
lation of Florida City for the same date is shown as
8
5,900. Both figures are completely unrealistic since
9
the latest population figures are officially shown on
10
county and state data sheets for revenue sharing as
11
being in excess of 17,000 in July of 1972, and the
12
population of Florida City is shown at 5,500 as of the
13
same date.
14
"The rate of growth already taking place and
15
that contemplated within the next five years makes the
16
population projections of Dade county, as shown in
17
your Environmental impact Statement utterly un-
18
realistic.
19 '
"page 59t 'Primary impacts'
20
"Much is made of the assumption that the
21
county plan when instituted will in effect eliminate
22
septic tanks and allow for collection and treatment
23
of a 40 MOD plant from areas in South Dade County
24
presently unsewered* I point out that from a realistic
25
WORLEY& ASSOCIATES
Court Reporters
62 First National Bank Building J58
DECATUR, GEORGIA 30030
(404) 378-6239
-------
F. Toller
2
3
25
standpoint the installation of the main transmission
system to the Homestead area as contemplated la the
Dade County plan, in no way insures relief from
0
septic tank usage nor in any way does it insure that
6
new developments taking place will connect to the
main transmission system, or even be required to connec
8
to the main transmission system.
9
"The location of the main transmission
10
system in such that the cost for any single developer
or property owner in any way remote from the trans-
12
mission system will be so great that it will be
13
economically unsound to connect to the system*
14
"I likewise point out that it is the opinion
15
of our consulting engineers and other engineer a that
16
the pumping of sewage from Homestead North to the
17
perrine-Qoulds area may result in insufficient
18
quantities pumped and will undoubtedly lie septic in
19
the lines,
20
"I likewise point out the Dade county pro*
21
gram is so far behind schedule that no relief for the
22
South Dade area can reasonably be expected prior to
23
1978. in the meantime, the needs of this area* both
24
existing and projected* go unmet, while not
WOR LEY & ASSOCIATES
Court Reporters
62 First National Bank Building
DECATUR, GEORGIA 30030
-------
F. Toller
thoroughly familiar with the engineering of the
proposed Dade county program, I question whether or
not connecting into the proposed Dade County system
will require that the connection be made at the
various pump stations proposed along the route of the
transmission line, zf this be the case, then the cost
to any one requiring to connect into that system could
be such that economics would preclude such a con-
nection because of distances involved.
"gage 681 This page refers to the long term
beneficial impact of deep well disposal and states,
'-— or it will possibly be pumped to
the surface and reused.'
"This is such a generalized statement that I
question it even being contained in a report of this
nature, while the information that will have to be
developed could have already been developed through the
use of the City of Homestead program, this possibility
has been ignored and as a result the cost of that
investigation, when and if it takes place, will be
considerably more than had we been permitted to embark
upon that investigation when we requested to do so.
"page 71i The statement is made that canals
WORLEY& ASSOCIATES
Court Reporter!
62 First National Bank Building
DECATUR, GEORGIA 30030
(404) 378-6239
-------
i F. Toller
2
in south Dado show signs of pollution.
3
•Shis pollution of surface water is
4
attributed to poorly functioning septic
5
tanks and discharge of poor quality
6
effluent from snail, overloaded treatment
7
plants, implementation of the proposed
8
project will eliminate these sources o£
9
pollution.'
10
"As previously stated, the institution of
11
the Dade county plan will do little, if anything*
12
toward the elimination of septic tanks in the South
13
Dade area, it will in all probability enable those
14
undeveloped lands in the area adjacent to the trans*
15
mission system and/or pumping facilities to become
16
developed. Thus the anticipated pollution abatement
17
will not necessarily be accomplished,
18
"Again« on page 73. reference is made con-
19
corning pollution from septic tank effluents and
20
polluted canals• Apparently someone has made the
21
determination that septic tank effluents 'presently
22
flow directly into the acquifer.1 if this be true
23
then every step should be taken as quickly as possible
24
to eliminate this danger, with the policy of Dade
25
WOR LEY & ASSOCIATES
Court R«port«ri
62 Fir«t National Bank Building
DECATUR, GEORGIA 30030
-------
F, Toller
County approving additional septic tanks and with its
sewage abatement plan encouraging the use of septic
tanks through economies, the elimination of this
dangerous situation will be prolonged rather than
curtailed.
"Likewise, while it is contended at this
point elimination of canal pollution vill minimise
the danger of contaminating well water other areas of
the report encourage the reuse of sewage effluent to
contain salt intrusion. As previously stated, the
two positions are simply not consistent.
"This position is reiterated on page 74,
and throughout the report there is used the words*
'could'* 'may1, 'possibly', indicating to this writer
that to use these statements as justification in the
Environmental impact statement simply indicates lack
of thorough investigation before approval is given
for the Dade County program.
"I find likewise on page 80. under the title
'impacts on the Economy'* inconsistency that is ex-
tremely difficult to comprehend. The report indicates
a sewage system would stimulate the economy in the
area through the resulting construction boom* yet there
WORLEY& ASSOCIATES
Court Reporters
62 First National Bank Building 362
DECATUR, GEORGIA 30030
(404) 378-6239
-------
i F. Toller
2
has been talk At the county level of restricting
3
population and of placing building moratoriums in
4
various areas of the county* X likewise point out the
5
position in the report that employment in the eon-*
6
atruction industry during the construction of the
7
Dade County facilities will increase. I question the
8
validity of this statement since major construction
9
of this nature is not necessarily handled by companies
10
within Dade County* I point out that even in the
11
study conducted by Dade county, that engineers were
!2
employed from outside the State of Florida*
13
"I likewise raise the question concerning
14
the economic long tern benefit of the Dade County pro-
is
gram in stating* * slight increase in employment for
16
operation of the plants.'
17
"what is to be done with the overflow of
18
plant operators, maintenance men, laborers, etc.,
19
now employed, whose jobs would be eliminated by this
20
program* is it the county intent to employ these
21
individuals? X think not.
22
"Page 811 Aesthetic Values* X would like
23
to know the definition of the term 'low profile
24
structures'. An Individual 500,000 gallon package
25
WORLEY& ASSOCIATES
Court Reporters
62 Pint National Bank Building 36$
DECATUR, GEORGIA 30030
-------
F. Toller
sewage treatment plant at surface level projects into
the air in excess of two stories. Is this considered
low profile, particularly in a residential area?
•Page 91i Environment Protection Agency has
concluded*
"——•—that disposal of secondary dis-
infected effluent by injection through deep
wells —~-i« a viable method for use in
Bade County.'
"This statement is in agreement with the
research long since done by the city of Homestead,
however, nothing in the report seems to indicate any
serious study to be made concerning retrieving of the
effluent for other uses,
"Page 92 through 95i
•This writer seriously contests the
economics presented as it relates to costs of con-
struction, maintenance and operation, as presented on
these pages. I likewise underline an engineering cost
of $3 Million for a ten (1) NOD disposal well. This
cost Z think in terms of the Homestead project cost
of construction, are extremely excessive and to this
writer represents the inability of the county to handle
WORLEY& ASSOCIATES
Court Rvportart
62 Fir»t National Bank Building 364
DECATUR. GEORGIA 30030
(404) 378-6239
-------
i F. Toller
2
the situation economically. For instance, the City
3
of Homestead had programmed, through its engineers*
4
a 6 MGD plant with deep well disposal and closed
5
circuit reuse, at a total cost under $6 million. I
6
do not believe that the addition of four million
7
gallons to such a plant would require an additional
8
$9 million as contemplated under the county program.
9
"Page 109 > The statement is contained here
10
'Clearly, the construction of a 50 ragd
11
plant, when at the time construction would
12
be completed (1975-1976) there would be a
13
low initial flow (17 mgd), indicates an
14
optimism which can only be baaed on the
15
assumption that large land developments
16
will insure rapid population growth and
17
urbanization in time to make the project
18
financially feasible.1
19
"If the City of Homestead were forced into
20
disposing of ten mgd cooling water into such a plant
21
by 1975-76, i would estimate that this loading would
22
require somewhere in the area of 5096 of the 50 mgd
23
plant without the addition of sewage effluent from a
24
rapidly expanding area. In other words, the capa-
25
WORLEY & ASSOCIATES
Court Reporters
62 Pint National Bank Building o/- r
DECATUR, GEORGIA 30030
-------
F. Toller
bility, under these circumstances, may well be used
up by the time it opens.
"Thus, the economics projected by the report
and used to justify the elimination of the Homestead
program and a fourth district simply do not meet with
reality.
"in conclusion I would like to state that
the City of Homestead has been attempting, through its
engineers and administrative staff, over the past
three years, to convince county, state and federal
officials that the question of waste water disposal
while being considered can not be considered
separately from the question of water conservation.
We have not, up to this moment, been able to interest
any of the aforementioned agencies in the obvious
interconnection of these two vital resources. Ho one
has given consideration to the program of the city of
Homestead in its attempt to conserve a tremendous
amount of fresh water now being required to be used
from the Biscayne Acquifer. It is the contention of
this writer that political considerations have
influenced as much as anything the proposal of Dade
County, as embodied in the Environmental Impact
WOR LEY & ASSOCIATES
Court Reporters
62 First National Bank Building 366
DECATUR, GEORGIA 30030
(4O4) 378-6239
-------
i P. Toller
2
Statement."
3
(Attached to the above-referred to letter,
4
the following was attached thereto, being a letter on
5
the letterhead of Metropolitan Dado County, Florida,
6
Planning Department, addressed to Mr, O. R. Pearson,
7
City Manager, city of Homestead, post office Drawer
8
429, Homestead, Florida 33030, dated April 5, 1973,
9
and signed by Reginald R. Walters, AXP, Director.)
10
'Pursuant to your recent request, the
11
provisions of the Demonstration Cities and
12
Metropolitan Development Act of 1966 and the inter-
13
governmental Cooperation Act of 1968, this agency, as
14
the designated Metropolitan Clearinghouse, has—with
15
the assistance of other concerned governmental
16
agencies—reviewed the Condensed interim water Quality
17
Management Plan on wastewater Collection System
18
Improvements for the City of Homestead, Florida*
19
"Our review indicates the proposed improve-
20
ments are in conformance with the physical and
21
technical provisions of the Metropolitan Dade County
22
Interim water Quality Management Plan, it is, however,
23
the possibility of the city requiring annexation of
»
24
the unincorporated areas to be served, not mentioned
25
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building
DECATUR, GEORGIA 30030
tAf\A\ Q-70 fiooo
-------
39
1 F« Toller
2
in the plan, which concerns us. We believe the city's
3
policy or intentions should be clearly stated in the
4
application for federal funds.
5
"If Homestead intends to condition the pro-
6
vision of the proposed wastewater collection service
7
to the designated areas outside its boundaries on the
8
annexation of said areas, we oppose approval of the
9
application on the grounds that, according to accepted
10
planning principles, municipal annexations should be
11
based on a number of important factors, as described
12
in the Metropolitan Dade county Code, rather than th«
13
provision of a single service. The Metropolitan Dad*
14
County Interim water Quality Management Plan is based
15
on a pattern of regional systems and forced annex-
is
ations by municipalities is not in keeping with that
17
objective.
18
"On the other hand, if the city intends to
19
serve the designated areas outside its boundaries
20
without requiring annexation, we favor approval of th«
21
grant."
22
23 - - -
24 MS. TOLLERi My MUM is Flori«n« B. Toller.
25 I *• with the City of Homestead.
WORLEY & ASSOCIATES
Court Reporters
62 Fir«t National Bank Building
DECATUR, GEORGIA 30030
(404) 378-6239
-------
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
I have attended most of these meetings, X
think, for the last two and a half years, and know
most of ycm.
Again, after reading the Statement, we have
f
tried to answer page by page and show why we have been
after deep wells down in our area,, and tried to get
our power plant and our sewage treatment plant as one.
We have in the statement that we are in a
drought session right now for a period. We are using
some 28 million gallons of water a day to cool our
power plant, if you add this — multiply this by 365,
you have a few million gallons of water that goes into
the canal and into the ocean. It can't be recovered.
Wo have made a proposal which would put our
sewage into the canal -- into the deep well, bring it
back and use it to cool our engines, thus using very
little fresh x?ater.
The only people who don't seem to agree BO
far has been the county, mainly because they want three
plants instead of four.
I have to leave it up to you as to why this
idea would not be one of the better ways. You don't
«
worry about putting water down in your deep well and
WOR LEY & ASSOCIATES
Court Reporters
62 First National Bank Building 350
DECATUR, GEORGIA 30030
(4O4I 37H-K91Q
-------
41
F. Toller
leaving it there; we intend to bring it back and re-
cycle it. Our engine manufacturers have said it can
be done.
I have received a letter last week from Mr.
Rainwater in Corvallls, who stated he was very dis-
appointed that we had not been able to get some backing
8
and some helpf so that they could study this project
9
without any danger to the Everglades or to the environ-
ment, but only through eighteen generators in our
power plant.
12
If there are any questions I can answer, I
will be glad to. This is our main concern.
At one time Mr. Statler said he would be
glad to take our 28 million gallons of water if we
wanted to pump it up to the Cutler Ridge plant at
twenty cents per thousand gallons. I think that runs
around $800,000 a year, which we could give them the
19
city for that, which is pretty far out, I believe.
20
It still doesn't cut down the use of fresh
21
water and each year this problem gets worse.
MR. BRIGGS: Thank you, Ms. Toller.
MS. RAVEN: Mr. Chairman, Ms. Toller, may I
13
14
15
16
17
18
24
sk you, would you care to make Dr. Rainwater's letter
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 37()
DECATUR, GEORGIA 30030
(404) 378-6239
-------
i R. Willit»
2
a part of the record?
3
MS. TOLLER: I will be glad to mail it to
4
you. I don't have it with me. I didn't think about
5
bringing it until after I got here,
MR. RAVAN* That is fine, if you would
7
please, and would care to, I would appreciate it.
8
MS. TOLLER: I will be glad to.
9
MB,. BRIGGSj We will make that letter a part
10
of the record when we receive it.
11
12
13
MR. BRIGGSj At this time, we will call the
14
next witness, Mr. R. C. Willits, Chief Engineer,
15
Miami-Dade Water and Sewer Authority.
16
17 R. C. WILLITS
18 CHIEF ENGINEER
19 MIAMI-DADB WATER AND SEWER AUTHORITY
20 MIAMI, FLORIDA
21
MR. WILLITSs I am here this morning speaking
22
for Mr. Sloan, who could not attend. He is out in
23
Las Vegas attending a AWWA Conference in which he ia
24
an officer, but I would like to present our statement
25
WOR LEY & ASSOCIATES
Court Reporters
62 First National Bank Building 37]_
DECATUR, GEORGIA 30030
(404) 378-6239
-------
43
R. Killits
on his behalf.
3
Our comments on the drafts of the North,
4
Central and South Dade District Environmental impact
Statements arc presented below in summary form. They
are the product of the independent study of each
Environmental Impact Statement by both our staff and
the consulting engineering fr'.rtn assigned to the
specific project and to the overall T-Tater Quality
Management Plan.
General Consents.
The three Environmental Impact C tatencnts
generally follow the projects recompensed in the
4
latest draft of the Water Quality Management Plan of
5
Metropolitan Dade County, Florida, which wo support.
Two of the Environmental Impact Statements speak of
important alternatives which should be considered
because of limitations on the availability of funds
during the initial stages of the large scale projects,
In addition, each Environmental impact
Statement considers alternatives to the Water Quality
Management Plan which have been raised previously by
local citizens at public hearings conducted during
the summer of 1972 when the Environment Assessment
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building
DECATUR, GEORGIA 30030
(4041 378-6239
-------
! R. Willits
2
Statement was in preparation. Thus, a serious effort
3
has been made to continue to re-examine citizen
4
objections and questions right up until the issuance
5
of the final draft of each Environmental Impact State-
is
went.
7
The North Dade District Environmental impact
8
Statement0
9
A, initial Capacity of wastewater Treatment
10
Plant,
11
The initial capacity of the wastewater treat-
1 L1
raent plant is reduced from 80 to 40 million gallons
13
per day as a first stage with the remaining stage to
14
be constructed nt a future date to provide a total of
15
GO million gallons per day in the future.
16
However, recognition is given to the possi-r
IT
bility of increasing the sise of the initial waste-
is
water treatment plant in the Environmental Impact
19
Statement as follows:
20
Quote, "if it can be shown that this capa-
21
city will not be adequate to meet the local management
22
needs, the initial capacity of the treatment facility
23
may be expanded." Unquote, page 13.
24 *
Anothor important reference is Figure 3 on
25
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 37.3
DECATUR, GEORGIA 30030
-------
R. Wlllits
page 33 of the Environmental impact statement, it
shows an initial average daily wastewater flow of 60
million gallons a day for 1976-77, increasing to 80
million gallons a day by 1985.
As a result of our review of this matter* it
is recommended that the North Dade District Water
Treatment Plant have an initial capacity of 60 million
gallons per day rather than 40, and that basic capacity
of 80 million gallons per day be completed before 1985.
The Alternative Methods of Disposal of
Treated Wastewater.
The first, an ocean outfall, is placed at a
disadvantage by economic comparison becaua© it cannot
be constructed in increments to conserve the expendi-
ture of funds at an early stage of the project.
Consideration of the need of the Environmental
protection Agency for conserving of funds is directly
linked to the recosuaendation for constructing an
initial wastewater treatment plant of 40 million
gallons capacity rather than any larger.
An acceptance of the initial 60 million
gallons a day capacity for the wastewater treatment
plant and its larger volumes of treated wastewater
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 374
DECATUR, GEORGIA 30030
(404) 378-6239
-------
i R. Willits
2
would favor the ocean outfall alternative from an
3
economic standpoint.
4
The second alternative for disposal of
5
treated wastewater is the combined use of the existing
6
ocean outfall extended beyond the third reef and deep
7
wells. Our objections to this alternative are as
8
follows s
9
It will not be of significantly lower initial
10
cost if the initial wast©water treatment plant capacity
11
is 60 million gallons a day.
12
The deep wells cannot receive raw sewage
13
and must await completion of the wastewater treatment
14
plant in 1977 or later* before providing additional
15
capacity to the existing overtaxed North Da.de
16
interceptor and ocean outfall.
17
The adoption of deep wells for treated
18
wastewater disposal requires that a test well be
19
drilled to confirm geologic formations at the site
20
and this will delay construction of the installation
21
of the full capacity units by more than one year,
22
based upon local experience. A deep well of 3,000
23
feet depth, of 24 inch or larger diameter, is a major
24
project.
25
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 375
DECATUR, GEORGIA 30030
-------
-47-
R. Wlllits
2
The companion project, the extension of the
3
existing ocean outfall some 1,100 feet to a depth of
4
90 feet, and the installation of diffusers beyond the
5
third reef will decrease its hydraulic capacity to
6
approximately 30 million gallons s day. This flow is
rather small by comparison to the total peak flow for
the project which is in excess of 175.5 million gallons
per day. The quality of construction of the existing
outfall facility has been subject to question so that
the investment of large expenditures to extend it for a
long-terra service is not clearly supported.
3
B. An additional site for deep wells would b
4
required in ar. area where land is difficult to acquire.
15
It Is our recommendation that an ocean out-
16
fall be installed to serve the North Dade District
Wastewater Plant of sufficient capacity to meet peak
18
flows from that plant.
C. Disinfection.
Requirements for, or definition of secondary
treatment have been cited differently with respect to
disinfection in the Impact Statements relating to
Dade County. These should be superseded to conform to
the recently proposed national standards as stated by
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 376
DECATUR, GEORGIA 30030
(404) 378-6239
-------
1 R. WillitS
2
EPA In the Federal Register, Volume 38, Number 82,
3
April 30, 1973. Details of these differences arc
4
somewhat technical for presentation at this hearing,
5
Three, central Dad© Environmental impact
6
Statement.
This Environmental impact statement Draft
is in complete agreement with the Water Quality
9
Management Plan for Metropolitan Dado County, Florida,
10
and its approval is recommended.
11
Four, south Dade District Environmental
12
Impact Statement*
13
A. initial Capacity of the wast©water
14
Treatment Plant*
15
It is recommended that the wast©water treat-
16.
ment plant be constructed initially of 30-mgd capacity
17
instead of the 50-mgd recommended by the Water Quality
18
Management Plan* If the initial plant size were
19
limited to 30 million gallons a day, it would not be
20
possible to receive sewage from the Kendall area until
21
1985 when it is to be re-routed to the future West
22
Dade District Wastewater Treatment plant* It is
23 ' ti,
recognized that it is not desirable to continue
24 *
operation of the two Kendall area wastewater treatment
25
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 377
DECATUR, GEORGIA 30030
IAe\A\ ti-ja coon
-------
R. Willita
plants owned and operated by General water Worka
Corporation after construction of the south Dade
District Regional wastewater Treatment Plant* However,
it is probably the more economical alternative,
especially sine® Kendall area wastes are permanently
designated for discharge to the west Dade District
Wastewater Treatment Plant. Therefore, by continuation
of operation of the two Kendall plants after its
completion* the initial capacity of the &outh Dade
District Regional flant can be established at 30-mgd,
for future enlargement to 50-mya capacity.
B. Location of the Deep Disposal wells.
The requirement to install the proposed deep
disposal wells, east of the salt line, or 1,000 part
per million isochlor at the base of the Biscayne
Aquifer, has been questioned in the Environmental
Impact statement for reasons of economy, it would
save some estimated $2,850,000 if the deep wells
could be installed on the wastewater treatment plant
site by elimination of a pipe line.
The Miami-Dade water and sewer Authority has
a dual responsibility to the community. The protection
of the water resources of Dade county are of ~ital
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 378
DECATUR, GEORGIA 30030
(404) 378-6239
-------
_ JVJ
Willits
2
importance, also. South Dade County, in the vicinity
3
of the south Dade District Wastewater Treatment Plant
site, is wholly dependent for its fresh water supply
5
on the Biscayne Aquifer. No public water utilities
6
7
have mains in the area so that wells are the source of
supply for domestic and irrigation water. Any damage
8
to this resource would be of extreme concern to all
9
interests in the area.
10
During the summer of 1971, it was found that
11
brackish water resulting from drilling of the sunset
12
park wastewater plant deep disposal well had reached
13
the Authority's Alexander Orr water Treatment Plant
14
supply wells, some one and a half miles distant. Again*
15
during 1972, the drilling of the second deep well at
16
the Kendale Lakes wastewater Treatment Plant produced
17
high chloride concentration in the Biscayne Aquifer
18
at the well which were drawn towards the Southwest
19
Well Field of the Authority, approximately two miles
20
distant. Fortunately, protective measures by General
21
Waterworks, ordered by the Florida Department of
22
Pollution Control, and changes in pumping schedules by
23
the Authority prevented either of these salt spills .
24
from impairing the public water supply, but it was a
25
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 379
DECATUR, GEORGIA 30030
(404) 378-6239
-------
R. Willits
warning of what could happen, in retrospect, each of
the two deep wells drilled for treated wastewater
effluent disposal produced a serious hazard to our
water resources.
Au a result of these two incidents, the
Dade County Health Department, the Florida Department
of Health arid Rehabilitation services, the Florida
Department of Pollution Control, the Metropolitan Dade
County Pollution Control Department, and the Authority
jointly adopted an informal policy urging that future
deep wells be limited to areas east of the salt line
where salt spills resulting from drilling could cause
no damage to the fresh water in the Biscayne Aquifer.
For the reasons stated above, the Authority
staff will vigorously oppose the drilling of deep wells
on the south Dade District wastewater treatment plant
site. However, the installation of deep wells east of
the salt line or 1,000 part per million isochlor will
be supported.
Five, conclusions.
The preparation of the three Environmental
Impact statements for wastewater treatment in Dade
County, Florida, was a most difficult project for
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 380
DECATUR, GEORGIA 30O30
(404) 378-6239
-------
25
i R. Willits
2
your staff* because of the wld* range of problema to
3
be received. The quality and detail presented in each
4
Statement are appreciated and will serve as valuable
5
reference data, certainly* nothing of importance wan
6
overlooked. We will make every effort to support your
7
Statements, subject to the comments presented herein*
8
Thank you.
9
MR. BRIGGS: Thank you, Mr. Willits.
10
just a second. Are there any members of the
11
panel that have questions at this tine?
12
Mr. Fransmathes?
13
MR. FHANSMATHESt Mr. Willits, on page 2*
14
it is stated that about the 60-ragd. Could you supply
15
a schedule showing the sources of the 60-mgd and what
16
lines it would take to get that to the intcrama site?
17
in our impact statement, we have identified how we
18
arrived at the 40-mgd and the base flows that we used*
19
MR. WILLITS i okay, we certainly can. Yes,
20
sir*
21
MR. FRANSMATHESj Thank you.
22
MR. BRIGGSi That material will be made a
23
part of the record when we receive it.
24
WOR LEY & ASSOCIATES
Court Reporters
62 First National Bank Building 381
DECATUR, GEORGIA 30030
(404) 378-:6'239
-------
53
1 J. Moffat
2
MR. WZLLZTSj All right, sir.
3
MR. BRIGG3: Thank you, Mr. Willits.
4
At this time, we will call the next witness,
Mr. Joseph Moffat, chairman. Committee For sane Growth,
North Miami, Florida.
JOSEPH MOFFAT, CHAIRMAN
COMMITTEE FOR SANE GROWTH
10 HORTH MIAMI BEACH PROPERTY OWNERS ASSOCIATZOH
n NORTH MIAMI, FLORIDA
12
MR. MOFFATs Good morning, Mr. Ravan,
13
gentlemen
14
My name is Joseph Moffat* Z am past
15
President of the North Miami Beach Property owners
16
Association, and chairman of the Committee For sane
17
Growth of that same Association.
18
X have been asked to speak for the following
19
people and register their objections to the Horth Dade
20
Regional Plan, which is commonly known as sewerama.
The first and concurring in the Statement
12
that z will present is the Vice-Mayor of the City of
13
North Miami Beach, Ma. M. McDonald.
! 14
The City of north Miami Beach has taken a
5
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 382
DECATUR, GEORGIA 30030
(404) 378-6239
-------
i J. Moffat
2
position in opposition to this Go-called sewerama Plan,
3
and they have presently a case in Court, in Leon
4
County, in objection to the proceedings as having been
5
illegal.
6
The additional people who asked me to raise
7
this objection today is Dr. Hobart Feldraan, who is
8
chairman of the Tri-County Alert Citizens. Mrs* Annie
9
Ackerman, who is the head of the pollution Revolution
10
Organisation, a number of other associations, in-"
11
eluding the pal-Alto, p-a-1-A-l-t-o, Eastern Shores
12
Association, the Eniles Unit Owners Association and
13
many others, who object to this plan*
14
Before x present the statement, X would
15
like to say, and x am not saying this in the name of
16
the people who X have just mentioned, X would like to
17
say that our Association wants to be on record that
18
we object to the Greater Miami Chamber of commerce
19
injecting itself into the problems of the people of
20 ;
North Dade. The Greater Miami Chamber of Commerce in
21
our area is a dirty name.
22
This is an emotional issue in North Dade*
23
and you caa look forward to an emotional reaction.
24
How, for the statement.
25
WORLEY& ASSOCIATES
Court Reporters
62 First National Bank Building
DECATUR, GEORGIA 30030
(4O4) 378.6739
-------
1 J. Moffat
W« challenge the North Dade Regional
3
collection, treatment and disposal system, better
4
known as "Seweraraa", as being basically wrong in con-
5
cept and in gross error in the proposed execution.
6
We understand the local engineers being
7
locked into their antiquated plan by circumstances be-
8
yond their control, such as financing for the interama
9
project.
10
But, we fail to understand the lack of vision
11
on the part of the Environmental Protection Agency of
12
Region XV*
13
We are told by competent authority that the
14
solution to this problem is not on a single county
15
basis* but on a tri-county basis. We find nothing in
16
this study aimed in that direction. There is a
17
basically wrong concept.
18
Further, competent authorities state there
19
Is a section of southeastern Florida which is ideally
20
structured by nature to solve three of our basic
21
problems* That is, solving our problems of waste-
22
water treatment, the replenishing of our fresh water
23
supply, and the replacement of our disappearing farm
24
land soil. We find nothing about this in this study.
25
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 384
DECATUR, GEORGIA 30030
(404) 378-6239
-------
J. Moffat
2
How can you deliberately Ignore this major
3
possible solution?
4
The complete plan here presented is committed
to the outdated and rejected practice of wasting our
national resources by just, quote, "throwing it away".
End of quote.
o
Well, the people are a way ahead of that
9
antiquated thinking, and will take strong measures
10
against such thinking, and are already questioning
11 „,.,,,,
o:: •. j.c\;.'j- credibility.
12
The plans call for a forced conduit to be
13
laid to Northwest 50th Street to carry the sludge. It
14 I
! is obvious that if the heavy sludge can be forced
15
from east to west, the full effluent can be collected
in the west, the sludge removed whore it will be used,
and the treated liquid piped to the east, temporarily
18 I
to the ocean outfall line.
1 9
There are engineering figures which set the
°o i
cost of this method at less than twenty cents per unit
per month, for eight to ten years, until, as the
n n
local engineers have told us, the, quote "state-of-th*-
23 art", end quote, will permit recycling, and when the
24 truth of the Tri-Counties concept can no longer be
25
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 385
DECATUR, GEORGIA 30030
(404) 378-6239
-------
57
1 J. Moffat
2
ignored.
3
After that time, the western location will
4
effectuate savings which will compensate for those
5
costs, many, many times over, for the next fifty or
6
a hundred years.
7
This plan is not included in the statement
8
and it is certainly not answered by section 4(d),
9
The claim that all potential sites were
10
considered, and that the site selected is at the
11
downstream end, that is in quotes, "downstream end", of
12
the proposed collection system is in gross error.
13
The highest elevation of South Florida
14
Coastal Ridge is not far removed frora the Coastal Line,
15
and the majority of the area to be served drains to
16
the west and not to the east. There are several large
17
tracts available, and wa await your inquiry on this
18
subject to demonstrate your sincerity to serve the
19
people of southeastern Florida.
20
Perhaps you do not know that the original
21
selection of the interaiaa site was an act to funnel
22
funds into the starving interama project and not as a
23
proper site. We have documented proof of this state-
24 . ^
ment, and we further await your request to produce
25
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 386
DECATUR, GEORGIA 30030
(404) 378-6239
-------
58
J. Moffat
those statements.
3
It is surprising to us as to the diligence
4
with which the engineers and the Environmental Fro-
5
tection Agency and the press have avoided the
6
Tri-County concept.
7
we respectfully request an answer regarding
8
the Tri-County concept.
9
The people of all of North Dade, not just
10
North Dade, but South Dade and Central Dade, are
11
affected by this concept. They will be much benefited
12
by the Tri-County concept. It will solve all of their
13
problems of this nature. They are entitled to know
14
why you persist in ignoring this practical solution
15
to our common problem.
16
Thank you, gentlemen.
17
Are there any questions?
18
MR. BRIGGSi Any questions?
19
Mr. Franzmathes?
20
MR. FRANZMATHESs Sir, for the record, I think
21
you have identified five areas where you have asked
22
for an inquiry by the Agency. I would like to make
23
that inquiry.
24
MR. MOFFATl Yes, Sir.
25
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 387
DECATUR, GEORGIA 30030
-------
59
1 J. Moffat
2
MR. FRAHZMATBBSi These are identification
3
of the Court case that is pending in Leon County.
4
MR. MOFFATi Yes, sir.
5
MR. FRAMZMATHBSs Identify the competent
authority that is in your statement, in the first part
7
you reference to a competent authority.
8
MR. MOFFATi Uh-huh.
9
MR. FRAMZMATHBSi A reference is not given
10 |
as to where the figures from engineers for twenty cents
11
per unit per month was arrived at.
12
There was indications that large tracts were
13
available that you have documented.
14
MR. MOFFATt Yes, sir.
15
MR. FRANZMATHBSt And that there are document^
16
proofs on the origin of the interama site.
17
I belive that covered everything that I
118
noted that you said the Tri-County Alliance had avail-
..9
able.
MR. MOFFATi I will see that you get that
::i
information.
2
MR. FRAMZMATHBSt Thank you.
3
MR. BRIOGSt Thank you, Mr. Moffat, we
4
appreciate it.
15
WORLEY& ASSOCIATES
Court Reporters
62 First National Bank Building 3gg
DECATUR, GEORGIA 30030
(404) 378-6239
-------
C. Morrissey
3
4
5
MR. MCFFAT: Thank you, gentlemen.
MR. BRIGGSt Any material that you submitted
1-yill b© raade part of the record.
MR. MOFFATt Thank you.
6
8 MR. BRIGGSs At this time, X would like to
9 call our next witness, Mr. Colin Morrissey, Director
10 of Dad© County Pollution Control.
11
COLIN MORRISSEY, DIRECTOR
DADE COUHTY POLLUTION CONTROL
MIAMI, FLORIDA
MR. MORRISSEY: Gentlemen, my name is Colin
Morrissey. 1 am Director of the Dade County Pollution
Control Department
We are here today to participate in decisions
which will have long-lasting effects on the health and
viability of our ecosystem here in Dade County, and
21 as such I feel decisions of this magnitude should be
22 made with some in-depth evaluation.
23 My office only very recently, as a matter of
24 fact, May 7th, received a copy of the North Dade Impact
25
WOR LEY & ASSOCIATES
Court Reporters
62 First National Bank Building 389
DECATUR, GEORGIA 30030
(404) 378-6239
-------
C. Horrissey
Statement, and we have had no direct contact with the
representatives of EPA, so as yet, we haven't had an
opportunity to totally evaluate what it is being
proposed in these impact Statements.
I would like to reserve at the time to sub-
mit a written statement with comments in detail.
X received this morning from my engineers a
draft of their review, which was only four days time
we had to do that.
However, there are several changes in the
Impact Statements which represent radical departures
from the original plan.
I would like to comment briefly on them, and
again reserve the written comments for a later date.
The suggestion to relocate the south Dade
disposal wells near the plant, I believe, has been
adequately commented on by representative of the
Miami-Dade County Water and sewer Authority, Mr.
Willits.
I would like to, suffice it to say, I agree
with those comments that the wells should not be re-
located and that the saving in money doesn't seem to
justify the risk incurred at that area.
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 390
DECATUR, GEORGIA 30030
(404) 378-6239
-------
C. Morrissey
The second area that I would like to comment
on Is the suggestion to go to deep well disposal In
the North Bade area, would also seem to be undesir-
able from the standpoint of potential risks involved
in this system, as we do not at this point fully
understand all of the possible problems that we really
have in deep wells, and we have only for the past
several years been operating deep wells here in Dade
County, at a much lower volume than is proposed to be
used at this point. Also, a departure at this point
to deep disposal wells will require much more evaluatlo^i,
and I would suggest at this point any further delay in
the implementation of our sewer system in Dade County
may be disastrous for the county. So, in that regard,
I would again oppose a change to deep well disposal
systems for the North Dade area.
As it was stated -- I think Mr. Moffat
commented on the fact, that we should be going to some
recycling system and if I had to choose what I felt
was most desirable, I would again choose some system
of recycling for Dade County.
But, I believe that the decisions of this
nature, which have such long-lasting impact on
WORLEY& ASSOCIATES
Court Reporters
62 First National Bank Building 391
DECATUR, GEORGIA 30030
-------
to
11
C. Morrissey
2
environment, should not be made on economics or what
3
is considered to be desirable from an emotional
4
standpoint, but should be made on what presents the
5
very least risk to the community, to the environment,
6
public health.
So, again, on that basis, I would oppose the
change to a deep well disposal system in the North
Dade area.
Thank you, gentlemen. That is all Z have.
Are there any questions?
12
MR. BRZGGSt Any questions from the panel?
13
Mr. Morrissey, we will include as a part of
14
the Final Impact Statement any comments that the Dade
15
County pollution Control Authority submits to us.
16
18
MR. MORKISSBYi Thank you.
19 MR. BRlGOSt At this time, I would like to
call the next witness, Mr. Neil M. Goldman from
21
Opa-Locka, Florida.
22
23
24
25
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 392
DECATUR, GEORGIA 30030
(404) 378-6239
-------
i N. Goldman
2
NEIL N. GOLDMAN
3
FEDERAL M.D.T.A.
4
WASTE WATER TREATMENT OPERATION PROGRAM
5
OP A-LOGKA, FLORIDA
6
7 MR. OOLDMAHt X just wanted to ask, X just
g wanted to ask some questions. I am here with a group
g of students, as you may know* who are being trained
10 in a program sponsored by your Agency for wastewater
n treatment operators.
10 And, x live in the North Dado area, and X
1 Zi
13 have received in the mail all three Environmental
]4 impact Statements and what X am confused about is the
Statements indicate that it has been found that there
ID
16 is no damage resulting from the current outfall lines
17 in my area to the sea of raw sewage.
1Q This is not true, and it does not — X am a
1 o
biology teacher as well as now in this training pro-
I gram. X know that is nonsense.
& U
Bacteria do not completely die off, like,
ij 1
for example, we come from Miami Beach through an out-
22
fall line into the ocean and harmful bacteria could
23
survive. There is no proof adduced yet as your own
24
UK
impact statement admits, that these bacteria could not
25
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 393
DECATUR, GEORGIA 30030
IA<\A\ QTa.eo'aa
-------
65
l N. Goldman
build up over a period of time and possibly be harmful
3
to tourists that swim in the ocean. That is number
4
one.
5
Number two. I understand, in spite of the
6
recommendations in your Impact Statement, for 90 per-
7
cent or better treatment in the near future, the City
8
of North Miami specifically has indicated to me in
9
terms of job potential in the area, that they have
10
absolutely no plans in the immediate future -- they
11
said X could quote them -- for treating the wastewater
12
in the area in terms of 90 percent or better treatment.
13
They feel that their merely adding
14
chlorine to the water, is adequate and sufficient to
15
meet current needs, and of course, this is nonsense.
16
The cities of Opa-Locka, sections of Hialeah,
17
and other parts of the North Dade area are also doing
18
the same thing.
19
The City of Miami Beach, as you people well
20
know, is pumping the raw sewage completely untreated
21
into the ocean.
22
Now, I don't understand why you are
23
sponsoring this program of training for wastewater
24
treatment operators, and why you are making these
25
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building
DECATUR, GEORGIA 30030
(404) 378-6239
-------
i M* Goldman
2
recommendations for 90 percent or better treatment,
3
and even thinking in terms of deep well disposal that
4
was in the paper yesterday, which would involve 90
5
percent or better treatment, prior to being put in the
6
deep wells, and yet you are allowing, and z don't
7
understand this, you are allowing for example the City
8
of North Miami to provide what amounts to no treatment
9
at all, and not even requiring them to have any plans
10
for the immediate future for treatment.
11
And, z don't understand this, and I think
12
that — z at least would like some answers, if not,
13
the other members of my class, as to why'this area is
14
not being required of north Dade to submit plans to
15
meet various deadlines and everything for 90 percent
16
or better treatment.
17
Thank you.
18
MB. LZTTLEi Mr. Goldman, may Z ask you one
19
question?
20
MR. GOLDMANi Yes.
21
MR. LiTTLEt YOU indicated that you might
22
have some information that seemed to me, from what you
23
said, in terms of documented damage from outfalls in
24 , *
use at the present time.
25
WOR LEY & ASSOCIATES
Court Reporters
62 First National Bank Building
DECATUR, GEORGIA 30Q30
-------
1
2
3
4
5
6
7
8
9
10
11
12
13
H
15
16
17
18
19
20
21
22
23
24
25
67
N. Goldman
MR. GOLDMANs I would refer you to Dr.
Peldman and to the various other people that are more
scientifically oriented than me, the group represented
by Mr. Moffat and so forth, z am sure, they have some
data on this, or at least at the last hearing in Miami
Beach, my class and I spoke to Dr. Peldman outside of
the hearing. Where he indicated that he had some data
to show that there was potential harm from the outfall
lines and that the statements given by another
scientist from the University of Miami were contra-
dictory on this subject, that he at one time said
there was a potential danger from the outfall lines,
and at the most recent hearing, he said there was little
or no danger, so he issued conflicting statements.
X do know as a licensed biology teacher that
when you have an outfall line and when you are pumping
raw sewage into the ocean, it is a little silly to say
this is harmless because the solution to pollution is
dilution.
I thought that we abandoned that concept
years ago, of jttst pumping raw sewage into the ocean,
and yet we seem not only to still be doing it, but the
area has absolutely no plans and they smid I could
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 39fi
DECATUR, GEORGIA 30030
(404) 378-6239
-------
N. Goldman
2
3 quote them, for 90 per cent or better treatment in the
4 immediate future. Thay are going to wait for the
Interaraa or "Sewerama" as it was called facility, which
may not appear until 1985 or 0, and quite frankly I
don't intend to wait that long to see 90 per cent or
better treatment for my area, and I will join with any
Court action to enforce the various county or city
10 officials in this area to provide some decent treatment
so the swimming can be effectuated safely.
MR. BRIGGS: Mr. Goldman, we will be glad to
answer some informal questions of the students after
]4 we have the hearing, but as a part of the response to
i
ji what you said, I would like for Mr. Franzmathes to
I
16 indicate what the law requires before 1985 with regard
17 to secondary treatment of wastewater that comes out of
18 all municipal facilities.
J9 I am going to ask him to give us a brief
20 report on what the status of the guide lines are for
21 secondary treatment from EPA. Okay?
22 MR. GOLDMAN: Are you aware of the fact,
23 though, that for example, the City of North Miami has
no immediate plans to follow those guide lines?
25 MR. BRIGGS: We will have to address that
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 397
DECATUR, GEORGIA 30030
(404) 378-6239
-------
69
1 M. Goldman
2
question in the impact statement* I am not going to
3
address that now. I do want Mr. Franamathes to in-
4
dictate what the requirements of the 1972 Amendments
v
are for the future with regard to secondary treatment*
6
MR. FRANSMATHESj Every municipality that
was discharging into navigable waters must file for
8
a permit, they must provide by mid-'77 or at the
9
latest, mid-'73, secondary treatment.
10
The interim definition of secondary treat-
11
ment was published in the Federal Register on April
12
30th of this year. The final definition will be
13
published later after comments.
14
Anyone who is discharging without a permit
15
would be subject to action by either our Agency or the
16
State Agency.
17
The constructing authority for this area
18
would be Dado County.
19
MR. BRIGGS« Okay. At this time, I would
20
like to ask for the next witness. Dr. Elton
21
Gissendanner, Chairman, State of Florida inter-
22
American Center Authority.
23
24
25
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 3QQ
DECATUR, GEORGIA 30030
(404) 378-6239
-------
i B. Gissendanner
2
DR. ELTON GISSEKDANNER, CHAIRMAN
3
STATE OF FLORIDA IWTER-AMERICAN CENTER AUTHOR!TV
4
MIAMI, FLORIDA
5
3 DR. GisSENDANNERi Mr. Chairman, members of
7 the Committee.
s X have not appeared before this group before.
s My name is Elton Giasondanner. 1 am in charge of
10 inter-American center Authority. X live in North Dade.
11 X am a graduate veterinarian* trained in
12 public health, pathogenic, bacteriology* viriology, et
is cetera, et cetera, which you are aware of*
14 x was the Mayor of the city of North Miami
15 when the first outfall was built* X wa* Chairman of
is the xnterama Authority when we made the transaction
n with Dade county for the location of the North Dade
is treatment plant*
ig X must* x think, in all fairness to you and
20 to the record* take considerable i**ue with Mr* Ho*fat,
21 who X have known for many years, and the people he
22 represents, because there are many technical in-
23 accuracies in his statement which can be shown and
24 proven*
25 Also, x think you should be aware of the
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 399
DECATUR, GEORGIA 30030
'(404) 378-6239
-------
71
E. Gissendanner
fact Mr. Moffat, although he himself is not a
candidate for office, many of those in his group are.
Dr. Feldman is now in the political struggle of his
life running for office. Mrs. McDonald just was
elected. Many in that group have used this issue as
a political forum, and are continuing to use it as it
is an emotional, political issue.
I might point out that my dear friends in
North Miami Beach, that they have never even bothered
to approve, and have had many opportunities by referendiim,
a collection system. They are still putting their
sewage in the ground, in septic tanks.
I think you should measure some of these
statements in the light of the history, and in the
light of the facts today. I do not wish to get in a
personal argument with them, but I think that it is time
that I appeared here, since you have had other
occasions when I did not appear, but it seems that now
is the time to set the record straight on some of these
matters so that you can consider them in the proper
light.
First, I would like to speak to the fact
that the City of North Miami built the outfall line
WORLEY& ASSOCIATES
Court Reporters
62 First National Benk Building 400
DECATUR, GEORGIA 30030
(404) 378-6239
-------
i E. Gissendanner
2
in 1965, '64 and '€5, after the City of Horth Miami
3
Beach had failed to get it done in the referendum.
4
I believe that Mr. Moffat was on the Council some years
5
just prior to that, and was involved in the original
6
planning of this outfall line himself„
7
We built the outfall line and it went through
8
the route that it goes today, primarily because that
9
it had been engineered for the City of North Miami
in
Beach. As you know, it takes the north jog, then
11
eastward to the ocean over 163rd street, which at that
1 2
time was totally in North Miami Beach.
13
We took that route over ray-considerable
14
objection as Mayor at the time, which our records will
15
show, because it wasn't the shortest route, number
16
one, and it was the most expensive since it went down
17
improved road. Had it gone through the Interama tract,
18
which we had permission to go at that time, it would
19
have cost much less money, and it would not have done
20
the ecological darcage that it did at the time,
21
Now, we have agreed to give the County a
22
right-of-way through the interama tract at the proper
23
location, and it just so happens — I believe the
24 *
engineers are present in the audience today — which
25
WOR LEY & ASSOCIATES
Court Reporters
62 First National Bank Building 401
DECATUR, GEORGIA 30030
(404) 378-6239
-------
73
E. Gis sendanner
would show that there is a little valley in the reef
Out there at this point that keeps—so it makes it
convenient to put the outfall line in without doing too
much damage to the reef.
We know it will transverse a couple of spots
cf mangrove, but they will return to their original or
near original in the future. There will be very
little ecological damage to the area with the present
proposed outfall line.
It will save Dade County, to go this route,
some two or three million, and from what I have read in
the paper this morning and yesterday, that savings of
money is somewhat of an interest to you.
I further would like to say that, you know,
sewage doesn't run downhill, the way we pump it around
Dade County, and the fact there is a ridge FTC Railroad
goes, just east and west of the Interama tract, has
nothing to do with the flow of sewage whatsoever, and
any engineer or anybody who knows anything about that
can very well verify that. This is all pumped under
pressure, no matter if it is downhill.
There are some other considerations -- pardon
me for taking some time — since I haven't appeared
before you before, I think you should be aware of •-
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 402
OECATUR, GEORGIA 30030
(404) 378-6239
-------
E. Gissendanner
The President has designated Interaraa in this
3
area as one of the primary locations for the bicen-
4
tennial, and it appears and we have pretty good
5
evidence to show that no other city in the country will
6
have a major bicentennial presentation in 1976.
7 .
Now, this much-maligned Chamber of Commerce,
o
was able to get that designation for us in Washington
9
by the President, and the American Revolution Bi-
10
centennial Commission.
11
And, we have a mandate to try to do something
12
at Interama in 1976, which will let the troubled people
13
of this country have a showcase for their pride and the:
14'
freedom and the form of government which we all enjoy.
We take that challenge and that mandate serious-
1 fi
ly. We have been working at it very consciously now
17
for several years, many people in the community and
18
many organizations, both government and private* We
19
believe that we will be able to do this.
20
Of course, we are also having a State
University there, a brand new State University which
22
will be open in 1976, which will be of considerable
23
benefit to the people in North Miami, North Dade,
24
North Miami Beach, et cetra, et cetra, and South
25
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 4Q3
DECATUR, GEORGIA 30030
(404) 378-6239
-------
75
E. Gissendanner
2
Broward .
3
4 So, the business that we are about, it is
5 serious business, and it can be comically referred to
6 as "Sewerama" if those irresponsible citizens so desire
7 but we take it quite seriously. The State Legislature
and the Governor of Florida is taking it quite
8
g seriously, since they are helping us fund the project
and giving us the legislative power to proceed.
I think it is well too, for me to point out
to you that 1 primarily got involved in the Interama
project as Mayor of the City of North Miami because of
an environmental and conservation type of thing, becaus
r
the original authority went into default and the land
was going to be sold for private speculation. So, the
16
City of North Miami put up $12 million to save this piece
of land.
18
And, I think it is to their credit that they
19 *
did, and the majority of the people of North Miami,
North Dade, favor this project, and favor the sewer
plant and favor everything that has gone on, because
* &
they know they have to flush their toilets several
I &O
times a day.
:24
We also know that it is going to cost more
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 404
DECATUR, GEORGIA 30030
(404) 378-6239
-------
1 E. Gissendanner
2
money to do it right, and when we built the outfall
3
line in 1964 or '65, these same questions arose, not
4
in as many minds as they have today, but certainly my
5
mind as a trained professional in public; health*
6
What happens to the bugs when you put then
7
into the ocean? X asked Ralph Baker, who was an
8
engineer in Jacksonville, I went up there, spent a day,
9
to try to find out what kind of research they had done,
10
and they showed me some documentation. Obviously,
n
there is a septic boil at the point of exit of the
12
effluent, we all know that, we would actually not be
13
responsible not to recognize that. But, no one — it
14
has never been proven that anyone has received any
15
sickness from that particular boil in the ocean.
16
Obviously, it is not something that we desire
17
to have, but it was something that was necessary, and
18
in 1964, now nearly ten years ago. We were told then
19
by using the skimming treatment or the pre-treatment
20
that it was called, there was an interim situation and
21.
it would just be a matter of time before we would have
22
to extend the treatment* We all know that. And, now,
23
we know that there is another consideration, which is
24 ' '*'
water conservation, that we must consider in addition
25
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building AQ c
DECATUR, GEORGIA 30030
(404) 378-6239
-------
77
E. Gis 8endanner
to the extra, treatment.
And, so, we know that this outfall line and
this treatment plant, probably in ten years from now
or sooner, will have to go to tertiary treatment and
some type of recycling.
It just so happens that the site and lo-
cation for the North Dade treatment plant is ideal
for all of these things that I have mentioned, primarily
because you would have an outfall line to use in
emergency cases, in case of a breakdown in equipment,
so you wouldn't contaminate the inland waterways or the
land in the event of breakdown. So, you could always
use the outfall line if it is built as a pressure
valve, a safety valve, to go into the ocean while you
had breakdown.
We had a breakdown in North Miami at a
junction box where Hialeah comes in. We had to pump
raw sewage into Biscayne Bay for several days or so.
We know these things can happen.
There is one other consideration. When you
go to tertiary treatment or recycling, removal of
nitrates and phosphates and bacteria from the water, thjat
the Oleta River is just a few blocks due north of this
site, and the.
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 406
DECATUR, GEORGIA 30030
(404) 378-6239
-------
i E. Gissendanner
2
Oleta River had a salt water dam in it. So, when this
3
water is treated in the future, we know it will have
4
to be conserved, it is a simple matter to pump it a few
5
blocks north in the Oleta River, and you have a natural
6
conduit to the west.
7
So, all of this business you have heard so
8
much about, about building treatment plants in the west
9
and pumping everything to the west is absolutely un-
10
necessary and uncalled for and extra expense.
11
Now, the Interama Authority must open this
12
facility January 1, 1976, to meet our deadline. We
13
have budgeted three quarters of a million dollars for
14
the purposes of -- and this will answer some of Mr.
15
Goldman s questions -- of secondary treatment, 90 per-
16
cent treatment, to beef up the existing plant. There
17
is a treatment plant on Interama. Some of you may have
18
been, in listening to some of the people, they don t
19
know it is there. They make out like it isn't there.
20
There is one there already. It is not being used.
21
We are budgeting three quarters of a million
22
dollars to upgrade it to secondary treatment or else to
23
spend that money in Eastern Shores and let them treat
*
r\ A
our sewage. We are not going to contaminate further th
25
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 407
DECATUR, GEORGIA 30030
(404) 378-6239
-------
£. Gi aaendanner
environment and waters of the community.
I would be very happy to answer any questions
that you might have, I did not prepare a formal
presentation because I really didn't intend to come
here -— J didn't intend to get involved in sort of a
shouting contest.
I have been listening to some of our people
in North Dade now* very vocal minority, for over two
years. And, it has just reached the point where z
felt the record should be clarified and straightened
out.
Now, one final thing. How did Dade County
arrive at the site? Very simple* By economics.
The land that they would have had to acquire
that was available in the area was something like a
hundred* $200,000 an acre.
We sold them the land for thirty thousand
an acre* because it is public land. It does not have
to have a private profit made upon it.
We originally agreed to sell them a piece of
land which was right adjacent to 163rd Street in a
very fine mangrove area. The state said they could
not, so it was relocated, and the Environmental impact
WORLEY& ASSOCIATES
Court Reporters
62 First National Bank Building 408
DECATUR, GEORGIA 30030
(404) 378-6239
-------
£. Gtssendanner
Statement was made or an environmental study was made
3
by two different entitles to settle on the site.
4
And, we at that time thought we had settled
5
the political matter of having it so close to North
6
Miami Beach. And, the site that is proposed today
7
certainly will not do any great environmental damage to
the area. - x.*.
Mow, it is true that we needed their money.
10
They needed our land. That is the basis of doing
11
business, I think, in a free society.
It is true that we need the $2 million. They
13
have only paid us four hundred thousand of the two
14
million four. We could use the two million.
15 j
As I have just said, we will have to spend
16
three quarters of a million just to upgrade our sewage
17
facility, so we are going to be really putting it right
18
back. But, to say there was some nefarious scheme to
19
sell this land to Dade County is an out and out un-
20
truth, and I deny it, and I wish it would not continue
21
to be repeated, or I wish groups such as you would not
22
give it any credibility or consideration.
23 :
So, 1 will be happy to answer any questions
24
you might have.
25
MR. BRIGGS; Any questions from the Panel?
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 409
DECATUR, GEORGIA 30030
(404) 378-6239
-------
81
B. Gissendanner
KR. SAVAWi Just on*, Mr, Chairman.
Sir, would you state for the record the
amount of acreage that is now available positively at
interaraa for this plant?
DR. GIssENDANNERi we have a contract for
SO acres with Dade county. That is what they asked
for, that is what we agreed to sell them, we had, in
the property under the control of the Authority,
originally some 1700 acres of land. 350 acres of that
land went to the City of North Miami for putting up
their $12 million to bail the project out, to keep it
from being sold to private speculators.
we have earmarked some for the State Uni-
versity, we have said that we would give to Dade
County a hundred and fifty acres along the Oleta River
to preserve it forever as a mangrove area.
We could, if it was necessary, sell more
land to Dade County in that area. We would not like
to, because we would like to save as much of it as we
can.
We think that we gave them a challenge, and
in our contract with them, they have to let us approve
their plans so that they can't go in there and build
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 410
DECATUR, GEORGIA 30030
(404) 378-6239
-------
1 B. Gissendanner
2
something that will be detrimental to our project, to
3
the University or the neighborhood, if they ao chose.
4
And* I am sure they would not do that.
0
As a matter of fact, they are under a man-
6
date to do something special there, if not recycling,
maybe even possibly* and it has been talked about*
8
to have some demonstration recycling project there
9 !
for the bicentennial. That hasn't been completely
10
thrown out yet. It has to be talked about with Bade
11 |
County.
12
Bear in mind, this location is unique. He
13
have the salt water intrusion sewage that comes from
14
the coastal areas, we have the non-saline infiltrated
15
sewage coming from the west. So, this particular
16
location lends itself well to innovation and research
17
and consideration* and this young man was here
18
talking about training people and you giving him
19
money. That is one of the things we hope can be
20
accomplished. And, Dade County has agreed to use this
21
treatment facility as a training facility for
22
operators.
23
I served in the state Legislature in '66-67.
24 *
We tried to pass a bill then requiring training of
25
WORLEY& ASSOCIATES
Court Reporters
62 First National Bank Building 411
DECATUR, GEORGIA 30030
-------
83
1 £. Giesendanner
2
operators. I don't know whether the state ever done
3
anything with it. we couldn't get it through then. I
4
think they have done it by now. Be that as it may,
5
this matter has not been forced upon the public in
6
some irresponsible manner.
7
Thank you very much.
8
MR. BRIGGSs Thank you, sir.
9
I would like to call the next witness, Mr.
10
John Bergacker, of the Department of public works in
11
the City of Miami.
!2
MR. MOFFATi Excuse me, Mr. Briggs —
13
MR. BRIGGSj Mr. Moffat, can you wait until
14
the other witnesses have been heard?
15
MR. MOFFAT» Mr. Briggs, may I have the
16
opportunity to respond to two points later?
17
MR. BRIGGS t You can go after two more
18
witnesses, you can go a second time.
.9
MR. MOFFATTs Thank you.
20
21 JOHN BERGACKER
22 DEPARTMENT OP PUBLIC WORKS
23 CITY OF MIAMI
24 MIAMI, FLORIDA
25
WORLEY& ASSOCIATES
Court Reporters
62 First National Bank Building 412
DECATUR, GEORGIA 30030
(404) 378-6239
-------
i J. Bergeckcr
2
MR. BERGACUERt X have one comment with
3
regard to the Environmental Impact Statement for
4
Central Dade County, datod April 13, 1973*
5
That ia on page 47* It it headed "Impact on
6
the Ocean" and it gives a criteria in the first para*
7
graph. I should say gives a criteria for the effluent
8
to be disposed of in the ocean in the first paragraph,
9
I question this Agency or any other Agency
10
as to where they came up with this criteria, what
11
scientific evidence or evidence of fact you have that
12
you came up with the material that is listed here,
13
The reason I have raised this point is X know
14
quite a few scientists who have done quite some re-
search on Miami Beach's outfall and other outfalls in
1 R
the southeast Florida area* And, some of them were
17
quite hostile and had made hypothesis prior to making
1 8
their investigations as to the bad effects of bio-
degradable sanitary sewage effluent in the ocean, only
2 0
to find that after they had gathered it, their facts,
21 that they could not substantiate their hypotheses*
22 I, for one, after reviewing just about all
23 of the Information that X could on the subject and the
*
24 Impact that la of the existing sewage outfalls that
25 :
WOR LEY & ASSOCIATES
Court Roportort
62 Pint National Bank Building
DECATUR, GEORGIA 30030
(404) 378-6239
-------
es
'. Bergacker
2
are here today, find it hard to Justify the financial
3
burden that will have to be put on the taxpayers of
4
the United states and this local area to meet the
5
criteria that you have called for.
16
I think this criteria is nothing wore than
a reply to the newspapers and some environmental groups
Who have become politically oriented. They have found
9
a need to correct a situation which, I am happy they
iO
did. X agree with the fact that there is a need. I
think they overdid the thing by trying to predict what
2
the treatment should be or what the solution to the
13
problem should be.
4
I think the solution to the problem should
15
lie in the experts or with the experts. That has not
16
been the case so far as I have been able to determine
7
so far, and unfortunately, it is going to cost the
taxpayers a lot of money, a lot of unnecessary money.
How, I want to get ov.er to statements by a
previous speaker, Mr. Goldman*
Be stated that the beaches off of Miami
Beach were unsafe to swimmers because of the existing
Miami Beach ocean outfall. And, I would like to —
He didn't support his statement with any type of fact.
WOR LEY & ASSOCIATES
Court Reporters
62 First National Bank Building
DECATUR, GEORGIA 30030
(404) 378-6239
-------
i J. Borgacker
2
And, x state right here and now that he can't.
3
There has been considerable research done,
4
not only by private laboratories for the City ©f Miami
5
Beach, but also by scientists for Environmental Pro-
6
tection Agency, the stats Department of Health, the
7
University of Miami, and other private* individuals,
8
none of which have been able to come forward with any
9
facta showing that the bathing conditions off of Miami
10
Beach are unhealthy*
11
Hr. Goldman also stated that, almost in a
12
factual manner, that the effluent coming out of the
13
outfall at Miami Beach, that the bacteria ~-~ that
14
there is a harmful bacteria, is not killed within a
15
short distance, and that it can reach the Beach*
16
I say again, that there is no factual
17
evidence to prove this. On the contrary, there is
18
every — definitely a preponderance of factual evi-
19
dence to prove otherwise,
20
z hope this Board or anyone else does not
21
listen to unqualified statements, and that they stick
22
really to the scientific evidence in coming to their
23
conclusions.
24 a
Z think, unfortunately, there are too fflany
25
WOR LEY & ASSOCIATES
Court Reporters
62 First National Bank Building 415
DECATUR, GEORGIA 30030
(404) 378-6239
-------
87
1 J. Bergacker
2
decision* made today that are completely unsupported
3
by facts, and that are — I mean, big decisions made,
4
large monetary decisions that affect our tax dollar,
5
and our health without the proper support of
6
scientific evidence which is already at hand.
7 .
That is not to say that more shouldn't be
8
sought, but all too often, conclusions are made con-
9
trary to the facts that are already at hand. And, I
10
say this is something that has happened down here in
11
south Florida.
12
I think there is a good system that can be
13
used, utilizing ocean outfalls for sanitary sewage
14
disposal without going to the extent and the expense
15
that is proposed in your statements. And, I think it
16
can be done readily. I think there is enough money
17
available to do it readily.
18
MR. BRIGGSi Thank you, sir.
19
Any questions from the panel?
20
At this time, I would like to call the next
21
witness, Mr. James p. Redford, Jr., who is a member
22
of the Board of Florida pollution Control.
23
24
25
1 WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 416
DECATUR, GEORGIA 30030
(404) 378-6239
-------
1 J. Radford
2
JAMBS F. RBDPQRD, JR.
3
PRESIDENT, IZAAK WALTOU LEAGUE
4
AND MEMBER OF THE
5
FLORIDA POLLUTION CONTROL BOARD
6
MIAMI, FLORIDA
7
s MR. REDFORDt Although I am a member of the
9 Florida pollution control Board, I am not sp*ftkiag in
10 that capacity today except as one vote in ease the
11 question should come up, which, I am sure it will*
12 X am speaking more as a member of the isaak
13 Walton League and as the president of that organi-
H zation, both state and local, at various times for a
is number of years*
16 I want to bring you up-to-date as to why you
n are here today, and what events have brought you here.
is In 1968, Dade County** Pollution Control
19 Program, its sewering program was touched upon dead
20 center, it was the ixsak Walton League, in conjunction
21 with Herbert W. Hoover, Jr., who started this whole
22 business of what has now become known affectionately
23 as the •coliform cruise", we started a loud drum beat
24 going OB for several months, and we precipitated with
25 the aid of the BOW Assistant secretary of the interior,
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building ,-.-,
DECATUH, GEORGIA 30O30 ^ '
-------
1 J. Redford
2
and then conservation Aide of Governor Kirk, Hataaniel
3
Reed, a Federal-State water Conference, that you are
4
all familiar with.
5
had numerous meetings here on this thing,
6
and we did, I think, "sand-bag", if you want to use
'7
that rather crude terra, Dade county into an action*
based on the fact and convincing me, after a long
period, that ocean outfall is the thing, ocean outfall
is it. we say how about recyclingi no such thing,
you can't recycle. We were told this by this
:2
particular organization, not particularly the same
3
cast of characters, but then one of the many initials
you have gone under in the past.
Now, we have been told this for years, and
the efforts that started this whole business going
here was the izzak Walton League, joined by the other
conservation societies in Dade county and throughout
Florida.
And, I can tell you here right now, gentle-
men, if we are going to go to deep wells with all of
the necessary research and so forth that must go into
that, before we can make this a massive disposal of
effluent, you can depend, the conservation societies
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building AIR
DECATUR, GEORGIA 30030
(404) 378-6239
-------
2
3
4
5
6
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
J. Bedford
oppose this with all their strength, because It
is dilatory* it is expensive* and it is not * proven
way of effluent disposal in this geologic structure.
Vow* contrary to utterances made in various
letters and IA the reports* you do not know whether
this is an «£f*etiv* way for «a»»iv« waste disposal in
this geologic structur*. You have had oao woll that
is fully opsratsd in this county, you have not
monitorsd this with another well* Therefore, you do
not know where this water goes* what happens at the
bottom of the pipe* There is no knowledge of this*
You only have to ask your local U.8.O.S.
Representative and to find this thing out.
Further than this* you have* every tiae a
deep well has been dug in Dado County* it &*s wide a
The first time one was dug* during a drought*
and dumped approximately 60 million gallons of salt
water* running about two or 3*000 parts per million*
rightOft the ground* which eventually seeped in the
drinking water a mile away* causing the wells to have
to shut down*
There is a gentleman from the Miami Water
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building
DECATUR, GEORGIA 30030
(404) 37,8-6239
-------
7
8
y
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
§1^
jr. Radford
and Savor Dapartmant horo who can varify that.
Vha sacond wall was pradietad for a ear tain
dapth, for tha bouldar sona, thay wara almost a
thousand foot off. It was amazing that tha structura
thay uaod to drill tha wall wasn't auekod right down
tha wall.
Again, aalt watar was dumpod on tha ground
and again millions of gallons of aalt watar driftad
into anothar wall f iold — yat anothar vail f iold
away,
You hava prohlams with this thing, you do
not know, goatlomoa, whathar a daap wall injaction is
going to work horo, you do not know how many aoraa it
ia going to tako to put down 40 to 80 million gallons
of aowago a day. You ara going to hava to find out
about this.
In any soiantific oitporimont, you ara going
to tako two yoara to find out, if you do it proporly,
unlass you ahotgiux tha thing through, drill a hola,
swaap it undar soma gigantio rook.
So, again, wo ara raady to go tha minuta wa
hawo monay. wo ara roady to go oa oeoaa outfall, wo
aro willing to axparimant with daap wall, it daap
WORLEY & ASSOCIATES
Court Rapornrt / 90
62 Firit National Bank Building
DECATUR, GEORGIA 30030
(404) 378-6239
-------
1 J. Redford
2
well la a. grand thing, let's have it, later. Let's
3
clean up now. This is the aim of conservation
4
societies, and has been since 1968. And, if you want
the wrath of the conservation societies, postpone our
clean-up some more. We recognize the shortage of
funds. We recognize all of the problems.
We maintain that a sparrow can drop here in
9
Dade County with a soft flop and it sounds like a
10
loud gon> in EPA1s Office in Atlanta; here the people
i
want a clean-up, and the people's representatives are
1 2
in the process of getting a clean-up and we want it
13
now.
14
Now, the thing is, the whole business smacks
15
of illogic. Why can you say that we must go ahead in
16
Virginia Key and we can permit it to go up to hundred
17
million or more gallons a day sewage dumped into the
18
ocean like in the outfall. But, we can't do it up in
19
North Dade because of various reasons, namely the
20
economic, but we can do it in Hollywood because we are
21
along there, we can do it up fifteen miles. Every
22
fifteen miles, we have a new decision, some of them are
23
economic, some of them are environmental; but, gentle-
24 *
men, we cannot proceed that way.
25
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 421
DECATUR, GEORGIA 30030
(404) 378-6239
-------
^^ 93
1 J. Redford
2
We want to clean up, we want the fastest
3
clean-up wo can get. we maintain now that deep walla
4
may be a grand thing, when you find out how it works,
5
but you don't know now. And, we will enliat all our
6
forces, whatever they happen to be, against it.
7
I want to reiterate again, z an not repre-
8
aanting the point of view of the state pollution
9
Control Board, I am representing the point of view of
10
a fairly active conaervation society in Dade county,
11
and will enliat the support of others, z am sure.
12
Thank you,
13
MR. BRlOOSi Thank you, air.
n
Any questions from the panel?
15
At this time, we have a request from Mr.
16
Joaeph Moffat to get in additional time, and to — X
17
am going to allow him four minutee at thia time.
18
,9 JOSEPH MOFFAT, CHAIRMAN
2Q COMMITTEE FOR SAME GROWTH
2i NORTH MIAMI BEACH PROPERTY OWNERS ASSOCIATION
22 NORTH MIAMI, FLORIDA
23
MR. MOFFATi Thank you, gentlemen.
24 My name ia groaeph Moffat, a previoua speaker.
25
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building A22
DECATUR, GEORGIA 30030
(404) 378-6239
-------
j. Hoffat
2
X would just like to respond, x think it is
3
about three or four points.
4
We have been told that the people of north
5
Dade favor this regional sewer plan.
6
First, x would like to say that x don't
7
think there is strong objection to the ocean outfall
system, we recognise that there are problems, and
that there is a possibility of breakdown, and it is a
10
good safety valve.
11
But, the important point, of course, is that
12
we don't accept it as the ultimate solution, and we
13
accept it only as a temporary thing and something to
14
be used as a safety valve,
15
But, relative to the position of the people
16
of north Dade, x believe that it can best be answered
17
by the fact that the political structure has come out
18
strongly in objection to the xnterama location*
19
The city of north Miami Beach, through its
20
rather — rather through its officials, that is, the
21
citizens have impressed this point upon the officials
22
so strongly that they have taken a strong stand in
23
opposition to the xnterama location. They have
24
pursued it in the Courts which information you will
25
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 423
DECATUR, GEORGIA 30030
(404) 378-6239
-------
______ 95
1 j. Moffat
2
be supplied with.
3
So that, as far as the City of North Miami
4
Beach is concerned, I think the citizens who have
5
spoken out — there is no group who has spoken in favor
6
of it with the exception of one chamber of Commerce
7
Group. How, there are many groups who have spoken in
8
opposition to that location.
9
As far as the City of North Miami Beach is
10
concerned, the Mayor has taken a strong position
11
against it. z don't know what the city Council has
12
done, I think it has more or less been through the
13
press of other matters, they have not taken a position,
14
because each one of the members of the Council who
15
have spoken in my presence have taken a stand in
16
opposition to the xnterama location for the plant.
n
And, today there is, or tomorrow there will
18
be an election in north Miami, in which proponents of
19
the western Pade and the Tri-County concept are
20
leading in the primary vote, and one very strongly,
21
and each of the other two decisively, or at least by a
22
fair margin, and tomorrow will tell the tale as to how
23
I the people feel about these people, because these
24
people's primary position has been on this matter of
25
WOR LEY & ASSOCIATES
Court Reporters
62 First National Bank Building 424
DECATUR, GEORGIA 30030
(4O4)
-------
i J. Moffat
2
sewage treatment and handling, so, I think, as far as
3
the people are concerned —
4
I don't want to go on at great length, but
5
z think you should understand that when a statement is
6
made that the people favor this Interaraa location* z
7
think that ie not the true facts.
8
The statement has been made that tertiary
9
treatment at the znterama site could have the treated
10
effluent pumped into the canal which is emptied into
11
the oleta River*
12
Now, this has been discussed and the
13
engineers have told us that it is not acceptable to
14
process treated water in that manner because it will
15
have to be retreated before it can be returned either
16 I
to the conservation area or to the Blscayne Aquifer.
17
So, there again, if the treatment plant is at the
18
point where it will be returned to the conservation
19
area, it is a more practical location, and that is
20
Western oade County.
21
w.e are not overlooking the Tri-County con-
cept because that fits in, right with the treatment of
23
the plans of the sewage ia Western Dade County, either
24 *•
return it to the conservation area 3B or pump it to
25
WOR LEY & ASSOCIATES
Court Reporters
62 First National Bank Building
DECATUR, GEORGIA 30030
-------
97
J. Moffat
the area which can use the sludge and the other
effluent, which is Northwest Palm Beach County, which
partially answers one of the questions that you asked
before.
Two more points. No, one more point.
Well, yes, this nefarious scheme that has
been referred to. There has been no statement made or
charges made that there is any nefarious scheme with
respect to the arrangement between Dade County and the
Interama Authority, but you have heard stated here by
the Chairman of the Interama Authority that they needed
the money, and that is all we are saying, they needed
the money.
He has further said that Dade County needed
the land and that instead of spending a hundred thousanj:
dollars an acre, that they would spend in this case
thirty thousand dollars an acre. So, this is not the
fact of the case either, because a hundred thousand
dollars an acre property is not under consideration.
The property in Western Dade County is considerably
less than the $30,000 an acre figure, which the County
is paying, so it would have been much simpler as far as
the economics are concerned and much better to go to th
western part of the county.
WOR LEY & ASSOCIATES
Court Reporters
62 First National Bank Building 426
DECATUR, GEORGIA 30030
(404) 378-6239
-------
i j. Moffat
2
3
But* instead of that, the arrangement was
made to go into interama, admittedly to favor or
4
benefit the interama Authority* or at least the
5
interama Authority benefited to that extent of several
6
million dollars.
7
Final point* The gentleman spoke here with
8
respect to the contamination of the water off of
9
Miami Beach, and along the Miami Beach shore. I don't
10
know if he has witnessed the floatable s that accuau-
11
late on the beach at Miami Beach* but I can guarantee
12
you one thing, they are not going to show pictures of
13
those floatables that are washed up on the beach for
14
publication.
15
Thank you very much, gentlemen. X appreciate
16
your great work that you are doing.
17
MR, BRIGGSI Appreciate your interest* Mr*
18
Moffat* and the interest of all of the other people
19
who have cone today.
20
At this time* I would like to ask if there
21
are any other persons who wish to register and
22
speak.
23
24
25 :
WOR LEY & ASSOCIATES
Court Reporters
62 First National Bank Building
DECATUR, GEORGIA 30030
(404) 378-6239
-------
B. Gissendanner
2
DR. ELTON GISSEHDAHHER, CHAIRMAN
3
STATE OP FLORIDA INTER-ARERICAH CSBTfiR AUTHORITY
4
MIAMI. FLORIDA
5
DR. GISSEHDANNBRt Mr. Chairman. I hate to
burden the record, but I think Mr. Moffat pretty well
confirms what I said, it is all political situation,
he offers no alternatives, eost estimates for his
Tri-County or Everglades system that he proposes. They
11 have never done it.
- The County has looked into it. it is
13 terribly expensive to do what they proposed to do.
14 They have not asked the people or asked the people
15 if they would pay,number one, or told them what it
would cost*
n These same people he proposes to represent,
is they won't even build a collection system in their
19 city. I doubt if they will want to pay for this type
20 system.
21 Z think that ought to be clarified, and say
22 that we did say, save oade county several million
23 dollars. I think that i« important at this point. We
24 do know what th« system as proposed will cost, we do
25 not know what the other on* will eost.
WORLEY & ASSOCIATES
Court Reportert
62 First National Bank Building
DECATUR, GEORGIA 30030
(404) 378-6239
-------
R. Ferguson
MR. BRIGGSi Thank you. Doctor.
3
Any other persons who wish to be heard at
4
this time?
Since you haven't registered, I wish you
would indicate your name in the other podium so the
court reporter can get your name.
RANDOLPH FERGUSON
POLITICAL SCIENTIST STUDENT
FLORIDA INTERNATIONAL UNIVERSITY
MIAMI, FLORIDA
MR. FERGUSONt Yes. My name is Randolph
14
Ferguson. I am a student, political scientist student
15
from Florida international University, studying public
16
policy.
17
I would like to call the attention of the
18
Committee to the book "Florida's Environmental
19
Problems, Close to Crisis" published by the New Florida
20
Press in 1972, and in it, this gentleman took a bunch
21
of bottles with names in it and dumped it at one of
22
the outfalls, and what he found was that these bottles
23
floated right back onto the beaches from Fort
24
Lauderdale north. So, this is in reference to the
25
WOR LEY & ASSOCIATES
Court Reporters
62 First National Bank Building A9Q
DECATUR, GEORGIA 30030
(4O4) 378-6239
-------
101
R. Ferguson
gentleman that wanted to continue using the outfalls
as they are now used.
And, then, a couple of weeks ago, in a
conversation with one of the Commissioners, there comes
a question to mind of storm drains and possible effects
of having storm waters coming into the sewage col-
lection system, and with the Commissioner that I talked
to, was — is at Miami Beach International Airport,
they are developing a system to skim oil off of the
water of the canal. And my question is, what possible
effects have been studied from storm waters running
into the sewage collection systems and possibly how
about let's — having separate lines laid as we lay
sewer lines down at the present time, so we can
separate these waters and skim the oil off these
waters and right away return these waters back to the
aquifer.
Now, you do list in your Impact statement
the amount of runoff into the ocean. So, it is con-
ceivable then at the same time, we are discussing
collection of sev.'oge, we can also collect these waters
plus minimize the loss of these waters.
And, then, lastly, through my research, I
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 430
DECATUR, GEORGIA 30030
(404) 378-6239
-------
i R. Ferguson
2
have encountered the fact that Cocoa Beach and St.
3
Petersburg at the present time use a form of treatment,
4
rather secondary treatment, and then they take the
5
effluent that is left over and they use it for irri-
6
gation purposes, in one place the golf course and in
7
another place for farm land.
8
And my question is: Possibly, can this be
9
used to be -- the water used for irrigation of the
10
farm lands of West Dade? The advantage that St.
11
Petersburg and Coca Beach claim is that they have this
12
effluent that has a lot of nutrients remaining in it,
13
and it substitutes as a form of fertilizer.
14
So, here again, we have something that
15
necessitates further study.
16
MR. BRI6GS: Mr. Ferguson, would you indicate
17
where your voting residence is for the record?
18
MR. FERGUSON: Yes, sir, it is in the City
19
of Miami.
20
You want my street address?
MR. BRIGGS: Yes.
22
MR. FERGUSON: 864 Northwest 14th Court.
23
MR. BRIGGS: Okay. Thank you.
24
Are there any other persons who wish to
25
WOR LEY & ASSOCIATES
Court Reporters
62 First National Bank Building 431
DECATUR, GEORGIA 30030
tAnA\ T7R.ROTQ
-------
103
O. Briggs
register and speak before the hearing today?
If there are no other persons who wish to
speak before the panel today on the Draft Environmental
Impact Statements for North, Central and South Dade
County, this hearing is concluded.
(Whereupon, at 10|45 o'clock, A.M.,
the hearing was concluded.)
WOR LEY & ASSOCIATES
Court Reporters
62 First National Bank Building 432
DECATUR, GEORGIA 30030
(404) 378-6239
-------
2
3 REPORTER'S CERTIFICATE
4 GEORGIA)
5 DEKAI*B COUNTY )
6
x, HOWARD E. WORLEY, Certified shorthand
Reporter, do hereby certify that the within
and foregoing matter was heard as set forth
10 in the caption page thereof9 that X was
11 authorized and did report stenographically
12 the proceedings of said hearing* and after-
is wards had same reduced to writing under my
supervision, and that the foregoing pages
15 number 1 to 103, inclusive, comprise a
i6 true and complete transcription of my
IT stenographic notes taken at said time and
is place.
xn testimony whereof, X have hereunto
20 affixed my signature at my office in Decatur,
21 Georgia, this *2^^i.day of Hay, 1973*
22
23 Howard E. worley
Certified shorthand Reporter
24
25
WORLEY & ASSOCIATES
Court Reporters
62 First National Bank Building 433
DECATUR, GEORGIA 30030
(404) 378-6239
-------
The Greater Miami Chamber of Commerce
120O BISCAYNE BOULEVARD. MIAMI. FLORIDA 33132. <3O5> 377-4711
May 24, 1973
RICHARD BRUSUELAS
DIRECTOR OF ENVIRONMENTAL
HEALTH PLANNING
Mr. Sheppard N. Moore
Chief, EIS Staff
1421 Peachtree Street, NE
Atlanta, Georgia 30309
Dear Mr. Moore:
RE:
Addendum to Chamber's Position Taken
at May 15 EPA Hearing on Dade County's
Interim Water Quality Management Plan.
In further review of the draft Environmental Impact statements we would like to address
the following points and include them in the record as part of our presentation.
In our concern for North Dade we again would like to question the feasibility of building
IaGJ.iJ.Ll6t> ill StayBa wi 4G iiiix.Liuii yQj.j.OnS pST w
Sy"
lion gallon per day unit is completed it would be at capacity and the North part of Dade
County will again be faced with the dilemma of building moratoriums or making variances
for package treatment plants, septic tanks or other modes of treatment until the second
unit can be completed. Good community planning in North Dade will depend on the
completion of a total package, giving us 80 million gallons per day capacity. Therefore,
we feel that it is imperative that we construct an initial 80 million gallon per day sewage
treatment facility.
In light of the fact that there will be a Bi-centennial Celebration at the Interama site, we
would hope that all construction will be completed before the exposition opens.
We are further concerned with the operation of deep well injection systems because of the
energy or power requirements which are considerably higher ac compared to ocean outfalls.
In light of South Florida's electrical dorr.end:; and nation vide fuel shortage;; it v/ould rrccrn
the best and least environmentally damaging approach to use ocean outfalls.
Because of our interest in the total environmental health of Dade County, we would like to
request a consideration of the impact of disinfection procedures which would be required
of all our ocean outfalls. We understand that large quantities of chlorine will be required
to mept nronosfirt FPA standards for disinfection. Our auestions are in two narts. 1)
what the impact of chlorine will be on the ocean ecosystems, and 2) what precautions will
be taken to avoid extremely hazardous situations involved in shipping and handling large
quantities of chlorine gas in a heavily urbanized area. Possibly, another ramification of
this question would be: can this chlorine, gas be provided and can we as a community cope
wun me uaiiara auu potenuai uanger to uumdii me poyeu uy me uduspoiLaLion auu uctnuiuiy
of large quantities of toxic and corrosive substances such as chlorine.
434
continued....
-------
Mr. Sheppard N. Moore
May 24, 1973
Page Two
Appreciate your handling these items mentioned above as an addendum to our presenta-
tion.
ery truly yours,
Richard Brusuelas
Director of Environmental
Health Planning
RB/omt
435
-------
NORTH MIAMI BEAOI PROPERTY OWNERS
ASSOCIATION
P. O. BOX 574
NORTH MIAMI BEACH, FLORIDA
May 25, 1973
oseph Fransmathes
f, Facilities Branch
ronsental Protection Agency
ton IV.
Peachtree Street, II, E.
jnta, Georgia, 30309.
re: North Dade County, Fl., Regional System
Meeting of May 1M-, 1973
Dade County CourLhouse
Kiaxoi, Fl.
Mr. Franzmathes,
The following is submitted in accordance with your request made to me at
above referenced ace ting, for additional information regarding five items:
,1. A law suit is presently pending before the Florida State Supreme Court,
'''i-l, against the procedures of Metropolitan Dade County regarding the
.Dado wVtor ~u=ilit-v I'l&iicigc^cnt- Plan — "Petition for writ of Certiorari"c
2. The competent authority refered to is Dr. John R. Sheaf fer, Chief En-
Hental Expert to the United States Secretary of Defense.
3» The iii^ineering Authority quoted can not be named as it would violate
p Code or Jbthics because theyhave not been retained in an official capacity,
^ County Commissioner Edward Stephenson has stated there are tracts of
Up to 600 acres available for the uses in question, in far wertern Dade
£1 .at prices considerably less than the Inter cue. costs.
? TV. T? n* f~*-^A^^-nr>.-n r.^^* -*-->-~A ,-.4- ^-t~~ ^i^cvc rc^crc—cci .
r factor in the decision to locate the subjoct plant c.t the Inter ana. site
the Interama Authority's need for funds. Ke further stated at it was a
*££ to D^d-"1 Q^V--*--^ -t-~ buy tiro Iirtci\"..i iu. acrG£.£C Tor sr"3 ' , CCO per c cro as
* -L " *^ J mi . ~ . . r . - - , , n
r*C"T f*\ 4* M *^ ^** M ** «wk fa. r*. r+ f~* *^ •£- * " *1 ^ (~\ /*^ f^ ^^ ^- <^ -r> »^ '"I ~"» •" ' I **'>•- •-. '^ — ,_-l-,^,-,,^-.-.-»- -»- ~n >--» ^-i-1- ,*••» -*- ^ ^-» fH
1 • . • ^^ "^ i1 " 1^ ^* "^ >r1p' t I I • 1 r. ^ ^.» —• >• -—*_ k-l t-< V^ i_. W *^A_* V^ -.- W . . ^_ _i._t. — J. W W^ I-/ V>Oh^-<-^i.
|iny because suitable "acreage is available at considerable less cost, as
*> J- - .1 J. „ T ._ _ ^ ) ,
''
. ^ , .
Attached is abrief outline of a plan which we believe will imch sore
J1 itself to thn vnrr)n.re.r-cntn of the fn.tiire, p^.ci ^-o ^'^ich v:c recp
pst your attention.
i| 159CO K. -_. 13 avenue
,1 i-o. r.xa/ni iiaacu, i-l. 331^2
-------
NORTH MIAMI BEACH PROPERTY OWNERS
ASSOCIATION
P. O. BOX 574
NORTH MIAMI BEACH, FLORIDA
STATEMENT -AGAINST REGIONAL SEYffiR PLANT AT INTERAMA
Dr. John R. Sheaffer, Chief Environmental Expert for the ..United States Array
said that the solution of tho problem of Southeast Florida, waste water treat*
t can best be handled on a Tri-County basis. To that end we submit the folio1
proposal to the Environmai-tal Protection Agency, Region IV, Atlanta office.
That.the North Dade Regional Waste Uater Treatment Plant be located in far
tern North Dade County ai.d chc effluent which has been treated, be puaped to
proposd new ocean outfall line? for the following reasons:
This would;
(1) Eliiiinate the cost of the sludge pipeline which is proposed to
ce the sludge from the Interaaa site to the N. W. land-fill site,
(2) Avoid piping untreated sewage from the cities of Hialeah, Opa
:a? Carol City and other Northwest Dade areas, across all of North Dade Count;
;\Y preventing possible contamination by untreated sewage due to transuissio;
failure,
Place the Sewer Plant in the best location when, in 8 to 10 ye
"state of the art" v/ill permit recycling to replenish the fresh water supply
e 8 to 10 year period is the statement of the Dade County iiigineers»)
(5) Be supported by engineering cost study placing the temporary
t at an extra cost not to exceed 2C£ per unit per south, until recycling is
cticale After that tine, instead of costing additional funds there will be a
thly savings of funds for the life of the plant arid the equipeaent. This stud;
now in. the planning stage.
ntually acted upon, the far western North Dade Coiuity location will be in the
t possible location and the Interaina site would be the worst possible locatio
Ifaf&USs toen,j £c.n . U
437
-------
/'**<'
POST OFFICE DRAWER 429
HOMESTEAD. FLORIDA 33O3O
May 25, 1973
Mr. Sheppard N. Moore
Chief, EIS Staff
1421 Peachtree Street, N.E.
Atlanta, Georgia 30309
Re: Environmental Impact Statement,
Dade County, Florida
Dear Mr. Moore:
In connection with the hearing held in the County Commission
Chambers, Dade County Courthouse, Miami, Florida, on Monday,
May 14, 1973, I am. enclosing a letter received from Mr. A. F.
Bartsch, Director, National Environmental Research Center,
Corvallis, Oregon, relative to the City of Homestead's
application for EPA Grant #800630, "Project Boulder Zone".
Inadvertently I advised those present for the meeting,
had signed the letvar when in reality
Mr. Bartsch signed it. Mr. Rainwater had attended the two
meetings in Homestead, referred to in the second paragraph
of the letter. We were offered approximately $165,000 for
a project costing around $600,000. Unfortunately, unless we
were able to test the advisability of using the sewage effluent
in fh i q research, alonn with the fresh water return from the
electric o'lant, the city could -not come up with the additional
$500,000, despite our many efforts.
I would annreciate it verv much if von would
in the recorded minutes of that meeting.
make the chanae
S i nee re I y yours,
(,''i r s . ; K i o r i e n e c.. Toller
Federal Grants Coordinator
ft
Enc. (!)
438
-------
7 ? UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
^ NATIONAL ENVIRONMENTAL RESEARCH CENTER
: rno»*-
200 S.W. 35TH ST.
CORVALLIS. OREGON 97330
April 27, 1973
Mr. 01 af R. Pearson
City Manager
P. 0. Box 429
Homestead, FL 33030
Dear Mr. Pearson:
This is in connection with the City of Homestead's application
for EPA Grant #800630, "Project Boulder Zone."
In light of the fact that two meetings among you, the City's
consultants, and representatives of EPA and other interested federal
and state agencies (August 14, 1972 and November 3, .1972) were
unsuccessful in developing a revised proposal in line with provisions
stipulated in Dr. Greenfield's July 10, 1972, letter to you, we
conclude that there is no hope of keeping the proposal alive this
fiscal year. Consequently, to clear the records, I must declare
the original proposal rejected.
I regret that my action cannot be more positive. We had looked
forward to developing a mutually beneficial cooperative project with
the City of Homestead.
Sincerely yours,
A. F. Bartsch
Director
439
-------
MIAMI-DADE WATER AND SEWER AUTHORITY
P. C 10X316 MomOffic.
3575 S. LeJeunv Road
MIAMI, FLORIDA 33133 Telephone 66S.7471
Jur.e 1, 1973
Mr. Sheppard Moore
Chief, E.I.S. Staff
U. S. Environmental Protection Agency
1421 Peachtree Street, N. E.
Atlanta, Georgia 30309
Re: Environmental Impact Statement
for the North Regional Wastewater
Treatment Plant in Dade County,
Florida
Dear Mr. Moore:
The views and comments of the Miami-Dade Water and Sewer
Authority on the Environmental Impact Statements for Wastewater
Treatment Plants for Dade County are contained in a letter dated
May 11, iy/3, addressed to Mr. JacK Ravan, and were presented
at a public hearing held in the Dade County Courthouse on May
14, 1973.
At the conclusion of the presentation, Mr. Franzmathes
requested that the recommendation to construct an initial
60 MGD wastewater treatment plant for the North District,
instead of the 40 MGD plant proposed in the draft E.I.S.,
be supported by additional information. The Water Quality
Management Plan approved for Dade County states, in Table
11-2. that an RO MGD plant should be completed by 1975, and
in Figure 11-8 "Flow Curves" indicates the flow in the North
District to be 60 MGD in 1975.
The actual tabulated rlow to i:he Noriih Daue ocean out-
fall during December, 1972, averaged 26.9 MGD. The present
flows from currently operating municipal and privately
operated package plants, which are to be diverted to the
regional pla.nt as so^n as it is completed, amount to 14.2
MGD (this" figure obtained, .from Dade County Pollution Control
440
-------
Mr. Sheppard Moore
June 1, 1973
Page Two
anticipated flow from building permits issued prior to January
1, 1973, is about 3.0 MGD0 These figures total 44.1 MGD, to
which should be added the flow to be expected from normal
population increase during the period of plant construction
and the sewering of areas presently on septic tanks. Thid
additional flow would average at least 100 MGD per year, or
4.0 MGD by 1977.
The above facts and conservative estimates indicate that
a 40 MGD plant would be overloaded by the time it could be
built, which is the reason why the recommendation was made
that the initial construction in North Dade should be at
least 60 MGD capacity,,
If you need additional information, please call/me.
Very truly yours. /
• - , / / '
'- < > L
x .-: ^ /
Garrett Sloan
Director
GS/ft
cc: Mr. Colin Morrissey. Director
Dade County Pollution Control Department
441
-------
NOTICE OF PUBLIC HEARING
You are hereby notified that a public hearing will be held
at 9 a.m. on May 14, 1973 at the County Commission Chambers, Dade
County Courthouse, Second Floor, 73 West Flagler Street, Miami,
Florida. This will be a public hearing to present and receive
comments on the Draft Environmental Impact Statements on North,
South, and Central Dade County, Florida. The hearing is being
conducted by the
N.
U.S. Environmental Protection Agency
K Region IV
1421 Peachtree Street, NE
Atlanta, Georgia 30309
Telephone: 404/526-5415
The hearing will be called to order at 9 a.m. and will continue
until those persons who have registered to speak have been heard.
A registration desk will be set up at the hearing room and any
person who wishes to present a statement shall be required to
personally enter his name in the registration book provided for that
purpose. Persons may begin to register at 8 a.m. All persons will
be called to speak in the order in which they have been registered.
Anyone may present data, make a statement, or offer a viewpoint
or argument either orally or in writing. Lengthy statements con-
taining considerable technical or economic data shall be submitted
in writing for the official record. Oral statements should be concise
to permit everyone an opportunity to be heard. Hearing participants
will not be subject to questioning from the audience but may be
442
-------
questioned by the hearing officer for clarification of technical
points or to develop better understanding of statements. The
hearing will be recorded and transcribed by an official court
reporter, and the record of the hearing will be included in the
Final EIS. Statements, supplements to statements, or briefs, may
be submitted within 15 calendar days following the date of the
hearing. Such information should be mailed to
Sheppard N. Moore
Chief, EIS Staff
U.S. Environmental Protection Agency
1421 Peachtree Street, NE
Atlanta, Georgia 30309
The Draft EIS shall serve as an outline for discussion. Copies
of this draft and the application for grant are also available for
inspection at the following locations during usual office hours.
Atlanta, Georgia Environmental Protection Agency
Region IV
Room 505 - 1421 Peachtree Street, NE
Atlanta, Georgia (Phone: 404/526-5415)
Dade County, Florida
Miami Dade County Courthouse
Office of the County Manager
Mr. R. Ray Goode
911 Courthouse
73 West Flager Street
Miami, Florida (Phone: 305/377-5311)
Miami-Dade Public Library System
One Biscayne Boulevard
Miami, Florida (Phone: 305/358-3801)
Homestead City Hall
Office of the Mayor
Mr. W. F. Dickinson
43 North Krome Avenue
Homestead, Florida (Phone: 305/247-1801)
443
-------
APPENDIX IX
Projected Population Trends
North Bade County
445
-------
The North Dade District is one of three immediate service
areas proposed in the Miami-Dade County Interim Water Quality
Management Flan. The initial phase of this district has a northern
boundary marked by the Dade County-Broward County line. The
western and southern boundaries include U.S. Highway 27 and
Okeechobee Road to N.W. 42 Avenue, easterly along N.W. 79 Street
to the bay and up to an area slightly north of Bal Harbour.
Analyzing and projecting demand in the North Dade Service
Area can be accomplished in part, by utilizing population data as
a measure of the domestic contribution to the total volume of
wastewater flows. As part of facilities planning requirements,
the U.S. Environmental Protection Agency uses areawide population
projections in order to determine the reasonableness of proposed
transmission and treatment capacities in terms of the domestic
flows. These projections estimate that Dade County will have a
1970 peak or seasonal high population of 1,440,492 residents and
will increase to 2*441,100 residents by the year 2000, or a 71%
increase over a 30-year period. A summary in ten-year intervals
of population increases projected for Dade County is presented
below:
446
-------
Table I
Projected Bade County Population
1970-2000
1970 1980 1990 2000
Permanent
Residents3 1,267,792 1,516,000 1,866,700 2,246,100
Occasional Residents^
Tourists 172.700 188,700 195,100 195,000
Totals0 1,440,492 1,704,700 2,061,800 2,441,100
Permanent residents include that portion of the population which
claim year round residence in Dade County.
^Occasional residents and tourists may maintain households but indicate
permanent residence elsewhere.
°The combined permanent and occasional tourists residents represent
a peak or seasonal high population total.
From data in Table 1 it can be determined that the Dade
County peak population consists of a transient or seasonal population
fluctuation of approximately 13 percent in the base year 1970, with
8 percent projected by the jear 2000. This is an average annual
fluctuation rate of approximately 10 percent for the total 30-year period.
On the basis of land uses described in the Dade County land use plan,
most of the seasonal fluctuations can be expected to concentrate in
coastal locations where the supply of tourist accomodations is pro-
portionately greater than the supply in inland areas.
Population projections for the North Dade District, as discussed
earlier, were constrained by the EPA countywide control total.
447
-------
Population in this district is estimated to increase from a 1970
seasonal high population of 457,717 to 678,000 seasonal high
residents in 1990. This is a 48 percent increase for the 20-year
1970-1990 period. A summary of these population trends in five-
year intervals is presented in Table 2<
Table 2
Projected North District Population
1970-1990
1970 1975C 1980 1985^ 1990
Permanent
Residents3 415,717 452,000 505,000 552,000 598,000
Occasional*1
Residents/Tourist
42.000 45.000 51.000 55.000 60.000
Total 457,717 497,000 556,000 607,000 678,000
aPermanent residents were derived by totalling census counts for tracts
included in the North District. Census projections were provided by the
Miami-Dade County Planning Department.
^Occasional residents and tourist estimates assume that seasonal
fluctuation rate for the North District is the same as the Dade County
annual average,rate of 10% of the permanent resident population.
C1975 and 1985 permanent resident projections derived by linear inter-
polation of 1970, 1980, and 1990 growth trend projections.
Available land use and population data indicate that areas of
concentrated demand exist in, or near, incorporated municipalities.
Below, in Table 3, is a tabular summary of population trends for
incorporated areas in the North District and estimates of the seasonal
high populations to the year 2000:
448
-------
Table 3
Incorporated Municipalities Population
North Bade District
1970-2000
1970
1980
1990
2000
Biscayne Park
El Portal
Golden Beach
Hialeah
Hialeah Gardens
Islandia
Miami Shores
North Bay
North Miami
N,orth Miami Beach
OpaLocka
Subtotal3
Seasonal high
Total0
2717
2068
852
101,728
492
8
9425
4831
34768
30833
12505
200227
20000
3200
1900
2500
120,000
1000
0
8800
5600
39800
41800
15200
239800
24000
3300
1900
3100
125,500
1500
0
8700
5100
37200
48900
17000
252200
25000
3600
1900
3300
133,000
2500
0
8800
5500
45500
54300
17900
276300
28000
220227
263800
277200
304300
Subtotal figures for municipalities are provisional estimates by the Miami-
Bade County Planning Department.
Seasonal high totals were derived by assuming an annual 10% occasional
residents/tourist rate for the North Bistrict. Totals are to the nearest
1000.
CTotal of permanent and seasonal fluctuation estimates represent the
seasonal high population for the municipalities.
Future distributions in the domestic demand for the North Bade
District can be generally assessed by comparing projections for incorporated
areas with those of the unincorporated areas. Table 4 presents population
data for this comparison.
449
-------
Table 4
North Bade District Population
Incorporated and Unincorporated Areas
1970-1990
1970 1975a 1980 1985a 1990
Incorporated
Areasb 220227 241000 263800 270000 277200
Unincorporated
Areasc 237690 256000 292200 337000 400800
Totals 457717 497000 556000 607000 678000
a!975 and 85 figures derived by linear interpolation of previous
year trend
bDerived from Table 3 .
°Derived by subtracting seasonal high estimates Table 2' from estimated
totals in Table 3.
In summary, population in the initial phase of the North Dade
District has been projected to increase from an estimated seasonal
high of 457,717 residents in 1970 to an estimated seasonal high of
678,000 residents in 1990. This will represent approximately a
52 percent increase in the domestic demand by 1990 from the base
year, 1970. As indicated in Table 4, existing concentrations in
incorporated areas (also Table 3) will increase approximately 25
percent by 1990, or 57,000 residents over the 1970 seasonal high
population of 220,227 residents. Growth in unincorporated areas will
increase at approximately a 67 percent rate by 1990 from the base
450
-------
year 1970 (Table 4), or from 237,690 seasonal high residents in
1970, to 400,800 seasonal high residents by 1990. Population
projections, as noted earlier, can be utilized as a means of estimat-
ing domestic portions of the total wastewater flows anticipated in
a transmission and treatment system. Population trends with respect
to this use are presented below:
Table 5
Seasonal High Incorporated Unincorporated
Year Residents Area Residents Area Residents
1970 457,717 220,227 237,690
1975 497,000 241,000 256,000
1980 556,000 263,800 292,200
1985 607,000 270,000 337,000
1990 678,000 277,200 400,800
Table 5 specifies Seasonal High Residents in five-year
intervals. These figures should be utilized to estimate domestic
flow volumes. Table 5 also presents data which are suggestive of
concentrated demand in the incorporated areas.
451
*U.S. G.P.O. ; 1973—748-254/3283, Region No. 4
------- |