FINAL
ENVIRONMENTAL  IMPACT  STATEMENT
       NORTH  DADE  COUNTY
             FLORIDA
              CI20375
              (g&j
        ENVIRONMENTAL PROTECTION AGENCY
               MK«ION IV
            1421 PEACHTHCC (TNirT. N. E
             ATLANTA, OCOKOIA

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 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

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                           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

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                                                                 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

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                                                             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

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                               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

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                              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

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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

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                  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.

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     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

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 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

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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

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     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.

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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.

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     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.

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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

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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

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                                                                       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)

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                                                                      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

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Figure 1
  PROPOSED NORTH DADE
WASTEWATER MANAGEMENT

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                         Figure 2
GREELEY AND HANSEN
CONNELL ASSOCIATES
     ENGINEERS
13
    DADE COUNTY, FLORIDA

WASTEWATER  COLLECTION
       ZONE  MAP

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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

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     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

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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

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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

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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

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     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).

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     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

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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

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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

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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

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                                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

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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

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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

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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

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                            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

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                            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

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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

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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

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                         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

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     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

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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

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                                                              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

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         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

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                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

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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

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      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

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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

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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

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 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

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     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

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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

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                           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

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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

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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

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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

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     • 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

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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

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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

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        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

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     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

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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

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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

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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

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     •  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

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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

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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

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         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
-------
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

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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

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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

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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

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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

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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

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     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

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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

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                                                                                                              EXISTJNG

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                        NORTH MIAMI

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                                                  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

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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

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      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

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     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.

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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

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     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

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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

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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

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     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

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         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

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       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

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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.

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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

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                               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

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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

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  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

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      •  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

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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

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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

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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

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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

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         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

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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

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                                                  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

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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

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'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

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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

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     - 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

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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

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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

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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.
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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

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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.





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     •  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

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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

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                                      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.

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                                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.

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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.

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                                   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.

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                          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.

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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




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     •  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

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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

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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.
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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

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     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

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 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

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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
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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.
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     «  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
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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:
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    •  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

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    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

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     •  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

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     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

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     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

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                                      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

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        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

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        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

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   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

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•  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

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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

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     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

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•  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

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     •  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

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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

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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

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                               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

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    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

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                                                                         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.

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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

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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.

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                              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

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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

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     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.
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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

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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

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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.
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      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

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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

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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

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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

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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.

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      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.
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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

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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

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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

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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

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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.
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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

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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

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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.
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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

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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

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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

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.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

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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

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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?


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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.
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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.
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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
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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
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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.
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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
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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.


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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
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 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.
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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.
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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
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 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.
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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.
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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.
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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.
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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
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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
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     (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
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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

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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

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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

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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

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     (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

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      (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

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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

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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

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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

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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

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     (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

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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

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     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

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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

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                            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

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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

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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

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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

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APPENDICES
    207

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          APPENDIX I







Summary Analysis of OCEAN OUTFALLS AND




OTHER METHODS OF TREATED WASTEWATER DISPOSAL




IN SOUTHEAST FLORIDA
              208

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                             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

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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

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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

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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

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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

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     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

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     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

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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

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     «   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

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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

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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

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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  •/

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     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

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     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

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                 APPENDIX II
ADMINISTRATOR'S DECISION STATEMENT NO. 5
  EPA POLICY ON SUBSURFACE EMPLACEMENT OF
          FLUIDS BY TOLL INJECTION
                      223

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       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

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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

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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

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    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

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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

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     (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

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     (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

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          (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

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                          APPENDIX III
865.06  PRESERVATION OF WILD TREES, SHRUBS AND PLANTS;  PENALTY
                             232

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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

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(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

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               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

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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

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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

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         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

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  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«

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        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

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                   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

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                 - 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

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                   -  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

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                   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

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          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

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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

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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

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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

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                                                     (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

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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

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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

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        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

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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

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                            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

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               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

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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

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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

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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

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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

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 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

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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

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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

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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

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                             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....

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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

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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

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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

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   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

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                                                                   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

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 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

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                           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

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                      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

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 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

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                                                        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

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                                                         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

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                                                           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

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                        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

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 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

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	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

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 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

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	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

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   ^___	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

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                                                          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

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                             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

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                        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

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 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

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 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

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 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

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 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

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                                                          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
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                          62 Fir«t National Bank Building
                          DECATUR, GEORGIA 30030
                             (404) 378-6239

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 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
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                                                          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
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                            (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


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                          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
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-------
 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
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                                                     -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
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-------
 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


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                             Court Reporters
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                             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
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                                               _   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


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-------
                       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
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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
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    	                                              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
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-------
 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
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-------
 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
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-------
                             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
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-------
                                                           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

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                            	     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


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    	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

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                         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
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                      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.
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                   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
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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


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 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


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    	                       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

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 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

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 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
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                          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
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                                                           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


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 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


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                                                   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
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 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
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                                                  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 •-
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                       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
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                                                    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
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 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

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                                                   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
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                        (404) 378-6239

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 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
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                       £. 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
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                         £.  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?
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                                                     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
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  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
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            	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

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 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 :
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                           	    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.
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 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
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                                                           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
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 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,
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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
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                        DECATUR, GEORGIA 30030
                            (404) 378-6239

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 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
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 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
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 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

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           	^^       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
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                             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

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   ______	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

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                    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

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               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

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                  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

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                                                         /'**<'
   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

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   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

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               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

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                    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

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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

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         APPENDIX IX
Projected Population Trends
    North Bade County
              445

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     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

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                             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

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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

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                                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

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                           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

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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

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