United States     Region 4      EPA 904/9-81-085
        Environmental Protection 345 Courtland Street NE October 1981
        Agency	Atlanta, Ga. 30365	


4>EPA  Environmental   Final

        Impact Statement
        Farmland Industries Inc.
        Phosphate  Mine
        Hardee County, Florida

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 I  UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
 /
                         REGION IV
                     349 COURTLAND STREET
                     ATLANTA. GEORGIA 3O3CS
                     October 15,  1981
REF: 4SA-EIS

TO:  ALL  INTERESTED GOVERNMENTAL  AGENCIES,  PUBLIC GROUPS,  AND
     CONCERNED INDIVIDUALS

The  Final  Environmental   Impact   Statement   for   the   Farmland
Industries,  Inc.  Phosphate  Mine  is  enclosed  for  your  review.
This document has  been  prepared  pursuant  to Section  102(2)(c)
of  the National  Environmental  Policy  Act   (NEPA)  (Public  Law
91-190) and applicable  EPA regulations at 40  CFR Part  6.9.   The
Final  EIS may be reviewed at the following  locations:

     Lakeland Public Library,  Lakeland,  Florida
     Bartow Public  Library, Bartow, Florida
     Ausley Memorial Library,  Wauchula,  Florida
     DeSoto County  Public Library,  Arcadia, Florida
     Selby Public Library,  Sarasota,  Florida
     Manatee County Library System, Bradenton,  Florida
     Tampa-Hillsborough County Public Library,
         Tampa, Florida

EPA has  not reprinted  in  the Final  EIS the  material  contained
in the Draft  EIS, which was made available to the  public  in  May
1981.   Both  documents   should   be  retained  for  a   complete
evaluation of the project.

Comments on the Final EIS may  be submitted in writing to:

             Ms. A. Jean Tolraan, EIS  Project  Officer
             Environmental  Protection Agency,  Region IV
             345 Courtland Street, N.E.
             Atlanta, Georgia  30365

The comment period will end November  23, 1981.

Sincerely yours.
Charles R. Jeter
Regional Administrator

Enclosure:  FEIS

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               FINAL ENVIRONMENTAL IMPACT STATEMENT

                               for

            Proposed Issuance  of  a New Source  National
          Pollutant Discharge Elimination System Permit

                               to

                Farmland Industries,  Incorporated
                          Phosphate Mine
                      Hardee County, Florida

                           prepared by:

               U.S.  Environmental Protection Agency
                Region IV,  Atlanta, Georgia  30365

                       cooperating agency:

                   U.S.  Army Corps of Engineers
                      Jacksonville District
                   Jacksonville,  Florida  32201


Farmland  Industries,  Inc. has  proposed  an open  pit phosphate
mine  and  beneficiation  plant  on  a  7810-acre   site   in  west
central  Hardee County,  Florida.   Mining  and processing  will
involve  5280  acres,  all  of  which  will be reclaimed,  and will
produce  2  million tons  of  phosphate  rock   per   year   for  20
years.   The EIS examines  alternatives,  impacts  and mitigative
measures  related   to  air,   geology,  radiation,  groundwater,
surface water, ecology and other natural and cultural systems.

       Comments will be received through November  23, 1981.

          Comments or inquiries  should be directed to:

               A.  Jean Tolman, EIS Project Officer
               U.S.  Environmental Protection Agency
                            Region IV
                    345  Courtland Street, N.E.
                     Atlanta,  Georgia   30365
                          (404) 881-7458
                           approved  by:
Charles R. Jeter                                Date
Regional Administrator

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                             Summary Sheet
                                  for
                    Environmental Impact Statement

                       Farmland Industries, Inc.

                            Phosphate Mine
( )  Draft
(X)  Final
            U.S. Environmental Protection Agency, Region IV
                      345 Courtland Street, N.E.
                        Atlanta, Georgia  30365
1.  Type of Action!  Administrative (X)  Legislative  ( )

2.  Description of Action:

     Farmland Industries, Inc. (Farmland) is proposing to construct and
operate a phosphate mine and beneficiation plant in Hardee County,
Florida (Figure 1).  The EPA Region IV Administrator has declared the
proposed facilities to be a new source as defined in Section 306 of the
Federal Clean Water Act.

     In compliance with its responsibility under the National Environ-
mental Policy Act  (NEPA) of 1969, EPA Region IV has determined that the
issuance of a new  source National Pollutant Discharge Elimination System
(NPDES) permit to Farmland for planned discharges from the proposed
mining and beneficiation facility would constitute a major Federal
action significantly affecting the quality of the human environment.
                                  -1-

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!
-
;
PROPERTY


   SOTO
        FIGURE 1.   FARMLAND  INDUSTRIES, INC. SITE LOCATION MAP.
       SOURCE: FARMLAND INDUSTRIES. INC., HARDEE COUNTY MASTER PLAN, JUNE 1979
                                                                                                  0       10       20

                                                                                                    SCALE IN MILES

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Therefore this Environmental Impact Statement has been prepared in
accordance with the requirements of NEPA and EPA regulations at 40 CFR
Part 6.

     Farmland's proposed mine operation is planned to produce 2 million
tons per year of wet phosphoric rock over the 20-year life of the mine.
Approximately 4951 acres of the 7800-acre site would be mined, with an
additional 329 to be occupied by other facilities such as the bene-
ficiation plant (Figure 2).  During the life of the mine, all of the
rock mined from the tract would be shipped to existing fertilizer plants
for conversion to finished fertilizer, with approximately 50 percent of
the tonnage going to Farmland's existing phosphate fertilizer manufac-
turing facility at Green Bay, Florida.  Farmland currently and histor-
ically has bought the phosphate rock processed at their Green Bay plant
from other producers.  Farmland states that the proposed mine is needed
to stabilize their phosphate rock supply.

     The initial phase of the proposed activity would be land clearing
and open burning in advance of the mine.  The cleared acreage in front
of the mining operation would be about 20 acres.  The mining operation
would employ a single large dragline supplemented, beginning in year 10,
by a second, smaller dragline.  The mined matrix would be slurried and
transported via pipeline to the beneficiation plant for washing to
separate pebble product, clay, and fines, and for flotation to recover
additional product.  The wet rock would be stored temporarily at the
plant.  Farmland plans to construct an 8000-foot long railroad spur,
linking the plant with the Seaboard Coast Line Railroad, and rail ship
the wet rock product to receiving phosphate fertilizer plants.

     The proposed waste sand and clay disposal plan would employ the
sand-clay mix technique.  Limited conventional disposal would be re-
quired to store these wastes until the sand-clay mix procedure becomes
operational and to periodically store waste generated in excess of the
sand-clay mix requirements and capabilities.  Conventional Settling Area
I (495 acres) would be constructed on unmined land and utilized during
                                  -3-

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FIGURE  2.  FARMLAND INDUSTRIES,  INC.  DRAGLINE MINING
             SEQUENCE FOR 20-YEAR  MINING PLAN.
_._._  PROPERTY IOUNDARY

CyE-2  OUT 'ARCEL (NOT FARMLAND PROPERTY)

BSZH  UNMINEAM.E AREA - ENVIRONMENTAL SENSITIVITY

II"' j  UNMINEAILE AREA - MINE PLANNING

  IT   YEAR MINED - DRAGLINE I

  :«;•   YEAR MINED - DRAGLINE 1
SOURCE: FARMLAND INDUSTRIES. INC., HARDEE COUNTY MASTER PLAN, JUNE 1979
                                                   -4-

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the first 5 years of mining, after which  time the  stored  clays would be
removed  (and used for sand-clay mix) and  the ground beneath would be
mined.   Settling Area II  (583 acres) would be used as early as year 2 of
operation and remain active for the life  of the mine.  Sand-clay mixing
could begin in the fourth year of mine operation and continue for the
mine life, ultimately creating 3915 acres of sand-clay mix areas, or 79
percent  of the total mined area.

     The proposed mining operation would  require water for matrix
transport and processing equivalent to a  flow rate of 50,000 gpm  (72
mgd).  The proposed water management plan incorporates extensive re-
cycling of process water to minimize water consumption.   The mine water
recirculation system, the clay settling areas, active sand-clay mix
areas, and return water ditches would act as a water clarification
system, returning decanted water to the clear water pond  for reuse at
the mine and beneficiation plant.  Recycle water would be reused many
times before being lost to the waste or phosphate  products as entrained
water.  Actual freshwater use would be about 8.83  mgd, most (6.02 mgd)
of which is required for the amine flotation section of the benefici-
ation plant.  The additional amount would be required for make-up to
replace water losses within the recirculating system.

     The proposed reclamation plan is based on the use of a waste sand-
                                 i
clay mix material as backfill over most of the mined area (3915 of the
5169 acres mined).  The proposed plan is designed  to return the site to
a land form and use compatible with the surrounding area, which is
primarily agricultural.  The reclaimed site (Figure 3) would consist
primarily of improved pasture, restored marshes, lakes, and areas
(totalling 2530 acres) to be preserved by Farmland (e.g., Oak Creek
Islands).  Following reclamation, the acreage of forested uplands,
freshwater marsh, improved pasture, and lakes would increase, while the
acreages of freshwater swamp, pine flatwoods-palmetto range, and citrus
would decrease.
                                  -5-

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 FIGURE  3.   POST RECLAMATION LAND USE ON  THE
             FARMLAND INDUSTRIES, INC. MINE  SITE.
     FRESHWATER SWAMP
     FRESHWATER MARSH
     PINE FLATWOODS/PALMETTO RANGE
     UPLAND FOREST
     IMPROVED PASTURE
     CITRUS
m  OTHER AGRICULTURE
E5~=g  REFORESTATION WITH MIXTURE
       OF PINES AND HARDWOODS
Mi  LAKE AREAS

             0     2,000   4,000

                 Z3
              SCALE IN FEET
SOURCE: FARMLAND INDUSTRIES, INC.. HARDEE COUNTY MASTER PLAN, JUNE 1979
                                             -6-

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 3.  Alternatives Considered:

     Farmland has developed an integrated plan for  the mining and
 processing of phosphate rock at their Hardee County mine.  This plan  is
 comprised of a number of individual components linked so as to provide a
 total project capable of meeting Farmland's goals.  The identifiable
 components included in the Farmland project are as  follows:

        • Mining
        • Matrix Transport
        • Matrix Processing
        • Waste Sand and Clay Disposal
        • Process Water Source
        • Water Management Plan
        • Reclamation

     The Draft EIS identified and evaluated various methods (i.e.,
 alternatives) available to satisfy the objectives of each of these
 components.  These are summarized below, and each alternative, including
 "no action", is briefly described in the succeeding paragraphs:
Component
Mining
Matrix Transport
Matrix Processing
Waste Sand and
 Clay Disposal
Objective
Remove overburden and
deliver matrix to a
transport system.
Transport matrix from the
mine to the beneficiation
plant.
Process the matrix to
separate the phosphate
rock product from the
waste sand and clay.
Dispose of the waste sand
and clay generated by
matrix processing.
Alternatives Considered
Dragline Mining*, Dredge
Mining, and Bucketwheel
Mining.
Slurry Matrix Transport*,
Conveyor Transport, and
Truck Transport.
Conventional Matrix Pro-
cessing* and Dry Matrix
Processing.

Sand-Clay Mixing* and
Conventional Sand and
Clay Disposal.
*Farmland's proposed action.
                                  —7—

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 Component
 Process Water
  Sources
Water Management
Reclamation
Objective
Provide a continuous
source of freshwater
(about 8.83 mgd) for use
in matrix processing and
as make-up for losses to
the recirculating system.
Provide a means to reduce
the amount of water in
the recirculating system.
Return the mined site to
useful productivity.
Alternatives Considered
Groundwater Withdrawal*
and Surface Water
Impoundment.
Discharge to Surface
Waters* and Use of
Connector Wells.
Farmland's Reclamation
Plan, Conventional Recla-
mation, and Natural Mine
Cut Reclamation.
Mining
     Mining of  the Farmland deposit would require  the removal  of  about
40  feat  (total) of overburden and phosphate matrix at a rate of about
250 acres per year, eventually resulting in the mining of 4951 acres of
the 7810-acre site over a planned 20-year mine life.  Over  this period
39 million short tons of phosphate rock and 174 million tons of over-
burden would be handled.  The alternative mining methods evaluated which
are capable of handling this quantity of material  were dragline mining,
dredge mining, and bucketwheel mining.

Dragline Mining.  Farmland proposes to use a single large (45-cu  yd)
dragline to move overburden and mine matrix during the first 9 years of
operation.  In year 10 a second smaller (20-cu yd) dragline would be
added to supplement the larger unit.  Other than the fact that Farmland
proposes to initially mine with only a single large dragline (rather
than two smaller units), the proposed mining method is as conventionally
practiced in the Florida phosphate industry.

Dredge Mining.  The three most common dredge types are the bucket line,
cutter head,  and bucketwheel.  Each is basically a large, barge-mounted
machine consisting of a continuous digging apparatus mounted on a long
boom extending below the water surface.  The bucket line's chain-carried
*Farmland's proposed action.
                                  —8—

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buckets continuously transfer material up  to  the barge, while  the other
two units pump material from beneath the water  to  the  surface  via a
suction pipe.

Bucketwheel Mining.  Bucketwheel excavators are large  continuous mining
machines which excavate material with a series of  buckets mounted on  the
periphery of a rotating wheel and deposit  it  onto  a conveyor belt
system.  Overburden would be conveyed for  disposal in  previously mined
areas, while matrix would be sent to the beneficiation plant.

Matr ix Transport
     Farmland's operating requirements call for the delivery of about
1500 short tons of phosphate matrix per hour  to the beneficiation plant.
The alternative delivery methods evaluated in the  DEIS were slurry
matrix transport, conveyor matrix transport,  and truck matrix  transport.

Slurry Matrix Transport.  Slurry matrix transport  is used at most
existing Florida phosphate mines.  Matrix would be placed into a slurry
pit and mixed with recycled water (17,720 gpm) from high pressure
nozzles, breaking down the clay and sand matrix into a 26 percent solids
slurry which would then be transported via pipeline to the beneficiation
plant by a series of large pumps operating at about 19,400 gpm.

Conveyor Matrix Transport.  Conveyor matrix transport would require that
matrix be placed onto a belt conveyor at the mine  for  transport to the
beneficiation plant.  In order to minimize the number  of transfer points
and still maintain mobility of the conveyor sections,  such a conveyor
belt system would most likely include belt sections of up to 2000 feet
in length.

Truck Matrix Transport.  A dragline would load the trucks, which would
then transport the matrix via haul roads to the beneficiation plant.  At
the plant matrix would be dumped and/or washed out of  the trucks.
                                  -9-

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Matrix Processing
     Matrix from the Farmland  site  contains waste  sand  and  clay  as well
as phosphate rock.  The waste  sand  and  clay must be  separated  from the
product phosphate rock before  it  can be  shipped to the  chemical  plants
for further processing.  For each ton of product,  1.08  tons  (dry) of
clay and 2.82 tons  (dry) of sand would be produced.  The alternative
processing methods evaluated in the DEIS were conventional matrix
processing and dry matrix processing.

Conventional Matrix Processing.  Conventional matrix processing  involves
the separation of phosphate rock from waste sand and clay using  a series
of wet-process operations.  These consist of washing, feed preparation,
and flotation.  This is the only method of matrix processing in  oper-
ation in the Florida phosphate industry today.

Dry Matrix Processing.  The general concept of dry processing  involves
the production of usable phosphate product from matrix—directly fol-
lowing its excavation and drying.  The method utilized would probably
involve both air separation and electrostatic separation.

Waste Sand and Clay Disposal
     As indicated above, 2.82 tons  (dry) of waste sand and 2.08  tons
(dry) of waste clay would be generated for each ton of phosphate rock
product produced.  With some 40 million tons of product to be produced
over the 20-year life of the mine, 156 million tons of waste sand and
clay would be generated (112.8 million tons of sand and 43.2 million
tons of clay).  Alternative methods of waste sand and clay disposal
evaluated in the DEIS were sand-clay mixing and conventional sand and
clay disposal.

Sand-Clay Mixing.  Sand-clay mixing involves the recombining of  the
waste sand and clay removed from the phosphate matrix in areas sur-
rounded by dikes 17-20 feet high.  Although Farmland proposes  to use the
dredge-mix method for creating such a mixture, the technique for applying
this method at the Farmland site has not yet been proposed by Farmland.
                                 -10-

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 The  supply  of  sand  and  clay  in  the matrix should  be sufficient to allow
 development of such a technique.   Farmland has  committed to do this once
 operation begins.

 Conventional Sand and Clay Disposal.   Conventional  methods  for disposing
 of the waste sand and clay removed from the phosphate matrix during
 processing  involve  their  impoundment  in separate  areas  surrounded by
 dikes as high  as 41 feet  above-grade.   More than  half of the area to be
 mined would be covered  with  waste  clays impounded to a  height of  35 feet
 above-grade and surrounded by such dikes.

 Process Water  Sources
     Process water  requirements for the proposed  mining and benefi-
 ciation of  phosphate (using  slurry matrix  transport and conventional
 matrix processing)  amount to a flow rate of about 50,000 gpm (72  mgd).
 Much (88 percent) of this would be recycled water.  Actual  freshwater
 requirements will be about 8.83 mgd with most (6.02 mgd)  required for
 use in the  amine flotation section of  the  beneficiation plant.  The
 alternative  freshwater  sources to  meet  this requirement which were
 evaluated in the DEIS were groundwater  withdrawal and surface water
 impoundment.

 Groundwater  Withdrawal.   The major source  of freshwater  used  at the mine
 would be from onsite deep (1400-foot) wells.  The mine  field  would
 likely consist  of a primary production  well, standby production well,
 and a potable water well.  The production well would have a  capacity of
 6200 gpm, with  the  average daily pumping rate being about 6l33 gpm.

 Surface Water Impoundment.  The most readily available  freshwater  source
which could  be  utilized by Farmland would be surface water  from nearby
 creeks and rivers.   Since the creeks on  the  site  typically  exhibit  low
 flows,  or even  intermittent flows, the  quantity available for  use  as
process water could be best provided by  impoundment within  a  reservoir
 system constructed on the site.
                                 -11-

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Water Management Plan
     During normal operations, water  losses  through  entrainment,  seepage,
evaporation, and wet rock  shipment would  equal  the freshwater  input  to
the recirculating water  system and a  discharge  would not  be  required.
During periods of heavy  rainfall  the  recirculating system might become
overloaded, however, and a means  of reducing the water  volume  would  thus
be required.  The alternative methods  for removing water  from  the
recirculating system which were evaluated in the DEIS were a discharge
to surface waters and use  of connector wells.

Discharge to Surface Waters.  Seasonal changes  in rainfall and evap-
oration rates will affect  the active water volume of the  recirculating
water system.  When heavy  rainfall occurs, the  system may become over-
loaded, forcing a discharge to an existing natural drainage  (either
Hickory Creek or Oak Creek) through a  control structure.

Use of Connector Wells.  Connector wells  would  serve to reduce the
amount of water in the recirculating system  by  dewatering the  Surficial
Aquifer (a source of water inflow to the  system) in  the vicinity of the
active mine pit.   This water would be  pumped downward through  wells into
a deeper aquifer and serve as a source of recharge to that aquifer.

Reclamation Plan
     The mining of phosphate and disposal of wastes  generated  during
beneficiation would greatly alter the  land surface of most of  the Farm-
land site.  Future use of  the site would  be  largely  dependent  upon the
manner in which the mined  land surface is reformed (i.e., reclaimed).
The alternative methods of reclaiming  the mined site which were eval-
uated in the DEIS were Farmland's proposed reclamation plan, conven-
tional reclamation and natural mine cut reclamation.
                                 -12-

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Farmland's Proposed Reclamation Plan.  Farmland's proposed reclamation
plan consists of five general types of restoration.  These are generally
described as follows:

     Sand-Clay Mix Landfills                  - 3915 acres
     Crust Development on Clay Settling Areas -  583 acres
     Sand Tailings Landfills                  -  104 acres
     Land and Lakes Areas                     -  567 acres
     Disturbed Natural Ground                 -  111 acres

Reclamation would proceed over the life of the mine, with the final
areas mined being reclaimed in the 24th year after operation begins.

Conventional Reclamation.  Conventional reclamation is reclamation
associated with the separate disposal of sand and clay waste (i.e.,
conventional sand and clay waste disposal).  Reclamation would consist
of allowing a crust to form over the more than 2500 acres of impounded
clays and seeding these areas with forage species, and creating ex-
tensive land and lakes areas in those areas of the site not covered with
impounded clays.  The revegetation of these areas would likely consist
of forage species plantings on most land areas, with forest tree plant-
ings along the edges of the lakes.

Natural Mine Cut Reclamation.  Natural mine cut reclamation would amount
to leaving mined-out areas in windrows, with sand-clay mix deposited
between windrows.  Mined areas would be allowed to revegetate naturally,
as has been the case in many of the older central Florida mines.  The
resultant use of the mined-out land would be largely for fish and
wildlife habitat, with some pastureland.

The No Action Alternative
     The no action alternative by EPA would be the denial of an NPDES
permit for the proposed project.  The effect of permit denial would be
to precipitate one of three possible reactions on the part of Farmland:
(1) termination of their proposed project; (2) indefinite postponement
                                 -13-

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of the proposed project; or (3) restructuring of the project to achieve
zero discharge, for which no NPDES permit would be required.

     Termination of the planned project would allow the existing en-
vironment to remain undisturbed and the gradual socioeconomic and
environmental trends would continue as at present.

     If EPA were to deny Farmland's NPDES permit application, the
project might be postponed for an indefinite period of time and then
successfully pursued by either Farmland or another mining company.  This
might be expected to occur when high grade phosphate reserves are
depleted and the resource retained on the Farmland site becomes ex-
tremely valuable strategically as well as economically.

     If EPA denies the NPDES permit, Farmland could still execute a
mining project provided the project could be performed with zero dis-
charge to surface waters.  Under zero discharge conditions, neither an
NPDES permit nor an Environmental Impact Statement would be required.

4.  Mitigation Measures;

     Farmland's proposed action includes a number of measures to reduce
the potential for adverse impacts on the environment.  These are des-
cribed below by the components with which they are most closely associated:

                                Mining
   • The existing vegetative cover would be maintained on all land for
     which mining or support activities are not imminent.
   • The vegetative cover on about one-third of the mine site would be
     preserved—including the most important wetland acreages.
   • Dragline crossings of stream channels would be selected to disturb
     the least total area, particularly the least wetland area; and
     crossings of Oak Creek and Hickory Creek would be timed to coincide
     with the dry, no-flow periods.
   • The Oak Creek crossings through the preserved portion of Oak Creek
     Islands would be made along a single corridor.
                                 -14-

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• Vegetation would  be  established  on  the  approaches  to  creek  crossings
  and  these would be maintained  until the final  crossing  is made.

• Fill introduced into  creek  channels during dragline crossings would
  be removed after  the  crossings and  the  banks immediately stabilized
  with vegetation.

• Mine  cuts adjacent to property boundaries would be promptly back-
  filled, and rim ditches would be used,  where necessary, to maintain
  Surficial Aquifer levels at adjacent property  boundaries and in
  preserved areas.
                        Matrix Transport

• Double-walled pipe and catchment basins would be used at matrix
  pipeline stream crossings to contain matrix slurry in the event of
  a leak at that point.

• Pressure sensitive devices would be installed in matrix pipelines
  to alert mine personnel to a significant leak in the system.
• Cut-off valves would be installed at both sides of pipeline stream
  crossings to assist in controlling a pipeline leak at these points.
                        Matrix Processing
• During plant construction, water sprays would be applied to unpaved
  areas and roads to reduce particulate emissions.
• During plant construction and operation, perimeter ditches would be
  installed to collect runoff from the plant site area.
• Storage facilities for reagents, fuel, lubricants, etc. would be
  above ground within a walled or diked tank farm.
• Petroleum storage tanks would be built to standards and designed to
  prevent accidental spillage.  Storage areas would be designed to
  route spillage and/or accumulated rainfall to the mine water
  recirculating system or to a tank within the area.
                  Waste Sand and Clay Disposal

• The design and construction of dams required for the impoundment of
  clay and sand-clay wastes would comply with all provisions of
  Chapter 17-9 of the Florida Administrative Code.
• Dam faces would be planted in grasses to inhibit wind and water
  erosion, and would be mowed as necessary for visual inspection.

• All dams would be inspected daily by a trained Farmland employee,
  and annually by a design engineer.
                              -15-

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                         Process Water Source

   • Pumping may be reduced in dry periods in order  to  comply with
     Southwest Florida Water Management District  (SWFWMD) regulations.
                         Water Management Plan

   • Water would be recycled to the maximum extent possible  (approxi-
     mately 90 percent).

   • Discharges should occur only during periods of heavy, rainfall.


                              Reclamation

   • All dikes and ditches would be graded to acceptable slopes and
     revegetated.

   • All disturbed land would be revegetated.  An experimental revege-
     tation program would be conducted on the first sand-clay mix land-
     fill that becomes available to determine the agricultural and
     wetland restoration potential of such areas.


     Additional mitigation measures which would serve to reduce the

impacts which the project will have on the surrounding environment were

developed from inputs received from the preparers of the various sec-
tions of the Environmental Impact Statement.   These are described below:
   • Pile overburden such that the volume available for below ground
     waste disposal is maximized.

   • Use "toe spoiling" to reduce the radioactivity of reclaimed surface
     soils.

   • Cover reclaimed sand-clay mix disposal areas with about 6 inches of
     low activity soil to reduce gamma radiation levels.
   • Cover reclaimed clay disposal areas with 10-15 ft of overburden to
     reduce gamma radiation levels.

   • Use treated mine water, rather than Surficial Aquifer water, for
     pump seal lubrication.

   • Divert Hickory Creek around the mining area to its preserved lower
     portion,  rather than to Troublesome Creek.

   • Restrict mining along the preserved lower portion of Hickory Creek
     to only one side of the stream channel at a given time.

   • Monitor the Surficial Aquifer in the vicinity of sand-clay mix
     disposal areas.
                                 -16-

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   • Increase the acreage to be reclaimed as forest habitat and provide
     corridors for wildlife movement between reclaimed and preserved
     areas by planting additional areas with trees.
   • Establish a 7- to 10-acre littoral zone at the downstream end of
     the lake system proposed for reclamation of the Hickory Creek
     channel.
   • Increase the acreage to be reclaimed as marsh by 116 acres.
   t Implement a program to reduce impacts on the indigo snake, a
     threatened species which occurs on the site.
5.  EPA's Preferred Alternatives and Recommended Mitigating Measures;

     The alternatives evaluation for the Farmland project is presented
in detail in Section 2.0 of the Draft EIS.  Based on analyses described
in that section, the DEIS identified EPA's preferred alternative for
each of the project components as follows:

     Project Component             EPA Preferred Alternative
     Mining                        Dragline Mining
     Matrix Transport              Slurry Matrix Transport
     Matrix Processing             Conventional Matrix Processing
     Waste Sand and Clay Disposal  Sand-Clay Mixing
     Process Water Source          Groundwater Withdrawal
     Water Management Plan         Discharge to Surface Waters
     Reclamation                   Farmland's Proposed Reclamation Plan

     While EPA's preferred alternatives for the various project compo-
nents are in agreement with Farmland's proposed action, implementation
of most of the mitigation measures described in the previous section was
also recommended in the DEIS.  The measures not recommended were the
capping of waste disposal areas with low activity overburden and the use
of treated mine water to meet pump seal requirements.  All other miti-
gation measures listed in Section 4 were proposed as conditions of the
Draft NPDES permit for the Farmland project.
                                 -17-

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6.  Summary of  the Environmental Effects  of  the  Alternatives:

     After identifying  the  environmentally preferable alternatives for
the various project components, the DEIS  developed a comparison between
(1) Farmland's  Proposed Action; (2) EPA's preferred alternatives and
mitigating measures; and  (3) the No Action alternative of permit denial
by EPA, which could lead  to termination of the project, postponement of
the project or  restructuring of the project  to achieve zero discharge.
A summary of the impacts  of each of these three  alternatives is pre-
sented in a comparative format in Table 1.

7.  Identified  Issues and Concerns!

     The DEIS was made available to the Council  on Environmental Quality
(CEQ) and the public in May of 1981.  A joint public hearing to receive
comments on the DEIS and  the Draft NPDES permit  and state certification
was held in Wauchula,  Florida on July 14, 1981.  The comment period on
the DEIS remained open through July 28, 1981, and wirtten comments on
the DEIS were received from the following:

                           Federal Agencies
     U.S. Department of Energy
     U.S. Department of Agriculture, Forest Service
     U.S. Department of the Air Force, Headquarters Environmental Division
     U.S. Department of Housing and Urban Development
     U.S. Department of the Air Force, Regional  Civil Engineer
     U.S. Department of the Army,  Corps of Engineers
     U.S. Department of Health and Human Services, Public Health Service
     U.S. Department of the Interior
     U.S. Department of Commerce

                            State Agencies
     Florida Department of Transportation

                   Interested Groups or Individuals
     Farmland Industries,  Incorporated
                                 -18-

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      Table  1.    COMPARISON OF  THE  ENVIRONMENTAL IMPACTS OF  THE  ALTERNATIVES.
Discipline      Farmland's Proposed Action

tit Quality,    Minor increases in fugitive
 Meteorology,   dust emissions and emissions
 and Noise      from internal combustion
                engines; minor emissions
                of volatile reagents;  In-
                creased noise levels In
                the vicinity of operating
                equipment.

Geology and     Disruptions of the surface
 Soils          soils and overburden strata
                over the mine site;  deple-
                tion of 40 million tons of
                phosphate rock resources;
                creation of a reclaimed
                soil material which should
                be superior to existing
                soils.
Radiation       Disruption of the natural
                distribution of radioactive
                material within the over-
                burden and phosphate matrix;
                increased radiation levels
                from reclaimed surfaces.
                               EPA'S Preferred Alternatives
                                 and Mitigating Measures

                               Same as Farmland'a  proposed
                               action.
                                                                                               The Ho Action Alternative
                               Same as Farmland's proposed
                               action, except  that  the
                               height  of  the remaining
                               waste clay Impoundment could
                               be reduced by about  4 feet
                               by piling  overburden to
                               greater heights.
                               Same  as  Farmland's proposed
                               action,  except  that  reclaimed
                               surface  soils would  contain
                               less  radioactive  material
                               because  of toe  spoiling.
                                  Termination

                                 No change in
                                 meteorology &
                                 noise levels
                                 present;  possi-
                                 ble air quality
                                 changes from
                                 other sources.
                                 No change in
                                 geology;  no
                                 change in site
                                 soils  (I.e.,
                                 increased pro-
                                 ductivity) ;
                                 preservation  of
                                 40 million tons
                                 of phosphate
                                 rock reserves.

                                 No change in
                                 radiation
                                 characteristics
                                 of the site.
                  Postponement
                 Same as Farm-
                 land's proposed
                 action.
                 Possible in-
                 creased phos-
                 phate recovery
                 and more effec-
                 tive sand-clay
                 mix disposal,
                 reclamation,
                 and wetlands
                 restoration.


                 Sane as Farm-
                 land's proposed
                 action.
                 Achieve Zero Discharge

                 Same as Farmland's
                 proposed sction.
                 Increased dike heights,
                 and water storage capa-
                 city;  probable Infringe-
                 ment on preserved areas;
                 less desirable recla-
                 mation plan.
                 Probable increase  in
                 area covered  with  waste
                 clays—the  reclaimed
                 material having  the
                 highest radioactivity
                 levels.
Groundwater
Surface Water
Aquatic
 Ecology
Terrestrial
 Ecology
Socioeconomics
Withdrawal of groundwater
from the Floridan Aquifer at
an average rate of 8.83 mgd;
lowering of Surflclal Aquifer
in the vicinity of active
mine pits; possible local
contamination of Surflclal
Aquifer adjacent to sand-
clay mix disposal areas.

Disruption of surface water
flows from the mine aite;
minor reduction in flows
following reclamation;
degradation of water
quality due to discharges
from the mine water system.
Destruction of aquatic habi-
tats on the mine site;
aquatic habitat modifica-
tions due to reduced sur-
face water flows and
addition of contaminants
to creeks flowing from
the site.
Destruction of terrestrial
habitats and loss of indi-
viduals of some species on
the mine site; creation of
modified habitats following
reclamation.

Generation of Jobs with com-
paratively high Incomes; ad
valorem and sales tax revenue
for Hardee County; aeverenee
tax revenue for the state,
Land Reclamation Trust Fund,
and Florida Institute of
Phosphate Research; some
population Influx to Hardee
County; Increased demands
for housing, transportation,
fire protection, police,
and medical services.
Same as Farmland's proposed
action.
No change in     Possible reduc-  Same as Farmland's pro-
existing ground- tion in ground-  posed action.
water quantity   water withdrawals
and quality.     because of more
                 effective de-
                 watering of waste
                 materials.
Same as Farmland's proposed
action, except that flow would
be maintained in lower Hickory
Creek, Instead of Increasing
flow in Troublesome Creek;
and there would be reduced
loss of baaeflow to Hickory
Creek in years 12-13.


Same as Farmland's proposed
action, except that the Impacts
on aquatic biota in Hickory
Creek will be lessened by the
continuation of flow through
Ita preserved lower portion.
Same as Farmland's proposed
action, except that the wild-
life habitat on the reclaimed
mine site will be more exten-
sive (both marsh and forest).


Same as Farmland's proposed
action.
No change in
surface water
quantity; sur-
face water
quality would
be dependent
upon future land
uaes In the site
area.
No change in
existing
aquatic
ecology.
No change in
existing
terrestrial
ecology.
Loss of jobs
which would be
generated by
the project;
loss of tax
revenue for
Hardee County
and the State;
less demand for
transportation,
housing, fire
protection,
police and medi-
cal services;
continuation of
phosphate rock
market uncer-
tainties for
Farmland and a
loss of their
Investment.
                                                                                                Same as Farm-
                                                                                                land's proposed
                                                                                                sction.
Same as Farm-
land's proposed
action.
Possibly more
effective
reclamation
and wetlands
restoration.


Continuation of
phosphate rock
market uncer-
tainties for
Farmland and
potential in-
creased project
costs; possible
Improvement in
supply/demand
for housing In
Hardee County.
                 Elimination of surface
                 water quality Impacts
                 resulting from discharge
                 from mine water system;
                 Increased probability of
                 dike failure Imparts.
Elimination of habitat
modification resulting
from discharge from mine
water system; Increased
probability of dike
failure Impacts.
Probable creation of In-
creased reclaimed land
areas (waste clays)  of
limited use (e.g.,
pasture).

Same as Farmland's pro-
posed action.
                                                                   -19-

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      All questions and comments on the DEIS, written and verbal,  are
 individually addressed in Section 3, Public Participation, of the Final
 EIS.   Comments that resulted in changes to EPA's recommendations  are
 discussed in the following paragraphs.

      U.S.D.A.  Forest Service comments on the DEIS resulted in the
 expansion of NEPA requirement No.  8 of the Draft NPDES permit by  the
 additional requirement that Farmland coordinate with the District State
 Forester  regarding the forestry aspects of the reclamation plan.

      Careful consideration of Farmland's comments on the technical
 feasibility  of  certain of  EPA's recommended mitigating measures brought
 about minor  changes  in those recommendations.   Since the spoiling of the
 leach zone,  required by EPA,  precludes maximum theoretical high profile
 stacking  of  overburden,  NEPA requirement No.  2 of the Draft NPDES permit
 has been  revised  to  require high profile stacking in Settling Area II to
 the maximum  extent compatible with toe spoiling,  with any gain in waste
 storage volume  to  be reflected in  a lower reclamation profile.

      Secondly,  because the EPA-recommended change in the proposed
 temporary division of Hickory Creek (NEPA requirement No.  12)  would have
 required  a major  change in the recommended mining and reclamation plan,
 this proposed NPDES  permit condition has been  revised to provide  for
 water quality monitoring in both Hickory Creek and Troublesome Creek.
 Similarly, the  recommendation (NEPA requirement No.  13)  to  avoid  active
 mining on both  sides of lower Hickory Creek at the same  time  (a situ-
 ation which  would  occur only for a few months  during mine year 12)  would
 also require a  major change in the mining and  reclamation plan recom-
mended by EPA.  Therefore,  this draft permit condition has  been revised
 to require (1)  monitoring  of  the Surficial Aquifer level within the
 preserved area, and  (2)  a  maximum  allowable limit of 3 feet that  the
 Surficial Aquifer  within the  preserved area may be lowered  due to  the
mining activities.   Where  necessary to prevent exceeding the  3-foot
 limit, Farmland must employ rim-ditching,  rapid refilling of mine  pits,
or other  appropriate measures.
                                 -20-

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     Lastly, at Farmland's request, EPA has revised NEPA requirement No.
14 to allow that the Surficial Aqufier be monitored for the life of the
mine or until such time that EPA and Farmland agree that the compiled
date indicate no adverse effect on the Surficial Aquifer.

     U.S. Department of the Interior comments on the DEIS included a
discussion of the uncertainties of wetlands reclamation and the need for
contingency plans should the proposed wetland reclamation fail.  Al-
though Farmland is committed, by both state and Federal requirements, to
successful restoration of the given acreages of wetlands, EPA recognizes
the need for a mechanism to monitor the results of the restoration
effort.   This would identify areas where changes or improvements in the
restoration program are required, as well as provide valuable infor-
mation on wetlands restoration in general.  Therefore, EPA has developed
a wetlands restoration monitoring program, given as NEPA requirement No.
15 of the Draft NPDES permit (previous No. 15 is now No. 17).

     The Department of the Interior also pointed out the need to address
paleontological resources on the site and impacts on those resources.
Since there is great potential that fossil remains will be discovered
during the mining of the Farmland site, EPA proposes the addition of
NEPA requirement No. 16 to the Draft NPDES permit, requiring that
Farmland provide to bonafide researchers and professionals for salvage
of specimens and information.

8.  Agency Decision;

     The Final Areawide Environmental Impact Statement for the Central
Florida Phosphate Industry (AEIS) published by EPA in November 1978
established a set of recommendations for future phosphate industry
operations in Florida which was determined to be as compatible as
practicable with other desired and intended land uses.  Section 6 of the
Farmland DEIS provided a detailed comparison between Farmland's proposed
project and the AEIS recommendations.  The Farmland proposal conforms to
all recommendations except in one area, i.e., the AEIS-recommended use
                                 -21-

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of connector wells to recharge the Surficial Aquifer.  However, the AEIS
also noted that the drained water should be monitored to assure that it
meets recommended drinking water criteria.  In the case of Farmland,
high gross alpha radiation levels, exceeding drinking water standards,
were found in the Surficial Aquifer water at the Farmland site.  There-
fore, Farmland does not propose to use connector wells to recharge the
Floridan Aquifer, and the use of such wells is neither required by
Farmland's SWFWMD Consumptive Use Permit nor recommended by EPA in this
site-specific EIS.

     Therefore,  pursuant to provisions of the Clean Water Act of 1977,
EPA proposes to issue an NPDES permit to Farmland for their proposed
Hardee County, Florida phosphate mine.  The proposed permit will impose
as conditions the performance of all mitigating measures identified in
Farmlands proposed action as well as those additional mitigating mea-
sures recommended by EPA, including the revisions and additions re-
sulting from comments on the DEIS.
                                 -22-

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                                    FINAL ENVIRONMENTAL IMPACT STATEMENT
                                                       TABLE OF CONTENTS
                                                                    Page
     SUMMARY SHEET FOR ENVIRONMENTAL IMPACT STATEMENT               -1-


1.0  PREFACE                                                        1-1


2.0  ERRATA                                                         2-1


3.0  PUBLIC PARTICIPATION                                           3-1

     3.1  WRITTEN COMMENTS                                          3-1
     3.2  RESPONSES TO WRITTEN COMMENTS                             3-27
     3.3  HEARING TRANSCRIPT                                        3-46
     3.4  RESPONSES TO TRANSCRIPT COMMENTS                          3-91


4.0  COORDINATION                                                   4-1

     4.1  FINAL ENVIRONMENTAL IMPACT STATEMENT COORDINATION LIST    4-1


5.0  LIST OF PREPARERS                                              5-1


6.0  APPENDIX                                                       6-1

     6.1  DRAFT NPDES PERMIT FOR THE FARMLAND INDUSTRIES, INC.
          MINE PROJECT,  HARDEE COUNTY,  FLORIDA                      6-1

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                                                                     1.0
                                                                 PREFACE
     In May of 1981, the Environmental Protection Agency published and
distributed a Draft Environmental Impact Statement (DEIS) on the pro-
posed Farmland Industries, Inc. Phosphate Mine.  The DEIS was written
pursuant to the National Environmental Policy Act (NEPA) of 1969.  While
the DEIS was a complete document, much of the detailed technical infor-
mation and supporting data were presented in a two-volume Supplemental
Information Document.  The DEIS was distributed to the appropriate
Federal, State, and local agencies and to interested individuals.  The
Supplemental Information Document was available for review at a number
of locations and was distributed on a limited basis.

     This Final Environmental Impact Statement (FEIS) has been prepared
to conform with the Council on Environmental Quality (CEQ) regulations
(40 CFR Part 6) for implementing NEPA.  The essence of the NEPA decision
process is contained in the Summary Sheet for the FEIS; it describes the
existing problem requiring a decision, summarizes alternatives—including
mitigative measures—and their associated impacts, identifies major
concerns and issues, and presents EPA's conclusions and decision.

     In an effort to avoid excessive paperwork and costly reproduction,
the DEIS text has not been reprinted in the FEIS.  The supporting
information furnished in the DEIS and its Supplemental Information
Documents should be reviewed and are incorporated herein by reference.
                                  1-1

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      Chapter  2,  Errata,  is  comprised  of the  corrections  to  substantive
errors  and  omissions  in  the DEIS  and  resource  documents  as  well  as  all
recognized  typographical and minor  errors.

      Chapter  3 contains  a description of  the public participation
program conducted  for  the EIS.  Included  in  this  chapter are copies of
written communications submitted  to EPA in response to the  DEIS, fol-
lowed by EPA's responses  to each  individual  comment.  These are  followed
by a  transcript of the public hearing on  the DEIS and a  point by point
response to the hearing  comments.

     Chapter 4 of the FEIS  lists  the  agencies  and groups to whom the
FEIS will be sent for review and  comment  and Chapter 5 identifies the
individuals involved in its  preparation.  An appendix to the FEIS
contains the Draft NPDES  permit.

     In accordance with CEQ  regulations,  there will be a 30-day review
and comment period following publication  of this FEIS and its filing
with the CEQ.
                                  1-2

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                                                                     2.0

                                                                  ERRATA
Page
Paragraph
Line
Correction
2-25

3-139
    1

    1
3-140         1


3-145         4
  2       Omit "nearly" and "(98 percent)".

  7       Following "...seven county region..."
          insert "(Charlotte, DeSoto, Hardee,
          Hillsborough, Manatee, Polk, and
          Sarasota Counties)".

  1       Omit ..."of"... and replace with
          "less than".

  3       Continue paragraph with "...screened
          from view.  As mining progresses and
          reclamation lags behind, impacts
          would become cumulative and would be
          noticeable to some degree from any of
          the bordering roadways.  However, the
          human perception information in
          Section 3.8.1 indicates that on a
          regional basis few people would see
          the mining development.  Locally, the
          mining development would totally
          change the existing rural character.
          Reclamation and revegetation would
          eventually restore most of the rural
          visual quality, but total restoration
          would take 24 years to complete.
          Total revegetation to similar exis-
          ting conditions would take longer.
          The visual impacts to the rural
          quality of this stie would be re-
          peated with additional mining pro-
          posals nearby creating areawide
          cumulative impact."
                                  2-1

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                                                                     3.0
                                                    PUBLIC PARTICIPATION
     The Draft Environmental Impact Statement (DEIS) was published in
May 1981 and made available to the Council on Environmental Quality and
the public.  A public notice appeared in the local newspapers.  The
Federal Register (Volume 46, No. 108) dated June 5, 1981, announced the
availability of the DEIS and the proposed issuance of an NPDES permit.
The DEIS was provided to numerous Federal, State, and local agencies as
well as concerned individuals, interest groups, and public officials.

     A notice of the public hearing was published on May 29, 1981.  The
public hearing was held in Wauchula, Florida, July 14, 1981 and was
attended by 47 participants.  The comment period on the DEIS remained
open through July 28, 1981.  In addition to the public input afforded by
the hearing (transcript provided herein), a number of letters were
received during the comment period and are included in this Final EIS.

     The designations in the margins of the letters (W-l thru W-38)
identify those specific comments for which responses have been devel-
oped.  These responses follow the letters.  In a similar manner, the
designations in the margins of the hearing transcript (T-l thru T-5)
identify those comments which have been responded to in the pages
immediately following the transcript.

3.1  WRITTEN COMMENTS
                                  3-1

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                          U.S. DEPARTMENT  OF ENERGY
Date
ROUTING AND TRANSMITTAL SUP 6/5/81
TO: (Nam*, office symbol, room number,
toufld/ng, Agency/Post)
2. Jean Tolman
2.
3.
4.
&







Initials




Date




Action File Note and Return
Approval For Clearance Per Conversation
As Requested For Correction Prepare Reply
Circulate For Your Information See Me
Comment Investigate Signature
Coordination Justify
     REMARKS


     Thank You for  the opportunity  to review this EIS,

     however,  we have a "no  comment" response therefore

     we are sending you back the documents.
     DO NOT use this form as e RECORD of approvals, concurrences, disposals,
                       clearances, and similar actions
     FROM: (Name, org. symbol. Agency/Post)

Jill  Sperling, NEPA  Affairs  Division
Room No.—Bldg.
 40064 -  Ftsl.
                                                 Phone No.
                                                  252-6374
     5041-102                           OPTIONAL FORM 41 (Rev. 7-76)
                                      PrMeribrt by Q8A
    • U S GOVCBNMtNT PRINTING OFFICE 1979 — 3B1.|«4'I  r"PMR (41 CFR) 101-11.204
                                       3-2

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UNITED STATES DEPARTMENT OF AGRICULTURE
            FOREST SERVICE


    1720  Peachtree Road,  N. W.
     Atlanta,  Georgia  30367
                                   1950
                                   June 5,  1981
 Ms. A. Jean Tolman, EIS Project Officer
 U. S. Environmental Protection Agency
 345 Courtland St., NE
 Atlanta, Georgia  30365
u

 Dear Ms. Tolman:

 We have reviewed the Draft EIS for the Farmland Industries
 Phosphate Mine and Beneficiation Plant, Hardee County, Florida,
 and have the following comments.

      1.  Overall, the draft EIS was well written with a good
 reclamation plan for the disturbed phosphate mining areas.
 However, there will be a 30 percent loss (790 acres) of pine
 flatwoods, (583 acres)  and wetland communities (207 acres) in the
 post reclamation land use.  This loss of natural vegetation will
 have a large impact on the terrestrial ecology and wildlife
 habitat than will the loss of agriculturally managed lands.  It
 would seem that high yielding well-managed pine plantations on the
 pine flatwood and some pasture sites would produce at least 150
 board feet per acre per year through a rotation.  Some thought
 should be given to establishing slash pine plantations on good
 forest sites in the area.

      It is suggested that Farmland contact the District Forester
 or the State Forester, Florida Forest Service to request
 assistance on the forestry aspects of the reclamation plan and its
 implementation.  The State Forester's address is Mr. John Bethea,
 Director, Division of Forestry, Florida Department of Agriculture
 and Consumer Services, Collins Bldg., Tallahassee, FL  32301.

      2.  Some mention should be made of plans to salvage
 commercial timber and pulpwood in areas that will be clearcut
 prior to mining operations.

      3.  The draft statement notes that the construction and
 operation of the facility will remove a small percentage of the
 total amount of the affected vegetative communities found in
 Hardee County.  The loss of 5,280 acres of the various ecotypes,
 i.e. pine flatwoods, upland forests, swamps, wetlands, lakes,
 citrus groves, and pastures, may be insignificant when compared to
 Hardee County and Florida as a whole.  However, with the thousands
 of acres of Florida citrus groves, pastures, forest lands,
 wetlands, swamps, lakes, etc., being lost annually  to urban
 development and sprawl, industrialization and road construction;
                      3-3
                                                                     CM
                                                                      I

-------
•Ms.  A.  Jean Tolman
 it is only a matter of time until many of these vegetative
 communities will be gone and the problem does become significant.
 It is extremely important that the mitigative measures indicated
 in the reclamation plan be carried out to the extent they have
 been written.

      4.   Another important concern which we have is the effect  of
 the use  of large quantities of ground and surface water for  the
 mining and beneficiation process.   The presented data shows  there
 will be  little affect on water levels and water supplies necessary
 for the  mining process as well as the irrigation systems and wells
 already  in operation.   However,  if more mining operations were
 started  and more wells for irrigation drilled in Hardee and
 surrounding counties,  there no doubt would be an adverse effect on
 the water tables,  levels,  and aquifers especially in times of low
 rainfall and drought.   Water levels and water quantities and
 qualities should be constantly monitored to make certain that
 aquifers are being  recharged and not being destroyed when actual
 mining operations  are  being conducted.

 We appreciate  the  opportunity to review this draft EIS and look
 forward  to receiving a copy of the final when it is published.
                                     3-4

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                    DEPARTMENT OF THE AIR FORCE
                      HEADQUARTERS UNITED STATES AIR FORCE
                             WASHINGTON, D.C.  20330
                                                      0 JUAl J98J
Ms. A. Jean Tolman,  EIS  Project  Officer
U.S. Environmental Protection Agency
Region IV
345 Courtland Street,  N.E.
Atlanta, Georgia  30365
Dear Ms. Tolman
We have reviewed the Draft  Environmental Impact Statement on the
Farmland Industries, Inc. Phosphate  Mine in Hardee County, Florida
and have no objection.
                                  Sincerely
vo
                                 'ROBERT L.  KLINGENSMITH, COL, USAF
                                  Chief,  Environmental Division
                                  Directorate of Engineering & Services
                                  3-5

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Florida  /Eadm  Department   of  Transportation
                                  Haydon Burns Building, 605 Suwannee Street. Tallahassee, Florida 32301. Telephone (904) 488-8541
   BOB GRAHAM       >g^y>r V^H                          JACOB D. VARN
   GOVERNOR              ^^V                           SECRETARY

                                                   June 11,  1981
        Ms. A. Jean Tolman
        EIS Project Officer
        U.S. Environmental Protection Agency
        Region IV
        345 Courtland Street, N.E.
        Atlanta, Georgia 30365

        Dear Ms. Tolman:

                  Subject:  Draft EIS - 4SA
                           Farmland Industries, Inc.
                           Phosphate Mine
                           Hardee County, Florida

             We have reviewed the Draft Environmental Impact  Statement and offer
        the following observations.

        1.  The Department  of Transportation prefers the Slurry Matrix Transport
        alternative.   If  Matrix Slurry is transported via pipeline to the bene-
        ficiation plant  from the phosphate mine, and then by  rail to the phosphate
        fertilizer plants,  we foresee no involvement from a highway standpoint.
        However, if the  proposed 8,000 foot long railroad spur crosses any state
        highways, we anticipate normal safety precautions be  included in the design
        of the at-grade  rail crossings.

        2.  No problems  are expected due to the addition of 70 rail car trips per
        day on the existing Seaborad Coastline Railroad  track in terms of time
        delay at crossings.

        3.  The Department  endorses the use of carpooling for commuters to reduce
        such negative effects as increased fuel consumption,  noise and reduced
        air quality.

             We appreciate  the opportunity to comment.

                                                 Sincerely,
        CLI:Imd
                                                    L.  IrwlA, Administrator
                                                 Environmental Impact Review
                                             3-6

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                        DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
   **UIIIILJ!II*1                        ATLANTA REGIONAL OFFICE
                               RICHARD B. RUSSELL FEDERAL BUILDING
                                      75 SPRING STREET. S.W.
                                     ATLANTA. GEORGIA 30303
                                                                          IN REPLY REFER TO:
                                       June 19,  1981                     ^

   Ms. A. Jean To!man
   EIS Project Officer
   Environmental Protection Agency
   Region IV
   345 Courtland Street, N.E.
   Atlanta, Georgia  30365

   Dear Ms. Tolman:

   The Department of Housing and Urban  Development  Region  IV  Regional  Office wishes  to
   offer the following comments on the  Draft Environmental  Impact  Statement  (DEIS) for
   Farmland Industries, Inc., Phospate  Mine, Hardee County, Florida.

   1.   At this time the proposal  does  not  appear to have a potential  for impacting
        existing or ongoing HUD projects in the  immediate vicinity of  the proposed         o
        mining area.  However, according to unofficial reports  from local  agencies         7
        in jurisdictions adjacent  to Hardee County,  there is  concern over the potential    3
        transmission of increased  radiation levels  in  the subsurface strata  of water
        tables, particularly at those levels where  wells are  used  to provide irrigation
        for lawns and gardens in housing developments.

   2.   Mining, as noted in Section 2.9.1  (pg. 2-26),  will elevate gamma  radiation         r-
        levels and increased exposure to Rn 222.  If EPA's consideration  of  radon          7
        exposure as representing a linear,  non-threshold effect is true then public        s
        health risks will  be increased.

   3.   We concur in EPA's preferred alternative and the mitigating measures as pro-
        posed if the reclaimed areas are used exclusively for agricultural purposes.
        However,  since it is probable that  residential structures  will be constructed      £'
        on reclaimed land, the EIS should indicate  how the different soil  radium           7
        levels will  affect interior spaces, the probability of  health  risk and            3
        preventative measures that should be taken  to  reduce the potential for unsafe
        concentrations of radon daughters in the homes.

   We appreciate  the opportunity to review  and comment on this  DEIS.

   Sincerely,
      ional  Administrator
ATLANTA. GEORGIA. BIRMINGHAM. ALABAMA-COLUMBIA                EENSBORO, NORTH CAROLINA 'JACKSON. MISSISSIPPI
                 JACKSONVILLE, FLORIDA' KNO       J~7      .OUISVILLE. KENTUCKY

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                             DEPARTMENT OF THE AIR FORCE
                     REGIONAL CIVIL ENGINEER, EASTERN REGION (HO APE8C)
                            »• TITLE BUILDING. 30 PMYOR STREET, ».W.
                                   ATLANTA, OKOMOIA 10303
FLY TO
TN or,
ROV2                                                        7 July 1981

Draft Environmental Impact Statement  (DEIS), Farmland Industries,
Incorporated Phosphate Mine, Hardee County, Florida

U. S. Environmental Protection Agency
Region IV
ATTN:  Ms. A. Jean Tolman
EIS Project Officer
3^5 Courtland Street, N. E.
Atlanta, Georgia  30365

We have reviewed the subject DEIS and find it will have no adverse impact
on Air Force operations in Florida.   Thank you for the opportunity to
review this DEIS.  Our point of contact is Mr. Winfred G. Dodson,
telephone number 221-6821/6776.
        DMAS D. SIMS                           Cy to:  56 CSG/DEEV
        Lef
       nvironmental Planning Division
                                            3-8

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                                [COOP]
                                                   ,

                      poet office box 73O5/kar\8os city, missouri 64116
REPLY TOt
 f. O. Bex 441
 Mulberry, Florida 33840
 PheiM: §13-425-4981
  14th  July,  1981


  Jean  Tolman
  Environmental  Protection Agency
  345 Courtland  Street
  Atlanta,  Georgia  30308

  RE:   Farmland  Industries, Inc.
       Hickory Creek Mine (Hardee County, Florida)

  Dear  Jean:

  Farmland  Industries, Inc. respectfully submits the attached
  comments  on the  Draft Environmental Impact Statement  for  Its  Hickory
  Creek Mine. We  think the EIS is well prepared and we  appreciate
  the efforts by EPA to conduct a thorough and accurate  review.   We
  do wish to  point out that the NPDES permit (Appendix  A  of the
  EIS), state certification under Section 401 of the Clean  Mater  Act
  and NEPA  procedures are highly Interrelated matters.   Thus, v
  our comments pertain to the EIS, the NPDES permit, and  the state
  certification  process.  Those comments relating to the  NPDES  permit
  are submitted  in compliance with both EIS procedures  and  Section
  124.13 of the  consolidated permit regulations [45 Fed.  Reg. 33490,
  May 19, 1980 (to be codified at 40 C.F.R. S 124.13TT~

  We appreciate  your cooperation and hope.you will contact  us 1f  _
  we can be of further assistance.
  Yours  trul
  C,  Richard
  Executives-director
  PhosplKfte  Manufacturing

  CRM/jm
                                     3-9

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                     COMMENTS TO EPA'S RECOMMENDED
                  CONDITIONS AND MITIGATING MEASURES
                    INCLUDED IN DRAFT NPDES PERMIT
I.   Effluent Limitations

          The Draft NPDES permit establishes the following effluent
     limitations.

     1.   Total Suspended Solids: 30 mg/1 Daily Average
                                  60 mg/1 Daily Maximum

     2.   Biochemical Oxygen Demand: 2 mg/1 Daily Average
          (BOD5) (5-Day)             3 mg/1 Daily Maximum

     3.   Specific Conductance: 550 Daily Average
          (mhos/cm @ 25° C)    1100 Daily Average

     4.   Radium:  5pci/l
                 10pci/l

     5.   Flow: 2.51 m3/Day (MGD)

     6.   The pH shall not be less than 6.0 standard units nor greater
          than 8.5 standard units.

     7.   The flow at Hickory Creek must be at least 1.8 times the
          discharge flow to the Creek.

     8.   The flow in Oak Creek must be at least 1.6 times the discharge
          flow to the Creek.

     Response
          Farmland  has no  objection to  the effluent  limitations  that
     incorporate the published EPA guidelines for pH and TSS.   We under-
     stand the  other  discharge limitations contained in the Draft NPDES
     Permit are based on EPA's expectation of the limits to be required
     by  the  Florida Department of Environmental  Regulation (DER).   The
     State, however,  has  indicated  that routine requirements may not be
     adequate for  the Hickory Creek mine, and may  apply special condi-
     tions.  These  conditions  are being discussed with  DER at the cur-
     rent  time.  Accordingly,  Farmland  requests  that  the Draft NPDES
     Permit be  revised to incorporate the published EPA guidelines and
     simply state  that any  conditions  imposed by DER  will be incorpo-
     rated  by  reference  in the  federal permit.   Farmland  agrees  to
     comply with the  published EPA limitations and any state conditions
     imposed  following  discussions  and  other  proceedings  with  DER.
                                 3-10

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II.  MITIGATING MEASURES

     These comments are directed to the indicated mitigating measure and
     all  related  information in the Environmental Impact  Statement and
     supporting documents.

     EPA Recommendation 2

          Farmland  shall perform  the dragline  mining  operation  in  a
     fashion  that  increases  the  casting  distance  of the  overburden,
     causing the overburden to be piled higher and thereby increasing by
     approximately  10 percent  the below  ground  volume  available for
     waste  disposal and lowering  the  above ground  profile  of Settling
     Area II by approximately four feet.

     Response

          Farmland agrees to utilize high profile stacking of overburden
     in the mining areas covered by Settling Area II.  However, Farmland
     does not believe  that  it is appropriate to lower the dam height of
     Settling Area II  from 35  to 31 feet  for the  following reasons:

     *    Additional  volume within  a settling  area  can only  be
          created  by stacking overburden  above the  maximum waste
          disposal level.  Since much of the overburden material in
          the upper portion  of  the spoil piles will  be borrowed to
          construct  the retaining dam,  it  is  likely that  very
          little  overburden material will  remain above  the waste
          disposal  level in  Settling  Area  II, even if high profile
          stacking is used.

     *    The  toe  spoiling  requirement  (EPA  Recommendation  5)
          requires  that  the  leach zone strata  be spoiled  at the
          bottom  of the  mine pit which may  preclude maximum theo-
          retical high profile stacking of overburden.

     *    One of  the primary reasons for keeping  Settling Area II
          active  throughout  the  life  of  the mine  is  to retain the
          area as  an alternate  waste disposal area.   During mining
          operations, localized concentrations of high clay ore may
          be encountered.  Settling Area  II will provide an outlet
          for clay periodically generated  in excess of  the sand-
          clay  nixing capability  of the  mine.   Lowering the dam
          height  by  four  feet  does  not,  in Farmland's  opinion,
          justify  the loss  in alternative  waste disposal  volume
          that would result.
                                 3-11

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     As  shown  by the  proposed  use of the  sand-clay mix technique
(with  dam  heights from  11  to 20  feet),  Farmland  is committed to
minimizing overall dam heights by maximizing below grade storage of
wastes.  However,  because  of the  above  considerations,  Farmland
believes that  the dam height for Settling Area II should remain 35
feet as originally proposed.  High profile overburden stacking will
be used  in the mining of the area  covered  by the settling area to
the maximum extent  compatible with the  toe  spoiling requirement.
Any increased  waste  storage volume achieved by this technique will
be realized in a lower reclaimed elevation for the area even if the
originally proposed dam height of 35 feet is retained.  At the same
time,  the   alternative waste disposal storage  volume will  be re-
tained for use if needed.

EPA Recommendation 5

     During the dragline mining activity, Farmland shall employ the
technique  of  leach  zone management by  toe spoiling,  i.e.,  over-
burden  from near the  interface  with the matrix (the  leach zone,
where  radioactivity  in  the overburden  is concentrated)  shall be
placed  at  the toe of the  spoil  pile and  covered  with overburden
from upper strata.

Response

     Farmland  agrees  to  utilize the  recently  introduced technique
of  toe spoiling in  mining  areas where prospecting has identified
the presence of  a leach  zone layer overlying the matrix interface.

EPA Recommendation 8

     Farmland  shall  increase the acreage reclaimed  as  forest hab-
itat and provide  corridors  for  wildlife movement between reclaimed
and  preserved  areas  by  planting additional  areas  as  depicted in
Figure 2, attached.

Response

     Farmland  agrees  to  expand its upland  reforestation plantings
as depicted  in Figure 2, Appendix A of the Draft NPDES Permit for
the Farmland Industries,  Inc. Mine Project, Hardee County, Florida.

EPA Recommendation 9

     Farmland  shall  incorporate  into its reclamation plan  a lit-
toral zone  at  the downstream extent of the proposed reclaimed open
lake in  the  Hickory  Creek channel.  This littoral zone shall be at
least 500  feet wide  and at a depth suitable  for emergent vegeta-
tion,  providing  for  the  establishment  of  710 acres  of  marsh
community.
                               3-12

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Response

     Farmland  will  establish  a littoral  zone  at the  downstream
extent  of  the reclaimed  lake  proposed  for  the reclamation  of
Hickory Creek.  The  original reclamation plans  for the  lower por-
tion of  this lake system  provided for an open lake  approximately
600  feet  wide and 3000  feet long  created by  double spoiling the
mine cuts  in this area.   The original  plans also provided for a
100-foot wide  littoral  zone approximately 1-3  feet deep along the
eastern margin of the  lake and for  filling the  remainder of the
lake as necessary with  sand tailings to establish a  maximum water
depth of 15 feet.

     In order to create the desired littoral zone at the downstream
extent of  the  reclaimed lake,  sand tailings fill will be placed in
the  mine  cut to within 3 to 5 feet of the planned water elevation.
An overburden  cap of 1  to 2 feet will then be established over the
tailings  fill  to  provide  a final water depth of 1 to 3 feet and a
suitable  substrate for  emergent  vegetation.   The lower 900 feet of
the  open  lake  will be reclaimed in this manner to create an addi-
tional 10 acres of freshwater marsh.

     The  reclaimed lake will continue to intercept the undisturbed
lower  portion of  Hickory  Creek at an elevation  of  65  feet MSL.
This elevation will serve as the outfall elevation into the natural
stream  channel and establish  the  water level  in the  entire lake
system.   The  reclaimed  marsh will  therefore  serve  as  a wetland
filter for  flow exiting the lake system into the  undisturbed por-
tion of Hickory Creek.

EPA Recommendation 10

     Before  beginning  any  land-disturbing  activities,  Farmland
shall  develop a  program  wherey indigo  snakes  encountered  in the
work area are  captured  for relocation to other areas of suitable
habitat  in the site  region.  This program  shall include informing
Farmland  workers  of  the importance of the  indigo snake, familiar-
izing  them  with  its appearance  and  instructing them  as  to its
preservation.  In addition, the gopher tortoise population shall be
protected  to the  extent possible in the site area.  Farmland shall
coordinate  its recovery  and  relocation  efforts  with  the Florida
Endangered  Species Coordinator,  and shall maintain a record of the
program  to  be submitted  to the U.S.  Fish  and Wildlife Service.

Response

     Farmland  will   institute  the  recommended  program  for  reduc-
ing  impacts on the  indigo  snake and the gopher  tortoise.  Prior to
                               3-13

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beginning operations,  Farmland will work with  the Florida Endang-          g
ered Species Coordinator to develop a program that is acceptable to         £.
both parties.                                                               w

EPA Recommendation 11                                                       a

     Farmland  shall  comply with  the  categorization  of  wetlands
present  on  the mine  property  as  set  forth in  the  EIS and illus-
trated in Figure  3,  attached.   In summary, within Category 1 wet-
lands,  Farmland shall  not mine,  shall  limit activities  to those
essential  to and  unavoidable  for the  mining opeation,  and shall
otherwise take  all reasonable  measures to  preserve  all Category 1
wetlands.   Additionally,  Farmland shall restore the total acreage
of  Category 2  wetlands  disturbed by  mining.    Specifically,  the
acreage  to  be restored as freshwater marsh or  swampt according to
Farmland's  proposed action  in the  EIS shall  be increased  by at
least  116 acres (from 398 acres to a minimum of 514 acres).  This
shall be done my differential grading and settling of sand-clay mix
areas  in addition  to that already proposed by Farmland in the EIS.

Response

     Farmland  will  comply  with  the   categorization  of  wetlands
presented in the  EIS,  protect  all Category 1 wetlands  from mining
or  related  disturbance, and reclaim all other  wetlands  from dis-
turbed by mining.   According to the plans presented in the EIS, no
Category 1  wetlands  are to be mined or otherwise disturbed by the
proposed operation.  However,  514 acres of Category 2 and 91 acres
of  Category 3  wetlands  are included  in the  mine and waste dis-
posal plans.  The  reclamation plan proposed in the EIS provides for
the reclamation of 398 acres of wetlands.

     Since  the  EIS  reclamation   plans  were  submitted,  mandatory
State  reclamation requirements for wetlands  (Chapter 16C-16, FAC)
have been  revised.  Farmland has  therefore revised its reclamation
plan to  reclaim 207 additional wetland acres.   The primary increase
in  reclaimed wetland  acreage  will  be  provided by  expanding the
shallow depressions proposed around the outlet end of sand-clay mix
reclamation  areas.   The  depressions  will be  expanded   to  cover         °
approximately  ten  percent  rather  than  five percent  of each sand-         ^
clay  reclamation  area.   The  expansion will be achieved  by con-
trolled grading of overburden spoil and by  raising the elevation of
the overflow drainage swales.  For the 3,628 acres of sand-clay mix
reclamation areas  (excluding the two special mix areas specifically
scheduled for wetland   reclamation),  this  expansion will result in
182 additional  reclaimed wetland acres.

     A  further  change  in mandatory  State  reclamation  standards
requires that  at  least  25  percent  of  the high water surface of
reclaimed lakes consist of an  annual zone  of water fluctuation to


                               3-14

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serve as the wetland  component  of the lakes.   The  large reclaimed
lake  in Sections  34  and  35,  T345,  R24E  and the  reclaimed lake
system  created  for  the  reclamation of  Hickory  Creek both have
sufficient littoral zone to meet this requirement.  However, the 59
acre  lake which  serves  as  the  clear water  pond during the life of
the  mine has  no  planned wetland  component.   Provision  for  the
required 25 percent wetland  zone in this reclaimed  lake will pro-
vide  the necessary  15  additional  wetland  acres.   The following
table  summarizes  Farmland's expanded  wetland reclamation plans:

     Expanded Wetland Area              Additional Wetland Acreage

Expansion of Depressions in Sand-Clay           182 acres
Mix Areas (from 5 percent to 10
percent of reclamation area)                                                 —
                                                                             -p
Littoral Zone at Downstream Extent of            10 acres                    o
Hickory Creek Reclamation Area                                               •¥*
                                                                             o
Zone  of Fluctuation in Reclaimed                 15 acres                    ^
Clear Water Pond                                                             -31

      TOTAL                                      207 acres

The revised wetland reclamation plans will therefore meet mandatory
State requirements and  exceed  Category 2 wetland  reclamation re-
quirements of the Draft NFDES permit.

EPA Recommendation 12

      During the mining of the unpreserved portion of Hickory  Creek,
the  flow from this  area shall be diverted  around  the active mine
area  into the lower preserved section of Hickory Creek  (rather than
to Troublesome Creek).

Response

      Farmland  believes  that  the temporary diversion  of Hickory
Creek to Troublesome  Creek as originally proposed is the preferred
alternative from the  standpoint of water quality protection and the
sand-clay  mix reclamation  program.  Farmland also  believes that
this  diversion can be  accomplished without permanent  adverse im-
pacts on the downstream  vegetation.                                          r-

      The  flow in  Hickory  Creek  is  intermittent  and periods of  no          ^
flow  are common  in  the dry season.  The  vegetation in the  undis-
turbed  lower  portion  of Hickory  Creek  is therefore  adapted  to
short-term no  flow periods.  The  mining and reclamation of the  area
                                3-15

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has been  scheduled  to be carried out as rapidly as possible.  Min-
ing of  the  area is planned to take place over a period of slightly
over two  years,  beginning in year 12  and  ending early in year 14.
Physical  reclamation  and revegetation  of  the area will  require a
period  of slightly  over two years, beginning in year 12 and ending
early  in year  14.   Physical  reclamation  and revegetation  of  the
area will require a  period of  two  years  before  the  creek is  re-
routed  through  the system.  Therefore,  although the  upstream flow
will be cut off  for  slightly over four years,  runoff from mining
blocks  12 and  13 wil  continue to  enter the  existing  channel until
the areas are mined.   Moreover, the  undisturbed  lower portion of
the creek lies  in  a  deeply incised area and will continue to  re-
ceive direct  rainfall inputs as well as runoff  from  offsite areas
to the  south even after mining of the upstream portion is complete.
Farmland  therefore  believes that,  although the area may be subject
to  stress,  there  will  be  no  permanent damage  to the  overstory
vegetation.

      In  developing  the  proposed diversion  plans, Farmland gave
careful  consideration  to  protection  of water  quality.   Both  the
diversion channel to Troublesome Creek and the reclaimed channel of
Hickory Creek are  to  be stabilized and the banks  revegetated prior
to allowing flow to enter  the channels.  A period of two years has
been allowed  to  reclaim, stabilize,  and revegetate the channel for
Hickory Creek while  flow  is  diverted  to Troublesome  Creek.   The
alternative  of  creating a  diversion  channel  through a  recently
mined area might pose water quality problems downstream.

     The  mining block  scheduled for year  13,  which  includes  the
lower portion  of Hickory  Creek, covers the  entire area  from  Oak
Creek Islands east  to S.R.  661  (Figure  2-2,  Draft EIS).   With the
present mine  plan,  it  is  not  possible to  divert Hickory  Creek
around  the active mine area to intersect the undisturbed downstream
segment.  Such a diversion would require a major change in the mine
plan.   Since  sand-clay  waste disposal follows  so closely behind
mining,  a change in  the mine plan would also necessitate a major
change  in the reclamation plan.

     In summary, Farmland anticipates some stress but no permanent
damage  to the downstream overstory vegetation because of the pro-
posed  temporary diversion  of  Hickory Creek  to  Troublesome Creek.
The  alternatives of  diverting  the  flow around the active mining
area  to  intersect  the  undisturbed portion of the creek would re-
quire major  changes in the mining and  reclamation plans  and might
pose  a  threat  to  downstream water  quality.  Therefore,  Farmland
believes  that the temporary diversion  to Troublesome  Creek is  the
preferred alternative.
                             3-16

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    EPA Recommendation 13

         Mining  in  the  vicinity of lower Hickory Creek shall be sched-
    uled  such that open  mine  pits exist adjacent to  only  one side of
    the preserved portion of the creek at a given time.

    Response

         Mining  is  scheduled  along  both the north  and south sides of
    the preserved portion of Hckory Creek in the second half of year 12
    (mining  blocks 12C  and 12D,  Figure 2-2 of  the  Draft EIS).   The
    mining  blocks  are scheduled  for  immediate  conversion to sand-clay
    mix  reclamation areas (S/C 11 and S/C  12,  Figure 2-6,  Draft EIS).
    The  waste disposal  areas  are to  begin receiving  sand  and  clay
    wastes  in year  13.   Open mine  pits will  therefore  occur on both
    sides  of the  preserved area  for a period of  only a  few months.
    Within  a year  after mining,  the water  table  will have  been re-
    established  on  both sides  of the  area by the deposition of the sand
    and  clay wastes  in  aqueous  suspension.   The   period  of moisture
    stress  due  to  pit dewatering will  therefore be  very short-term.

          A  change in  the  mine  plan to avoid the short-term  condition of
    open mine pits  on  both  sides  of  the  preserved  area would  also
    require  a change  in the  sand-clay mix reclamation  plan.  The accom-
    modation of  the  sand  and clay  wastes  within  the  low level  dams
    proposed in  the  EIS  requires that waste disposal  follow almost
    immediately  after mining.  As  with the case of the temporary diver-
    sion of  Hickory Creek  to Troublesome  Creek, Farmland expects no
    permanent damage  to the vegetation  in  the  preserved area and does
    not  believe  that the short-term  stress  is  sufficient to justify a
    change  in the mine and  reclamation plans.

    EPA  Recommendation  14

          Farmland   shall  monitor  the water  quality of  the Surficial
    Aquifier at  the  location  identified on the attached map, Figure 3.
    The  following  parameters  shall be  monitored on a quarterly basis
    for  the  life  of the  mine:   ph,  specific conductance, sulfates,
    fluoride, and ammonia.   A  written report  summarizing the data shall
    be submitted once a year to  EPA.

    Response

          Farmland will  establish a Surficial  Aquifer monitoring station
    at the  location  identified on  Figure  3, Appendix  A,  Draft NPDES
    Permit   for  the  Farmland  Industries,   Inc.  Mine Project,  Hardee
    County,   Florida.  Monitoring for  the  indicated parameters  will
    continue for the life  of  the mine  or until such  time  that the EPA
    and  Farmland  agree  that  the  compiled  data indicates no adverse
     impact  on the Surficial Aquifer.


TC1C                               3_17

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                          DEPARTMENT OF THE ARMY
                     JACKSONVILLE  DISTRICT. CORPS OF ENGINEERS
                                   P.  O. BOX 497O
                             JACKSONVILLE. FLORIDA 32232
 SAJPD-ES                                                      17  July 1981
 Ms. A. Jean To!man
 EIS Project Officer
 Environmental Protection Agency
 Region IV
 345 Court!and Street, NE
 Atlanta, Georgia  30365
 Dear Ms. Tolman:

 Reference is made to the Draft Environmental Impact Statement  (DEIS) for
 Farmland Industries, Inc. Phosphate Mine in Hardee County, Florida,
 furnished this office on 29 May 1981.  The Corps of Engineers  is  a
 cooperating agency for this EIS.

 Review of the DEIS reveals that sufficient factual information  is presented
 to identify areas of importance comprising those wetlands subject to
 Department of the Army regulatory authority.  The alternatives  to such work
 as presented in the draft, however, are related to an artificial  categoriza-
 tion of such wetlands as Class I (preserve), Class II (mine and restore) and
 Class III (mine with no restoration).

 These categories remain inconsistent with this office's disposition to con-
 sider the overall impacts of such work as it relates to regulated fill work
 and  with the requirements of our regulations to assess the important func-
 tions (or lack thereof) of all wetland subject to Corps authority.  In
 addition, we must determine whether the proposed work is primarily dependent
 upon location in (or in close proximity to) the aquatic environment and
 whether feasible alternative sites are available and practicable.

 These analyses have been reinforced by EPA regulations as well, whereas the
 artificial  categorization of such wetlands is sanctioned neither by Federal
 law  nor by published regulations.  Therefore, this is to advise your office
 and  the applicant that the Corps will conduct its public interest review of
 the  environmental  impacts as required by regulation based upon both infor-
mation  obtained from the EIS as well  as from the additional  sources of input
 received  in  response to public notice and hearings as required in processing
the  completed permit application for all  project work.

 In this  regard,  this office will  explore all  feasible and practical  alter-
natives  identified  in the permit public interest review process as well as
those which  become  apparent from our review.   On the basis of this


                                         3-18

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SAJPD-ES                                                     17 July 1981
Ms. Jean Tolman

information, the EIS information and requisites of our current regulations,
decisions on all related applications by Farmland Industries, Inc. will be
made.

The Jacksonville District remains prepared to consider all concerns and to
review all proposals and alternatives in this regard.  Please contact Mr.
Victor Anderson, Permits Section project manager, or Dr. Gerald Atmar,
Chief, Environmental Studies Section, concerning 404 and EIS concerns
respectively.

                                     Sincerely,
                                                  o
                                                  o
LLOYD H. SAUNDERS, Ph.D.
Acting Chief
Planning Division
     3-19

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DEPARTMENT OF HEALTH & HUMAN SERVICES                            Public Health Service
                                                                Centers for Disease Control
                                                                Atlanta. Georgia 30333

                                                                (404)  262-6649

                                                                July 22,  1981
Ms. A. Jean Tolman
EIS Project Officer
U.S.  Environmental Protection Agency
Region IV
345 Courtland  Street, N.E.
Atlanta,  Georgia  30365
Dear Ms. Tolman:
We have reviewed  the Draft Environmental Impact Statement (EIS)  for the
Proposed  Issuance of a New Source National Pollutant Discharge Elimination
System Permit  to  Farmland Industries,  Incorporated,  Phosphate Mine, Hardee
County, Florida.   We are  responding on behalf of the U.S. Public Health
Service and are offering  the following comments for  your consideration in
preparing the  Final EIS.

In general, we have no major objections to the proposed action,  and we believe
that long-term effects can be successfully minimized provided the mitigation
measures  outlined in the  EIS are imposed upon the applicant.

We have some concern about the potential for radiation exposure  of future
populations living or working on this  land.  According to the EIS, the
reclaimed farmland site ".  .  .will slightly exceed the recommended limit
of .009 WL for slab-on-grade homes."  Without special land use controls and            to
local regulations, the applicant could affect the safe and healthful use of            ^
the disturbed  lands in the future.   Certain commitments by the applicant               •*
should be made to assure  the safe use  of any reclamation lands by future
populations when  such lands are sold.   For example,  consideration might be
given to  recording special deed restrictions so that all purchasers would be
fully aware of the uses that could be  made of the property.

While connector wells will not be used to recharge the Floridan  Aquifer with
groundwater from  the Surf icial Aquifer because of the high gross alpha radia-
tion levels found in the  Surficial Aquifer, several  references are made in             ,«o
the EIS on pages  3-64 and 3-88 about discharging uncontaminated  water from             ™
the recirculating water system to deep aquifers.   The EIS should clarify               *
whether any well  injection via connector wells will  be performed by the
applicant.

According to the  EIS, a housing demand for 330 to 580 housing units will be
required  for direct and indirect employment.   The adequacy of local zoning,            is.
building,  and  sanitary codes to prevent poor construction and incompatible             *^
development should be discussed.                                                        SB
                                       3-20

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Page 2 - Ms. A. Jean Toloan

The EIS should also discuss the impact of the proposal upon vector populations
and whether any vector-borne disease patterns in the area would be affected.
Will control measures be necessary?  The vector management plan to be employed
by the applicant should be described relative to the requirements of the
local public health agency.

We appreciate the opportunity to review this Draft EIS.  Please send us one
copy of the Final EIS when it becomes available.

                             Sincerely yours,
                                      Lisella, Ph.D.
                               lief, Environmental Affairs Group
                             Environmental Health Services Division
                             Center for Environmental Health
                                         3-21

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           United States Department of the Interior
                      OFFICE OF THE SECRETARY
                       WASHINGTON, D.C.  20240

ER 81/11"                            WL 2 3  1981

A. Jean Tolman, EIS Project Officer
U.S. Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia  30365

Dear Ms. Tolman:

We have reviewed the draft environmental impact  statement for
the Farmland Industries, Inc., Phosphate Mine, Hardee County,
Florida, sent to us May 29, 1981.  The document, in general,
adequately discusses the probable  impacts of  the proposed mining
operation on the various resources of concern to this Department.
The following specific comments are provided  for your consideration
in preparing the final EIS.

Water Resources

The statement should discuss plans for monitoring the surficlal         o>
aquifer in the vicinity of disposal areas for the sand and clay         ^
mixture.                                                                a

It is stated that at the site boundaries the  drawdown of the
potentiometric surface of the Floridan aquifer must be kept within
a 5-foot limit, according to regulations of the Southwest Florida
Water Management District unless a variance is obtained (p. 3-58).
The Trescott model predicts a maximum steady-state drawndown of
31 feet (p. 3-58).  The applicant plans to evaluate the effects         0
of pumping the Floridan aquifer in detail with the Southwest Florida    °°
Water Management District (p. 3-58).  If a variance is expected,        i
the statement should evaluate more adequately the impacts of the
project's ground-water withdrawals from the Floridan aquifer.  If
a staggered pumping schedule is planned, effects on the potentio-
metric surface should be evaluated.

It is indicated in Sec. 2.5.1.2 that groundwater pumping would
lower  the potentiometric surface of the Florida Aquifer.  Con-         •—
sideration should be given to the long term impact of groundwater       °?
withdrawal on the entire region under drought conditions.               3
                                3-22

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A. Jean Tolman                                             2

Wildlife Resources

There should be more discussion of the forested wetlands that
are to be lost by this mining activity.  Forested wetlands are
extremely valuable fish and wildlife resource areas and they are
being altered and/or destroyed much faster than they are being
created.  The creation of these areas requires many years and the
techniques are not such that restoration is guaranteed.  The net
loss of 261 acres of forested wetlands should be addressed to a
greater extent in the impacts sections of the statement.

The proposed preservation of 2,530 acres is significant.  However
the rationale for establishing the preservation area boundaries is
not clear.  There appear  to be blocks of wetlands adjacent to but
outside the preserved areas that are proposed for mining.  Conversely,
there are several upland areas in the preservation area which appear
to be minable.  Selection of the areas to be mined should be
explained more fully.

Figure 3-12 includes "Category 2 Wetlands Disturbed" which is not
discussed in the body of the report.  The statement should include
a discussion of the disturbed wetlands of this category and the
tables on pages 3-114 and 6-8 should include acreages involved.

Reclamation

Successful reclamation of wetlands subsequent to phosphate mining
has not been demonstrated.  To address this problem the Bureau of
Mines' Tuscaloosa Research Center will begin a reclamation demon-
stration project on wetlands in Florida in FY 82.

The technical report (volume 1, page 2-35 Waste Sand and Clay
Disposal Plan) states that "...the majority of the sand and clay
wastes will be disposed through the sand-clay mix technique."  It
is not clear as to what Farmland Industries really proposes.
Brewster Phosphates, Incorporated, has developed a sand-clay mix
technique that in a small-scale test was successful; however,
during large-scale operation serious problems were encountered and
the company requested the State to approve a return to "state-of-
the-art" clay storage techniques.  An alternate sand-clay mix
technique, "dredge-mix," has proven successful in the experimental
stage, but more testing is needed.

Several other techniques to dewater waste clays are presently being
evaluated.  Bureau of Mines rotary trommel-PEO and Enviro-Clear
techniques each use a flocculant to achieve rapid dewatering.  We
believe that these techniques hold more promise in eliminating
waste clay storage areas than the proposed sand-clay method.   The
preferred methods should eliminate above-ground clay storage areas.
                                3-23

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A. Jean Tolman                                             3

In view of these uncertainties, we believe the reclamation of
the mined wetlands needs more explicit discussion.  Details
should include species to be planted, planting methods, community-
type proposed, surface contours and elevations to be created,
and the method used to recontour the site.  Discussion (page 3-126)
implies that wetland reclamation on 181 acres is going to occur
naturally, and there will be no specific effort to contour and          «>
recreate these wetlands.  We believe that the chance of attaining       *?
the goal of 181 acres of wetlands under these conditions is not         •*
very high.  Specific reclamation techniques for this acreage
should be addressed.  The statement should include a discussion of
contingency plans if wetland reclamation as proposed fails.

It is mentioned (p. 3-134) that a partial mammoth skeleton was
removed from Hickory Creek in 1965 but no paleontological remains
were found by Milanich and Willis.  In view of the known occurrence,    m
there should be some discussion as to the potential for further         ^
fossil finds in the area and possible impacts to these resources.

Portions of the proposed work will require permits from the Corps
of Engineers pursuant to Section 404 of the Federal Water Pollution
Control Act.  The Fish and Wildlife Service (FWS) will review project
plans and offer specific recommendations with regard to mitigation
and restoration of wetlands during consideration of the permit
application by the Corps of Engineers, in accordance with provisions    oo
of the Fish and Wildlife Coordination Act.  These comments do not       **>
preclude separate evaluation and comment by the FWS when reviewing      ac
the permit application.  The FWS would be pleased to coordinate
with you or the permit applicants to preclude delay and to insure
that any recommended permit stipulations or conditions are under-
stood and included in the final statement.  Please consult with the
Field Supervisor, Fish and Wildlife Service, P.O. Box 2676, Vero
Beach, Florida 32960.

We appreciate the opportunity to review and comment on this statement.

                                 Sincerely,
                                  iruce Blanchard, Director
                                 Environmental Project Review
                               3-24

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                               GENERAL COUNSEL OP THE
                               UNITED STATES ftEPAIITMENT OF COMMERCE
                               Washington. D.C. 20230
JUL 2 4 1981
 Ms. A. Jean Tolman
 EIS Project Officer
 Environmental Protection Agency
 Region IV
 345 Courtland Street, N.E.
 Atlanta, Georgia 30365

 Dear Ms. Tolman:

 This is in reference to the draft environmental  impact
 statement entitled, "Farmland Industries Phosphate Mine
 and Beneficiation Plant, Hardee County, Florida."  The
 enclosed comment from the National Oceanic and Atmo-
 spheric Administration  (NOAA) is forwarded for your
 consideration.

 Thank you for giving us an opportunity to provide this
 comment, which we hope will be of assistance to  you.  We
 would appreciate receiving four copies of the final
 statement.

 Sincerely,
 Robert T. Miki
 Director of Regulatory Policy

 Enclosure Memo From:  Robert B. Rollins
                       National Ocean Survey
                       NOAA
                                3-25

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                                           UNITED STATES DEPARTMENT OF COMMERCE
                                           National Oceanic and Atmospheric Administration
                                           NATIONAL OCEAN SURVEY
                                           Rockville, Md. 20852


                                           JUL 13 1981       OA/C52x6:JVZ
TO:       PP/EC - Joyce M. Wood

FROM:     OA/C5 - Robert B. Rolll

SUBJECT:  DEIS #8106.05 - Farmland' Industries,  Inc.,  Phosphate Mine,
          Hardee County, Florida


     The subject statement has been reviewed  within the areas  of the  National
Ocean Survey's (NOS) responsibility and  expertise, and  In terms of the Impact
of the proposed action on NOS activities and  projects.

     Geodetic control survey monuments may  be located 1n the proposed project
area.  If there is any planned activity  which will disturb or  destroy these
monuments, NOS requires not less than 90 days'  notification in advance of such
activity in order to plan for their relocation.   NOS  recommends that  funding            <*
for this project includes the cost  of any relocation  required  for NOS monu-             i
ments.  For further information about these monuments,  please  contact Mr.  John         3
Spencer, Director, National Geodetic Information  Center (OA/C18)  or Mr.  Charles
Novak, Chief, Network Maintenance Branch (OA/C172), at  6001 Executive Boulevard,
Rockville, Maryland  20852.
                                      ,  I 10TH ANNIVERSARY 1970.1980

                                      3-26        Oceanic and Atmospheric Administration
                                         •   . -  „ «jncy with a historic
                                         I tradition of service to the Nation

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3.2  RESPONSES TO WRITTEN  COMMENTS

Response W-l
     No Response Required.

Response W-2
     The loss of natural vegetation which results  from  clearing and
mining the Farmland site will have a more significant impact  on the
terrestrial ecology of the site than will the  loss of agriculturally
managed lands.  Replacement of some of the wildlife values  (as well as
timber resource) provided by the natural communities could  be obtained
through the establishment of slash pine plantations on  reclaimed  land.
Farmland plans to utilize the first sand-clay  landfill  that becomes
available during reclamation as an experimental revegetation  area.  This
236-acre area will be used to evaluate the growth  of forage crops, truck
crops, citrus, as well as commercial forest species on  sand-clay  mix
"soils".  Farmland has indicated that slash pine will be among the
commercial forest species evaluated.  In addition, EPA  is proposing to
expand NEPA condition No. 8 to the Draft NPDES permit to require  that
Farmland contact the District or State Forester (Florida Forest Service)
for assistance in the forestry aspects of the reclamation plan.

Response W-3
     Farmland has indicated that their plans for the clearing of  areas
to be mined include the salvage of commercial timber and pulpwood where
sufficient quantities are present.

Response W-4
     EPA notes the validity of the concern for cumulative effects of the
loss of vegetative communities and recognizes the  importance  that the
mitigation measures of the reclamation plan be fully implemented.  To
that end,  the mitigation measures are included as  conditions  to the
NPDES permit.   Should these measures not be implemented, the permittee
(Farmland) would become subject to any of the enforcement actions avail-
able to the EPA Administrator under Section 309 of the  Federal Clean
Water Act (33 U.S.C. 1319).
                                 3-27

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Response W-5
     Farmland plans  to monitor  the  levels and  quality  of  the various
aquifers present at  the site.   The  Floridan  and  Secondary Artesian
Aquifers will be monitored continuously at the site, while  Surficial
Aquifer levels will  be monitored at five  (5) locations monthly.  Data
collected will be reported on a quarterly basis.  Additional continuous
monitoring data will be obtained from two Southwest Florida Water
Management District  (SWFWMD) wells  near the  site.  SWFWMD exercises
regulatory jurisdiction related to  consumptive use of  water over sub-
stantially all of the Florida phosphate mining and chemical industry
(both existing and proposed), including all  of Hillsborough, Manatee,
Sarasota, Hardee, and DeSoto Counties, substantially all  of Polk County.
and a large portion  of Charlotte County.  In order for more wells to be
drilled in Hardee and surrounding counties,  applications  for Consumptive
Use Permits (issued  by SWFWMD)  would have to be  filed  (as Farmland did).

     The applicant for a SWFWMD Consumptive  Use  Permit carries the
burden of demonstrating that the intended use  will be  reasonable and
beneficial, consistent with the public interest  and not interfere with
any legal use of water existing at  the time  of application.  Issuance of
the permit will be denied if the intended withdrawal would  cause any of
the following results:

   • Violation of minimum regulatory levels  established for the flow of
     a stream or other watercourse,  for the  potentiometric  surface or
     for surface water;
   • Saltwater encroachment; or
   • Lowering of the water table so  that the lake stages  or vegetation
     will be adversely and significantly affected on lands  other than
     those owned, leased, or otherwise controlled by the  applicant.

     The Consumptive Use Permit will also be denied if the  amount of
water consumptively  used will exceed the "water  crop"  on  lands owned,
leased,  or otherwise controlled by  the applicant.  According to a
statement of policy  recently adopted by the  Board of Governors of
SWFWMD,  the assumed  size of the water crop throughout  the District is
                                 3-28

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1000 gallons per acre per day.  The actual water  crop  for  a  specific
area may be significantly larger or smaller  than  this  amount.   The
actual amount of the water  crop for a particular  area  depends  upon
rainfall and evapotranspiration rates, which vary from area  to area
within the district.

     The proposed withdrawal of water must not reduce  the  rate of flow
of a stream or other water  course by more than 5  percent at  the time and
point of withdrawal.  It must not cause the  level of the potentiometric
surface under lands not owned, leased or otherwise controlled  by the
applicant to be lowered by  more than 5 feet, nor  cause the level of the
water table of such lands to be lowered by more than 3 feet, nor cause
the level of the surface of water in any lake or  other impoundment  to be
lowered by more than 1-foot unless the lake  or impoundment is  wholly
owned, leased or otherwise  controlled by the applicant.  Finally, the
withdrawal must not cause the potentiometric surface to be lowered  below
sea level.

     For good cause shown,  SWFWMD may grant  exceptions to  criteria
listed above,  when after consideration of all data presented,  including
economic information, it finds that an exception  is consistent with the
public interest.

     In addition to permitting withdrawals of water, SWFWMD may also
approve "recharge wells" which drain water from upper  strata (i.e.,
water table or overburden)  to lower formations.   Recharge  wells, as a
water management tool, may be required as a  condition  of consumptive use
permits.  They are not, however, a requirement of  Farmland's SWFWMD
permit.
                                 3-29

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     Water  from Farmland's  production wells  (Floridan Aquifer)  will be
 collected monthly  and  analyzed  for  the following  parameters:

          pH                            Total  Nitrogen
          Total Phosphorus              Total  Dissolved  Solids
          Sulfates                      Total  Alkalinity
          Chloride                      Carbonate Alkalinity
          Specific  Conductance          Bicarbonate Alkalinity
          Total Hardness  (as  CaCO )     Fluoride

     Farmland has also agreed to monitor  the Surficial Aquifer  quarterly
 at a location specified by  EPA  for  the life of the mine  or until  such
 time that EPA and Farmland  agree that  the compiled data  indicate  no
 adverse impact  on the Surficial Aquifer.  Samples obtained from the
 Surficial Aquifer will be analyzed  for the following  parameters:

                              PH
                              Specific Conductance
                              Sulfates
                              Fluoride
                              Ammonia

Response W-6
     No response required.

Response W-7
     The railroad spur from the existing Seaboard Coast Line Railroad
track to the proposed Farmland beneficiation plant will cross S.R. 663.
Farmland has confirmed that normal safety precautions  (i.e., blinking
signal lights) are to be included in the design of this at-grade rail
crossing.

Response W-8
     No response required.
                                 3-30

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Response W-9
     No response required.

Response W-10
     Naturally occurring radiation levels  (gross alpha) in the Surficial
Aquifer on the Farmland site are high relative to the Floridan and
Secondary Artesian Aquifers.  The proposed mining operations are not
expected to significantly alter the radiation levels in subsurface
strata of the site, nor to increase the transmission of the naturally
occurring radionuclides to subsurface strata in adjacent areas.

Response W-ll
     Increased health risks would be limited to those associated with
construction of residential structures on reclaimed land (see Response
W-12).

Response W-12
     Farmland proposes that the reclaimed mine site be used exclusively
for agricultural/wildlife habitat purposes.  Therefore, the health risks
             A .
associated with the construction of residential structures on the
reclaimed site should not occur.  If such structures were constructed on
reclaimed land, the health risk would be best described in terms of
Working Level (WL)  measurements.  This issue was addressed in Section
3.3.2.2.4 of the DEIS and discussed in detail in Section 5.2.4 of the
Supplemental Information Document.  The following information is taken
from the Supplemental Information Document.  Indoor radon and radon
progeny concentrations as measured by WL have been related to increased
risk of lung cancer.  Since indoor WL measurements are not possible
before construction, considerable research effort has gone into pre-
construction predictor measurements and the associated correlations.
                                 3-31

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Three parameters  have  been  considered  for  prediction of  indoor  WL:
external  gamma  exposure  rate,  soil  radium,  and  surface radon  flux.   The
prediction  equations are as  follows:

          WL =  0.0022  (G-3.6)1'01

          WL =  0.0065  (CD )°'563
                         K3.

          WL =  0.0087  (J)0'461
where
            G = external gamma exposure, yR/hr

          C   = soil radium-226, pCi/g
and
                                       2
          J = surface radon flux, pCi/m s.
The predicted indoor WL by land type on the Farmland site after recla-
mation are as follows:

               	 Estimated WL
                Gamma, uR/hr    ]
Land Type
Overburden
Sand-Clay Mix
Waste Sand
Waste Clay

     Should buildings  (such as residences) be located on the reclaimed
Farmland site, indoor radon and radon progeny concentrations would be
higher in these structures than outdoors.  For any homes that were
constructed, the predicted indoor radon progeny  (WL) could range from a
                                 3-32
Gamma, yR/hr
vs. WL
0.014
0.019
0.013
0.029
Ra-226, pCi/g
vs. WL
0.011
0.013
0.011
0.018
Radon^222 Flux
pCi/m s vs. WL
0.0083
0.0098
0.0083
0.013





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low of  0.Oil over reclaimed  sand  and  overburden  tailings  to  a high of
0.018 WL  over reclaimed  clay settling areas.   The  value for  homes  over
sand-clay mix areas would be 0.013 WL.   In  comparison, slab-on-grade
structures in Polk County over undisturbed  lands have WLs ranging  from
0.001 to  0.010, with a geometric  mean of 0.003.  While areas of  separately
stored  waste clay would  represent the highest  potential hazard,  this
material  is one of the least attractive  land types for home  building
because of foundation design problems.   Furthermore, reclaimed clay
areas only represent some 12 percent  of  the site.   It should be  noted
that the  WLs for the Farmland site discussed above were calculated
without consideration of the addition of  low activity topsoil to a
potential development site or the imposition of  some restrictions  in the
type of housing construction.  Such measures should serve to mitigate
the WL  hazard satisfactorily.

     In 1979, EPA provided the following  specific  guidance regarding the
siting  of new homes on any reclaimed,  debris,  and  unmined lands  which
contain phosphate resources:
          "IV.  Development sites for new residences should be selected
     and prepared, and the residences so designed and sited,  that  the
     annual average indoor ...." Working Levels "...do not exceed  ....
     background levels...."
     Following this guidance, the upper limit of predicted WLs in slab-
on-grade homes is approximately 0.009 WL (normal background of 0.004 WL
plus the uncertainty of 0.005 WL).  Overall, the reclaimed Farmland site
will slightly exceed this upper range.  Therefore, if residences were
planned they would have to be designed so as to prohibit the accumu-
lation of radon progeny to levels above the .009 WL limit.  (See also
Response W-25.)

Response W-13
     No response required.
                                 3-33

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Response W-14
     The Florida DER limits referred  to are  the water quality  standards
contained in Chapter 17-3 of  the Florida Administrative  Code.  These
water quality standards were  established in  accordance with  Section 303
of the Clean Water Act.  Federal regulations  (40 CFR 122.62[d][1])
require that the NPDES permit include conditions meeting any require-
ments in addition to or more  stringent than promulgated  effluent limita-
tions guidelines necessary to achieve water  quality standards  established
under Section 303.  Therefore, EPA is unable  to grant Farmland's request.

Response W-15
     EPA recognizes the validity of the issues raised by Farmland
regarding high profile stacking.  Therefore,  the mitigation  measure and
corresponding proposed permit condition (NEPA Requirement No.  2) are
revised to read as follows:

     Farmland shall employ high profile overburden stacking  in the
mining of the area covered by Settling Area II to the maximum extent
compatible with the spoiling of the leach zone.  Any increase  in below
ground waste storage realized by the use of this technique shall be
reflected in a lower reclaimed elevation for  Settling Area II.

Response W—16
     No response required.

Response W-17
     No response required.

Response W-18
     No response required.

Response W-19
     No response required.
                                 3-34

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Response W-20
     No response required.

Response W-21
     EPA recognizes the validity of the points raised by Farmland
regarding the diversion of Hickory Creek under the current mine plan,
and agrees that the impacts resulting from the short-term loss of flow
to the downstream preserved portion of Hickory Creek do not warrant
revision of the mining and reclamation plan for this purpose alone.
While such an alteration could alleviate the short-term impacts of
diverting water from Hickory Creek, it could at the same time result in
the loss of certain desirable aspects of the reclamation plan.  However,
recognizing the concern for the maintenance of water quality in the
preserved portion of Hickory Creek and in Troublesome Creek during the
period of the Hickory Creek diversion, EPA is proposing to revise NEPA
condition No. 12 of the Draft NPDES permit.  The revised condition will
require monitoring of both Hickory Creek and Troublesome Creek.

Response W-22
     Farmland's comment that open mine pits will occur on both sides of
the preserved area of Hickory Creek for a period of only a few months is
accurate.  This short-term loss of base flow to lower Hickory Creek does
not warrant revision of the mining and reclamation plan since such an
alteration could result in the loss of certain desirable aspects of the
reclamation plan.   However, recognizing the importance of maintaining
the integrity of the preserved area of Hickory Creek, EPA is proposing
to revise NEPA condition No. 13 of the Draft NPDES permit.  The revised
condition will require the monitoring of Surficial Aquifer levels within
the preserved portion of Hickory Creek, impose a maximum 3-foot limit on
the lowering of the Surficial Aquifer levels within the preserved area,
and require mitigative measures such as rim ditching adjacent to the
preserved area to prevent exceeding this limit.
                                 3-35

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Response W-23
     EPA has no  objection  to  revising NEPA condition No.  14  to  indicate
that the required monitoring  will  continue for  the life of  the  mine  or
until  such  time  that EPA and  Farmland agree that the compiled date
indicate no adverse effect on the  Surficial Aquifer.

Response W-24
     Categorization of wetlands  is done  in accordance with  the  recom-
mendations  of  the Central Florida  Phosphate Industry Areawide EIS.
EPA's  use of wetlands categorization has been  the subject of previous
discussions between the Corps of Engineers and  EPA,  and there continues
to be  a difference of opinion between our two agencies regarding  its
appropriateness  and utility.   EPA  remains of the opinion  that catego-
rizing wetlands  as Category 1 (preserve),  Category 2  (mine and  restore)
or Category 3  (mine and no restoration)  is of value  in developing and
evaluating alternative mining/reclamation plans,  and  EPA  intends  to
continue application of the principle.

Response W-25
     In the spring of 1980, the  State of Florida established a  phosphate-
related Task Force to identify problems  resulting from construction  of
homes  on phosphate mined and  reclaimed lands and to  recommend appro-
priate solutions.  One of the problems identified was the potential  for
high levels of radon and radon progeny accumulating  in such  homes.   As a
result of its investigations,  which are  still underway, the  Task  Force
is expected to produce recommended State of  Florida guidelines  for radon
exposure levels  in homes built on  reclaimed  lands.

     Meanwhile,  in December of 1980, EPA initiated a  study entitled,
"Program for Control of Indoor Radon Levels  - Common  Building Practices
and Soil Gas Entry Routes in  Central Florida".   This  study,  which is
scheduled to take place over  a 12- to 15-month  period,  is aimed at
determining appropriate remedial measures for homes already  constructed
on reclaimed lands.  The study will also address recommended building
practices for the construction of  new homes  on  reclaimed  lands.
                                 3-36

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     The results of EPA's study will be made available to the State of
Florida, and it is expected that the Task Force will use the information
in its development of state building codes for construction of homes on
reclaimed lands.  It is also fully anticipated that Florida's guidelines
for radon exposure levels and building codes will be completed and
adopted well in advance of the time that the Farmland site would be
considered for residential development.  In light of these facts, EPA
does not consider it necessary or appropriate to condition the Farmland
Draft NPDES permit to require the recording of deed restrictions for the
mine property.

Response^ W-26
     Well injection via connector wells would not be performed by
Farmland nor is it recommended by EPA in this instance because of the
potential for groundwater quality degradation.

Response W-27
     Discussions with Hardee County officials indicate that local
zoning, building, and sanitary codes should prevent poor construction
and incompatable development from occurring.  Codes which new construc-
tion would be subject to include the Southern Building Code, Southern
Plumbing Code, Southern Mechanical Code, National Electric Code, and
Florida Model Energy Efficiency Code.  Development within the county is
also being guided by the 1980 Hardee County Comprehensive Plan which
includes both a Housing Element and a Sanitary Sewer, Solid Waste,
Potable Water, and Drainage Element.

Response W-28
     Discussions with Hardee County Health Department officials indicate
that there are no known vector-borne disease patterns in the area and no
vector management plans required for a project such as the proposed
Farmland mine.

     Discussions with Polk County officials regarding the impact of past
mining activities on vector populations (specifically, mosquitos)
                                 3-37

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 indicate  that  the  creation  of  wetland  areas during reclamation of  rained
 areas  has increased  mosquito populations  in some localities  to levels
 associated with  salt marsh  areas  (bite counts  of 200/rainute).   A vector-
 borne  disease, St. Louis  Encephalitides,  also  recurs  at  about  a 2-year
 cycle  in  Polk  County.  However, occurrence  of  this disease does not
 appear to be centered  around phosphate operations.  The  county maintains
 flocks of chickens which  are tested  periodically for  the presence  of
 this mosquito-borne  virus.

 Response  W-29
     One  of the  "NEPA  Requirements"  of the  proposed NPDES permit for  the
 project identified in  the DEIS was that Farmland monitor the water
 quality of the Surficial  Aquifer  at  a  location identified by EPA (see
 NEPA Requirement No. 14).   This location  was selected because  of its
 proximity to a sand-clay  mix landfill.  Farmland has  agreed to monitor
 the Surficial  Aquifer  for the  parameters  requested by EPA for  the  life
 of the mine or until such time that  the EPA and  Farmland agree that the
 compiled  data  indicate no adverse impact  on the  Surficial Aquifer  (see
 Farmland's written comment W-23).

     As a result of  comments received  on  the DEIS,  the Surficial Aquifer
 monitoring requirements are now proposed  to include both water quality
 and water level data acquisition.  The water level  station location
 requested by EPA is  in the preserved portion of  Hickory  Creek  adjacent
 to an  area which is  to be mined and reclaimed  with sand-clay mix
 material  in year 13  of operation.

 Response  W-30
     The  maximum steady-state  drawdown of 31 feet  predicted by the
 Trescott  model would occur at  the proposed  well  head  which would be well
 within the limits of the  Farmland site.   The reference to the  potential
 for violation of Southwest Florida Water  Management District (SWFWMD)
 regulations relates  to the lowering of  the  potentiometrie surface  at  the
well head  below sea  level.  The elevation of the Farmland site in  the
vicinity  of the proposed  well  field is  about 75  feet  above MSL.  Water
                                 3-38

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levels in the Floridan Aquifer were measured in 1977-78 and found  to
vary between 53 and 28 feet above MSL.  If the maximum steady-state
drawdown (31 feet) occurred during the period when the Floridan was at
its lowest level  (28 feet above MSL), the Floridan Aquifer's poten-
tiometric surface could fall below sea level.  The drawdown would  occur
directly in the pumped well with the core of influence rising above MSL
at a horizontal distance of about 4 feet from the center of the well.
In this event, in order to meet SWFWMD permit requirements pumping would
have to be reduced for a period of time to allow the potentiometric
surface to rise to sea level.

     A separate requirement of the SWFWMD permit is that drawdown  of the
potentiometric surface not exceed a 5-foot limit at the site boundaries.
Modelling of the projected drawdown indicates that the drawdown on
adjacent properties will be less than 4 feet (Figure 3-8 of the DEIS).

Response W-31
     See Response W-5.

Response W-32
     The forested wetlands on the Farmland mine site are comprised
primarily of mixed hardwood swamps/floodplain areas and bayheads
(including ponds and sloughs).  Mixed hardwood swamps and floodplain
forests comprise the majority (66 percent or 800 acres) of the forested
wetlands on the mine site.  In these areas, cabbage palm, diamondleaf
oak, and sweet gum dominate an essentially floodplain forest.  Mixed
hardwood swamps generally differ from the mesic hardwood forest in the
decreased occurrence of live oak and the increased occurrence of wetland
species such as water hickory, water locust, bald cypress, and American
elm.  In general, the dominant species are those with tolerance to a
wide range of moisture conditions.  Within the Oak Creek Islands area,
hardwood swamp vegetation consists primarily of two variants.  Along a
portion of the Oak Creek channel, cabbage palm forms almost a pure
stand.  Throughout the northern portion of this area, in the vicinity of
                                  3-39

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 the  poorly defined drainage pathways, sprouted or coppaced Carolina ash
 trees form dense stands in the depressions.

      Bayheads (hydric hammocks),  which range from 1 to 45 acres in size
 on the mine site,  are dominated by either a swamp bay/sweet gum asso-
 ciation or a sweet bay/red maple association.  Bayheads account for 34
 percent (405 acres)  of the freshwater type on the mine site.  Although
 these areas generally have a low species diversity, the higher quality
 stands contain  many uncommon groundcover and epiphytic species, partic-
 ularly ferns.   The better stands have high timber biomass and relatively
 old  trees.

      Mining will result in the loss of 7 percent (62 acres) of the mixed
 hardwood swamps/floodplain areas  and 64 percent (258 acres) of the
 bayheads on the site.   The extent of each type remaining at significant
 milestones,  expressed as acres and percentage of original acreage, will
 be as follows:
     Time
     Present
     Pre-mining
     Mining (1-4 yr)
     Mining (5-8 yr)
     Mining (9-12 yr)
     Mining (13-16 yr)
     Mining (17-20 yr)
     Post-Mining
Mixed Hardwood Swamps/
  Floodplain Forests       Bayheads
	(acres)	       (acres)
    800  (100%)             405  (100%)
    800  (100%)             386  (95%)
    795  (99%)              348  (86%)
    783  (98%)              250  (62%)
    771  (96%)              219  (54%)
    745  (93%)              177  (46%)
    738  (93%)              147  (36%)
    738  (93%)              147  (36%)
Overall, mining will result  in  a  26  percent  reduction in the extent of
the existing forested wetland acreage  on  the site.   Farmland's  recla-
mation plan calls for the planting of  59  acres  of  the reclaimed mine
site (primarily along reclaimed lake margins) with hydric species.
However, restoration of forested  wetlands such  as  those  which will  be
lost will require many years.
                                  3-40

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Response W-33
     The 2530 acres to be preserved by Farmland are comprised of  several
cover types, the most extensive being freshwater  swamp  (i.e., forested
wetlands).  The acreage of each type to be preserved by Farmland  will be
as follows:

          Freshwater Swamp               - 885 acres
          Improved Pasture               - 456 acres
          Pine Flatwoods/Paltnetto Range  - 354 acres
          Mixed Upland Forest            - 276 acres
          Hardwood Upland Forest         - 187 acres
          Citrus                         - 160 acres
          Freshwater Marsh               - 107 acres
          Other Agricultural             -  58 acres
          Coniferous Upland Forest       -  47 acres

     Combined into natural and agricultural types, these account  for
1856 and 674 acres, respectively.  Figures 2-2 and 2-3 in the DEIS show
the location of unmineable areas on the Farmland  site and the existing
land use within preserved areas.  As indicated in Figure 2-2, unmineable
areas include areas considered environmentally sensitive as well  as
areas considered unmineable because of mine planning constraints  (e.g.,
low quality matrix areas).  A comparison of Figures 2-2 and 2-3 shows
that about half of the unmineable mine planning areas are to be pre-
served.   These areas contain most (about 65 percent) of the preserved
agricultural acreage and a smaller amount (13 percent) of the preserved
natural cover type acreage.

     The selection of areas to be mined (as well as the mine schedule)
involved a detailed analysis of the distribution and quality of the
matrix over the site as well as environmental sensitivities.  Although
environmentally sensitive areas preserved contained some phosphate ore,
it was found that the deposits were not so extensive as to mandate
                                 3-41

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recovery.  By  sacrificing  some  adjacent  or  interspersed  deposits,  the
following environmentally  valuable  areas were  excluded from disturbance:
        •  the hydric  and mesic  forests  associated  with the floodplain of
           the Peace River  (Sections  7 and  18,  T35S,  R25E)
        •  the forested wetlands associated with the  floodplain of
           Troublesome Creek  (Section 1,  T35S,  R24E;  and Section 36,
           T34S, R24E)
        •  the heterogeneous  mixture  of  upland  forests,  forested wet-
           lands,  and  freshwater marshes  known  as Oak Creek Islands
           (Sections 3, 10, 11,  and 14,  T35S, R24E)
        •  the forested wetlands area along a northern tributary to Oak
           Creek (Section 34, T34S, R24E)
        •  the forested segments along the  lower reaches of Hickory Creek
           (Section 2  and 11, T35S, R24E).
     The largest of  these areas  is  the  822-acre  area known  as  Oak  Creek
Islands.  Oak Creek  Islands consists  of a complex,  highly interspersed
group of upland and  wetland communities, generally  grading  from  pine
flatwoods on the east through successional mesic hardwood stages to
mixed hardwood swamp and cabbage palm hammock  in the northwest.  Reduc-
tion in flow into the dissected  drainage pattern of the  north  end  of
the islands appears  to have resulted  in a successional trend of  increased
upland species.  Sweet gum and oaks have invaded the flatwoods whereas
upland shrubs and annual species have invaded  the marshes.  Marshes and
swamps appear to be  limited to depressed areas which may be related to
underlying geologic  conditions.  The  swamps  in these areas  are composed
primarily of coppaced or sprouted forms of Carolina willow  and buttonbush.

     Another large ecological unit  to be preserved  is the 598-acre
forested area along  Troublesome  Creek and the  Peace River.  This forest
has high value because of its high  species diversity, high  biomass,
unique habitat value, and the presence of large,  old-age trees shel-
tering a mature and  complex community.  The  floodplain forest  also
provides the Peace River with a  substantial  area for sediment  release,
energy dissipation,  and additional  storage volume.
                                  3-42

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     The wetlands proposed for mining  (i.e., those outside preserved
area boundaries) are those which EPA considers to be Category 2 and 3
Wetlands (see page 3-114 of the DEIS).  -Regarding Category 2 Wetlands,
the acreage to be mined must be restored as part of Farmland's recla-
mation plan.  Category 3 Wetlands need not be restored.  However, Farm-
land has proposed to enlarge its wetland restoration program such that
the total wetland acreage to be mined will be restored (605 acres).

Response W-34
     The Category 2 "Acres Lost" acreage tabulation on pages 3-114 and
6-8 of the DEIS refers to the Category 2 "Wetlands Disturbed" shown in
Figure 3-12.  The Category 2 Wetlands disturbed are primarily those
wetlands which occur within the 25-year floodplain above the point of 5
cfs and isolated wetlands which are larger than 5 acres in size.  Both
freshwater marshes and swamps are included in this category.  The
largest area, a 77-acre Bayhead/Inland Pond system, is located in the
southwestern portion of the mine site.  Additional large areas within
this category are a 40-acre cattail-bulrush-maidencane marsh in the
north central portion of the site and two 30-acre sawgrass/bayhead
systems in the northwest portion of the site.

Response W-35
     Farmland's plan for sand-clay mixing does not entail using the
sand-clay mix technique attempted by Brewster Phosphates, Inc.  As
stated in Section 2.4.1 of the DEIS, during the early years of mining
Farmland plans to experiment with the most up-to-date techniques avail-
able and select the technique that is best suited to the conditions at
their mine.  The technique to be employed could be any one or a com-
bination of the several techniques currently being refined (e.g., sand-
clay dredge mix, Enviro-clear, Gardinier, or Rotory frommel-PEO).  An
important source of information regarding the selection of a technique
will be the presentations to be made on this subject during the seminars
planned at the Bureau of Mines Tuscaloosa Research Center in the summer
of 1982.
                                 3-43

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 Response W-36
      The planned post-reclamation topography of the site is provided in
 Figure 2-14  of  the DEIS.   Farmland's proposed reclamation plan as
 presented in the DEIS  (Page  3-125)  provides for the creation of 339
 acres of freshwater marsh  and  59  acres  of  freshwater swamp.  Current
 plans for the restoration  of the  59 acres  of freshwater swamp include
 plantings of native hydric species  such as black gum,  sweet gum,  red
 maple,  and bald  cypress.   Of the  339 acres of freshwater marsh, 158
 acres are located in  the Hickory  Creek  and Oak Creek floodplains  and in
 the  reclaimed clear water  pool and  land and lakes area.   Detailed
 descriptions of  the reclamation plans for  these areas  are given in
 Sections 2.7.1.1.1 and  2.7.1.1.4  of the DEIS.   The details are somewhat
 limited by the fact that specific measures to be utilized in Farmland's
 wetlands revegetation programs will depend upon and take advantage of
 the  current  research being conducted in the phosphate  industry as well
 as the  onsite wetland revegetation  experimentation planned for the first
 available sand-clay mix landfill.   Farmland plans to utilize a 24-acre
 portion of Sand/Clay Area  I  (S/C  1)  for this experimentation.   Current
 Farmland plans include  the following experimental plots:

         • areas  in which volunteer  vegetation  is  allowed  to develop;
         • areas  in which organic  substrates removed  from  disturbed
          marshes  onsite are introduced to provide a source for the
           introduction  of  natural marsh vegetation;
         • areas  in which plantings  of typical marsh-type  species  such as
          maidencane, pickerelweed,  and arrowhead are made;  and
         • areas  in which plantings  of hydric tree species—such as bald
          cypress,  blackgum,  sweet  gum,   and  red maple are made (trees of
           2  to 4 inch diameter  transplanted  from  onsite disturbed areas
          would be included along with  bareroot and potted seedlings  to
          help determine the optimum transplant size for  forested
          wetland  restoration).

     The knowledge gained  in these  experimental plantings will be used
to guide  revegetation plans  for the  remaining  freshwater  marsh to be
located  in depressions within  the sand-clay mix landfills.   The 181
                                 3-44

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acres of restored depression wetlands described in the DEIS have been
expanded as a result of EPA and State requirements to total 388 acres
(see Farmland's Comment W-20).

     Successful restoration of the total wetland acreages indicated is
imposed as a permit condition of the Draft NPDES permit.  Should revege-
tation of the 388 acres of depression wetlands not occur by natural
colonization of indigenous species, other measures such as plantings and
seedings would have to be implemented in order to satisfy the permit
condition.  EPA further proposes a requirement for Farmland to monitor
the results of their wetlands restoration effort.  NEPA permit condition
No. 15 has thus been developed to require a wetlands restoration moni-
toring program (previous No. 15 is nov No. 17).

Response W-37
     In discussions with Dr. Clayton Ray (Curator of Vertebrate Paleon-
tology at the National Museum of Natural History) and Dr. S. David Webb
(Curator of Vertebrate Paleontology at the Florida State Museum) con-
cerning the mammoth skeleton reported from Hickory Creek, it was learned
that these remains were actually found in Hickey Branch, a tributary of
Payne Creek 15 miles north of the Farmland site.  A number of such
Pleistocene remains have been found along the eroded channels of creeks
in the area (e.g., Horse Creek, Prairie Creek), and there is great
potential that fossil remains dating to the Pleistocene, Pliocene, or
even Miocene will be uncovered during the mining of the Farmland site.
From a strictly paleontological point of view, such mining can be either
very beneficial or very harmful.  Inevitably some fossils will be
damaged, lost, or destroyed in the course of mining.  If no provision is
made for salvage of fossils for science, then paleontologically it would
be better if no mining were done.  If, however, modest opportunity is
provided for salvage of specimens and information, then the mining can
be regarded as paleontologically beneficial.  The minimal requirement is
                                 3-45

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the provision of regular access to dragline spoil windrows  (most im-
portant) , ore residue, ore piles, and reject piles, on a strictly not-
to-interfere basis.  This mitigation measure is proposed by EPA and
incorporated into the Draft NPDES permit as NEPA requirement No. 16.

Response W-38
     No response required.

Response W-39
     Mr. Charles Novak, Chief, Network Maintenance Branch was contacted
regarding the locations of geodetic control survey monuments in the
Farmland site area.  Mr. Novak's review of such locations found no
markers in the site area.

3.3  HEARING TRANSCRIPT
                                 3-46

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 1



 2



 3                             PUBLIC  HEARING



 4                U.  S.  ENVIRONMENTAL PROTECTION AGENCY



 5                               REGION IV



 6                         IN CONJUNCTION WITH



 7             FLORIDA DEPARTMENT OF  ENVIRONMENTAL REGULATION



 8                              JULY 14,  1981



 9                            FARMLAND INDUSTRIES



10             PROPOSED  PHOSPHATE MINE AND BENEFICIATION PLANT



11                          HARDEE COUNTY,  FLORIDA



12



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                         ANN S. HORNE REPORTING SERVICE

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 1     7/14/81                  INDEX                             PAGE



 2           HEARING	       3



 3           CERTIFICATE  OF REPORTER	     44



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                             ANN S. HORNE REPORTING SERVICE

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 1
                             PUBLIC HEARING
 2        A  public  hearing on the Draft Environmental Impact



 3    Statement,  the proposed issuance of a National Pollutant



 4    Discharge Elimination System Permit, and State



 5    Certification  of  the NPDES permit for the Farmland



 6    industries,  Proposed Phosphate Mine and Beneficiation Plant,



 7    Hardee  County,  Florida,  was held on July 14,  1981, at



 8    7:00 p.m. in the  Hardee County Agricultural and Civic Center,



 9    at Altman Road and Stenstrom Road, in Wauchula, Florida.



 10        Thereupon, the following proceedings were had and



 H    taken:



 12        MR. IIAGAN:   Good evening,  ladies and gentlemen.   My name



 13    is John Hagan.  I am the chief of the Environmental Impact



 14    Statement Branch  of Region -IV,  Environmental  Protection



 15    Agency  in Atlanta,  Georgia.



 16        With me this evening on the hearing panel is



 17    Mr. Mickey  Bryant,  representing the Florida Department of


 19    Environmental  Regulation,  Mr.  Roosevelt Childress, an



 19    environmental  scientist in the permitting process section,



 20    Enforcement  Division of EPA in Atlanta,  and Ms. Jean  Tolman



 21    who has been the  Environmental Impact Statement Project



 22    Officer for  the preparation of this EIS.



.23        This evening's; hearing will address possible action by



 24    EPA with respect  to Farmland Industries'  phosphate mine and



 25   ;beneficiation:-plant: proposed-for construction in or near the




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 1    town of Ona, Hardee County,  Florida.
 2         The proposed project was  determined hy the Regional
 3    Administrator of EPA,  Region lv  to constitute a new source
 4    under Section 306 of the Clean Water  Act.   That's 33 U.S.
 5    Code 1251.  This requires the  issuance of a national pollutan^
 6    discharge elimination  system permit,  otherwise known as an
 7    NPDES permit.   Issuance of an  NPDES permit to a new source
 8    facility is by  law a major federal action and is therefore
 9    subject to the  provisions of the  National Environmental
10    Policy Act of 1969.
11         The National Environmental Policy Act of 1969,  as
12    amended, requires federal agencies to prepare an environ-
13    mental -impact statement on major  federal actions which
14    significantly effect the quality  of the human environment.
15    The Regional  Administrator of EPA  Region IV determined that
16    the proposed Farmland  facility would  have a significant
17    impact on the quality  of the human environment.
18         To meet the requirements  of  NEPA,  a draft environmental
19    impact statement has been prepared and FPA has distributed
20    it government agencies and to  the public.   Notice of its
21    availability was published in  the Federal Register,  Volume 46
22    No. 108, dated  June 5th, 1991.
23         In addition to FPA's action, the state of Florida has
24    been requested  to certify the  proposed NPDF.S permit in
25    accordance with the provisions of Section 401 of the Clean
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 1    Act.


 2         This hearing is for the purpose of  receiving  comment  on

 3    the draft environmental impact  statement,  the proposed

 4    issuance of the NPDES permit, and the  state  certification

 5    of that proposed permit.

 6         The Federal Water Pollution Control Act, commonly

 7    referred to as the Clean Water  Act, has  as its  explicit  goal

 8    the elimination of discharge of pullutants by 1985.   To

 9    achieve this goal, the act created the National Pollutant

10    Discharge Elimination System, a national permit program to

11    control the discharge of pollutants into the nation's waters.


12    Under this permit program, anyone who  proposes  to  discharge

13    wastes into waters of the United States  must receive  a

14    permit setting limits and conditions on  the  discharge of

15    pollutants.  The act requires strict limits  for new sources

16    such as the Farmland Industries' facility.  The NPDFS permit

17    is the basic regulatory tool for water pollution abatement

18    under federal law.  This discharge must  be in compliance

19    with it's permit effluents upon initiation of the  discharge.

20    And any violation of the terms  or limits of  the permit will

21    subject the discharger to civil and/or criminal penalties.

22         In accordance with this NPDES permit  system and


23    Subsection 306(c) of the Clean  Water Act,  Farmland Industries


24    has applied to the Environmental Protection  Agency for a

25    permit to discharge pollutants  from its  plant to be
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constructed and operated near the town of Ona in Hardee

County, Florida.  The permit application describes two

proposed discharge points from the facility.  The primary

discharge, proposed outfall Serial No. 001, would discharge

from the clear water pond to Hickory Creek at a location

given as Latitude 27 degrees 27' 54" and Longitude 81

degrees 53' 6".  The proposed outfall Serial No. 002 would

discharge from the area described as the reclamation area

into Oak Creek at about Latitude 27 degrees 27' 44" and

Longitude 81 degrees 54' 43".  Both receiving streams are

tributaries to the Peace River and are classified by the

state of Florida as Class III.  That is recreation and

propagation and management of fish.

     The draft NPDES permit proposed for Farmland Industries

was prepared by the staff of Region IV, FPA, using applicable

water quality standards and new source performance standards

for the mining—mineral and mining point source category,

phosphate rock subcategory, contained at Title 40 Part 436 of

the Code of Federal Regulations, and the best professional

judgment of the staff concerning the application of these

guidelines to the site-specific conditions.  A fact sheet has

been prepared which details the rationale for the permit

limitations and conditions.

     We have made available for distribution here this

evening copies of the public notice, the fact sheet, and othe
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     permit rationale information, and the draft environmental

2    impact statement.  Each of these documents, as well as other

3    relevant documentation and all comments received tonight or

4    submitted in writing by the close of business on July the

5    28th, 1981, will become a part of the administrative record

6    for this permit.  The information in the record will be used

7    in evaluating the draft permit and in either preparing a

8    final draft NPDES permit in the final EIS, or denying the

9    applicant a permit for the proposed discharge.  In addition,

     you should be aware that all public comments on the

     Farmland Industries' facility and the draft environmental

12    impact statement, whether received here tonight and

13    transcribed for the record or whether submitted in writing

14    directly to the EPA, will be summarized and addressed in the

15    final environmental impact statement.

16         This hearing is to be an EPA public information hearing

17    conducted pursuant to 40 Code of Federal Regulations,

18    Subsection 124.42 (b).

          Notice of the public hearing was published in the Tampa

20    Tribune and in the Wauchula Herald Advocate on May the 28th,

     1981.  Additionally, copies of the public notice and fact

22    sheet and the EIS were mailed to individuals and

23    organizations on the EPA mailing list and to all

24    appropriate governmental agencies.

25         At this time, I would like to ask Mr. Mickey Bryant
                        ANN S. HORNE REPORTING SERVICE
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                             3-53      083°

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                                  	^^    8

 of the State Department of Environmental Regulation to make


 any comments he has concerning the State 401 certification.


 Mr. Bryant.


      MR.  BRYANT:  Thank you.   I'd like to,  on behalf of the


 state of  Florida and Secretary Shinkle of the Department of


 Environmental Regulation,  also welcome everyone  here to


 tonight's hearing.   My main reason  for being here  is to


 listen and receive  public  input and comments relative to


 state certification of this proposed phosphate mine.   At


 this  point in time  the department is also currently reviewing


 the environmental impact statement  and has  not formulated


 a  definite position.   And  we  certainly encourage public


 input.


      I might  mention that  in  addition to the requirement


 under Section 401 of the Clean VJater Act that a  state


 issues certification or act upon  certification.  The  state


 of Florida also  will  be involved  in  issuing or at  least


 considering a number of permits for  this proposed  facility.


 These permits will  consider the construction and operation


 and discharges from the mine  as well as  permits  for the


 construction  of  dams  around holding  structures for receiving


wastes, clay  wastes  and sand  wastes  from the mine.


      The public  is  also—has  the  opportunity to become


 involved in the  state  permitting  process.   And it is


encouraged to  send  any comments that they might have relative
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 1    to state permits to our sub-district office  in Tampa,


 2    Florida.


 3         I don't really have any other comments  at this time.


 4    And I am here to listen to your input.


 5         MR. HAGAN:  Thank you, Mickey.


 
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	     10

 Farmland EIS.   However, FPA retains ultimate responsibility

 for the EIS.

      To comply with the goals of NFPA, the ETS must do the

 following:   One,  provide a thorough description of the

 environmental  background and setting;  two, evaluate all

 reasonable  alternatives which meet project objectives, as

 well as the no action alternative; assess the environmental

 impacts of  the alternatives; and No. 4,  identify all

 potentially adverse impacts and evaluate means to mitigate

 these impacts.

      At this time,  I would like to call  on Ray Hinkle  of

 Woodward-Clyde  Consultants here tonight  to describe how the

 Farmland EIS preparation was conducted by the third-party

 consultant  to  satisfy the requirements of MEPA.   At the

 conclusion  of  Mr. Hinkle's remarks,  I  would like to conclude

 a  discussion of the EIS development by comparing EPAls

 recommendations and proposed agency action on the Farmland

 project to  the  recommendations contained in the  Central

 Florida Phosphate Industry Areawide EIS.   Ray.

      MR.  HINKLE:  Thank you,  Jean.   What I would like  to  do

 is  just briefly describe in a little bit more detail perhaps

 the  way in  which we were involved  with EPA in the preparation

 of the  document and then talk a bit in addition  about

 content of  the  document itself.  As  some  of you  probably

 recall, this all was started  nearly  two  years ago in the
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                                              	11


 I    scoping meeting held in Mulberry, August 1st,  1979.  Of


 2    course, several things have happened along the way to


 3    bring us to this date.  And I'll just briefly  mention  some


 4    of those to kind of set our time—our spot in  time today.


 5    Following that scoping meeting, a final plan of study  was


 6    prepared for work on EIS and work was initiated and proceeded


 7    through the end of 1980 when a modification project was made


 8    by Farmland and at the direction of EPA the scope of FIS


 9    was modified to reflect a—the—rather the exclusion of the


10    chemical plant portion which had previously been proposed as


11    part of the action.


12         At this point the alternatives considering—concerning


13    the chemical plant were omitted as well as any discussions


14    of impacts of that part of that project and the preliminary


15    draft was prepared for EPA review.  That occurred in the


16    period between February and April 1981.  And the draft which


17    was submitted for the reproduction and distribution was


18    completed in May of 1981.


19         As Jean indicated, the basic components of the draft


20    EIS are a description of the alternatives which meet the


21    project goals.  These alternatives include Farmland's


22    proposed action.  Also included is a description of the


23    existing environment of that of the Farmland site and  a


24    description of the impacts of the various alternatives on


25    that existing environment.  The alternatives evaluation is
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 what is considered to be the part of the RIS.  It is really


 where the least damaging or most environmentally suitable


 means of achieving the project goals come forth and can be


 then evaluated with other alternatives,  evaluating in


 addition the technical and economic aspects of each.   The


 proposed action,  that being the mine only,  is the same


 action as was discussed by Farmland during their DRI


 hearings which again many of you may have heard or may have


 had  the opportunity to attend.   So that,  in effect, we're


 talking about the same project.   And the proposed action


 with the addition of some mitigating measures is also as


 Jean will discuss the EPA's preferred alternative.   So that


 we're all, really I think,  talking about the proposed action


 as kind of the alternative that is to get the—in the lime-


 light,  so to say.


      Farmland's objective is to produce  two million tons per


 year of wet  phosphoric rock over a 25 year  life of  the mine.


 This will require the mining of some 4,951  acres of the


 7,800  acre site with an additional 329 acres to be  occupied


 by other facilities such as the beneficiation plant.   During


 the.  life of  the mine,  all of the rock mined from the  tract


will  be  shipped to existing fertilizer plants for conversion


 to finished  fertilizer with approximately 50 percent  of the


tonnage  going  to  Farmland's existing phosphate fertilizer


manufacturing  facility at Green Bay.   The rock currently
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 1    being processed at that existing  facility  has  historically



 2    been purchased from other producers of  raw material  in



 3    Florida.



 4         The initial phases of the proposed activity would



 5    include land clearing and open burning  in  advance  of the



 6    mine.  The cleared acreage in front of  the mining  operation



 7    being about 20 acres.  The mine operation  will  involve  a



 8    single large dragline supplemented beginning in year 10 by



 9    a second smaller dragline.  The mine matrix will be  slurried



10    and transferred by a pipe line to the beneficiation  plant



11    for washing, to separate several—pebble product,  clay,



12    and fines and for floatation to recover additional product.



13    The wet rock will be stored temporarily at the  plant.



14         Farmland plans to construct  a railroad spur  to the



15    plant linking it with the existing Seaboard Coastline



16    Railroad and rail ship the product from the plant  to the



17    receiving phosphate fertilizer plants.  There will be



18    impacts that will result as, or occur as a result  of these



19    activities.  And what I would like to do is just briefly go



20    through the various disciplines which are  discussed  within



21    the document and perhaps highlight some of the  impacts  that



22    would result.



23         Air quality meteorology and  noise  impacts  will  result



24    from both mining and processing activities.  These will



25    however be minor increases, notably in  fugitive dust




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 !    emissions and emissions from internal combustion engines.

 2    There  will also be minor emissions of all reagents used in

 3    the  processing.  Noise levels will be increased in the

 4    vicinity  of operating equipment,  but should dissipate within

 5    relatively short distances.   Geology and soils impacts will

 6    result from the disruption of surface soils and overburden

 7    over 4,951 acres of the site and  a—and the mine will result

 8    in a completion of some four million tons of phosphate rock

 9    reserves  over the life of the mine.   Waste disposal and

 10    reclamation will also result in the  formation of unnatural

 H    surface soils on the site.   The acreage being as follows:

 12    sand-clay  mix  reclamation areas,  3,915 acres;  clay disposal

 13    areas, 583 acres;  sand disposal areas 104 acres; other types

 14    of land disturbance would be—and reclamation would be land

 15    and  lakes,  567  acres as well as 111  acres of land left

 16    following  construction.   That would  be buildings and such

 17    that are removed,  but the land disturbed.   Radiation levels

 18    will be increased at the surface  within the surface soils.

 19    The—this  will  result as a result of the natural—it will

 20    result in  the natural distribution being altered resulting
                                                       (picocuHe)
 21    in higher  levels than the generally  less than one hy-Picocury
22
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per gram radium 226 currently found on the  site.  Examples
23    are that the average radium  226  level  in  sand-clay mixer  is—
                                             (plcocurles per gram).
24    should be on the order of three  to four hydrograms Picocury.
     The levels in clay areas should be on  the order of  six
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(picocunes per gram),             ~
hydrograms Picocury.  Areas reclaimed  with sand will have
the lowest of the three types of  unnatural  soils.   These
                                                 (picocuries  per
having radiation, radium  226 levels  of  about  two hydrograms

gram)
Picocury.  Groundwater will be withdrawn for  use in process-
ing.  The average rate being  8.83 mgd.   This will cause a


lowering of the potentiometric  surface  in the immediate site


area.  The Surficial Aquifer  will also  be lowered in the


vicinity of active mine  cuts  due to  the dewatering simply


through the surface or the  Surficial Aquifer waters draining


into the pits.  Surface  waters, there will be a disruption of


surface water  flows from the  mine site.  Following


reclamation, however, these alterations will be such that


the end or the net difference is only -.5 CFS so that


surface flows  will be returned  following reclamation.  There


will be discharged into  surface waters  from two discharge


points which will described to  you.   These are planned so


that they will occur at  times when  flows are above the


normal flow, I'll say, and  that the streams should absorb


the pollutants, I'll say, that  are  contained within the


discharge so that they do not exceed any standards.


     The destruction of  aquatic habitats on the mine site


will result in losses of aquatic  organisms.  However,


reclamation of the  site  will  be such that there will be many


acres of acquatic habitat provided that are now lacking.


Currently, the surface waters on the site support primarily
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 I    fish species such as mosquito fish  and ki.llif Ish.  The


 2    creation of some 500 acres of lakes and meandering streams.


 3    will provide additional habitat for species such as large


 4    mouth bass and bluegill and red-eared sunfish.   The mining


 5    will also result in destruction of terrestrial  habitat on the


 6    site.   The totals being as follows:  pasture 1,960 acres;


 7    citrus 1,757 acres;  early successional areas which are


 8    really roadside type areas where the plants are just becoming


 9    established 95 acres; pine flatwoods, palmetto range 583


 10    acres;  upland forest 280 acres;  swamp 320 acres; marsh 285


 11    acres.   The species  affected by the disturbance include a


 12    species which is considered threatened by the US Fish and


 13    Wildlife Service, that being the Eastern Indigo Snake.


 14    The impacts on the Eastern Indigo Snake population, however,


 15    are not considered to be significant.  And therefore the


 16    proposed action does not represent a threat to  the


 17    continued existence  of the species.  There are, however,


 18    mitigation measures  which are proposed to reduce the impacts


 19    on this species.


 20         The socio-economic impacts  which the project will


 21     result in include the generation of jobs  with comparatively


 22     high incomes for Hardee County,  the addition of ad valorem


 23     and sales tax revenue for Hardee County,  the creation of


24     severance tax revenue for the state,  land reclamation trust


25     fund,  and Florida Institute of Phosphate  Research.   There
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!    will be some additional influx of population to Hardee


2    County which will have an increased or will create an


3    increased demand for housing, transportation, fire protection


4    police, and medical services.  But these should all be within


5    the capabilities of the county to handle.  The monetary


6    returns to the county are sufficient to cover those increased


7    costs.


8         I think that basically provides an overview of the


9    impacts of the proposed action.  There are other alternatives


10    as I say, that were considered which have different impacts


11    in some cases, particularly on surface waters and in some


12    cases on terrestrial habitats.  These are discussed in the


13    EIS in more detail.  And I think that would be a better


14    source rather than taking more time here.


15         MS. TOLMAN:  Thank you, Ray.


16         The Central Florida Phosphate Industry Areawide EIS


17    published by EPA in 1978 contains several recommendations for


18    future phosphate mining operations.  These guidelines were


19    kept closely in mind in evaluating Farmland's proposed project


20    and in developing and evaluating alternatives and mitigating


2i    measures.


22         EPA's recommendations and proposed agency action are


23    embodied in the draft NPDES permit contained in the DEIS,


24    specifically in the 15 NEPA generated permit conditions


25    found in the last six pages of the draft permit.  Those of you
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 !    who have the  fact  sheet  in  hand might  like  to  turn  to



 2    Attachment C, the  permit.   These  permit  conditions  follow



 3    the order of  the Areawide EIS  recommendations  and I would



 4    like at this  time  to quickly go over the recommendations and,



 5    where applicable,  the corresponding permit  condition.



 6    First, the Areawide EIS  recommended the  elimination of



 7    the rock-drying process  at  beneficiation plants and the



 8    transport of  wet rock to chemical plants.   The proposed



 9    Farmland project does not include a rock dryer and  calls



 10    for all rock  to be transported from the  site in a wet



 11    condition.  Secondly, the Areawide EIS called  for any new



 12    source mine to meet state of Florida and local effluent



 13    limitations for any discharge.  The draft NPDES permit



 14    prescribes limits which  will meet those  effluent limitations.



 15    They will be  addressed in some detail by Mr. Childress on my



 16    left.  Third, the elimination of conventional  above ground



 17    slime disposal areas was a  recommendation by the Areawide



 18    EIS.  In order to meet this recommendation, the Areawide EIS



 19    encourages the use of a  mixture of sand  tailings and  waste



 20    clays in reclamation while  at the same time it recognized



 21    the need for  an initial  above ground storage area.  Farmland1!



 22    proposal conforms to this recommendation, and  NEPA  generated



 23    Permit Condition No. 1 reads:  Farmland^  shall  exclude the



24    utilization of any conventional above ground slime  disposal



25    areas with the exception of clay setting areas I and  II




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described in the EIS.  Farmland's waste disposal and


reclamation plan shall employ a sand-clay mix process as


described in the EIS.  Only settling area II shall remain


active for the life of the mine.  Furthermore, Permit


Condition No. 2, proposed by EPA is a—as a further mitigatini


measure, reads:  Farmland shall perform the dragline mining


operation in a fashion that increases the casting distance


of the overburden, causing the overburden to be piled higher


and thereby increasing by approximately 10 percent the below


ground volume available for waste disposal and lowering the


above ground profile of settling area II by approximately


four feet.  I might add that this was the mitigation measure


that was suggested by the mining engineer as part of the


third party consultant team.  The Areawide EIS recommended


that any new source mining operation meet Southwest Florida


Water Management District consumptive use permit requirements


Farmland is obligated to the terms and conditions of the


SWFWMD permit.  Should Farmland fail to comply with the


permit, the permit will automatically become null and void.


In addition, EPA has made this obligation a part of the


NPDES permit by Condition No. 3 which reads:  Farmland shall


meet the requirements of its Southwest Florida Water


Management District Consumptive Use permit.  The Areawide


EIS recommended that new source minutes provide storage


allowing for recirculation of water recovered from slimes.
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 The water recirculation system for Farmland's proposed mining


 operation provides for containment and for approximately 90


 percent water recirculation so that a discharge should be


 required only during periods of heavy rainfall.   Commitment


 to this proposed system is required by Permit Condition No.


 4,  which I will  not read out loud.  I believe you have it


 before  you.   Another AEIS recommendation was  for the use of


 connector wells.   Farmland does not propose to  use connector


 wells for recharging the Floridan Aquifer from  the Surficial


 Aquifer,  not  does EPA recommend it in this case.  It is not


 considered desirable since high gross alpha radiation levels


 were found in the Surficial Aquifer at the site.  The


 Areawide  EIS  recommended that  new source mines  develop minina


 and reclamation  plans that reduce the amount  of radiation


 at  the  surface.   Permit Condition No.  5 states  that:   During


 the dragline  mining activity,  Farmland shall  employ the


 technique of  leach zone management by toe spoiling,  that is,


 overburden from  near the interface with the matrix (the leach


 zone, where radioactivity in the overburden is  concentrated)


 shall be  placed  at the toe of  the spoil pile  and covered with


 overburden from  upper strata.   The Areawide EIS recommends


 that new'source mines meet county and state reclamation


 requirements  and  that they conduct an inventory of types of


wildlife  in the mine site.  On December 4th,  1980,  Hardee


County issued Farmland a  development  order for  their  project.
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     applicable—pardon me—the permit condition applicable  to




4
3


    this recommendation  is No.  6, which  states:   Farmland shall
     meet county and state reclamation requirements.   Also,  an
o


     inventory of wildlife habitats on the site was made and
6


„    is included in the DEIS.   The Areawide EIS recommends that
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    A master plan has also been  filed pursuant  to the county's



    mining and earthmoving ordinance.   The permit condition
     the  mining  and  reclamation plan take into account the



     protection  and  restoration of habitat so selected species of



     wildlife will be protected.   Farmland's  mining plan calls



     for  areas to be cleared  only as mining  approaches.  Included



     in the  reclamation plan is the restoration of some mined



     areas as wildlife  habitat.   Lastly,  Farmland proposes to



     preserve approximately 2,500 acres on the site.  This



     commitment  is include  in Permit Condition No. 7,  which



     states:  Farmland  shall preserve from mining, or  any other



     disturbance, the areas proposed for preservation  in



     Farmland's  proposed action in the EIS.  These areas are



     depicted in the attached map, Figure 1.   These areas—pardon



     me—specifically,  the  total preserved acreage of  2,530 acres



     shall  include a minimum of 510 acres of  forested  uplands,



     885  acres of freshwater swamp, 107 acres of freshwater marsh,



     and  354 acres of pine  flatwoods/palmetto range, all in the



     locations depicted in  Figure 1.  Additionally, EPA proposes



     as mitigating measures Permit Conditions No. 8 and 9.  These
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 1    also apply to  that  recommendation  in  the Areawide EIS.   No.


 2    8 reads:  Farmland  shall  increase  the acreage  reclaimed  as


 3    forest habitat and  provide  corridors  for wildlife movement


 4    between reclaimed and preserved  areas by planting additional


 5    areas as depicted in Figure 2, attached,  also  in  your permit


 6    fact sheet.  No. 9  reads:   Farmland shall incorporate into


 7    its reclamation plan a  littoral  zone  at  the  downstream extent


 8    of the proposed reclaimed open lake in the Hickory Creek


 9    channel.  This littoral zone shall be at least 500 feet  wide


 10    and at a depth suitable for emergent  vegetation,  providing


 11    for the establishment of  7  to ten  acres  of marsh  community.


 12    I might interject at this point  that  this is not  the only


 13    instance of littoral zone provisions.  This  is in addition


 14    to the littoral zone vegetation, revegetation  already been


 15    included in the proposed plan.   This  is  a mitigating measure


 16    which adds to  that  already  being done.    Farmland's proposed


 17    project, as Mr. Hagan pointed out, will  affect one species


 18    considered threatened by  the US  Fish  and Wildlife Service.


 19    To mitigate effects on  the  Indigo  snake,  EPA proposes


 20    Permit Condition No. 10.  Permit Condition No.  10 reads:


21    Before beginning any land-disturbing  activities,  Farmland


22    shall develop  a program whereby  Indigo snakes  encountered


23    in the work area are captured for  relocation to other areas


24    of suitable habitat in  the  site  region.   This  program shall


25    include informing Farmlarid  workers of the importance of  the
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 1    Indigo snake, familiaring them with its appearance and


 2    instructing them as to its preservation.  In addition, the


 3    gopher tortoise population shall be protected to the extent


 4    possible in the site area.  Farmland shall coordinate its


 5    recovery and relocation  efforts with the Endangered Species


 6    Coordinator, and shall maintain a record of the program to


 7    be submitted to the US Fish and Wildlife Service.  The


 8    Areawide EIS recommended the protection and restoration of


 9    wetlands under jurisdiction of the Corps of Engineers


10    pursuant to Section 404 of the Clean Water Act.  The Areawide


11    EIS established three categories of wetlands.  No specific


12    boundaries or wetlands area have been officially identified


13    by the Corps of Engineers.  The following three categories


14    of wetlands, however, were established by the EPA in the


15    Areawide EIS:  Category 1, wetlands to be protected, not


16    mined or disturbed; Category 2, wetlands which may be mined


17    but must be restored as wetlands capable of performing useful


18    wetland functions; Category 3, wetlands which can be mined


19    without restoration as wetlands.  Wetlands on the Farmland


20    site were categorized "fallowing EPA criteria.  Wetland area


21    on the property were classified as either Category 1, 2, or


22    3.  Farmland's proposed mine plan will result in the loss


23    and protection of the following acreages of each of the above


24    wetland categories.  Category 1, acres lost 0, acres protected


25    710, percent protected 100 percent.  Category 2, acres lost
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 1    502, acres protected 264, percent protected 34.  Category 3:


 2    acres lost 91, protected 18, percent protected 16.  Farmland1

 3    reclamation plan would restore 398 acres of wetlands on the


 4    Farmland mined site.  This amounts to 77 percent of the

 5    Category 2 wetlands on the site.  I might reiterate,


 6    Category 2, wetlands according to EPA's criteria should be

 7    restored in their entire acreage.  Therefore, EPA proposes


 8    Permit Condition No. 11.  Permit Condition No. 11 reads:

 9    Farmland shall comply with the categorization of wetlands

 10    present on the mine site as set forth in the EIS and


 11    illustrated in Figure 3, attached.  In summary, within


 12    Category 1 wetlands, Farmland shall not mine, shall limit

 13    activities to those essential to and unavoidable for the


 14    mining operation,  and shall otherwise take all reasonable


 15    measures to preserve all Category 1 wetlands.  Additionally,

 16    Farmland shall restore the total acreage of Category 2


 17    wetlands disturbed by mining.  Specifically, the acreage to

 18    be  restored as freshwater marsh or swamp according to


 19    Farmland's proposed action in the EIS shall be increased by


 20    at  least 116 acres (from 398 acres to a minimum of 514

 21     acres).   This shall be done by differential grading and

 22     settling of sand-clay mix areas in addition to that


 23     already  proposed by Farmland in the EIS.   In addition,


24     Conditions 12 and  13 are mitigating measures proposed by EPA


25     to  further minimize impacts on wetlands.   No.  12:   During
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 the  mining  of  the unpreserved portion  of  Hickory Creek,  the



 flow from this area  shall be diverted  around  the active



 mine area into the lower preserved  section  of Hickory  Creek



 rather  than to Troublesome Creek.   Thirteen:   Mining in  the



 vicinity of lower Hickory Creek  shall  be  scheduled  such  that



 open mine pits exist adjacent to only  one side of the



 preserved portion of the creek at a given time.



      The final Areawide EIS recommendation  applicable  to



 Farmland is to attempt to preserve  archaeological or



 historical  sites through avoidance  or  mitigation.  An



 archaeological and historical survey of the Farmland site



 was  conducted. The  State Historic  Preservation Officer  for



 Florida concluded that the archaeological and historical



 resources of the site did not merit any mitigative  measures



 or preservation.



      Permit Condition No. 14 has no direct  relationship



 to a recommendation  of the Areawide EIS,  but  reflects  rather



 the  new technology represented by the  use of  sand-clay mix.



 No.  14  reads:   Farmland shall monitor  the water quality  of



 the  Surficial  Aquifer at the location  identified on the



 attached map,  Figure 3.  The following parameters shall  be



 monitored on a quarterly basis for  the life of the  mine: pHf



 specific conductance, sulfates,  fluoride, and ammonia.  A



 written report summarizing the data shall be  submitted once



 a year  to EPA. The  purpose of this is we are dealing with




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 I     a  new technology and we're trying to establish what exactly


 2     does  occur,  what,  if anything,  does seep out and stand in


 3     this  area of the Surficial Aquifer.


 4          No.  15  is what might be described as a general condition


 5     It commits Farmland to carry out the project as described in


 6     evaluating the EIS, so that everything that they propose to


 7     do including all mitigating measures in their proposed action


 8     shall be  done.


 9          No.  15  reads:   Unless specified otherwise by a preceding


 10     condition in this permit,  Farmland shall carry out its mining


 11     project in complete accordance  with the applicant's proposed


 12     action described and evaluated  in the Farmland EIS, including


 13     the employment of all mitigating measures presented as part


 14     of the proposed action.   However, this shall not preclude


 15     the imposition of any additional or more stringent conditions


 16     which may be required by any local or state regulatory agency


 17     or governmental entity.


 18          Thank you for  your patience in going over these rather


 19     extensive permit conditions.  What we're trying to do is


 20     supply information  obtained through the EIS process in a


 21     very  real fashion to a permit issued—proposed to be issued


 22     to Farmland.

 23          MR.  HAGAN:  Thank you, Jean.  Now, I would like to call


24     on Mr. Roosevelt Childress of our Permits Program in


25     Atlanta to discuss  in a little  different light the NPDES
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I    permit that is proposed to be issued.  Mr. Childress.


2         MR. CHILDRESS:  Thank you, John.


3         The draft National Pollutant Discharge Elimination


4    System, NPDES, permit—I'll start again.  The draft—draft


5    National Pollutant Discharge Elination System—the draft NPDES


6    permit for the Farmland Industries was developed by the


7    Permit Processing Section of the Consolidated Permits Branch


8    in EPA.  It is our responsibility to insure that the


9    requirements of the Clean Water Act are carried out.


10         Mr. Hagan has stated that the proposed project was


11    determined by the Regional Administrator to be a new source


12    under Section 306 of the Clean Water Act.  For this reason,


13    the environmental aspects of the project are subject to


14    review procedures specified in the National Environmental


15    Policy Act, abbreviated NEPA.  The review process, as Jean


16    Tolman just discussed, is directed by our EIS Branch.  The


17    NPDES permit issuance process is conducted in conjunction


18    with this review process.


19         In this regard, effluent guidelines have been published


20    to address the wastewater generated from this facility.


2i    However, in some cases, effluent guidelines requirements


22    alone are not enough to insure that the integrity of the


23    water quality within the receiving stream is protected.  This


24    brings me to my discussion of the terms and conditions of


25    the proposed permit.  You should have gotten a copy of it as
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 l     you entered and registered at the registration desk in the


 2     rear of the room.   It will be helpful if you refer to this


 3     draft permit as I  briefly cover its contents.


 4          The effluent  limits on page 1 and 2 of part I are


 5     applicable to wastewater discharges dependent on heavy


 6     rainfall events, which will occur in non-continuous


 7     discharges.   Discharge No. 1 will consist of overflow from


 8     waste settling areas to Hickory Creek and discharge 002 will


 9    originate from the reclamation area to Oak Creek.  The


 10    company expects to discharge 182 days out of the year.  The


 11    effluent guidelines for this industry, Phosphate Rock


 12    Subcategory of the Mineral Mining and Processing  Category,


 13    only identifies total suspended solids and pH as parameters


 14     warranting permit  conditions.  As I said before, the effluent


 15     guideline requirements alone will not protect the water


 16     quality within Hickory and Oak Creeks.  Both creeks are


 17     classified as Class III waters suitable for contact


 18     recreation and the management and propagation of fish and


 19     wildlife.  Therefore, additional parameters included in the


 20     draft permit are biochemical oxygen demand - five day,


 2i     Specific Conductance and combined Radium 226 and 228.


 22          State of Florida requirements for Class III waters


 23     require that the instream measurement of specific


24     conductance  not be raised above a maximum level.  The


25     dilution requirements on page 3 of part I will ensure
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     compliance with this standard.  Conductivity is a measure




     of the ability of water to conduct an electric current.




     This measurement can be used to indicate the total amount of




 .    dissolved solids in the effluent.  State standards also
 4



     require that radium limits and more stringent pH upper
 3



 6    limit of 8.5 to be placed in the permit.  The effluent




 7    guideline requirement for pH is 6.0 to 9.0.  So in writing




     the current conditions we had to use the more stringent




     standard of 8.5.




10         Also on page 3 of part I is a statement which will




     relieve the company from complying with the total suspended




     solids and pH conditions during a heavy rainfall even which




13    might occur once in 10 years if the treatment facilities




14    are designed and maintained to meet certain criteria.




15         Finally, the permit conditions I have just discussed




16    constitute the principle part of the permit from an NPDES




17    standpoint.  However, as previously explained, a new source




18    such as this facility is subject to additional environmental




19    regulations under NEPA.  And those conditions were just




20    discussed by Jean Tolman.




          Thank you.  John.




22         MR« HAGAN:  This concludes the Environmental Protection




23    Agency and the state of Florida's presentation with regard




24    to this permit.  It is now time for the principal purpose of




25    our meeting which is to receive the public comments.  A goal






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 1    of the Clean Water Act and National Environmental Policy


 2    Act is to be encouraged and provide for public participation


 3    and input into the decision-making process for actions


 4    legislated by these two acts,  to encourage governmental


 5    responsiveness to the public,  and to promote a general


 6    awareness of the actions proposed by federal agencies, we


 7    are now conducting this public meeting.


 8         We asked you to register  so that we may have a record


 9    of those in attendance, and also that we can send you the


 10    notices of our determination regarding this permit.  If


 11    you have not already registered and wish to make an oral


 12    statement,tonight, we ask that you do register and indicate


 13    that you wish to make a statement on the registration card.


 14         There are some other formalities here that I think I


 15    need not go through.   The rules of our public hearing


 16    process are really quite simple.  We ask you to come to the


 17    microphone, identify yourself  and—for the benefit of our


 18    court reporter,  and then make  your statement.  We have only


 19    one person so far who has indicated that they wish to make


 20    a  statement.  So with that, I  will not impose any kind of


 21     time limit on the statement to be made.   However, I would


 22     ask that if the statement that is to be  made is a lengthy


 23     or highly technical statement, that you  present to us in


24     writing so  that the court reporter can get it entirely


25     correct.   Our first and only registered  speaker tonight is


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 1    Murray Hellein, H-e-1-l-e-i-n.


 2         MR. HELLEIN:  Do you want me to come on up  there?

 3         MR. HAGAN:  Yes, if you would come to the rostrum  for


 4    us/ please/ sir?


 5         MR. HELLEIN:  You know, on the—your overflow or that


 6    waste material that is coming off of there, what effect now


 7    will that have on the cattle?

 8         MR. HAGAN:  On the cattle?  Does  anyone—do you care


 9    to address that?  Do you have a specific concern for the

10    cattle?  You know, are you  in the cattle business?


11         MR. HELLEIN:  I have.  I've got some people here that


12    do, so that's, you know, whan you say  you're going to unload it,

13    dump it down Hickory Branch, I was just wondering what  effect

14    would that have on the cattle?

15         MR. HAGAN:  I would have to defer, I think,  to our


16    third-party consultant and  ask him if  it has—what the  water


17    quality in Hickory Branch is going to  be as a result of this


18    discharge.

19         MR. HINKLE:  I think that's a question that we'll  have


20    to address in specific terms, you know, in the response


21    section of the final  EIS.   I don't know if we  can actually


22    come up with the numbers at this time.


23         MR. CHILDRESS:  Well,  one thing,  one thing  I would like


24    to say to address that, is  that the discharge would only


25    occur during a heavy rainfall event such that the dilution
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 1    of the wastewater from the facility should be so great,


 2    because the rainfall then should be one such that it might


 3    occur maybe once in ten years.to cause the effluent to over-


 4    flow.  So it would not be a continuous discharge.


 5         MR.  HELLEIN:  All right.  Now, are they going to put


 6    a  monitoring station down on Hickory Branch there at Murphy


 7    Road where it's coming out?


 8         MR.  HAGAN:  Yes, there will be a monitoring station


 9    there.


 10         MR.  HELLEIN:  Mow,  you just put one up down on Whidden


 11    Road at Oak Creek.


 12         MR.  HAGAN:  That's  a USGS  gauging station.   That's not—


 13    that's not one  of our monitoring stations.


 14         MR.  HELLEIN:  Then  they'll be one put up on each road


 15    though or on Hickory Branch there?


 16         MR«  HAGAN:  There will be  monitoring on the branch, yes.


 17         MR.  HELLEIN:  All right.


 18         MR.  HAGAN:  I might point  out that the water quality


 19    standards for both of these streams are for fish and wildlife


 20    And the numerical standards,  the water quality that goes


 2i     along with that use classification is specifically designed


 22     to protect fish and wildlife.  And, you know,  it would be my


 23     presumption that the same water quality would be sufficient


24     to protect that.   That's a presumption on my part.   And as


25     Mr.  Hinkle indicated,  we will address that specifically in
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1    the final EIS.


2         MR.  HELLEIN:  Well, I know on the other ones, runoffs


3    on other mines, it's so brown you can't never see through it.


4    And I just wondered how that—how anything can live in that.


5         MR.  HAGAN:  We saw some pretty nice brown water streams


6    this afternoon and they had fish in them.


7         MR.  CHILDRESS:  I would like to—I would like to also


8    add that this industry is one which was studied by FPA to


9    identify the type of pollutants that would be in the waste-


10    water.  And the only ones that can be identified to include


11    as permit conditions were suspended solids and pH.  If they


12    had chemicals within the wastewater toxic enough to do any


13    harm to the fish and wildlife, we would have identified them


14    biochemical effluent guidelines.  And also this industry is


15    not one of the industrial categories which were identified


16    in the NRPC as containing toxic materials.


17         MR.  HELLEIN:  All right.  And what about on the dust


18    control now?


19         MS.  TOLMAN:  Dust emissions, do you mean dust that	


20         MR.  HELLEIN:  Right.


21         MS.  TOLMAN:  OK.  That is something also that is


22    evaluated and discussed in the environmental impact statement


23    The conclusions in the environmental impact statement were


24    to the effect that the emissions, and we're not talking about


25    emissions from handling dry rock or emissions from a
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      chemical  plant,  all we're talking about is earthmoving




 2    equipment going  out and stirring .up dust which is not




 ,,    considered to have any impacts off the property.
 o



 4        MR.  HELLEIN:   All right.




          MS.  TOLMAN:   Or during the—the dragline stirs up a
 O



 6    little  dust when it picks up a, you know, a bucketful of




 7    earth.  The beneficiation plant, the rock product,  everything




 8    is  in a wet condition.  So in summary, I hate to  paraphrase




 9    the EIS because  it's a much better source of information




 10    than I  am sitting  here, but briefly it says that  dust




 n    emissions are not  considered to be a significant  problem




 12    with this mining and benefication operation as presently




 13    proposed.




 14        MR.  HAGAN:  Mr.  Bryant had a remark about the  water




 15    guality.




 16        MR.  BRYANT:   Yes, I'd just like to point out that,  as




 17    I mentioned earlier,  the department has not taken the




 18    position  on this mine and while there are recommendations,




 19    I'm sure  in the  record now there's certain monitoring and




 20    for certain limitations on the discharge in the draft permit.




      The department is  not prevented and shall consider  the
£»\



 22     inclusion of any other monitoring—any other parameters  in




23     the monitoring program and also other parameters  as




24     limitations  on this mine where we feel that it may  be of




25     concern.   I  know of one parameter that I don't believe is
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25
listed in the parameters to be-monitored,  is  fluoride.  And


that may be a parameter of some concern.   However,  fluoride


levels discharging from phosphate  mines that are not

connected with a chemical plant are considerably  lower.  But


I'm sure that is one parameter that we'll  be  concerned about

and will be required to be monitored.  And there  is a current

limitation, a state board quality  standard limitation for


fluorides.  And I'm sure that that standard will  be applied


to this permit.  I can't say particularly  at  this point any


other particular parameters that may be included.   I won't


exclude that there won't be others.  In addition  as far as


the monitoring goes, the department will evaluate where the


current monitoring requirements and may identify  other


locations.  If we feel they need to be monitored  at least


over a period of time to ascertain some downstream  impacts


or effects, and so very likely there may be a program to


monitor these effects for a period to determine the level of


impact.  And if the impact shows to be very minor>  then, of


course, those additional monitoring locations may be reduced


or the number of parameters be monitored may  be reduced at

some future time.


     MR. HELLEIN:  All right.  Will there  be  any  effect on


any of the wells down there?


     MR. HAGAN:  Well, you're asking questions, sir, that I


believe are really addressed in the EIS.   Have you  read the
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    	36

 !    EIS?


 2         MR..  HELLEIN:   Mot all of it.


 3         MR.  HAGAN:  Well, you know,  you're asking us to reiterate


 4    information here that I believe is really contained in the


 5    EIS.  We're—we're primarily here  to get comments on the FIS


 6    and, you  know,  I think we should  limit our discussion tonight


 7    to comments on  the FIS.  And I would—I would ask you if you


 8    would to  take advantage of the information that's in the


 9    document.   And  then if you have some questions that you—that


 10    you don't understand or some information that is not included


 11    in the document, then we'll be glad to address that.


 12         MR.  HELLEIN:   All right.   Fair enough.


 13         MR.  HAGAN:  Thank you.  Mr. Harwell, from Farmland, is


 14    our first maybe  on the list.   Did  you wish to say anything?


 15         MR.  HARWELL:   Richard didn't  have anything to say, so


 16    I'll withhold anything.


 !7         MR.  HAGAN:  Our—as I say, our meeting  is quite


 18    informal.   Is there anyone else who has not  previously


 19    indicated that they wish to speak  that would like to make a


 20    comment or  raise an issue?  Sir, would you come to the


 2i    microphone  and identify yourself,  please, sir?


 22         MR.  ABRONS:   I think my voice can carry if you don't


 23    mind.  I  just have a very simple question. One of the


24    conditions  is the  establishment of a littoral zone.


25         MR.  HAGAN:  Would you identify yourself for us?
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 1         MR. ABRONS:  Yes.  Herbert Abrons.


 2         MR. HAGAN:  Thank you, sir.


 3         MR. ABRONS:  A-b-r-o-n-s, Overlook Groves.


 4         MR. HAGAN:  All right.


 5         MR. ABRONS:  One of the conditions is the establishment


 6    of a littoral zone in the lower portion of Hickory Creek.  I


 7    just wanted to get a clear idea of what a littoral zone is.


 8    I'm not 100 percent sure.


 9         MS. TOLMAN:  Ray Hinkle and I are both biologists.  I


10    don't know who's going to get to answer this.


11         MR. HINKLF:  You've got the mike.


12         MS. TOLMAN:  The littoral zone refers to an area where


13    the water meets the shore.  What you're talking about is


14    you have a slope of land where the water meets the shore.


15    And the littoral zone is that area of interface of water


16    and land where conditions are wet anywhere from the point


17    where it is wet down to a few feet below that where the


18    plants can root and grow and come up out of the water for


19    them to get sunlight.  You see plants like your  macro


20     benthic irivertrates,   plants like that where they can—the


21    water is not too deep that they can root and grow and come


22    out of the water.  And these littoral zone areas are marsh


23    areas and provide important habitat and play an important


24    role in the wetlands.  So if you have a—the opposite would


25    be where you'd have just a straight vertical sloping—I mean



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 1    a vertical—what am I trying to say—what is the sort of

 2    situation—where the water and the land meet,  you don't have

 3    this  zone.  You just have the one point.   And there's no

 4    opportunity for vegetation to grow there.

 5          MR. BRYANT:  Jean,  in addition littoral zone should

 6    reduce  the amount of erosion that you might anticipate in a

 7    straight body and also serve that function to prevent the

 8    disturbance of the stream through the carrying of sediments

 9    that  are along the bank  as well.

 10          MR. HAGAN:   Are there any additional comments from the

 U    floor or questions from  the floor?  Yes,  sir.   Would  you

 12    come  to the podium and identify yourself  for us,  please,  sir?

 13          MR. MISLEVY:   Paul  Mislevy.   My question is:   You talk

 14    about sand-clay  mixing in your reclamation process.   Can you

 15    tell  me where I  can find some scientific  or research  data

 16    on  this to show specific vegetation,  how  certain vegetation,

 17    whether it be pasture, perennial  grasses, whether it  be corn,

 18    whether it be pine trees,  whatever,  how various vegetation

 19    responds on this type of a mixture?   And  the second part of

 20    the question  which maybe should have been first.   What is the

 21    time  period between digging this  and getting that sand-clay

 22    and getting the  vegetation on there  again?

 23          MS. TOLMAN:   Answering your  first question first,  what

24    I'd like to do is get your address.   I have some references,

25    sources of information that I don't  have  with  me tonight that
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 1
 2
 .
     tonight.   There are several figures depicting the sequence of
 O



     reclamation.   And there is also a table that shows exactly
 7
 o    filled and then what year reclamation of that same area will
 o



 9    be  complete.   So—and in addition there are more details.
10




11




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	39




 I will send to you.   And we'll be happy to provide that, mail




 it to you when we get back to Atlanta.  The second thing is




 that in the draft environmental impact statement which is




 available.   Copies are available for distribution here
     what year during the mine life any specific area will be
 There  are  just-'-some  of  the  drawings are in the EIS,  you



 know,  not  all of  them.   And  the  entire sequence of,  I don't




 know,  maybe  20 drawings  or something like that  is  in  one of




 the supplemental  information documents which we  do not have




available here tonight.  But if you  would like to have those




technical background documents, there are two volumes, again



if you '..ould give me your name and address we would be happy



to send you or anyone else here those drawings.  Let me  ask



Mr. Hinkle.  He's looking at it.  What page is that?




     MR. HINKLE:  The table is on page 11-78.




     MS. TOLMAN:  11—78 for the table and the drawings are  in



the general vicinity.



     MR. HINKLE:  And they start on page  11-67.



     MR. TOLMAN:  They start on page 11-67.




     MR. HAGAN:   Could I ask you, Paul, if you would spell



/our last name for our court reporter.
                        ANN S. HORNE REPORTING SERVICE



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                                                                   40
      MR.  MISLEVY:   Yes, M-i-s-1-e-v-y.   You have a card there


      MR.  HAGAN:   Right.  Thank you.


      MR.  MISLEVY:   You see, I've been trying to get


 scientific data.   And I have had the computer trying to find


 me  scientific  data on this for over a year now.  It comes up


 with  zero.   And  that's why I'm wondering if you have this,


 where you have university or someone, some line of doing


 this,  where we have this type of information.


      MR.  HAGAN:  I think a great deal of the work on sand-


 clay  mix  reclamation is going on right  now in this industry


 right here  in  Hardee and Polk County.  And that's probably


 why you don't  find it in the conventional literature.


 Because the technology is so new and so developmental  at


 this  point.  It just hasn't gotten  into the standard


 literature  yet.  But,  you know,  it  is	


      MR.  MISLEVY:   But Jean said she does have?


      MR.  HAGAN:  It is available, yes.   We have what's


 available.


      Are  there any other comments?


      There  are several copies of the environmental impact


 statement back there at the registration desk if anyone


would  like  to pick up an interesting copy.   It's a great


cure  for  insomnia.


      If there are  no other—if there are no other questions


or comments  tonight,  I would like to thank you-all for coming,
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                                                                   41
1    And I have a closing statement which needs to be read into

2    the record if you'll bear with me.

3         The record of this hearing will remain open through the

4    close of business on July the 28th, 1981.  This will allow

5    anyone wishing to submit additional statements sufficient

6    time to do so.  Further submissions must be in writing to

7    be included in the official record and should be sent to the

8    attention of John E. Hagan, III, Chief, Environmental Impact

9    Statement Branch, EPA, Region IV, 345 Courtland Street,

10    Northeast, Atlanta, Georgia.  Don't try to remember that.

11    It's in your agenda.

12         The final environmental impact statement will be

13    published after the close of the public comment period.

14    And that is after July the 28th, 1981.  The final EIS will

15    consist of a summary of the draft EIS, the agency's tentative

16    decision on the project, responses to the comments received

17    on the draft EIS, the transcript of this public hearing, and

18    any other comments submitted between now and July the 28th,

19    and any other relevant information or evaluations developed

20    after the publication of the draft EIS.  A copy of the draft

21    EIS should be retained if you wish to have a complete

22    evaluation of this project.

23         And I will reiterate to you saying that we do have a

24    two-volume set of technical opinions which goes into

25    considerable more detail on certain items than is included
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 1     in  this draft.
 2         After consideration of  all  the  written comments and of
 3     the requirements  and  policies  in the act and appropriate
 4     regulations/ the  EPA  Regional  Administrator will make
 5     determinations  regarding the permit  issuance.   If the
 6     determinations  are  substantially unchanged, the Regional
 7     Administrator will  so notify all persons making oral
 8     statements tonight  and all persons submitting written
 9     comments.  If the determinations are substantially changed/
 10     the EPA Regional  Administrator will  issue a public notice
 11     indicating the  revised determinations.
 12         Within 30  days of the receipt of the final
 13     determination or  the  date of the public notice/ any
 14     interested party  may  request an  evidentiary hearing on the
 15     determination.  Requests for an  evidentiary hearing should
 16     be  addressed to the EPA  Regional Hearing Clerk  at the
 17     address in your agenda.  The procedures for filing
 18     evidentiary hearing requests are set out in Title 40 of the
 19     Code of Federal Regulations/ Part 124, Subpart  E, or they
 20     can also be found in  Volume  45 of the Federal Register/ page
 21     33498, published  on May  the  19th/ 1980.
 22         Unless a request for an evidentiary hearing is granted,
 23     our determination will be the  final  action for  the EPA and
24    will be made public in the agency's  record of decision a
25    minimum of 30 days after publication of the final EIS.

                        ANN?           ^SERVICE
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 I         Pending final agency action or an evidentiary hearing


 2    which is granted by the Regional Administrator, the applicant


 3    will  be without the permit.


 4         The record upon which a determination to issue is made


 5    will  include both comments received at this hearing and


 6    those received in response to the public notice.  The final


 7    permit will be issued not sooner than 30 days after issuance


 8    of  the final EIS, pursuant to 40 Code of Federal Regulations,


 9    Subsection 124.61.


10         Thank you again for taking your evening to come to our


11    hearing.  We appreciate your attendance.  And I declare this


12    meeting adjourned.


13                           (Hearing concluded.)


14


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                        ANN S. HORNE REPORTING SERVICE

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                      	      44


 1    STATE OF FLORIDA


 2    COUNTY OF POLK


 3         I, ELAINE TURNER,  do hereby certify that a public- hearin


 4    of the US Environmental Protection Agency, Region IV, in


 5    conjunction with Florida Department of Environmental


 6    Regulation in  re:   Farmland Industries proposed phosphate


 7    mine and beneficiation plant,  Hardee County, Florida, was


 8    heard on July  14,  1981; that I was authorized to and did


 9    report on a shorthand machine  the proceedings and evidence


 10    in said hearing and that the above and foregoing pages


 11    numbered 1 to  43 inclusive constitute a true and correct


 12    transcription  of my shorthand  report of said proceedings,


 13         IN WITNESS MY HAND, this  the 31st day of July, A. D.,


 14    1981, at Bartow,  Polk County,  Florida.


 15


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3.4  RESPONSES TO TRANSCRIPT COMMENTS


Response T—1

     A comparison of the water quality of surface water in the vicinity

of the Farmland site and the supernant from several clay settling areas

is presented in Table 3-12 of the DEIS.  Since the primary discharge

from the proposed Farmland facility is to be limited to periods when

Hickory Creek's flow is no less than 1.8 X the discharge flow, the

resultant concentrations in the creek will not be those of the supernant

itself, but rather a combination of the two flows.  If the values

presented in Table 3-12 of the DEIS are considered in this respect, the

mg/1 concentrations presented can be adjusted to account for  this mixing

as follows:
Constituent

Total Dissolved
  Solids
Calcium
Magnesium
Sodium
Potassium
Bicarbonate
Sulfate
Chloride
Iron
Silica
Fluoride
Nitrate, as N
Phosphorus, as PO,
Radium, pci/1
Concentration
  in Surface
    (mg/1)
Concentration in Surface Waters
  After Mixing with Discharge
             (mg/1)
200
20
7.4
9.9
3.6
39.
19.
29.
0.76
8.2
0.2
1.2
253
33
12.6
12.8
2.8
65.
25.
25.
0.53
6.2
0.8
1.1
     1.62
     0.12
                1.14
                0.32
     None of the levels listed above should have an adverse effect on

livestock downstream of the discharge point.  The parameter with  the

greatest potential for adverse effects is fluoride, which if consumed  in

sufficient quantities can cause tooth and bone lesions, lameness  and

stiffness, and decreased weight gain and milk yield.  To produce  adverse

effects, fluoride levels would have to be four times  (4X) the  concen-

trations after dilution listed above.  Even the fluoride level listed
                                 3-91

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for clay pond supernant  in  Table  3-12 of  the DEIS  (2.0 mg/1)  is below
the threshold for adverse effects  on livestock  (3.0 mg/1).

Response 1-2
     Farmland's proposed monitoring plans  include  surface water quality
monitoring of Hickory Creek where  it enters  (south of S.R. 64) and
leaves  (near the Peace River)  the  Farmland property.  However, the
Hickory Creek channel downstream  of Murphy Road  (upstream of  the pro-
posed Farmland monitoring location) borders on both Farmland  and Over-
look Groves, Inc.  Thus, an additional Hickory Creek monitoring station
(at Murphy Road, or S.R. 661)  has  been added as  a  requirement (included
in NEPA Requirement No.  12) of the Draft NPDES permit for the project.
The parameters to be analyzed  for  and the  frequency of sampling at  this
location will be the same as for  the other weekly  surface water sampling
locations which Farmland has proposed in  their "Monitoring Plan" sub-
mitted to and approved by Hardee County.

Response T-3
     Fugitive dust emissions from  the proposed mining operation are
discussed on pages 3-9 thru 3-12 of the DEIS.

Response 1-4
     The projected drawdown resulting from groundwater withdrawal for
the proposed project is  shown  in Figure 3-8 of the DEIS.  The contour
lines shown in this figure  represent the number  of feet which the
potentiometric level of  the Floridan Aquifer (i.e., the level which
water would rise to in an open well) will  be lowered by in the vicinity
of the proposed mine.  As indicated in this figure, the proposed ground-
water withdrawals will reduce  the  water levels in  open wells  in the
immediate vicinity of the mine, but the effect should be less than
1-foot beyond about 3.5  miles  from the well from which Farmland plans to
pump.

Response T-5
     Information on sand-clay  mix  reclamation was  sent to Mr.  Paul
Mislevy.
                                  3-92

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                                                                     4.0

                                                            COORDINATION
4.1  FINAL ENVIRONMENTAL IMPACT STATEMENT COORDINATION LIST


     The following Federal,  state and local agencies,  public officials,

organizations,  and interest  groups have been requested to comment on

this impact statement.
                            Federal Agencies
Bureau of Outdoor Recreation
Bureau of Mines
Coast Guard
Corps of Engineers
Council on Environmental Quality
Department of Agriculture
Department of Commerce
Department of Education
Department of the Interior
Department of Transportation
Department of Health and Human
  Services
Department of Housing and Urban
  Development
Department of Energy
Federal Highway Administration
Fish and Wildlife Service
Food and Drug Administration
Forest Service
Geological Survey
National Park Service
Economic Development Administration
Soil Conservation Service
                           Members of Congress
Honorable Lawton Chiles
United States Senate
Honorable Sam Gibbons
U.S. House of Representatives
             t
Honorable L.A. Bafalis
U.S. House of Representatives
Honorable Paula Hawkins
United States Senate

Honorable Andy P. Ireland
U.S. House of Representatives
                                   4-1

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                                  State

Honorable D. Robert Graham           Department of State
  Governor                           Environmental Regulation Commission
Department of Natural Resources      Department of Commerce
Department of Agriculture and        Department of Health and
  Consumer Services                    Rehabilitative Services
Department of Veterans and           Department of Environmental
  Community Affairs                    Regulation
Game and Freshwater Fish             Department of Transportation
  Commission
Department of Administration
                           Local and Regional

Polk County Commission               Central Florida Regional
Manatee County Commission              Planning Council
DeSoto County Commission             Southwest Florida Water
Hardee County Commission               Management District
Hardee County Building & Zoning
  Department
                             Interest Groups
The Fertilizer Institute             Florida Defenders of the
Florida Phosphate Council              Environment
Florida Audubon Society              Izaak Walton League of
Florida Sierra Club                    America
Manasota 88                          Florida Wildlife Federation
                                  4-2

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                                                                     5.0

                                                       LIST OF PREPARERS
     The Draft EIS for the Farmland project was prepared for EPA by

Woodward-Clyde Consultants (WCC) of Clifton, New Jersey using the third

party EIS preparation method.  The names and qualifications of the WCC

staff responsible for the preparation of this EIS are presented in Table

5-1.  An independent evaluation of all information presented in the EIS

was also performed by the following EPA officials:


     Name                          Responsibility

     Robert B. Howard              Chief, EIS Preparation Section
     A. Jean Tolman                EIS Project Officer
     Lionel Alexander III          NPDES Permit Coordinator
     D. Brian Mitchell             Air Quality
     Doyle Brittain                Air Quality
     James E. Orban                Noise
     A. Eugene Coker               Geology and Groundwater
     H. Richard Payne              Radiation
     Curtis F. Fehn                Groundwater
     Thomas R. Cavinder            Surface Water
     John T. Marlar                Surface WAter
     William L. Kruczynski         Biology and Ecology
     Delbert B. Hicks              Biology and Ecology


     For information on the material presented in this section, contact

A. Jean Tolman at (404) 881-7458  (FTS/257-7458).
                                   5-1

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   Table 5-1.   LIST OF  PREPARERS.
Name

Richard A. Millet
Raymond L. Hlnkle
Perry H. Fontana
Donald R. Ganser
Ralph E. Luebs
Leland R. Bunney
John C. Halcpaaka
                                                                      Raaponaibllity
Gary G. Kaufman
Thonaa G. Campbell
Wayna P. MacCallum
Milton G. Carter
Robert F. Brewer
Jerry J. Cape
                                                                      Project  Sponaor
                                                 Project Manager
                                                 Air Quality,  Meteorology,
                                                   Noise
                                                                     Geology
                                                                     Soils
Quallflcatlona

M.S. Civil Engineering; Principal and Vice
President. Woodward-Clyde Consultants, 17
years experience Including the direction of
Interdlsclpllne studies for phosphate mining
projects and power plant siting project*.

M.S. Wildlife Management; Project Scientist.
Woodward-Clyde Consultants; 9 years experience
In the preparation of environmental Impact
statements for a variety of projecta Including
phosphate mines.
M.S. Meteorology; Staff Scientist. Woodward-
Clyde Consultant!; 4 years experience In
environmental studies Involving meteorology
and air quality Including air quality lapset
assessments for phosphate rock processing
operations.

B.S. Geology; Project Geologist, Woodward-
Clyde Consultants; 10 years experience In
conducting engineering geologic Investigations
and groundwater studies for projects Including
phosphate mining operations.

Ph.D. Soil Fertility; Agronomist. Woodward-
Clyde Consultants; 33 years experience In-
cluding the planning of and Interpretation of
results from soils investigations for evalu-
ating the Impact of mining on the environment
and for reclamation of surface mined land.

M.S. Physical Chemistry; Radiological Chemist,   Radiation
Woodward-Clyde Consultants; 31 years experience
in radlochemlstry. nuclear chemistry, ion
exchange, trace clement analyses, and the evalu-
ation of environmental hasard* of radioactive
materials.
Ph.D. Geosclence; Senior Hydrologlst, Woodward-  Hydrology
Clyde Consultants; 18 years experience in the
study of various phases of groundwater hydrol-
ogy Including the theory and control of seep-
age from earth tailings dams, earth water
retention dams, and gypsum fields at phosphate
fertilizer plants.

M.S. Environmental Engineering; Senior Staff     Water Quality
Engineer, Woodward-Clyde,Consultants; 9 years
experience Including the evaluation of poten-
tial water quality effects of solid and
hazardous waste disposal.

M.S. Marine Sciences; Staff Scientist, Woodward- Aquatic Ecology
Clyde Consultants; 6 years experience in the
collection and analysis of data from aquatic
environments as well as Impact analysis.
M.S. Wildlife Management; Senior Project
Scientist, Woodward-Clyde Consultants;  9
years experience In the collection and
analysis of data from terrestrial environ-
ments and Impact analyses for a variety of
projects.
M.C.R.P. City and Regional Planning;  Staff
Scientist. Woodward-Clyde Consultants;  3 years
experience In evaluating socloeconomics impacts
for both large and small scale Industrial
developments.
Ph.D. Horticulture and Soil Chemistry;  Asso-
ciate Horticulturist at the University  of
California with 21 years experience as  a con-
sultant in the area of air pollution  effects
on agricultural crops, including citrus.
B.S. Mining Engineering; Consulting Engineer
(P.E.) with 18 years experience In mineral*
development projects from mining prospect
data evaluations through conceptual planning,
construction, and start-up.
                                                 Terrestrial Ecology
                                                                     Socloeconomles
                                                                     Citrus
                                                Alternatives and Mine Plan
                                                   Evaluation
                                          5-2

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                                                                     6.0
                                                                APPENDIX
6.1  DRAFT NPDES PERMIT FOR THE FARMLAND INDUSTRIES, INC. MINE PROJECT,
     HARDEE COUNTY,  FLORIDA
                                  6-1

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                                                     mit Ho.:  FL0037915
       UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                               REGION IV

                           343 COURTLANO STREET
                          ATLANTA. GEORGIA )03«S
               AUTHORIZATION TO DISCHARGE UNDER THE
          NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
   In compliance with the provision* of the Clean Water Act, as amended
(33 U.S.C.  1251 et. seq; the "Act"),

    Farmland Industries
    P.  O. Box 441
    Mulberry, Florida  33860

is authorized to discharge from a facility located at

    about 27° 27',  54"  -  Latitude
         81° 53  06  -  longitude
    Hardee  County,  Florida
DRAFT
to receiving waters named

    DSN 001 - Hickory Creek
    DSN 002 - Oak Creek

in accordance with effluent limitations, monitoring  requirements and
other conditions set forth in Farts I, II, and III hereof.  The permit
consists of this cover sheet, Part I  4   pages(s),  Part II  12  page(s)
and Part III   7 page(s).


   This permit shall become effective on

   This permit and the authorization to discharge shall expire at
   midnight.
  Date Signed                                    Howard D. Zeller
                                                Acting Director
                                                Enforcement Division
                                     6-2

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A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS

 1. During the period beginning on  the effective date of  this permit and  lasting
   the permittee is authorized to discharge from outfall(s) serial number(s) 001 Clearwater

   Such discharges shall be limited and monitored by the permittee as specified below:

   Effluent Characteristic                      Discharge Limitations
                                kg/day (Ibs/day)            Other Units (Specify)
                            Daily Avg
Daily Max
   Flow-m3/Day (MGD)

    Total Suspended Solids

    Biochemical Oxygen
     Demand  (5-day)

    Specific Conductance
    (uohms/on @ 25°C)
    Radium*


  *Ocrribined Radiun 226 & 228
Daily Avg

 1.24 MGD


30 mg/1
Daily Max
                                     through  the term of this permit,
                                     Pond to Hickory Creek.
    Monitoring Requirements

  Measurement     Sample

(during discharge)

   Continuous      Recorder
                            60 mg/1     I/week
2 mg/1
550
5pci/l
3 mg/1
1100
10pci/l
I/week
I/week
I/week
                              24-hr, composite


                              24-hr, composite

                              24-hr, composite

                              24-hr, composite
   The pH shall not be less than   6.0  standard units nor greater than  8.5  standard units and shall be monitored

   once/Veek during discharge with a grab sample.

   There shall be no discharge of floating solids or visible foam in other than trace amounts.

   Samples taken in compliance with the monitoring requirements specified above shall be taken at the following lor;uion(s):
   nearest  accessible point after final treatment but  prior to  actual discharge or mixing with
   the receiving waters.
                                                                    3 TO   3>
                                                                    - n>   H
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                                                                    p I
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JS
            2. During the period beginning  on the effective date of this  permit and lasting through  the  term of this  permit,
               the permittee is authorized to discharge from outfall(s) serial number(s) 0Q2,  Reclamation Area to Oak Creek.

               Such discharges shall be limited and monitored by the permittee as specified below:
               Effluent Characteristic
Flow-n3/Day (MGD)

Total Suspended
  Solids

Biochemical Oxygen
  Demand (5-day)

Specific Conductance
 (uohms/on @
                                         Discharge Limitations
                                         Daily Avg
/day)
Daily Max
—
—
—
—
Other Units
Daily Avg
2.51 M3D
30 mg/1
2 mg/1
550
SpciA
(Specify)
Daily Max
60 mg/1
3 mg/1
1100
10pci/l
Measurement
Frequency
(during discharge)
Continous
I/week
I/week
I/week
I/month
Sample
Type
Recorder
24-hr, composite
24-hr, composite
24-hr, composite
24-hr, composite
                Radium*                  —


                *Cbntoined Radium 226 & 228


               Th«pH shall not be less than 6.0   standard units nor greater than 8.5   standard units and shall be monitored
                onceAreek during discharge with a grab sample.

               There shall be no discharge of floating solids or visible foam in other than trace amounts.


               Samples taken in compliance with the monitoring requirements specified above shall I* taken nt the followinu l.uM
               nearest  accessible point  after final treatment but prior  to actual discharge or mixing with
               the receiving waters.
                                                                                                                 >
                                                                                                           f H
                                                                                                              I
                                                                                                           *l tJ
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                                                                                                           to
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                                                         Part II

                                                        Page II-4
    8.   Power Failures
         The permittee is responsible for maintaining adequate safeguards to
         prevent the discharge of untreated or inadequately treated wastes
         during electrical power failures either by means of alternate power
         sources, standby generators or retention of inadequately treated
         effluent.  Should the treatment works not include the above
         capabilities at time of permit issuance, the permittee must furnish
         within six months to the Permit Issuing Authority, for approval, an
         implementation schedule for their installation, or documentation
         demonstrating that such measures are not necessary to prevent discharge
         of untreated or inadequately treated wastes.  Such documentation
         shall include frequency and duration of power failures and an estimate
         of retention capacity of untreated effluent.

    9.   Onshore or Offshore Construction

         This permit does not authorize or approve the construction of any
         onshore or offshore physical structures or facilities or the
         undertaking of any work in any waters of the United States.


B.  RESPONSIBILITIES

    1.   Right of Entry

         The permittee shall allow the Permit Issuing Authority and/or
         authorized representatives (upon presentation of credentials and
         such other documents as may be required by law) to:

         a.  Enter upon the permittee's premises where an effluent source
             is located or in which any records are required to be kept under
             the terms and conditions of this permit;

         b.  Have access to and copy at reasonable tines any records required
             to be kept under the terms and conditions of this permit;

         c.  Inspect at reasonable times any monitoring equipment or
             monitoring method required in this permit;

         d.  Inspect at reasonable times any collection, treatment, pollution
             management or discharge facilities required under the permit; or

         e.  Sample at reasonable times any discharge of pollutants.
                                     6-5

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                                                      Part  II

                                                     Page II-5
 2.    Transfer of Ownership or Control
      A permit may be transferred to another party  under  the  following
      conditions:

      a.   The permittee  notifies  the Permit  Issuing Authority of  the
          proposed transfer;

      b.   A written agreement  is  submitted to the Permit  Issuing  Authority
          containing the specific transfer date  and acknowledgement that
          the existing permittee  is  responsible  for violations up to that
          date and the new permittee liable  thereafter.

      Transfers are not  effective if, within 30  days of receipt of proposal,
      the  Permit Issuing 'Authority disagrees and notifies the current
      permitttee and the new permittee of the intent to modify, revoke and
      reissue,  or  terminate the permit and to require that a new  application
      be filed.
3.   Availability of Reports

     Except for data determined to be confidential under Section 308
     of the Act, (33 U.S.C. 1318) all reports prepared in accordance with
     the terms of this permit shall be available for public inspection at
     the offices of the State water pollution control agency and the Permit
     Issuing Authority.  As required by the Act, effluent data shall not
     be considered confidential.  Knowingly making any false statement on
     any such report may result in the imposition of criminal penalties
     as provided for in Section 309 of the Act (33 U.S.C. 1319).


A.   Permit Modification

     After notice and opportunity for a hearing, this permit may be modified
     terminated or revoked for cause (as described in 40 CFR 122.15 et seq)  '
     including, but not limited to, the following:

     a.  Violation of any terms or conditions of this permit;

     b.  Obtaining this permit by misrepresentation or failure to
         disclose fully all relevant facts;

     c.  A change in any condition that requires either temporary
         interruption or elimination of the  permitted discharge;  or

     d.  Information newly acquired by the Agency indicating the
         discharge poses a threat  to human health or welfare.
                                   6-6

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                                                     Part  II

                                                    Page II-6


     If the permittee believes that any past or planned activity would
     be cause for modification or revocation and reissuance under
     40 CFR 122.15 et seq,  the permittee must report such  information to
     the Permit Issuing Authority.  The submission of a new application
     may be required of the permittee.


5.   Toxic Pollutants

     a.  Notwithstanding Part II (B)(4) above, if a toxic  effluent
         standard or prohibition (including any schedule of compliance
         specified in such  effluent standard or prohibition)  is established
         under Section 307(a) of the Act for a toxic pollutant which is
         present in the discharge authorized herein and such  standard
         or prohibition is  more stringent than any limitation for  such
         pollutant in this  permit, this permit shall be revoked and
         reissued or modified in accordance with the toxic effluent
         standard or prohibition and the permittee so notified.

     b.  An effluent standard established for a pollutant  which is
         injurious to human health is effective and enforceable by the
         time set forth in the promulgated standard, even  though  this
         permit has not as  yet been modified as outlined  in Condition 5a.


6.   Civil and Criminal Liability

     Except as provided in permit conditions pn "Bypassing",  Part II
     (A) (6), nothing in this permit shall be construed  to relieve the
     permittee from civil or criminal penalties for noncompliance.


7.   Oil and Hazardous Substance Liability

     Nothing in this permit shall be construed to preclude the
     institution of any legal action or relieve the permittee from
     any responsibilities, liabilities, or penalties to which the
     permittee is or may be subject under Section 311 of the Act
     (33 U.S.C. 1321).
8.   State Law*

     Nothing in this permit shall be construed to preclude the
     institution of any legal action or relieve the permittee from
     any responsibilities, liabilities, or penalties established
     pursuant to any applicable State law or regulation under authority
     preserved by Section 510 of the Act.
                                   6-7

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                                                           Part II

                                                          Page II-7
      9.   Property Rights
           The issuance of this permit does not convey any property rights in
           either real or personal property, or any exclusive privileges, nor
           does it authorize any injury to private property or any invasion of
           personal rights, nor any infringement of Federal, State, or local
           laws or regulations.


     10.   Severability

           The provisions of this permit are severable, and if any provision
           of this permit, or the application of any provision of this permit
           to any circumstance, is held invalid, the application of such
           provision to other circumstances, and the remainder of this permit
           shall not be affected thereby.


     11.   Permit  Continuation

           A  new application shall be submitted at least 180 days before the
           expiration date of this permit.   Where EPA is the Permit Issuing
           Authority,  the terms and conditions of this permit are automatically
           continued in accordance with 40  CFR 122.5,  provided that the permittee
           has submitted a timely and sufficient application for a renewal permit
           and the Permit Issuing Authority is unable  through no fault of the
           permittee to issue a new permit  before the  expiration date.


C.  MONITORING AND REPORTING

    1.   Representative Sampling

         Samples and measurements taken as  required herein shall be
         representative of the volume and nature of the monitored discharge.


    2.   Reporting

         Monitoring results obtained during each calendar month (quarter if
         monitoring frequency is quarterly)  shall be summarized for each
         month (quarter) and reported on a  Discharge Monitoring Report Form
         (EPA No.  3320-1).   Forms shall be  submitted at the end of each
         calendar quarter and shall be postmarked no later than the 28th day
         of the month following the end of  the quarter.  The first report is
         due  by the  28th day of the month following the first full quarter
         after the effective date of this permit.
                                     6-8

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                                                     Part  II

                                                    Page II-8


     Signed copies of these,  and all other reports required herein,  shall
     be submitted to the Permit Issuing Authority at the following
     address(es):
                                              :. of Environmental Regulation

3.   Test Procedures
     Test procedures for the analysis of pollutants shall conform to all
     regulations published pursuant to Section 304(h) of the Clean Water
     Act, as amended (40 CFR 136, "Guidelines Establishing Test Procedures
     for the Analysis of Pollutants").


4.   Recording of Results

     For each measurement or sample taken pursuant to the requirements
     of this permit, the permittee shall record the following information:

     a.  The exact place, date, and time of sampling;

     b.  The person(s) who obtained the samples or measurements;

     c.  The dates the analyses were performed;

     d.  The person(s) who performed the analyses;

     e.  The analytical techniques or methods used; and

     f.  The results of all required analyses.


5.   Additional Monitoring by Permittee

     If the permittee monitors any pollutant at the location(s)
     designated herein more frequently than required by this permit,
     using approved analytical methods as specified above, the results
     of such monitoring shall be included in the calculation and reporting
     of the values required in the Discharge Monitoring Report Form
     (EPA No. 3320-1).  Such increased frequency shall also be indicated.
                                    6-9

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                                                         Part II

                                                        Page II-9
    6.   Records Retention
         The permittee shall maintain records of all monitoring including:
         sampling dates and times, sampling methods used, persons obtaining
         samples or measurements, analyses dates and times, persons performing
         analyses, and results of analyses and measurements.  Records shall
         be maintained for three years or longer if there is unresolved
         litigation or if requested by the Permit Issuing Authority.


D.  DEFINITIONS

    1.   Permit Issuing Authority

         The Regional Administrator of EPA Region IV or designee.

    2.   Act

         "Act" means the Clean Water Act (formerly referred to as the Federal
         Water Pollution Control Act) Public Law 92-500, as amended by Public
         Law 95-217 and Public Law 95-576, 33 U.S.C. 1251 et seq.

    3.   Mass/Day Measurements

         a.  The "average monthly discharge" is defined as the total mass of
             all daily discharges sampled and/or measured during a calendar
             month on which daily discharges are sampled and measured, divided
             by the number of daily discharges sampled and/or measured during
             •uch month.  It is, therefore, an arithmetic mean found by adding
             the weights of the pollutant found each day of the month and then
             dividing this sum by the number of days the tests were reported.
             This limitation is identified as "Daily Average" or "Monthly
             Average" in Part I of the permit and the average monthly discharge
             value is reported in the "Average" column under "Quantity" on
             the Discharge Monitoring Report (DMR).

         b.  The "average weekly discharge" is defined as the total mass of
             •11 daily discharges sampled and/or measured during a calendar
             week on which daily discharges are sampled and/or measured
             divided by the number of 'daily discharges sampled and/or measured
             during such week.  It is, therefore, an arithmetic mean found by
             adding the weights of pollutants found each day of the week and
             then dividing this sum by the number of days the tests were
             reported.  This limitation is identified as "Weekly Average" in
             Part I of the permit and the average weekly discharge value is
             reported in the "Maximum" column under "Quantity" on the DMR.

         c.  The "maximum daily discharge" is the total mass (weight) of a
             pollutant discharged during a calendar day.  If only one
             •ample is taken during any calendar day the weight of pollutant
                                         6-10

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                                                     Part  II

                                                    Page 11-10
         calculated from it is the "maximum daily discharge".   This
         limitation is identified as "Daily Maximum,"  in Part  I of the
         permit and the highest such value recorded  during the reporting
         period is reported in the "Maximum" column  under "Quantity"
         on the DMR.
4.   Concentration Measurements

     a.  The "average monthly concentration," .other than for fecal
         coliform bacteria, is the concentration of all daily discharges
         sampled and/or measured during a calendar month on which daily
         discharges are sampled and measured divided by the number of
         daily discharges sampled and/or measured during such month
         (arithmetic mean of the daily concentration values).  The daily
         concentration value is equal to the concentration of a composite
         sample or in the case of grab samples is the arithmetic mean
         (weighted by flow value) of all the samples collected during
         that calendar day.  The average monthly count for fecal coliform
         bacteria is the  geometric mean of the counts for samples collected
         during a calendar month.  This limitation is identified as
         "Monthly Average" or "Daily Average" under "Other Limits" in
         Part I of the permit and the average monthly concentration value
         is reported under the "Average" column under "Quality" on the DMR.

     b.  The "average weekly concentration," other than for fecal coliform
         bacteria, is the concentration of all daily discharges sampled
         and/or measured during a calendar week on which daily discharges
         are sampled and measured divided by the number of daily discharges
         sampled and/or measured during such week (arithmetic mean of the
         daily concentration values).  The daily concentration value is
         equal to the concentration of a composite sample or in the case  of
         grab samples is the arithmetic mean (weighted by flow value) of
         all samples collected during that calendar day.  The average
         weekly count for fecal coliform bacteria is the geometric mean
         of the counts for samples collected during a calendar week.  This
         limitation is identified as "Weekly Average" under "Other Limits"
         in Part I of the permit and the average weekly concentration
         value is reported under the "Maximum" column under "Quality" on
         the DMR.

     c.  The "maximum daily concentration" is the concentration of a
         pollutant discharged during a calendar day.  It is identified
         as "Daily Maximum" under "Other Limits" in Part I of the permit
         and the highest such value recorded during the reporting period
         is reported under the "Maximum" column under "Quality" on the
         DMR.
                                   6-11

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                                                     Part II

                                                    Page 11-11
5.   Other Measurement*

     a.  The effluent flow expressed as M3/day (MGD) is the 24 hour
         average flow averaged monthly.  It is the arithmetic mean of
         the total daily flows recorded during the calendar month.
         Where monitoring requirements for flow are specified in Part  I
         of the permit the flow rate values are reported in the  "Average"
         column under "Quantity" on the DMR.

     b.  Where monitoring requirements for pH, dissolved oxygen  or  fecal
         coliform are specified in Part I of the permit the values  are
         generally reported in the "Quality or Concentration" column on
         the DMR.


6.   Types of Samples

     a.  Composite Sample - A "composite sample" is any of the following:

         (1)  Not less than four influent or effluent portions collected
              at regular intervals over a period of 8 hours and  composited
              in proportion to flow.

         (2)  Not less than four equal volume influent or effluent
              portions collected over a period of 8 hours at intervals
              proportional to the flow.

         (3)  An influent or effluent portion collected continuously
              over a period of 24 hours at a tate proportional to the  flow.

     b.  Grab Sample:  A "grab sample" is a single influent or effluent
         portion which is not a composite sample.  The sample(s) shall be
         collected at the period(s) most representative of the total
         discharge.


7.   Calculation of Means

     a.  Arithmetic Mean:  The arithmetic mean of any set of values is
         the summation of the individual values divided by the number
         of individual values.

     b.  Geometric Mean:  The geometric mean of any set of values is the
         Kth root of the product of the individual values where  N is equal
         to the number of individual values.  The geometric mean is
         equivalent to the antilog of the arithmetic mean of the logarithms
         of the individual value*.  For purposes of calculating  the
         geometric mean, values of zero (0) shall be considered  to  be  one (1),
                                    6-12

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                                                    Part  II

                                                   Page 11-12
         Weighted by Flow Value:   Weighted by flow value means  the
         summation of each concentration times its respective flow
         divided by the summation of the respective flows.
8.   Calendar Day

     a.  A calendar day is defined as the period from midnight of one
         day until midnight of the next day.  However, for purposes  of
         this permit, any consecutive 24-hour period that reasonably
         represents the calendar day may be used for sampling.
                                    6-13

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                                                       Page III-4

15.  Farmland  shall  conduct  a monitoring  program  to  assess
     their   wetlands   restoration   efforts.    Three   wetland
     restoration areas  (the  24-acre  wetland  restoration area of
     Sand/Clay  Mix  Area  I  (S/C  1, within  Section  14),  the
     reclaimed Oak  Creek  stream channel in Special Mix Areas 1
     and 2, and  the littoral zone wetlands and  adjacent hydric
     tree  species  plantings  within  the reclaimed  Hickory Creek
     stream  channel)   shall  be  monitored  for   1-year  each
     according to the following program:

         (1)   Beginning   12   weeks  after  completion   of  the
         reclamation  of each  respective  area,   the water level
         shall  be  monitored biweekly;  and  (2)  following  the
         first  full  growing  season,   a  biological  assessment
         shall be  performed  by a degreed biologist for each of
         the   three  areas;   the  assessment   shall  include  a
         listing  of  plant   species  present,  mapping   of  their
         location,  a visual estimate  of  the  amount  of cover
         provided  by the wetland  species,  and  qualitative  and
         quantitative  sampling  of  the  benthic  macroinverte-
         brates  to  yield  a  list of  the  species present  and
         their density.

         After   the  above-described   monitoring  program   is
         performed  for  the experimental wetland  area  of the Oak
         Creek  stream channel,  a  long-term  monitoring program
         shall  be   initiated   in  this  area.   This  long-term
         monitoring   program   shall   consist   of   a   yearly
         biological   assessment  by   a  degreed  biologist   to
         include the items  in (2)  above.   In  addition, in order
         to  determine  the  degree of  subsidence  occurring,  if
         any,  in  the  marsh  depression  area   in S/C   1,  the
         maximum depth  of the  marsh  depression  area relative to
         a  fixed elevation  point  shall be monitored  quarterly
         for  the life  of  this  permit.   Farmland  shall submit
         annual  reports of   the  described monitoring  program to
         the EPA Region IV Ecology Branch.

16.  Farmland  shall  provide bona  fide researchers  reasonable
     opportunity   to  salvage   paleontological   specimens  and
     information  for the duration  of  mining operations on  the
     Farmland  site.   Prospective collectors  availing  themselves
     of  this provision  must have credentials   verified  by  the
     Florida State  Museum.    Such individuals shall  be allowed
     regular  access  to  dragline  spoil  windrows,  ore residue,
     ore   piles   and   reject   piles,   subject   to  Farmland's
     requirements  for safety and visitor accountability and on
     a strictly not-to-interfere with mining basis.

 17. Unless  specified  otherwise by a  preceding  condition  in
     this  permit,  Farmland   shall  carry  out  its mining project
     in  complete   accordance   with   the   applicant's  proposed
     action  described  and   evaluated   in   the   Farmland  E1S,
     including   the  employment  of  all   mitigating  measures-
     presented  as  part of  the proposed action.   However, this
     shall  not  preclude  the  imposition  of  any  additional  or
     more  stringent  conditions which  may  be  required  by  any
     local or state  regulatory  agency or governmental entity.
                               6-14

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                                                         Part III

                                                        Page III-l
                             PART III
OTHER REQUIREMENTS

     1. In accordance with Section 306 (d) of the Federal Water Pollution
       Control ACL (PL92-500) the standards of performance for conventional
       pollutants as contained in this permit shall not be made any more
       stringent during a ten year period begining on the date of completion
       of such construction or during the period of depreciation or
       amortization of such facility for the purposes of section 167 or
       169 (or both)  of the Internal Revenue Code of 1954,  whichever period
       ends first.  The provision of this this Section 306 (d)  do not limit
       the authority of the Environmental Protection Agency, to modify the
       permit to require compliance with a toxic effluent limitations
       promulgated under BAT or toxic pollutant standard established under
       Section 307 (a)  of the FWPCA.


National  Environmental Policy Act (NEPA)  Requirements

The  below listed  requirements,  conditions and  limitations  were
recommended  in  the  Farmland   Industries  Phosphate   Mine   site
specific   Environmental   Impact  Statement,   and   are  hereby
incorporated  into   National   Pollutant   Discharge  Elimination
System  Permit  No.  FL0037915  in accordance with  40  CFR 122.62
1.   Farmland shall  exclude  the  utilization  of any conventional
     aboveground  slime-disposal  areas  with   the   exception  of
     Clay  Settling  areas  I  and  II   described   in   the  EIS.
     Farmland's  waste  disposal   and   reclamation  plan   shall
     employ  a  sand-clay  mix process  as described  in the  EIS.
     Only Settling  Area II  shall remain active for the life  of
     the  mine.

2.   Farmland shall employ  high profile overburden stacking  in
     the  mining of  the area covered by  Settling Area II  to the
     maximum extent compatible with  toe  spoiling  oi the leach
     zone.  Any increase  in  below  ground waste storage  realized
     by  the use of  this technique  shall be  reflected  in  a lower
     reclaimed elevation  for Settling Area II.

3.   Farmland  shall  meet  the  requirements   of   its  Southwest
     Florida Viater  Management  District  (SWFV4MD) Consumptive Use
     Permit.
                               6-15

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                                                       Page III-2

4.   Farmland shall  provide  storage  that allows  recirculation
     of  water recovered  from  slimes.    The  water  circulation
     system and  storage capacity shall  be  as described  in the
     EIS for Farmland's proposed project.

5.   During the dragline mining  activity, Farmland shall employ
     the  technique  of  leach  zone  management  by  toe  spoiling,
     i.e., overburden  from near  the  interface with  the matrix
     (the leach  zone,  where radioactivity in  the  overburden is
     concentrated) shall be placed  at the toe  of  the spoil pile
     and covered with overburden from upper strata.

6.   Farmland   shall   meet   county   and   state   reclamation
     requirements.

7.   Farmland   shall  preserve   from   mining,  or   any  other
     disturbance,  the   areas  proposed  for   preservation  in
     Farmland's  proposed  action  in the  EIS.   These  areas are
     depicted in  the attached  map,  Figure 1.   Specifically, the
     total  preserved  acreage of   2530  acres  shall   include  a
     minimum  of   510  acres of  forested  uplands,  885 acres of
     freshwater  swamp,  107 acres  of  freshwater marsh,  and 354
     acres  of   pine  f latwoods/palmetto  range,   all  in  the
     locations depicted in Figure 1.


8.   Farmland  shall  increase  the  acreage  reclaimed  as forest
     habitat  and  provide  corridors   for   wildlife  movement
     between   reclaimed   and  preserved   areas   by   planting
     additional   areas   as  depicted   in  Figure  2,  attached.
     Beginning   with  the  experimental   revegetation  program
     conducted  on the  first  available  (236-acre)  sand/clay mix
     reclamation  area,  Farmland   shall  contact  the  District
     Forester  or the  State  Forester,  Florida  Forest Service,
     for  assistance  in the forestry aspects  of the reclamation
     program.

9.   Farmland  shall  incorporate  into   its  reclamation  plan  a
     littoral  zone  at  the  downstream   extent  of  the proposed
     reclaimed  open lake  in  the  Hickory Creek  channel.   this
     littoral  zone   shall  be  at  least  500 feet  wide and  at  a
     depth  suitable  for emergent  vegetation,  providing  for: the
     establishment of 7-10 acres of marsh community.

10.  Before  beginning  any  land-disturbing  activities,  Farmland
     shall  develop  a program  whereby  indigo  snakes encountered
     in  the  work area are  captured  for  relocation  to  other
     areas  of   suitable   habitat   in  the  site   region.    This
     program  shall  include  informing  Farmland workers  of the
     importance  of  the indigo  snake,   familiarizing  them  with
     its   appearance   and    instructing  them    as    to   its
     preservation.   In  addition, the gopher tortoise  population
     shall  be  protected  to  the  extent possible in  the  site
     area.    Farmland   shall   coordinate   its   recovery  and
     relocation   efforts  with  the  Florida   Endangered   Species
     Coordinator, and  shall  maintain  a  record of  the  program to
     be  submitted to the U.S.  Fish  and Wildlife Service.

                            6-16

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                                                       Page III-3
11.  Farmland shall comply with  the categorization of  wetlands
     present on the  mine property as  set  forth in the  EIS  and
     illustrated  in  Figure  3,   attached.   In  summary,  within
     Category 1 wetlands,  Farmland  shall not mine, shall  limit
     activities to those  essential  to and  unavoidable  for  the
     mining operation, and  shall otherwise take all  reasonable
     measures  to   preserve  all   Category   1   wetlands.   Addi-
     tionally,   Farmland   shall   restore  the  total  acreage  of
     Category  2 wetlands  disturbed by  mining.   Specifically,
     the acreage  to  be  restored as freshwater marsh  or  swamp
     according   to  Farmland's  proposed  action  in  the EIS  shall
     be increased  by at  least  116  acres  (from 398 acres  to  a
     minimum of 514 acres).  This shall  be  done by differential
     grading and settling of sand/clay mix  areas  in addition to
     that already  proposed by Farmland  in the  EIS.

12.  Farmland   shall  monitor  the   surface  water  quality  of
     Hickory Creek where  it  intersects Murphy Road (SR 661) and
     of Troublesome Creek at a point within 500 feet downstream
     of   where   the   Hickory   Creek   diversion   flow  enters
     Troublesome  Creek.    Parameters   monitored shall  include:
     temperature,    DO,    pH,    specific   conductance,   redox
     potential, alkalinity species,  suspended solids, fluoride,
     total  phosphorus,  ammonia,  organic nitrogen, nitrate  and
     nitrite,  total   Kjeldahl,   total  nitrogen and  turbidity.
     Frequency  of  sampling  shall be weekly, and the duration of
     sampling  shall be for the life  of the  mine for the Hickory
     Creek  station,  and  for the duration  of  the  diversion for
     the  Troublesome  Creek  station.,   The  data   collected  at
     these  two stations  shall  be  reported  monthly  to Hardee
     County, EPA and FDER.

13.  During  the second  half of  mine  year 12  and all  of mine
     year  13,  Farmland shall monitor the level of  the Surficial
     Aquifer within  the  preserved  portion of  Hickory  Creek at
     the  location depicted  on  Figure  3.   The   level of  the
     Surficial  Aquifer at the designated location shall not be
     lowered   by   more   than  three  feet   due  to  the  mining
     activities.   To prevent exceeding  this  three-foot limit,
     Farmland  shall   employ  rim ditching,  rapid   refilling  of
     mine  pits or any  other appropriate mitigative  measure to
     protect the preserved area  from dewatering.

14.  Farmland  shall  monitor the water quality  of  the  Surficial
     Aquifer  at  the  location identified  on  the  attached map,
     Figure  3. The  following parameters  shall be monitored on
     a  quarterly  basis for the  life of  the  mine  or  until such
     time  that EPA  and  Farmland agree  that  the  compiled data
     indicate  no  adverse impact on  the  Surficial Aquifer:  pH,
     specific  conductance,  sulfates,  fluoride,  and ammonia.   A
     written  report   summarizing the  data  shall  be  submitted
     once  a year  to EPA.
                                 6-17

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           The flow in Hickory Creek must be at least  1.8  times the discharge  flow to the creek.

           The flow in Oak Creek must be at least 1.6  times  the discharge  flow to the creek.

           Any overflow  from facilities designed, constructed, and maintained  to contain or treat the volume
           of wastewater which would result from a  10-year,  24-hour precipitation event shall not be subject
           to the suspended solids effluent limitation or  the pH  limitations listed on the preceding pages.
           Monitoring and reporting shall be required  for  all the parameters including TSS and pH.

           The effluent  limits and any additional requirements specified in the attached certification
           supersede any less stringent effluent limits listed above.  During  any time period in which more
           stringent state certification effluent limits are stayed or inoperable, the effluent limits
           listed above  shall be in effect and fully enforceable.


       2.   DEFINITIONS

           The term "10-year, 24-hour precipitation event" shall mean the maximum 24-hour precipitation
ON          event with a  probable re-occurrence interval of once in 10 years.   This information is available
M          in "Weather Bureau Technical Paper No. 40,  May  1961 and may be obtained from the Environmental
00          Data  Service, National Oceanic and Atmospheric  Administration, U.S. Department of Commerce.
                                                                                                                       o
                                                                                                                       o
                                                                                                                       10
                                                                                                                       t->
                                                                                                                       01

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                                                                PARTI

                                                                r«t*i-4
                                                                PcimitNo. PL0037Q15
B. SCHEDULE OF COMPLIANCE
   1.  The permittee shall achieve  compliance  with  the  effluent  limitations specified for
       discharges in accordance with the following schedule:

       a.  Permittee  shall comply vith the  effluent  limitations by
           the effective date of the permit.
    2.  No later than 14  calendar days following a date identified in the above schedule of
       compliance, the permittee shall submit either • report of progress or, in the case of
       specific actions being required by identified dates, a written notice of compliance or
       noncompliance. In the latter case, the notice shall include the cause of noncompliance,
       any remedial actions  taken, and  the probability  of meeting  the  next scheduled
       requirement
                                 6-19

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                                                            Part  II

                                                           Page II-l
A.  MANAGEMENT REQUIREMENTS

    1.   Discharge Violations

         All discharges authorized herein shall be consistent vith the terms
         and conditions of this permit.   The discharge  of  any pollutant more
         frequently than, or at a level  in excess  of, that identified and
         authorized by this permit constitutes a violation of the terms and
         conditions of this permit.  Such a violation may  result in the
         imposition of civil and/or criminal penalties  as  provided in Section
         309 of the Act.


    2.   Change in Discharge

         Any anticipated  facility expansions, production  increases, or process
         modifications which will result in new, different, or Increased
         discharges of pollutants must be reported by  submission of a new
         NPDES application or, if such changes will not violate the effluent
         limitations specified in this permit, by notice  to the permit issuing
         authority of such changes.  Following such notice, the permit may be
         modified to specify and limit any pollutants  not previously limited.
    3.   Koncompliance Notification

        a.  Instances of noncompliance involving toxic or hazardous pollutants
            should be reported as outlined in Condition 3c.  All other instances
            of noncompliance should be reported as described in Condition 3b.

        b.  If for any reason, the permittee does not comply with or will be
            unable to comply with any discharge limitation specified in the
            permit, the permittee shall provide the Permit Issuing Authority
            vith the following information at the time when the next Discharge
            Monitoring Report is submitted.

            (1)  A description of the discharge and causa of noncompliance;
            (2)  The period of noncompliance, including exact dates and tines
                 and/or anticipated time when the discharge will return to
                 compliance; and
            (3)  Steps taken to reduce, eliminate,  and prevent recurrence of
                 the noncomplying discharge.
                                        6-20

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                                                     Part II

                                                    Page II-2


     c.  Toxic or hazardous discharges as defined below shall be reported
         by telephone within 24 hours after permittee becomes aware of  the
         circumstances and followed up with information in writing as
         •et forth in Condition 3b. within 5 days, unless this requirement
         is otherwise waived by the Permit Issuing Authority:

         (1)  Noncomplying discharges subject to any applicable toxic
              pollutant effluent standard under Section 307(a) of the Act;
         (2)  Discharges which could constitute a threat to human health,
              welfare or the environment.  These include unusual or extra-
              ordinary discharges such as those which could result from
              bypasses, treatment failure or objectionable substances
              passing through the treatment plant.  These include Section
              311 pollutants or pollutants which could cause a threat  to
              public drinking water supplies.

     d.  Nothing in this permit shall be construed to relieve the permittee
         from civil or criminal penalties for noncompliance.


4.   Facilities Operation

     All waste collection and treatment facilities shall be operated in
     a manner consistent with the following:

     a.  The facilities shall at all times be maintained in a good
         working order and operated as efficiently as possible.  This
         includes but is not limited to effective performance based on
         design facility removals, adequate finding, effective management,
         adequate operator staffing and training, and adequate laboratory
         and process controls (including appropriate quality assurance
         procedures); and

     b.  Any maintenance of facilities, which night necessitate unavoidable
         interruption of operation and degradation of effluent quality,
         ahall be scheduled during noncritical water quality periods and
         carried out in a manner approved by the Permit Issuing Authority.

     c.  The permittee, in order to maintain compliance with this permit
         ahall control production and all discharges upon reduction, loss,
         or failure of the treatment facility until the facility is
         restored or an alternative method cf treatment is provided.


5.   Adverse Impact

     The permittee shall take all reasonable atepa to minimise any
     adverse impact to waters of the United States resulting from
                                     6-21

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                                                      P'rt II

                                                     Page II-3


          noncompliance with any effluent limitations specified  in  this
          permit, including such accelerated or additional monitoring as
          necessary to determine the nature of the noncomplying  discharge.


 6.    Bypassing

      "Bypassing" means the intentional diversion of untreated or partially
      treated wastes to waters  of the United States from  any portion of a
      treatment facility.   Bypassing of wastewaters is prohibited unless
      all of the following  conditions are net:

      a.   The bypass is unavoidable-i.e.  required to prevent loss of life,
          personal injury or severe  property damage;
                                           •
      b.   There are no feasible alternatives  such as  use  of auxiliary
          treatment facilities,  retention of  untreated wastes, or
          maintenance during normal  periods  of  equipment  down  time;

      c.   The permittee reports  (via telephone)  to the Permit  Issuing
          Authority any unanticipated bypass within 24 hours after
          becoming aware of it  and follows up with written  notification
          in 5 days.  Where the  necessity of  a bypass is  known (or  should
          be known)  in  advance,  prior notification shall  be submitted to
          the Permit  Issuing  Authority  for approval  at  least 10 days
          beforehand,  if possible.   All written notifications shall contain
          information as required in Part II  (A)(3)(b); and

     d.   The bypass  is  allowed  under conditions  determined to be necessary
          by the Permit  Issuing  Authority to minimize  any adverse effects.
          The  public  shall  be notified and given  an opportunity to comment
          on bypass incidents of significant  duration  to  the extent
          feasible.

     This requirement  is waived where infiltration/inflow analyses are
     scheduled to be performed  as part of an Environmental Protection
     Agency  facilities planning project.


7.   Removed Substances

     Solids, sludges, filter backwash, or other pollutants removed in
     the course of treatment or control of wastewaters shall  be disposed
     of in a manner such as to prevent any pollutant from such materials
     from entering waters of the United States.
                                  6-22

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                                                          Part III

                                                         Page III-l
                              PART III
  OTHER REQUIREMENTS
         m accordance with Section 306 (d)  of the Federal Water Pollution
         Control ACL  (PL92-500) the standards of perfornance for conventional
         pollutants as contained in this permit shall not be made any nore
         stringent during a ten year period begining on the date of completion
         of such construction or during the period of depreciation or
         amortization of such facility for  the purposes of section 167 or
         169 (or both) of the Internal Revenue Code of 1954, whichever oeriod
         ends first.  The provision of this this Section 306(d)  do not*limit
         the authority of the Environmental Protection Agency  to modify the
         permit to require compliance with  a toxic effluent limitations
         prorulgated under BAT or toxic pollutant standard established under
         Section 307 (a)  of the FWPCA.
National  Environmental  Policy Act  (NEPA)  Requirements

The  below listed  requirements,  conditions and  limitations  were
recommended   in  the  Farmland  Industries  Phosphate  Mine  site
specific   Environmental   Impact   Statement,   and   are   hereby
incorporated   into   National   Pollutant   Discharge  Elimination
System  Permit  No.  FL0037915  in accordance with 40 CFR  122.62
(d)(9).

1.   Farmland  shall  exclude  the utilization  o£ any  conventional
     aboveground  slime-disposal  areas  with   the  exception  of
     Clay  Settling  areas  I 'and   II   described   in   the  EIS.
     Farmland's  waste   disposal   and  reclamation  plan   shall
     employ   a  sand-clay  mix  process  as  described  in the  EIS.
     Only Settling  Area II  shall remain  active  for the life of
     the  mine.

2.   Farmland  shall  employ  high profile overburden stacking in
     the  mining of  the area covered  by  Settling  Area II  to the
     maximum extent compatible with toe  spoiling  or the leach
     zone.   Any increase  in below  ground  waste storage  realized
     by  the use of  this technique  shall be reflected  in  a lower
     reclaimed  elevation  for Settling Area II.

3.   Farmland  shall  meet  the  requirements   of  its   Southwest
     Florida Water  Management  District  (SWFWMD) Consumptive Use
     Permit.
                                6-23

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4.    Farmland shall  provide  storage  that  allows  recirculation
     of  water  recovered  from  slimes.    The  water' circulation
     system and  storage  capacity shall  be  as described  in  the
     EIS for Farmland's proposed project.

5.    During the dragline mining  activity,  Farmland shall employ
     the  technique  of leach  zone  management  by  toe  spoiling,
     i.e., overburden  from near  the  interface with  the matrix
     (the leach  zone,  where radioactivity  in  the  overburden is
     concentrated) shall be placed  at the  toe  of  the spoil pile
     and covered with overburden from upper strata.

6.    Farmland   shall  meet   county   and   state   reclamation
     requirements.

1.    Farmland   shall   preserve   from   mining,   or   any  other
     disturbance,  the   areas  proposed  for   preservation   in
     Farmland's  proposed  action  in the  EIS.   These  areas  are
     depicted in the attached  map,  Figure  1.   Specifically,  the
     total  preserved  acreage of  2530   acres   shall   include  a
     minimum of  510  acres  of  forested  uplands,  885 acres  of
     freshwater  swamp,  107 acres of  freshwater marsh,  and  354
     acres  of   pine   f latwoods/palmetto  range,   all   in  the
     locations depicted in Figure 1.
8.    Farmland  shall  increase  the  acreage  reclaimed as  forest
     habitat   and  provide  corridors  for   wildlife   movement
     between   reclaimed    and   preserved   areas   by   planting
     additional  areas  as   depicted   in   Figure   2,  attached.
     Beginning  with   the  experimental   revegetation   program
     conducted on  the  first available  (236-acre)  sand/clay  mix
     reclamation  area,  Farmland  shall  contact  the  District
     Forester  or  the  State Forester,  Florida Forest  Service,
     for assistance  in the forestry aspects  of  the  reclamation
     program.

9.    Farmland  shall  incorporate  into  its  reclamation  plan  a
     littoral  zone  at  the downstream  extent of  the  proposed
     reclaimed open  lake  in  the Hickory  Creek  channel.   this
     littoral  zone  shall  be  at least  500  feet  wide  and at  a
     depth suitable  for  emergent vegetation,  providing  for  the
     establishment of 7-10 acres of marsh community.

10.  Before  beginning  any land-disturbing  activities/  Farmland
     shall develop a program whereby indigo  snakes  encountered
     in  the  work  area  are captured  for  relocation  to  other
     areas  of  suitable  habitat  in  the  site   region.   This
     program  shall  include  informing  Farmland  workers of  the
     importance of  the  indigo snake,  familiarizing them  with
     its   appearance   and   instructing   them    as   to   its
     preservation.  In addition, the  gopher tortoise population
     shall  be  protected  to  the  extent  possible in  the  site
     area.    Farmland   shall   coordinate   its   recovery   and
     relocation  efforts   with   the  Florida  Endangered  Species
     Coordinator,  and  shall maintain a  record  of  the program to
     be submitted to the U.S. Fish and Wildlife Service.
                              6-24

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11.  Farmland shall  comply  with the categorization  of wetlands
     present on  the  mine property  as  set forth in  the  EIS and
     illustrated  in  Figure  3,  attached.   In  summary,  within
     Category 1  wetlands,  Farmland  shall not mine,  shall limit
     activities  to those essential  to  and  unavoidable  for the
     mining operation,  and  shall otherwise  take  all reasonable
     measures  to  preserve  all  Category  1  wetlands.   Addi-
     tionally,   Farmland  shall  restore  the  total  acreage  of
     Category  2 wetlands  disturbed by  mining.   Specifically,
     the  acreage to  be  restored as freshwater marsh  or swamp
     according  to  Farmland's  proposed   action  in  the  EIS shall
     be  increased  by at  least 116  acres  (from 398 acres  to  a
     minimum of  514 acres).  This shall  be  done by  differential
     grading and settling of sand/clay  mix  areas  in addition to
     that already proposed by Farmland  in the EIS.


12.  Farmland  shall   monitor   the  surface   water   quality  of
     Hickory Creek where  it  intersects  Murphy Road  (SK 661) and
     of Troublesome Creek at a  point within  500 feet downstream
     of   where   the   Hickory   Creek   diversion    flow   enters
     Troublesome  Creek.   Parameters  monitored  shall  include:
     temperature,   DO,   pH,    specific   conductance,    redox
     potential,  alkalinity species,  suspended  solids,  fluoride,
     total  phosphorus,  ammonia, organic nitrogen,   nitrate  and
     nitrite,  total  Kjeldahl,   total   nitrogen  and  turbidity.
     Frequency of sampling shall be weekly,  and the duration of
     sampling shall be for the. life of  the  mine for the Hickory
     Creek  station,  and  for the duration of the diversion for
     the  Troublesome  Creek  station.    The  data  collected  at
     these  two  stations  shall  be  reported  monthly  to  Hardee
     County, EPA and  FDER.

13.  During  the  second  half  of mine  year  12  and  all  of  mine
     year 13, Farmland shall monitor the level  of  the  Surficial
     Aquifer within  the preserved  portion  of Hickory  Creek at
     the  location  depicted  on  Figure  3.    The  level  of  the
     Surficial Aquifer at  the  designated location  shall  not be
     lowered  by  more  than   three  feet due  to   the  mining
     activities.  To  prevent  exceeding this three-toot  limit,
     Farmland  shall  employ  rim ditching,   rapid  refilling  of
     mine pits  or  any  other  appropriate mitigative measure to
     protect the preserved area from dewatering.

14.  Farmland shall monitor  the water  quality  of  the  Surficial
     Aquifer at  the  location  identified on  the  attached  map,
     Figure 3.   The  following  parameters shall be  monitored on
     a quarterly basis  for  the life of the  mine  or until  such
     time that  EPA and  Farmland agree  that the compiled  data
     indicate no adverse  impact on  the  Surficial Aquifer:   pH,
     specific conductance,  sulfates,  fluoride,  and  ammonia.  A
     written report  summarizing  the  data   shall  be  submitted
     once a year to EPA.
                              6-25

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15.  Farmland  shall  conduct  a  monitoring  program  to  assess
     their   wetlands   restoration   efforts.    Three   wetland
     restoration areas  (the  24-acre  wetland  restoration area of
     Sand/Clay  Mix  Area  I  (S/C  1, within  Section  14),  the
     reclaimed Oak  Creek  stream channel in Special Mix Areas 1
     and 2,  and  the littoral zone wetlands and  adjacent hydric
     tree species  plantings  within  the  reclaimed  Hickory  Creek
     stream  channel)   shall  be  monitored  for   1-year   each
     according to the following program:

         (1)  Beginning   12   weeks  after  completion   of  the
         reclamation  of each  respective  area,   the water  level
         shall  be  monitored biweekly;  and  (2)  following  the
         first  full  growing  season,   a  biological  assessment
         shall be  performed  by a degreed biologist for each of
         the  three   areas;   the  assessment   shall  include  a
         listing  of  plant   species  present,  mapping  of  their
         location,  a visual estimate  of  the  amount  of  cover
         provided  by the wetland  species,  and  qualitative  and
         quantitative  sampling  of  the  benthic  macroinverte-
         brates  to  yield  a  list of  the  species present  and
         their density.                                       •

         After   the  above-described   monitoring  program   is
         performed  for  the experimental  wetland  area  of the Oak
         Creek  stream channel,  a long-term monitoring program
         shall  be   initiated   in  this  area.   This  long-term
         monitoring   program   shall   consist   of   a   yearly
         biological   assessment  by   a  degreed  biologist  to
         include  the items  in (2) above.  In  addition,  in order
         to  determine  the  degree of  subsidence  occurring,  if
         any,  in  the  marsh  depression  area   in S/C  1,  the
         maximum depth  of the  marsh  depression  area relative to
         a  fixed elevation  point shall be monitored  quarterly
         for  the life  of  this  permit.   Farmland  shall submit
         annual  reports of   the  described  monitoring  program to
         the EPA Region IV Ecology Branch.

16.  Farmland  shall  provide bona  fide researchers  reasonable
     opportunity   to  salvage   paleontological   specimens  and
     information  for the duration  of  mining operations  on the
     Farmland site.   Prospective collectors  availing  themselves
     of  this provision  must have  credentials   verified  by  the
     Florida  State  Museum.    Such individuals  shall  be allowed
     regular  access  to  dragline  spoil  windrows,  ore  residue,
     ore   piles   and   reject   piles,   subject   to  Farmland's
     requirements  for safety and visitor  accountability and on
     a strictly not-to-interfere with mining basis.

 17. Unless  specified  otherwise by a  preceding  condition  in
     this  permit,  Farmland   shall  carry  out its mining project
     in  complete   accordance   with   the  applicant's  proposed
     action  described  and   evaluated   in  the  Farmland  EIS,
     including   the  employment  of  all   mitigating   measures
     presented as part of  the  proposed action.  However, this
     shall  not   preclude  the  imposition of  any  additional  or
     more  stringent  conditions which  may  be  required by  any
     local or state  regulatory  agency or governmental entity.
                              6-26

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                                                                                                .
                                                                      — —  PROPERTY lOL'NDARV
                                                                      CC~  OUT PARCEL (NOT FARMLAND PHOriRTYl
                                                                           FRBHWATIR SWAMP
                                                                           FRESH»ATER MARSH
FIGURE 1   EXISTING  LAND  USE OF  AREAS  TO BE  PRESERVED ON
           THE FARMLAND INDUSTRIES,  INC. MINE SITE,  HARDEE
       t   COUNTY, FLORIDA.
    PINE FLATWOODt PALMETTO RANGE
    UTLAND FORfST
    IMfHOVED PAinjRE
!•:•:•'. •:-.•! CTTRUS
^_ OTHER ACRICULTURI

    0     2,000    4.000
                                                                            SCALE IN FEET
 SOURCE: FARMLAND INDUSTRIES. INC., HARDEE COUNTY MASTER PLAN. JUNE 1979
                                                    6-27

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r
-
X
          FIGURE 2   PROPOSED AND ADDITIONAL  REFORESTATION PLANTINGS
                     ON  THE  FARMLAND  INDUSTRIES,  INC.  MINE SITE
                     HARDEE  COUNTY, FLORIDA.
   »  i »•».--•     \\   /^r,
Proposed Reforestation Areas
                                                                                    Additional Reforestation Areas

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         symbol
LEGEND
         meaning     Category 1   Category 2  Category 2  Category 3  Preserved
                      Wetl^-ds    Wetlands    Wetlands    Wetlands     Area
                                 Disturbed   Undisturbed
FIGURE 3  WETLAND CATEGORIZATION AND SURFICIAL AQUIFER
          MONITORING LOCATION, FARMLAND INDUSTRIES, INC.
          SITE, HARDEE COUNTY, FLORIDA.
SOURCE: WOODWARD-CLYDE CONSULTANTS (1980)
                                       6-29

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