United States
Environmental Protection
Agency
_ Region 4 .
345 Courtland Street, NE
Atlanta, GA 30365
EPA 904/9-85 134
SEPTEMBER 1985
«EPA
Environmental
Impact Statement
North Pinellas County,
Florida
Wastewater Facilities
Final
85-
134
ilM
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»
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
345 COURTLAND STREET
ATLANTA, GEORGIA 30365
SEP 20 1985
TO: ALL INTERESTED AGENCIES, PUBLIC GROUPS AND CITIZENS
Enclosed for your review and comment is the Final Environmental
Impact Statement (EIS) for proposed wastewater facilities for
northern Pinellas County, Florida.
This EIS was prepared in compliance with the National
Environmental Policy Act (NEPA) and implementing Agency
regulations. In accordance with these regulations, the Final
EIS will be filed with EPA's Office of Federal Activities.
Availability of the EIS will then be announced in the Federal
Register, beginning a 30-day comment period. (The Federal
Register date is the same as the date of this notice.) EPA
will take no administrative action on this project until the
close of the comment period.
Your review of this document and any comments you may have are
appreciated. Please send all comments to Robert B. Howard,
Chief, NEPA Compliance Section at the above address.
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Final
Environmental Impact Statement
for
North Pinellas County, Florida
Prepared by
U.S. Environmental Protection Agency
Region IV
Atlanta, Georgia
This Final EIS addresses proposed wastewater management
facilities for northern Pinellas County, Florida. The major
elements of the EIS include: (1) the development and
evaluation of wastewater disposal alternatives for existing
municipal wastewater treatment facilities, (2) the development
and evaluation of wastewater management alternatives for the
area east of Lake Tarpon, (3) the evaluation of the environmental
effects and costs associated with the disposal of wastewater
through a Gulf outfall, and (4) the evaluation of wastewater
reuse in the study area.
Due to lack of approved wasteload allocations for most of
Pinellas County's surface waters, a study area wide preferred
alternative cannot be selected. EIS conclusions or
recommendations that can be made include: (1) no federal
action related to funding wastewater facilities east of Lake
Tarpon, (2) the identification of wastewater reuse as the
environmentally preferred wastewater management alternative
for the study area, and (3) general findings related to the
disposal of wastewater through a Gulf outfall near northern
Pinellas County.
Comments and inquiries on this EIS should be directed to:
Robert B. Howard, Chief
NEPA Compliance Section
Environmental Assessment Branch
U.S. EPA - Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 3Q365
Telephone Number: 404/881-3776
APPROVED BY:
flUB
lack E. Ravan Date
Regional Administrator
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USEPA .
202-566-0556
, U.'S. ENVIRONMENTAL PROTECTION AGENCY
| JH"
REGION IV - ATLANTA
NORTH PINELLAS COUNTY,
FLORIDA
ENVIRONMENTAL IMPACT STATEMENT
FINAL
Repository Material
Permanent Collection
SEPTEMBER 1985
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Draft ( )
Final (X)
EXECUTIVE SUMMARY FOR THE
ENVIRONMENTAL IMPACT STATEMENT FOR
NORTH PINELLAS COUNTY, FLORIDA
WASTEWATER FACILITIES
Environmental Protection Agency
Region IV
345 Courtland Street
Atlanta, Georgia 30365
Type of Action:
Administrative Action (X)
Legislative Summary ( )
EXECUTIVE SUMMARY
PART A - NEED FOR ACTION
The Environmental Impact Statement (EIS) for North Pinellas County,
Florida addresses alternative wastewater treatment-disposal systems and the
potential impacts of these systems. The Study Area for the EIS includes the
northern half of Pinellas County including all of the City of Clearwater and
locations within the county north of Clearwater as shown on Figure i.
Facilities planning for the EIS Study Area, based on Section 201 of the
1972 Federal Water Pollution Control Act, was accomplished through the North
Pinellas County 201 Plan (which included areas within the County north of the
City of Clearwater: Dunedin, Oldsmar, Tarpon Springs and unincorporated areas)
and the Central Pinellas County 201 Plan (which included the Cities of
Clearwater and Safety Harbor and areas further south). Recommendations of the
201 Plans are summarized in Table i and the service areas are shown on
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N
LOCATION MAP
NORTH PINELLAS COUNTY, FLORIDA
ENVIRONMENTAL IMPACT STATEMENT
STUDY AREA
0 5
5
SCALE IN MILES
:
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IE ATLANTA, GEORGIA
FIGURE i
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TABLE i
WASTEWATER SERVICE AREAS
IN THE NORTH PINELLAS COUNTY EIS STUDY AREA
Service
Area
Clearwater
1984
Capacity
(MGD)
1984
Flow (MGD)
(3)
Year 2000
Projected ...
Flows (MGDrJ; Treatment Levels
Current Wastewater
Eff-luent Disposal
Current
Method
Method Recom.
in 201 Plan
East Plant
Marshall St.
Plant
Northeast Plant
(1)
5.0
3.3
10.0
6.3
8.0
4.6
5.3
8.6-10.0
12.0
Secondary plus ef-
fluent filtration
Secondary plus ni-
trification
Secondary (with
filters being in-
stalled)
Discharge to Old
Tampa Bay, 650
ft. from shore
Discharge to Ste-
venson Creek to
Clearwater Harbor
Effluent dis-
charged through
East Plant's
outfall
Deep-well injection
near the treatment
plant
Deep-well injection
near the treatment
plant
Deep-well injection
near East Plant in
combination with
East Plant
Dunedin
Mainland Plant
Oldsmar
Oldsmar Plant
4.0
3.3
1.0
0.75
5.5-7.0
Secondary
4.5(2)-7.5(2) Secondary with
nitrification
Discharge to St.
Joseph Sound,
1000 ft. from
shoreline
Evap.-perc. ponds
Gulf outfall
Spray irrigation as
primary method;
perc. ponds as
backup method.
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TABLE i
(Continued)
Service
Area
Pinellas County
N. Pinellas Co.
Plant
Safety Harbor
Safety Harbor
Plant
Tarpon Springs
Tarpon Springs
Plant
Area East of
Lake Tarpon
1984
Capacity
(MGD)
1984 n.
Flow (MGD)^ '
3.0
1.3
0.35
0.11
1.25
1.8
<0.5
<0.5
Year 2000
Projected ,_» Current Wastewater
Flows (MGDK Treatment Levels
4.5-10 Secondary
Redirect flow Secondary
to Clearwater
N.E. Plant
4,0 Secondary plus
nitrification
3.5 Secondary (pack-
age plants) and
Effluent Disposal
Current
Method
Spray irrigation
Redirect flow to
Clearwater N.E.
Plant
Discharge to
Anclote River
Holding pond
and reuse on
Method Recom.
"in 201 Plan
Spray irrigation as
primary method;
Gulf outfall as
backup method
Redirect flow to
Clearwater N.E.
Plant
Spray irrigation as
primary method;
Gulf outfall as
backup method
Conveyance to
Clearwater North-
on-lot systems
golf courses
east WWTP
(1)
(2)
(3)
Includes Safety Harbor's flows
Includes 3.5 MGD from unsewered area East of Lake Tarpon
Based on most recent conversations with representatives from each service area.
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Figure ii. All existing nearshore surface water discharges were to be
replaced by several deep well injection and spray irrigation alternatives. A
Gulf outfall was also recommended as both a primary and a back-up disposal
method.
Review of the facilities plans raised substantive questions concerning the
disposal options of deep well injection and a Gulf outfall, lack of wasteload
allocations to area surface waters and the impact of sewering the
environmentally sensitive area east of Lake Tarpon.
Based upon the concerns raised in the 201 Plans and through the review and
scoping processes, the following issues were identified as the major elements
of the EIS:
o Development and evaluation of wastewater disposal
alternatives for the numerous municipal wastewater
treatment facilities;
o Development and evaluation of wastewater management
alternatives for the developing area east of Lake Tarpon;
o Evaluation of the environmental effects and costs
associated with the disposal of wastewater through a Gulf
outfall; and
o Evaluation of water conservation and wastewater reuse in
light of existing groundwater supply limitations in the
Study Area.
PART B - DEVELOPMENT AND EVALUATION OF ALTERNATIVES
Six basic wastewater disposal alternatives were evaluated for the existing
municipal facilities:
o Discharge to coastal waters (Old Tampa Bay, Clearwater
Harbor-St. Joseph Sound or the Anclote River);
vii
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N
PASCO
COUNTY
EAST OF
TARPON
AREA
LAKE
S.A.
TARPON
S.A. «
GULF OF
MEXICO
NORTH
PINELLAS
COUNTY
WWTP
NORTH
PINELLAS
COUNTY 2
.A.
OLDSMAR SA
OLDSMAR
TP
DSMA
FETY
HARBOR
SAFETY
HARBOR
S.A.
CLEARV\ATER
NORTHEAST S.A
CLEAI MATE
CLEARWATER
MARSHALL ST. S.A.
S.A.
WWTP
LEGEND
SERVICE AREA
WASTEWATER TREATMENT PLANT
SURFACE WATER DISCHARGE
POINT
NORTH PINELLAS COUNTY, FLORIDA
ENVIRONMENTAL IMPACT STATEMENT
MUNICIPAL WASTEWATER
SERVICE AREAS
SOURCES: i. PINELLAS COUNTY SEWER SYSTEM
FEBRUARY 1979
2. OLDSMAR- PINELLAS COUNTY AGREEMENT
DECEMBER 1979
SCALE IN MILES
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION 33C ATLANTA, GEORGIA
FIGURE ii
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o A Gulf outfall extending from Clearwater Beach Island,
Honeymoon Island or the mainland north of Honeymoon Island;
o Deep well injection at the Marshall St. Plant or south of
the Study Area possibly at the County's McKay Creek
Wastewater Treatment Plant and injection site;
o Slow rate (spray irrigation) or rapid rate (rapid
infiltration) land application;
o Wastewater reuse of nonpotable wastewater for irrigating
recreational or other open land areas and industrial
cooling and service water; and
o The No Federal Action (no-action) alternative.
s
The service areas and the basic disposal options were combined to form
individual, sub-regional (2 or more service areas combined) and regional (all
seven service areas combined with a total projected flow for the year 2000 of
43 million gallons of wastewater per day (MGD)) disposal alternatives. These
alternatives were screened with some being eliminated because of cost or
environmental reasons.
1) Cost Analysis
(a) Tampa Bay Subarea Cost Summary
The Old Tampa Bay Subarea involves facilities (Oldsmar, Clearwater
Northeast, and Clearwater East) with proposed discharges to Upper Old Tampa Bay
(north of the Courtney Campbell Causeway) or Lower Old Tampa Bay (south of the
Causeway). The general findings of the cost analysis are summarized below:
o The individual service area disposal options with a surface
water discharge treated to secondary levels with no
outfall extension are least costly;
XI
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o Regional and sub-regional options are more costly than
individual options;
o A sub-regional alternative combining all facilities for a
discharge to Lower Old Tampa Bay at secondary treatment
levels is the least costly non-individual service area
option;
o Reuse plus secondary treatment and filtration is cost
competitive with regional Gulf outfall and deep well
injection options; and
o The regional Gulf outfall option (with secondary treatment
and with the outfall located four miles offshore from
Honeymoon Island) is cost competitive with the regional
deep-well injection option.
(b) Clearwater Harbor - St. Joseph Sound Subarea Cost Summary
The Clearwater Harbor - St. Joseph Sound Subarea includes the Clearwater
Marshall Street and Dunedin treatment plants. General findings of the cost
analysis are summarized as follows:
o The individual service area disposal options with a surface
water discharge are least costly;
o Reuse plus secondary treatment and filtration are less
costly than regional Gulf outfall or deep well injection
options; and
o The regional Gulf outfall option is cost competitive with
the regional deep well injection option (but at a higher
level of costs than the individual service area options).
xii
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(c) North Pinellas County Subarea Cost Summary
Rapid rate land application as an individual disposal option is the least
costly alternative.
(,d) Tarpon Springs Subarea Cost Summary
The Tarpon Springs wastewater service area is the Tarpon Springs
Subarea. The Anclote River has been assigned a wasteload allocation by the
Florida Department of Environmental Regulation (DER). Discharge of
wastewater, treated to advanced secondary treatment (AST) levels, is the
least costly disposal option that is judged environmentally acceptable. Some
of the unincorporated area northeast of Lake Tarpon may also be served by the
Tarpon Springs Wastewater Treatment Plant.
(e) Area East of Lake Tarpon
A range of alternatives including on-lot and community systems, land
application and a centralized sewer system were considered for this area. The
costs for on-lot and small community systems are based on an analysis of
three planned residential communities east of Lake Tarpon. The costs are for
existing residences and capacity for future growth. Annual user costs for
screened alternatives are:
Treatment Alternative Annual User Cost
Community Sand Mound-Septic Tank $386
effluent pump system
Land application following secondary $393
treatment
Centralized system with treatment $400
at Oldsmar WWTP
2) Evaluation of Non-Monetary Factors
The alternatives also were evaluated on the basis of expected environ-
mental impacts (with emphasis on aquatic environment, public health and
recreation), operability constraints and implementability limitations.
xiii
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Implemencability, operabllity, and environmental impact factors for the five
basic disposal options (excluding the no-action alternative) are presented
in Table ii.
The expected environmental impacts, operability constraints and
implementability limitations for the area east of Lake Tarpon are summarized
in Table iii.
PART C - CONCLUSIONS
In the absence of approved wasteload allocations for area surface waters
(except the Anclote River), EPA can not, in this EIS, select a preferred
alternative for wastewater disposal for all of North Pinellas County. The EIS
must instead be viewed as providing input to the Florida DER in their
wasteload allocation decisions and to local agencies for their wastewater
management decisions. The EIS can serve the purpose of narrowing the field
of reasonable alternatives; presenting the costs associated with various
effluent limitation combinations; and identifying expected environmental
impacts, operability constraints and implementability limitations associated
with the alternatives. The identification of the most cost effective,
environmentally sound disposal alternative that would be eligible for EPA
funding can not be accomplished until the wasteload allocation process is
completed. An environmentally preferred alternative of wastewater reuse can,
however, be identified in the EIS. Additionally, decisions concerning EPA's
role in wastewater management east of Lake Tarpon are not dependent on waste-
load allocations and therefore can be described in the EIS.
Decisions have already been made concerning the Tarpon Springs discharge
to the Anclote River, because wasteload allocations have been established and
approved. Further decisions concerning Tarpon Springs are not necessary.
Decisions in the North Pinellas service area can be made independently of
wasteload allocations. Land application of treated wastewater on-site or at
the Innisbrook Country Club is the most cost-effective, environmentally sound
disposal option regardless of the level of treatment provided prior to any
surface water discharge option.
xiv
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TABLE ii
IMPLEMENTABILITY, OPERABILITY AND ENVIRONMENTAL IMPACT FACTORS OF BASIC DISPOSAL OPTIONS
Option
Discharge to
Coastal Waters
Gulf Outfall
Deep Well
Injection
Implementability/Operability
Approved wasteload allocations for dis-
charges are unavailable. Wastewater dis-
charges are constrained because all
Pinellas County waters are state desig-
nated Outstanding Florida Waters and
Class II (shellfish harvesting) waters.
Public acceptability is uncertain. No
Gulf outfalls currently exist in
Region IV. Outfall operation is proven
technology.
Was first thought not viable at Clearwater
East Plant site. Funding for additional
testing is being sought by Clearwater.
Proven to be implementable south of the
Study Area. May be viable in southwest
section of Clearwater. 28 month testing
program required for new disposal sites.
Environmental Impacts
Water quality impacts (and impacts on
beach use, grass beds, aquatic ecosystem,
etc.) determined by quality of effluent
discharged (continued degradation is
expected with secondary treatment levels
and improvement with AWT). Non-point
source controls in some waters may be
needed for further water quality improve-
ments.
Construction: 12 acres of bottom habitat
potentially altered or destroyed per mile
of pipeline. Outfall corridor could be
sited to minimize construction impacts.
Operation; Benthic community within
100-200 feet of discharge would be
altered. Potential for beaches, reefs
and other sensitive areas to be
impacted. Estuarine water quality would
be improved by removal of near shore
surface water discharges.
Estuarine water quality would probably
improve. Could help retard saltwater
intrusion into potable aquifer zones.
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TABLE ii
IMPLEMENTABILITY, OPERABILITY AND ENVIRONMENTAL IMPACT FACTORS OF BASIC DISPOSAL OPTIONS
Option
Land Application
Non-potable
Reuse at parks,
golf courses and
other lands
x
H-
Implementability/Operability
Land availability, zoning changes and
land cost are implementation issues.
Under-drains may be required in many
areas because of high groundwater
table. Back-up disposal method and/or
large retention capacity is needed.
Proven to be implementable in
neighboring St. Petersburg. Costs
are usually higher than other dis-
posal alternatives. Back-up disposal
method is needed. Land availability
is an issue.
Environmental Impacts
Surface water quality would improve.
Land use alteration and conversion could
occur. Wildlife habitat could be
altered. Potential groundwater recharge
advantages.
Limited area groundwater supplies could
benefit by both conservation and reuse.
Potential health risk if reuse system
is not secured from casual human contact
with wastewater. Reduced surface water
discharges would potentially result in
water quality improvements.
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TABLE iii
COMPARATIVE FEATURES OF WASTEWATER MANAGEMENT ALTERNATIVES FOR THE
AREA EAST OF LAKE TARPON
Alternative
Sand-Mounds with STEP Systems
Package Plants with land
application
Centralized System with Treat-
ment at Oldsmar WWTP
1) No surface water discharge
2) Minimal public health concerns
with properly functioning
systems
3) Terrestrial ecosystem impacts
minimal
4) Without centralized systems,
densities may be decreased
resulting in reduced impacts on
wetlands, flood-prone areas,
recharge areas
5) Low cost alternative
6) Malfunctions could result in
public health, recreation and
odor impacts
7) Shallow groundwater supplies
could be affected by nitrate
increases
8) Soil suitability limited to
southern portion of area east of
Lake Tarpon
1) No surface water discharge
2) Minimal public concerns with
properly functioning systems
Same as 4) above
Existing developments are using
this technique now
5) Low cost alternative
6) Open space would be maintained
for Land Application and other
uses
Same as 6) above
Same as 7) above
Storage or back-ups required for
ve: vaather periods
Leige portions of potentially
developable land are required
for land application
11) Some vegetation removal required
1) No groundwater concerns
2) No operability constraints
3) High cost alternative when dis-
posal costs are added
3)
4)
7)
8)
9)
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TABLE ill (Cont'd.)
COMPARATIVE FEATURES OF WASTEWATER MANAGEMENT ALTERNATIVES FOR THE
AREA EAST OF LAKE TARPON
Alternative
Centralized System with Treat-
ment at Oldsmar WWTB (Cont'd.)
4) Wasteload allocations do not
exist for surface waters
5) Increased nutrient/BOD- load to
Old Tampa Bay could result in
water quality degradation
6) Potential public health/recrea-
tion impacts with discharge
7) Centralized system would support
dense development in area's wet-
lands, floodprone areas, re-
charge zones; nonpoint source
loads to Lake Tarpon could in-
crease
8) State law and regulations
constrain surface water dis-
charges
xvi 11
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The alternatives involving discharge into Old Tampa Bay, Clearwater Harbor
and St. Joseph Sound can undergo no further screening by EPA at this time.
Additional definitive decisions can not be made until wasteload allocations
for those water bodies are available.
Existing wastewater management methods east of Lake Tarpon include
septic tank - absorption field systems at individual homes and private package
plants that serve planned community developments. Wastewater from the package
plants is disposed via land application of effluent within that development.
With proper maintenance and sufficient acreage, this practice has apparently
been successful. Water quality or public health problems associated with these
existing systems have not been documented.
The thrust of facilities planning east of Lake Tarpon is toward the
provision of facilities for future population, not the existing population.
In this regard, the selection of EPA's funding decision is primarily dictated
by two factors.
First, the area East of Lake Tarpon contains many sensitive environmental
features that could be potentially impacted by continued development. The area
is drained by Brooker Creek, a major drainage basin of Lake Tarpon. This
tributary system is composed of a network of wetlands and floodplains that
comprise approximately 33 percent of the area east of Lake Tarpon. Much of
the area is also a groundwater recharge zone which is critical to the long-
term viability of the area's groundwater supply. One of the area's major
public water supply well fields is located in this portion of the study area.
EPA's participation in funding facilities to support development that would
adversely affect these sensitive environmental features is limited by both
policy and regulation.
Secondly, EPA's Construction Grants Regulations allow the agency to fund
facilities only to serve capacity for flows existing on the date of Step 3
grant award, but not to exceed 1990 flows. Since the focus of these
alternatives is to serve future development, the Agency's funding role in the
area east of Lake Tarpon is limited.
xix
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PART D - RECOMMENDATIONS
1) Wastewater Reuse
The wastewater reuse alternatives for each service area are hereby identi-
fied as the environmentally preferred disposal alternative. Reuse is the only
management option that responds to the area's surface water quality problems
while addressing ground water supply limitations. The costs, advantages, and
disadvantages are clearly outlined to the community and local decision
makers. The need for a wet weather backup for wastewater that cannot be reused
.is likely to exist. Potentially feasible backup options include continued but
intermittent surface water discharges or deep well injection.
In general terms, the cost of wastewater reuse represents an additional
$41 to $48 million beyond the costs associated with surface water disposal
options at AWT and secondary treatment levels, respectively for all seven
treatment plants. These costs do not recognize any value for the recycled
wastewater or the reduced costs associated with lesser needs for potable
supplies.
It should be noted that this recommendation is to identify the environmen-
tally preferred alternative, is not necessarily the "EPA fundable" al-
ternative. The "EPA fundable" alternatives for both the Clearwater Harbor -
St. Joseph Sound and Old Tampa Bay Subareas will be selected upon completion
of the wasteload allocation process. Additionally, identification of the
environmentally preferred alternative does not preclude the consideration of
other disposal options (e.g., deep well injection or intermittent surface
water discharges). Deep well injection is a disposal option that had been
considered as both a primary and backup disposal option. Local agencies may
wish to pursue further deep well investigations to determine its feasibility
as a disposal option and its relationship to a reuse alternative.
2) Tarpon Springs Subarea
Discharge to the Anclo'te River of advanced secondary treated (AST)
effluent is the recommended alternative for Tarpon Springs, in accordance with
the approved wasteload allocation.
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3) North Pinellas Subarea
Land application at the existing site and the Innisbrook Country Club has
been shown to be the most cost-effective, environmentally sound option
available. Regardless of wasteload allocations, land application is the
recommended alternative for the North Pinellas Subarea.
4) Clearwater Harbor - St. Joseph Sound Subarea
In the absence of wasteload allocations for this sub-area, numerous
alternatives remain viable for the Dunedin and Marshall Street service areas.
The information from the EIS process is available to the state for use in
their decisions. Upon completion of the wasteload allocation process, the
most cost-effective environmentally sound option for funding eligibility can
then be selected.
5) Old Tampa Bay Subarea
In the absence of wasteload allocations for this subarea, numerous alter-
natives remain viable for the Clearwater East, Clearwater Northeast and Oldsmar
service areas. The information from the EIS process is available to the state
for use in their decisions. Upon completion of the wasteload allocation
process, the most cost-effective environmentally sound option for funding
eligibility can then be selected.
6) Area East of Lake Tarpon
EPA's policy and regulations concerning funding facilities in environ-
mentally sensitive areas and funding capacity for future flows do not allow
funding assistance in the area east of Lake Tarpon. The reasonable alter-
natives have been evaluated in terms of cost, impact, reliability and
implementability. This information is available to the County and private
developers for local decision-making.
EPA also encourages governing bodies within the Study Area to consider
the function and value of environmentally sensitive undeveloped areas
xxi
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ease of Lake Tarpon (i.e., groundwater recharge areas, wetlands, floodplains)
in future planning and development decisions.
EPA's Construction Grants regulations allow the Agency to fund facilities
only to serve capacity for flows existing on the date of Step 3 grant award,
but not to exceed 1990 flows. Since the basis for many of the alternatives
for the area east of Lake Tarpon is to serve future development and not to
correct existing water quality or public health problems, the EPA will not
participate in funding wastewater facilities in this area.
7) Gulf Outfall
As part of this EIS, a Marine Measurement and Sampling Program was
conducted during 1980 to better define existing environmental and physio-
graphic conditions in the nearshore Gulf of Mexico off northern Pinellas
County. The data collected during the sampling program were utilized to
assist in evaluating the Gulf outfall wastewater disposal alternative and to
generically demonstrate the methodology that should be used in considering a
f
Gulf outfall. The general findings related to a Gulf outfall from northern
Pinellas County are as follows:
o It would provide the area with a reliable long-term waste-
water disposal option;
o It would require a major investment of capital in a dispos-
al option that would tend to discourage the environmentally
preferred alternative of wastewater reuse;
o It would involve the environmental tradeoffs of minimizing
impacts to estuarine waters while increasing impacts to the
Gulf (i.e., bottom disruption and community alteration,
attractant to fish and other organisms causing impacts,
nutrient impact);
o It would remove a development constraint that would poten-
tially promote higher density development and development
xxii
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in environmentally sensitive areas which are not suitable
for on-lot or recycle wastewater management;
o Secondary treatment and disinfection of wastewater would be
necessary to minimize adverse impacts of an outfall on
local beaches;
o Station 3F which is roughly four miles offshore from
Honeymoon Island was selected for additional study to
further demonstrate the generic methodology for evaluating
the Gulf outfall alternative. The area of Station 3F was
found to be less environmentally sensitive than other
sites located closer to shore that were evaluated during
the Marine Sampling Program;
o Station 3F appears to be more cost effective than other
stations evaluated during the Marine Sampling Program based
on estimated cost and combined impacts to public health,
the St. Joseph Sound estuary and natural hardbottom reef
habitat;
o Nearshore Gulf currents vary such that predictions of
effluent movement from a discharge are uncertain. Dye
discharged in the area of Station 3F during the Marine
Sampling Program generally moved in a south-southwesterly
direction. A discharge plume in the area of Station 3F
would be expected to have minimal impact on the area's
beaches;
o Any further consideration of discharge sites near Station
3F should focus on areas slightly north of the exact study
location to further minimize potential impacts to usage of
the Dunedin Artificial Reef;
o A precise outfall alignment and point of discharge would
require additional site-specific analyses (i.e., site
xxiii
-------
specific studies to select the exact outfall route, the
discharge point and required mitigation);
o Any further consideration of Station 3F or any other
potential" Gulf outfall site would be subject to permit/
administrative review and approval.
8) Water Conservation
The following conclusions can be stated about water conservation:
o Although evidence of drawdown from pumping is apparent,
water appears to be in sufficient quantity to satisfy water
supply needs. The costs of providing water, however, are
higher than costs for water conservation;
o Legal disputes over water rights and inter-county water
transfers could intensify. Such disputes have already
arisen between Pinellas and Pasco Counties;
o Water conserving devices are easy to install and require
little maintenance or operation;
o Losses in water revenue could result from decreased water
use;
o Local plumbing codes may require revision; and
o Water conservation measures can generally reduce annual
wastewater treatment and disposal costs by 10 percent in
developed areas and 15 - 20 percent in less developed
areas.
Local governments are encouraged to institute a water conservation program.
XXIV
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NORTH PINELLAS COUNTY, FLORIDA
DRAFT ENVIRONMENTAL IMPACT STATEMENT
TABLE OF CONTENTS
PAGE
EXECUTIVE SUMMARY i
A. Need for Action i
B. Development and Evaluation of Alternatives vii
C. Conclusions xiv
D. Recommendations xx
TABLE OF CONTENTS xxv
LIST OF TABLES xxvi
LIST OF FIGURES xxvi
I. BACKGROUND AND PURPOSE OF THE EIS 1
A. Background 1
B. Purpose 5
II. THE SELECTED ALTERNATIVE 7
A. Basis of Decision 7
B. EIS Recommendations 8
C. Remaining Alternatives 14
III. ERRATA AND REVISIONS TO THE DRAFT EIS 19
IV. PUBLIC COMMENTS AND EPA RESPONSES 21
A. Oral Comments 21
B. Written Comments 21
V. LIST OF PREPARERS 121
xxv
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LIST OF TABLES
Table No. Table Name Page
i Wastewater Service Areas in the North v - vi
Finellas County EIS Study Area
ii Implementability, Operability and Environmental xv - xvi
Impact Factors of Basic Disposal Options
iii Comparative Features of Wastewater Management xvii - xviii
Alternatives for the Area East of Lake Tarpon
1 Wastewater Disposal Alternatives ' 15-18
2 Index to Public Hearing Comments on North 22-24
Pinellas County Draft EIS
3 Summary of General Topics Covered by Oral 25
Comments
4 • Index to Written Comments on North Pinellas 77-81
County Draft EIS
5 Summary of General Topics Covered by Written 82
Comments
LIST OF FIGURES
Figure No. Figure Name Page
i EIS Study Area iii
ii Municipal Wastewater Service Areas ix
xxvi
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CHAPTER I
BACKGROUND AND PURPOSE OF THE EIS
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CHAPTER I
BACKGROUND AND PURPOSE OF THE EIS
PART A - BACKGROUND
The North Pinellas County Environmental Impact Statement (EIS) Study Area,
shown in Figure i, has experienced tremendous population growth since the
1950!s. Climate and the Gulf coast beaches attract vacationers, seasonal
residents, and permanent, year-round residents. Development began south of the
Study Area in St. Petersburg and Largo. As those areas became saturated with
homes, development began to increase in Clearwater, Dunedin and areas further
north. Pinellas County experienced a population growth of 39 percent from 1960
to 1970; it is now one of the most densely populated counties within the state
of Florida.
Areas most pleasant for residential and commercial development are often
environmentally fragile areas. As a result of being surrounded on three sides
by marine or estuarine waters, Pinellas County's fresh groundwater supply is
limited. All of the groundwater beneath the southern half of the county is now
not potable due to salinity intrusion resulting from excessive pumping.
Dispersed wellfields are still utilized in the northern half of the county, but
most of these wells have limited yields. Little open space remains for any
future development.
Degradation of surface water resources is a second example of the area's
environmental sensitivity. Abilities of local coastal waters to assimilate
wastewater are limited due to shallow depths, slow flushing rates and
pollution from stormwater runoff. Therefore, other ways to dispose of
wastewater have been investigated while still desiring to preserve the safe
use of local beaches.
Centralized wastewater transmission and treatment systems are managed
within the Cities of Clearwater, Dunedin, Oldsmar and Tarpon Springs by the
Cities themselves. The City of Clearwater manages three wastewater treatment
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plants: Clearwater East, adjacent to Old Tampa Bay just off the Courtney
Campbell Causeway; Clearwater Northeast which also is proposed to serve the
City of Safety Harbor; and Clearwater Marshall Street which serves the western
half of the City of Clearwater. These wastewater service areas are outlined
in Figure ii.
The Pinellas County government manages the North Pinellas Wastewater
treatment plant and all wastewater transmission lines in unincorporated areas
north of the Cities of Dunedin and Clearwater. The area east of Lake Tarpon is
not connected to any of the municipal wastewater treatment plants. On-lot
systems throughout the Study Area are managed by the Pinellas County Health
Department.
The Federal government provided funds for northern Pinellas County for
wastewater facilities plans (also called 201 Plans) beginning in the
mid-1970's. The North Pinellas County 201 Plan considered areas within the
county north of the City of Clearwater: Dunedin, Oldsmar, Tarpon Springs, and
unincorporated areas. The Central Pinellas 201 Plan considered the Cities of
Clearwater and Safety Harbor and areas further south.
The North Pinellas 201 Plan resulted in a proposed solution to wastewater
disposal problems which included the following:
o An outfall to the Gulf of Mexico to dispose of Dunedin's
wastewater;
o Spray irrigation to dispose of wastewater from the North
Pinellas wastewater treatment plant (WWTP)(serving unincor-
porated areas west of Lake Tarpon);
o Spray ; irrigation to dispose of Oldsmar's and Tarpon
Spring's wastewater; and
o Conveyance of wastewater from the unincorporated areas east
of Lake Tarpon to the Clearwater Northeast WWTP.
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Backup (wet-weather) disposal methods for spray irrigation recommended in the
North Pinellas 201 Plan were (1) a Gulf outfall for the unincorporated area
west of Lake Tarpon and the City of Tarpon Springs and (2) deep-well injection
at the Clearwater East WWTP for wastewaters generated in Oldsmar and in the
area east of Lake Tarpon. Treatment levels at these wastewater treatment
plants were recommended to be secondary or modified secondary.
Wastewater disposal methods recommended for the City of Clearwater in the
Central Pinellas 201 Plan included:
o Deep-well injection of effluent from the Clearwater Mar-
shall Street WWTP at a local site;
o Deep-well injection of effluent from the Clearwater East
and Clearwater Northeast service areas at the Clearwater
East WWTP; and
o Routing of untreated wastewater flows from the City of
Safety Harbor to the Clearwater Northeast WWTP. The Safety
Harbor WWTP was recommended to be abandoned.
Irrigation of publicly-owned lands was recommended in the Central Pinellas 201
Plan as a secondary disposal method. If deep-well injection was to be aban-
doned, the recommended municipal wastewater disposal system would be a Gulf
outfall in conjunction with facilities recommended in the North Pinellas
County 201 Plan.
After the 201 Plans were formulated, the U.S. EPA made two important
judgements:
o A Finding of No Significant Impact could not be issued for
the Gulf outfall alternative recommended in the 201 Plans;
and
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o Questions needed to be addressed regarding wastewacer
management in less developed portions of the Study Area,
particularly the area east of Lake Tarpon, which includes
significant floodplain and wetland areas and two large
public wellfields.
The 201 recommendations have been complicated by other events as well.
Preliminary deep-well injection field tests conducted during the late 1970s at
the Clearwater East WWTP site led to the judgment that continuous injection at
that site could not be carried out as recommended in the Central Pinellas 201
Plan without endangering nearby water supply wells. A suitable confining
layer(s) was not located during those preliminary drilling activities. Recent-
ly, however, the City of Clearwater attempted to acquire funding to reactivate
the Clearwater East test site because deep well injection regulation changes
may allow for injection at the East site. Attempts to acquire EPA funding
have, thus far, not been successful. Deep-well injection testing at the McKay
Creek WWTP (located south of the study area) is still continuing.
Secondly, the Florida Department of Environmental Regulation (Florida DER)
has not issued final wasteload allocations for Old Tampa Bay, Clearwater
Harbor, or St. Joseph Sound. The Florida DER has issued a draft Tampa Bay
Water Quality Impact Study which addresses wasteload allocations for Old Tampa
Bay as well as for other Tampa Bay waters. This document is currently under
review. Wasteload allocations for Clearwater Harbor and St. Joseph Sound are
currently being developed by Florida DER.
An additional factor of concern is that Pinellas County waters have been
designated as Outstanding Florida Waters (OFWs) and are afforded additional
state protection from the discharge of treated wastewater. The OFW designation
and protection is, however, not formally recognized by EPA funding decisions.
These waters are also classified as Class II waters (Shellfish Propagation and
Harvesting) and as such, the discharge of effluent is not allowed. DER had
also established a "no discharge" wasteload allocation for many of these waters
in 1978. Because of this allocation, EPA is now denying the reissuance of
NPDES permits for facilities with this "no-discharge" allocation. Although DER
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is currently conducting wasteload allocation studies for many of these waters;
the current "no-discharge" allocation, the OFW designation and Class II waters
classification provide justification for permit denial.
PART B - PURPOSE OF THE EIS
The North Pinellas County EIS originated in 1979 due primarily to envi-
ronmental concerns with a Gulf outfall and with wastewater management
decisions proposed for the low-lying areas east of Lake Tarpon. No wastewater
outfalls extend to the Gulf of Mexico from the Florida coast at the present
time. Costs, environmental impacts, operability considerations and implemen-
tability factors needed to be addressed. Very little information about the
nearshore Gulf Coast environment was available upon which to act on the 201
plan proposals; field data for the Gulf and for Clearwater Harbor - St. Joseph
Sound have been collected as part of this EIS process.
Based upon the concerns raised in the 201 Plans and through the review
and scoping processes, the following issues were identified as the major
elements of the EIS:
o Development and evaluation of wastewater disposal
alternatives for the numerous municipal wastewater
treatment facilities;
o Development and evaluation of wastewater management
alternatives for the developing area east of Lake
Tarpon;
o Evaluation of the environmental effects and costs
associated with the disposal of wastewater through a
Gulf outfall; and
o Evaluation of water conservation and wastewater reuse
in light of existing groundwater supply limitations
in the Study Area.
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CHAPTER II
THE SELECTED ALTERNATIVE
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CHAPTER II
THE SELECTED ALTERNATIVE
One specific, preferred alternative, or group of alternatives, can not yet
be selected as eligible for Federal funding. Instead, results of this EIS are
presented: (1) in terms of groups of alternatives which may become eligible for
Federal funding including the environmentally preferred alternative and (2)
in terms of overall results of the alternatives evaluation effort: cost
analyses, in-depth consideration and (where possible) quantification of
projected environmental impacts, evaluation of operational considerations for
the various technologies, and evaluation of procedures for implementing the
alternatives.
PART A - BASIS OF DECISION
Wasteload allocations for Old Tampa Bay, Clearwater Harbor - St. Joseph
Sound have not yet been established. These wasteload allocations will
prescribe required levels of treatment for wastewater discharges to these
coastal waters. The allocations will be established by the Florida DER with
EPA-Region IV approval. EPA will not recommend wastewater management alter-
natives at this time which may later not be in accord with these future
wasteload allocations. Recommendations for service areas in which wasteload
allocations are not involved are offered. All aspects of wastewater
management: costs, environmental impacts, operation and implementation
should be evaluated within the wasteload allocation process.
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PART B - EIS RECOMMENDATIONS
These recommendations are related to three major EIS issues:
o Disposal options for sewered areas of North Pinellas County;
o Management options for the area east of Lake Tarpon; and
o Statements concerning a Gulf outfall of treated wastewater.
Certain aspects of the recommended alternatives cannot be given until
approved wasteload allocations (including effluent limits and discharge
locations) are available from Florida DER.
1) Disposal Options for Sewered Areas of North Pinellas County.
The EIS narrows the field of reasonable alternatives by outlining general
costs, environmental impacts, operability concerns and implementability
limitations associated with the ElS-generated alternatives. Least costly
disposal options are identified and an environmentally preferred approach is
recommended.
The EIS does not identify a selected alternative for wastewater disposal
for the currently sewered portions of North Pinellas County because of a lack
of approved wasteload allocations for Pinellas County's surface waters.
It is the recommendation of the EIS that non-potable wastewater reuse at
parks, golf courses and other lands (and water conservation) be identified as
the environmentally preferred alternative. The need for a wet weather backup
for wastewater that cannot be reused is likely to exist. Potentially feasible
backup options include continued but intermittent surface water discharges or
deep well injection.
Reuse is the only management option that responds to the area's surface
water quality problems while addressing groundwater supply limitations. The
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coses, advantages, and disadvantages of wastewater reuse, which are summarized
below, are discussed in more detail in the Draft EIS. Cost comparisons
between reuse and non-reuse options and the costs of the least costly disposal
options are also presented in the Draft EIS.
The advantages in wastewater reuse include: 1) potentially high public
acceptance, 2) reduced reliance on surface water discharges (and resultant
water quality improvements) and 3) reduced strain on limited public ground-
water supplies. The disadvantages lay in: 1) high cost, 2) the need for
wet-weather back-ups (surface water discharge back-ups are constrained by
lack of approved wasteload allocations), 3) operability considerations which
include soils variations and the need for reliable maintenance at numerous
dispersed sites, and 4) amount of wastewater reused is dependent upon private
decisions and commitments. In general terms, the cost of wastewater reuse
represents an additional $41 to $48 million beyond the costs associated with
surface water disposal options at AWT and secondary treatment levels,
respectively. These costs include reuse at all study area facilities (i.e.,
Oldsmar; Clearwater Northeast, East and Marshall Street; Dunedin; North
Pinellas and Tarpon Springs).
It should be noted that this recommendation is to identify the environ-
mentally preferred alternative, not the "EPA fundable" alternative. The
"EPA fundable" alternative will be selected upon completion of the wasteload
allocation process. Additionally, identification of the environmentally
preferred alternative does not preclude the consideration of other disposal
options (e.g. deep well injection or intermittent surface water discharges).
Deep well injection is a disposal option that had been considered as both a
primary and backup disposal option. Local agencies may wish to pursue further
deep well investigations to determine its feasibility as a disposal option and
its relationship to a reuse alternative.
Florida DER has indicated and the EPA has concurred that a wasteload
allocation specifying advanced secondary treatment (AST) is appropriate for
the Tarpon Springs discharge to the Anclote River given current water quality
considerations. The effluent concentration must not exceed the following
average concentrations: 6 milligrams per liter (mg/1) of five-day BOD, 6 mg/1
of suspended solids, 6 mg/1 of total nitrogen and 3 mg/1 of total phosphorus.
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Based on this effort, continued discharge to the Anclote River has already
been pursued by Tarpon Springs. Decisions in the North Pinellas service area
can be made independently of wasteload allocations. Land application of
treated wastewater on-site and at the Innisbrook Country Club is the most
cost-effective, environmentally sound disposal option for this area.
2) Wastewater Management for the Area East of Lake Tarpon
Existing wastewater management methods east of Lake Tarpon involve
individual septic tanks with absorption field systems and private package
plants that serve planned community developments with land application of
effluent within that development. With proper maintenance and sufficient
acreage, this practice has, apparently, been successful. Water quality or
public health problems associated with these existing systems have not been
documented. The County, however, has expressed a desire for wet weather
back-ups (e.g., surface water discharges) for these land application systems.
The thrust of facilities planning in this area is toward the provision of
facilities for future population growth.
The area east of Lake Tarpon contains many sensitive environmental
features that could be potentially impacted by increased development. The
area is drained by Brooker Creek, a major drainage basin of Lake Tarpon. This
tributary system is composed of a network of wetlands and floodplains that
comprise approximately 33 percent of the area east of Lake Tarpon. Much of
the area is also a groundwater recharge zone which is critical to the long
term viability of the area's groundwater supply. One of the area's major
public water supply well fields is located in this portion of the Study Area.
EPA's participation in funding facilities that would support development could
adversely affect these sensitive environmental features.
It is the recommendation of the EIS that EPA not provide funding
assistance for wastewater facilities in the area east of Lake Tarpon. The
reasonable alternatives have been evaluated in terms of cost, impact,
reliability and implementability. No water quality or public health needs
have been identified necessitating any major actions, and the provision of
10
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additional facilities would promote growth in environmentally sensitive
areas. County and private developers should provide facilities if desired to
support future growth.
EFA's Construction Grants Regulations allow the Agency to fund facilities
only to serve capacity for flows existing on the date of Step 3 grant award,
but not to exceed 1990 flows. Since the basis for many of the alternatives
for the area east of Lake Tarpon is to serve future development, the Agency's
funding role in this area should be limited.
Since the EIS recommendation in this area does not involve a surface
water discharge, the wasteload allocation process is not a factor.
Scientific and engineering support for proper management of on-lot and
other small wastewater systems east of Lake Tarpon is available from numerous
sources. The EPA's experience with guiding the management of small wastewater
systems throughout the United States may be helpful to local wastewater
managers, and such experience is available upon request. Some suggestions for
providing the most effective management of small wastewater systems are the
following:
o Interactions between the local health agency and
homeowners are quite important. A Homeowners Guide may
be worth the effort needed to prepare.
o Engineers should be qualified and installers should be
licensed to work with all types of on-lot systems to be
utilized.
o Installers could be required to submit quarterly activity
reports (e.g. maintenance and septage hauling activities -
amounts and locations).
11
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3) Environmental Statements Concerning a Gulf Outfall for Treated Wastewater
A Marine Sampling Program was conducted as part of the EIS to collect
data to develop a Gulf outfall alternative for wastewater disposal to consider
along with other disposal alternatives. The Marine Sampling Program was also
designed to generically demonstrate the evaluation methodology that should be
used in considering a Gulf outfall. Physical, biological and chemical data
have been obtained in the EIS Marine Sampling Program. The Study Area for the
sampling program included 20 miles of the coast, from the Belleair Beach
Causeway north to the Anclote River, and extended 10 miles offshore of the
barrier islands.
Of the numerous environmental factors to be considered, three were chosen
as being the most important in the consideration of a Gulf outfall in this
area: potential health and aesthetic impacts at bathing beaches, ecological
impact to natural reef hardbottom-limestone outcrops, and impairment of the
beneficial uses of the manmade fishing reefs.
The following statements concerning a Gulf outfall from northern Pinellas
County can be made based on the Marine Sampling Program and EIS evaluations:
o It would provide the area with a reliable long-term
wastewater disposal option;
o It would require a major investment of capital in a
disposal option that would tend to discourage the
environmentally preferred alternative of wastewater reuse;
o It would involve the environmental tradeoffs of minimizing
impact to estuarine waters while increasing impacts to the
Gulf (i.e., bottom disruption and community alteration,
attractant to fish and other organizms causing impacts,
nutrient impact);
12
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o It would remove a development constraint that would
potentially promote higher density development and
development in environmentally sensitive areas which are
not suitable for on-lot or recycle wastewater management;
o Secondary treatment and disinfection of wastewater would
be necessary to minimize adverse impacts of an outfall on
local beaches;
o Station 3F was selected for detailed study to demonstrate
the generic methodology for evaluating the Gulf outfall
alternative. The area of Station 3F which is roughly four
miles offshore from Honeymoon Island, was found to be less
environmentally sensitive than other sites located closer
to shore that were evaluated during the Marine Sampling
Program;
o Station 3F appears to be more cost effective than other
stations evaluated during the Marine Sampling Program
based on estimated cost and combined impacts to public
health, the St. Joseph Sound estuary and natural
hardbottom reef habitat;
o Nearshore Gulf currents vary such that predictions of
effluent movement from a discharge are uncertain. Dye
discharged in the area of Station 3F during the Marine
Sampling Program generally moved in a south-southwesterly
direction. A discharge plume in the area of Station 3F
would be expected to have minimal impact on the area's
beaches;
o Any further consideration of discharge sites near Station
3F should focus on areas slightly north of the exact study
location to further minimize potential impacts to usage of
the Dunedin Artificial Reef;
13
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o The precise outfall alignment and point of discharge would
require additional site-specific analyses (i.e., site
specific studies to select the exact outfall route, the
discharge point and required mitigation);
o Any further consideration of Station 3F or any other
potential Gulf outfall site would be subject to permit/
administrative review and approval.
PART C - REMAINING ALTERNATIVES
Wasteload allocations for Old Tampa Bay and Clearwater Harbor-St. Joseph
Sound are in the process of being developed. The selected treatment level for
each body of water could be as minimal as secondary wastewater treatment or as
stringent as not allowing any wastewater discharge.
Therefore, all of the screened alternatives listed in Table 1 and evaluat-
ed in the EIS for the Clearwater East, Clearwater Northeast, Clearwater
Marshall Street, Dunedin and Oldsmar service areas remain under consideration.
Costs, impacts on the environment, operability and implementabillty of all
remaining alternatives are presented in the Draft EIS.
Two additional points need to be emphasized. The first is that no waste-
water alternatives for Clearwater, Oldsmar and Dunedin can be determined to be
eligible for funding under the Construction Grants program until the wasteload
allocations have been finalized through Florida DER. The second point is that
any statements about a Gulf outfall extending from the North Pinellas County
Study Area pertain only to this EIS. Statements made about potential impacts
of a Gulf outfall may not be applicable to other locations along the Gulf
coast.
14
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TABLE 1
WASTEWATER DISPOSAL ALTERNATIVES
Designation Alternative
Individual Alternatives
City of Clearwater East (E) Service Area
Continue existing discharge to Old Tampa Bay south of
the Courtney Campbell Causeway
E_2(D Discharge to Old Tampa Bay at different location south
of Causeway
E_3 Discharge to Old Tampa Bay north of Causeway
E-17^ Distribution of reusable wastewater to parks, golf
courses and other lands for nonpotable uses
City of Clearwater Marshall Street (MS) Service Area
Continue existing discharge to Stevenson Creek
Discharge to Clearwater Harbor
Discharge via outfall to Gulf of Mexico extending from
Clearwater Beach Island
Distribution of reusable wastewater to parks, golf
courses and other lands for nonpotable uses
City of Clearwater Northeast (NE) Service Area
NE-1^ Resume former discharge which flows into Possum
Branch (and subsequently to Old Tampa Bay)
NE-2 Discharge directly to Possum Branch
NE-3 Discharge to Safety Harbor
NE-4 Discharge to Old Tampa Bay north of Causeway
NE-16^ Discharge of reusable wastewater to parks, golf courses
and other lands for nonpotable uses.
City of Dunedin (D) Service Area
D-l^ Continue existing discharge to St. Joseph Sound
D_2 Relocate discharge to some other location in St. Joseph
Sound
15
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TABLE 1
(Cont'd.)
Designation Alternative
City of Dunedin (D) Service Area (cont'd.)
D-3 Discharge via outfall to Gulf of Mexico extending from
Honeymoon Island
D-15 Distribution of reusable wastewater to parks, golf
courses and other lands for nonpotable uses.
North Pinellas (NP) Service Area
NP-1 Discharge to St. Joseph Sound
NP-2 Discharge via outfall to Gulf of Mexico extending from
Gulf coast north of Honeymoon Island
NP-4^ Discharge to Anclote River
NP-15 Apply wastewater to sites within the county including
sites now receiving effluent (land application)
NP-19 Distribution of reusable wastewater to parks, golf
courses and other lands for nonpotable uses
City of Oldsmar (0) Service Area
^ '
Discharge to Safety Harbor
0-2 Discharge to Mobbly Bay
0-3 Discharge the Old Tampa Bay north of Courtney Campbell
Causeway
0-5 Combine with Higgins Power Plant cooling water and
effluent prior to discharge to Old Tampa Bay
0-18 Distribution of reusable wastewater to parks, golf
courses and other lands for nonpotable uses
City of Tarpon Springs (TS) Service Area
TS-1 Continue existing discharge to Anclote River
TS-2 Discharge via outfall to Gulf of Mexico extending from
Gulf coast north of Honeymoon Island
TS-4 Discharge to St. Joseph Sound
TS-5 Discharge to different location within Anclote River
16
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TABLE 1
(Cont'd.)
Designation Alternative
City of Tarpon Springs (TS) Service Area (cont'd.)
TS-6 Combine with Anclote Power Plant cooling water and
effluent prior to discharge to Gulf of Mexico
TS-14 Apply wastewater to sites within the county (land
application)
TS-19 Distribution of reusable wastewater to parks, golf
courses and other lands for nonpotable uses
Area East of Lake Tarpon
Various systems for individual establishments
Sub-division systems with land application at golf
courses
Interceptor connecting to the Oldsmar wastewater
treatment plant
Interceptor connecting to the Tarpon Springs treatment
plant
Sub-Regional Alternatives
Sub-Reg. 1 ' Discharge to Old Tampa Bay south of Courtney Campbell
Causeway from the Clearwater East, Clearwater Northeast
and Oldsmar WWTPs (wastewater treatment plants)
Sub-Reg. 2 Discharge to Old Tampa Bay north of the Courtney
Campbell Causeway from the Clearwater East, Clearwater
Northeast and Oldsmar WWTPs
Sub-Reg. 3 Discharge to Clearwater Harbor gouth of the Memorial
Causeway from the Clearwater Marshall Street and Dunedin
WWTPs
Sub-Reg. 4 Discharge to Clearwater Harbor south of the Dunedin
Causeway from the Clearwater Marshall Street and Dunedin
WWTPs
Sub-Reg. 5 Discharge to St. Joseph Sound north of the Dunedin
Causeway from the Clearwater Marshall Street and Dunedin
WWTPs
Sub-Reg. 6 Discharge to St. Joseph Sound north of the Dunedin
Causeway from the North Pinellas and Tarpon Springs
WWTPs
17
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TABLE 1
(Cont'd.)
Designation Alternative
Sub-Reg. 7 Discharge to Anclote River from the North Pinellas and
Tarpon Springs WWTPs
Sub-Reg. 8 Discharge via outfall to Gulf of Mexico extending from
Gulf coast north of Honeymoon Island. Discharges would
be treated at the North Pinellas and Tarpon Springs
WWTPs
Sub-Reg. 9 Discharge via outfall to Gulf of Mexico extending from
Honeymoon Island. Discharges would be treated at the
Clearwater Marshall Street and Dunedin WWTPs
Sub-Reg. 10 Same as Sub-Reg. 9 except discharges to be disposed
would be treated at the Clearwater Marshall Street,
Dunedin, North Pinellas and Tarpon Springs WWTPs
Sub-Reg. 11 Same as Sub-Reg. 9 except that the outfall would extend
from Clearwater Beach Island
Sub-Reg. 12 Deep-well injection at or south of the Clearwater
Marshall Street WWTP. Discharges would be treated at
the Clearwater Marshall Street and Dunedin WWTPs.
Sub-Reg. 13 Same as Sub-Reg. 12 (deep-well injection) except
wastewaters from the Clearwater East and Clearwater
Northeast WWTPs would be disposed.
Regional Alternatives
Reg. 1 Discharge to Old Tampa Bay, south of Courtney Campbell
Causeway
Reg. 2 Discharge to St. Joseph Sound south of Dunedin Causeway
Reg. 3 Discharge to St. Joseph Sound north of Dunedin Causeway
at southern end of Tarpon Springs
Reg. 4 Gulf outfall extending from Honeymoon Island
Reg. 5 Gulf outfall extending from Clearwater Beach Island
Reg. 6 Deep-well injection at or south of the Clearwater
Marshall Street WWTP
Alternatives that are evaluated in detail.
18
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CHAPTER III
ERRATA AND REVISIONS TO THE DRAFT EIS
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CHAPTER III
ERRATA AND REVISIONS TO THE DRAFT E1S
Page Paragraph Lines
vi
ix
1
1 1
10 2
15 4
15 5
15
16
34
2
6
3
2-3
3-4
Corrections
A revised Table ii is provided in the
Executive Summary of this document.
A revised Figure ii is provided in the
Executive Summary of this document.
Figure 1 should follow page 35.
"Shown in Figure i, has"
"The City of Safety Harbor is currently
served by the"
"McKay Creek WWTP in the unincorporated
area of Pinellas County".
"are approved but due to either possible
well construction problems or inadequate
confinement, effluent is leaking to the
overlying aquifer."
"wells at the McKay Creek and South Cross
Bayou are inoperative at this time and
testing is scheduled to determine if
these facilities are leaking, and St.
Petersburg Northwest WWTP is being"
"wells at the Albert Whitted WWTP will be
utilized; two 30-inch diameters injection
wells are proposed."
Add the following footnote to Table 5:
"(3) These are 4th quarter 1980 costs."
19
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CHAPTER IV
PUBLIC COMMENTS AND EPA RESPONSES
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CHAPTER IV
PUBLIC COMMENTS AND EPA COMMENTS
PART A - ORAL COMMENTS
Oral comments on the Draft EIS were received at a public hearing held on
June 11, 1985, at the Assembly Room of the Pinellas County Courthouse. This
Chapter contains the transcript of the hearing, including introductory
statements made by representatives of EPA. Public comments and EPA's
responses start on page 38.
Table 2 is an index to the oral comments, and Table 3 summarizes the
general subjects mentioned by each commentor.
PART B - WRITTEN COMMENTS
The hearing record remained open through June 25, 1985. Letters were
received after that date, but all comments have been included here. Table A
is an index to the written comments, and Table 5 summarizes the general
subjects mentioned by each commentor. The comment letters and EPA's responses
follow Tables 4 and 5.
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TABLE 2
INDEX TO PUBLIC HEARING
COMMENTS ON NORTH PINELLAS COUNTY DRAFT EIS
N)
Comment
Code
CCAW-1
CCAW-2
CCAW-3
CCAW-4
CCAW-5
JP-1
JP-2
JP-3
JP-4
JP-5
JP-6
JP-7
JP-8
JP-9
JP-10
JP-11
JP-1 2
JP-1 3
RK-1
RK-2
RK-3
RK-4
RK-5
Page(s)
38
39
39
39
39
40
41
41
42
42
44
44
45
46
46
47
49
50
51
52
52
53
54
Commentor
Committee for Clean Air and Water
Committee for Clean Air and Water
Committee for Clean Air and Water
Committee for Clean Air and Water
Committee for Clean Air and Water
Anchorage Homeowners Association
Anchorage Homeowners Association
Anchorage Homeowners Association
Anchorage Homeowners Association
Anchorage Homeowners Association
Anchorage Homeowners Association
Anchorage Homeowners Association
Anchorage Homeowners Association
Anchorage Homeowners Association
Anchorage Homeowners Association
Anchorage Homeowners Association
Anchorage Homeowners Association
Anchorage Homeowners Association
Dr. Robert Kuester
Dr. Robert Kuester
Dr. Robert Kuester
Dr. Robert Kuester
Dr. Robert Kuester
Nature of Comment
Capacity of Tarpon Springs Plant
System failure
Impacts of Gulf outfall
Tourism impacts
Support reuse
Population projections
Future study area problems
Cutoff for Federal Funds
Adequacy of wastewater treatment
Adequacy of treatment during wet weather
Plant consolidation
Legislate against development
Adequacy of wastewater treatment
Environmental feasibility of Gulf outfall
Intermittent wet weather discharge
Environmental feasibility of a Gulf outfall
Federal grant assistance availability
Lake Tarpon water quality
Lack of publicity
Support for EIS findings
Oppose Gulf outfall
Basis of costs
Limitations of Gulf outfall data
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TABLE 2 (Cont'd.)
INDEX TO PUBLIC HEARING
COMMENTS ON NORTH PINELLAS COUNTY DRAFT EIS
S3
OJ
Comment
Code
RK-6
RK-7
RK-8
RK-9
RK-10
RK-11
CO-1
CO-2
CO- 3
CO-4
CO-5
CO-6
CO- 7
CO-8
CO-9
CO- 10
CO- 11
CO- 12
CO- 13
CO- 14
CO- 15
CO- 16
Page(s)
54
55
55
55
56
56
59
60
61
61
62
63
65
66
66
67
68
69
69
69
70
70
Comment or
Dr. Robert Kuester
Dr. Robert Kuester
Dr. Robert Kuester
Dr. Robert Kuester
Dr. Robert Kuester
Dr. Robert Kuester
City of Oldsmar
City 'of Oldsmar
City of Oldsmar
City of Oldsmar
City of Oldsmar
City of Oldsmar
City of Oldsmar
City of Oldsmar
City of Oldsmar
City of Oldsmar
City of Oldsmar
City of Oldsmar
City of Oldsmar
City of Oldsmar
City of Oldsmar
City of Oldsmar
Nature of Comment
Support reuse
Oppose Gulf outfall backup for reuse
Development impacts of a Gulf outfall
EPA development of new water supplies
Current discharge of wastewater into Gulf
Groundwater recharge with effluent
Support reuse
Waste load allocation process
Conclusions of final wasteload allocation
Support land application and reuse
Support recycling of wastewater
Delay Final EIS
Solve future problems before they happen
Support recycling of wastewater
Outdated costs
Determination of new discharge
Determination of new discharge
Intermittent wet weather discharge
EIS study area
Funding of reuse
Outdated costs
Delay Final EIS
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TABLE 2 (Cont'd.)
INDEX TO PUBLIC HEARING
COMMENTS ON NORTH PINELLAS COUNTY DRAFT EIS
Comment
Code
Page(s)
Commentor
Nature of Comment
PCSS-1
PCSS-2
PCSS-3
PCSS-4
PCSS-5
PCSS-6
AB-1
AB-2
AB-3
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71
71
72
72
72
74
75
75
Pinellas County Sewer System
Pinellas County Sewer System
Pinellas County Sewer System
Pinellas County Sewer System
Pinellas County Sewer System
Pinellas County Sewer System
Mr. Alfred Boyd
Mr. Alfred Boyd
Mr. Alfred Boyd
Accomplishment of EIS purposes
Wastewater alternatives for area east of
Lake Tarpon
Support reuse
Other disposal alternatives
Intermittent wet weather discharge
Accomplishment of EIS purpose
EIS Study Area
Septic tank effluent discharge
Water supply contamination
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TABLE 3
SUMMARY OF GENERAL TOPICS COVERED BY ORAL COMMENTS
TOPICS COVERED
TREATMENT PLANT
GULF OUTFALL IMPACTS
ECONOMIC IMPACTS
RFOSE
POPULATION PROJECTIONS
WASTEWATER DISCHARGE
ALTERNATIVE. FUNDING
INTERMITTENT WET
WEATHER DISCHARGE
ALTERNATIVES
CONSIDERED
DEVELOPMENT IMPACTS
LAKE TARPON IMPACTS
PUBLIC PARTICIPATION
PUBLIC ACCEPTANCE
COSTS
GULF OUTFALL
WATER SUPPLY
DEEP WELL INJECTION
WASTELOAD ALLOCATION
PROCESS
LAND APPLICATION
RECYCLING WASTEWATER
E.I.S. COMPLETION
OUTDATED COSTS
E.I.S- STUDY AREA
E.I.S. PURPOSES
SOURCE OF COMMENTS
COMMITTEE. FOR CLEAN
AIR AND WATER
1. 2
3
4
5
ANCHORAGE
HOMEOWNERS
ASSOCIATION
9. II
1
2. A. 8
3. 12
5. 10
6
7
13
DR. ROBERT KUESTER
S. 8
6
10
1
2
4
3. 1
9
1 1
CITY OF OLDSMAR
1 . 4. 14
7. 10. 11
12
2. 3
4
5. 8
6. 16
9. IS
13
PINELLAS COUNTY
SEWER SYSTEM
3
5
2. 4
1. 6
MR. ALFRED 80YO
2
3
1
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UNITED STATES OF AMERICA
ENVIRONMENTAL PROTECTION AGENCY
REGION IV
In the Matter of:
DRAFT EIS PUBLIC HEARING
NORTH PINELLAS COUNTY, FLORIDA
ENVIRONMENTAL IMPACT STATEMENT
for
PROPOSED WASTEWATER FACILITIES
Time:
Date:
7:30 p.m.
June 11, 1985
Location: Pine lias County Courthouse
Fifth Floor Assembly Room
Clearuater, Florida
-oOo-
BAY PARK REPORTING
COIIK I HI-POUTING
H FOURIH STREET NORTH
APPEARANCES:
THE PANEL:
ROBERT HOWARD, Hearing Officer
Chief, NEPA Compliance Section
EPA, Region IV
Atlanta, Georgia
DOUG BRAMLETT
Environmental Specialist
Florida Department of Environmental Regulation
Tampa, Florida
RON MT.KULAK
EPA Project Officer, EIS
EPA, Region IV
Atlanta, Georgia
-oOo-
BAY PARK REPORTING
I nhR I Rt-PORTlNU
M lot'RIH SIFCFT NORTH
SI IM i I HSHURl.. FLORIDA JI701
|SII| I.')-Oil
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SPEAKERS:
MARY MOSLEY page 23
JOE PRESTON page 26
DR. ROBERT J. KUESTER page 37
ROBERT L. WILLIAMS page 44
DON MC CULLERS page 50
TODD TANBERG page 57
ALFRED BOYD page 61
-oOo-
BAY PARK REPORTING
i nlJR 1 Rl PORTINC
II IMI'RIH SIRI-FT NORIH
M PIIIRSBURf. FIORIDA II'OI
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PROCEEDINGS
(Whereupon, at 7:36 p.m. the
public hearing was called to order)
HEARING OFFICER:
Good evening. I'd Itke to welcome everybody to the
public hearing on the Draft Environmental Impact Statement
for Proposed Wastewater Facilities in the north Pincllas
County, Florida area.
My name is Robert Howard. I am Chief of the NEPA
Compliance Section for the Environmental Protection Agency,
Region IV, located in Atlanta, Georgia.
With me this evening on the hearing panel, on my left
is Doug Bramlett, an environmental specialist from the Tampa
District: Office of the Florida DER; and on my right, Mr. Ron
Mlkulak, the EPA Project Officer for this Environmental Impact
Statement.
I don't have any elected officials who indicated on
their cards that they were elected officials, but if there are
any, I would like to recognize them at this time.
Are there any elected officials?
(No response)
Okay. The purpose of this evening's hearing Is to re-
ceive public and other agencies' comments on the north Plnellasl
County Draft Environmental Impact Statement. This EIS is belnd
prepared on wastewater facilities proposed In the 201 facility |
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plans prepared for the north and central Pine lias County
areas.
The preparation of this EIS Is authorized by the
Clean Water Act and the National Environmental Policy Act.
The Clean Water Act enables EPA to fund up to 75% of the
eligible costs for the planning, design, and construction
of wastewater facilities. Effective October 1st, 1984, this
amount was reduced to 55%.
The planning phase of this process results in the
preparation of a plan for wastewater facilities for a 20-year
designing period.
Pinellas County has been designated as the local
agency responsible for facility planning in this area.
The National Environmental Policy Act requires federal
agencies to prepare an Environmental Impact Statement on
major federal actions significantly affecting the quality of
the human environment.
Because of the environmental complexities and water
quality Issues involved in this particular area and wastewater
facilities for this area, EPA made the decision to prepare an
Environmental Impact Statement on the 201 facilities plan.
This public hearing is being held to receive comments
on the Draft EIS pursuant to the guidelines of the President's
Council on Environmental Quality and EPA rules and regulations
regarding preparation of EIS's.
The Draft EIS is being discussed in a forum to en-
courage public participation in the federal decision-making j
process and to develop and improve public understanding of
federa lly-funded projects.
The Draft EIS was made available to the public and
was listed in the Federal Register on April 26th, 1985. The
Draft EIS comment period will extend until June 25th, 1985.
The comments received this evening and during the comment
period will become part of the record. EFA will respond to
the comments received this evening and in writing in the
final EIS.
Before we receive your comments this evening, I'd
like to ask Mr. Mlkulak to give a brief summary of the EIS
and some of the conclusions and recommendations that are
contained therein.
Ron?
MR. MIKULAK:
Thank you, Bob.
Good evening. As Bob mentioned, my name is Ron
Mikulak, the Project Officer for the north Pinellas EIS.
What I'd like to do this evening, before we receive
your comments, is to provide you with a little bit of back-
ground of the EIS, what we have done, the conclusions and
recommendations that we've come out with thus far in order to
set the stage and put things in perspective for your comments.
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What I'll be doing Is following very closely to the
handout that you should've picked up when you came In this
evening. The first page of the handout is Just an agenda
Item, which summarizes what we'll be going over this evening.
The next four pages of the handout, we put together a brief
summary. It's basically a brief outline of what I'll be
going over this evening so you can follow along some of the
details-that I won't be mentioning specifically, but you can
follow along with the details.
I've also Included two tables, one which outlines
the status for existing wastewater facilities In the study
area. The second table Is a summary of Implementablllty,
operablllty, and environmental Impact factors of some of the
alternatives; and finally, there are three maps that I'll be
referring to.
So If you just bear with roe In the rustling of the
papers back and forth, I'll start off with a short discussion
of what the purpose of the north Pine lias EIS was.
As we Indicate, we put down three basic objectives
that we tried to address through the preparation of this EIS,
the first being the Identification and evaluation of waste-
water disposal alternatives for the existing treatment
facilities In northern Pine lias County; secondly, to Identify
and evaluate wastewater management alternatives for the area
east of Lake Tarpon that Is not now currently served by the
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existing municipal facilities; and thirdly, to evaluate the
Impacts and costs associated with disposal of wastewater via
Gulf outfall extending from northern Plnellas County.
Again, to put things In a little bit better per-
spective, I'll take a few moments and go Into some of the
background of this EIS and facilities planning In this area,
and I'11 be brief with my comments.
As Bob Indicated In his comments concerning the
Clean Water Act, the Clean Water Act was first passed In
1972, and It was further amended In 1977 and 1981 with the
basic intent to Improve the quality of the nation's waters.
One of the primary mechanisms that's been employed
In the Clean Water Act Is Section 201. Section 201 authorized j
EPA, as Bob mentioned, to fund wastewater facilities through
the grants, the construction grants program.
It started out In the 75% funding level for planning,
design, and construction, and has now recently been reduced
to a 557. level.
To meet the mandate of the Clean Water Act, state
i
water pollution control agencies designate local agencies to
carry out the specific task of planning for wastewater
management strategies.
These strategies are typically called 201 facilities
plans, and again, as It was mentioned, In this area there
were two plans In the study area, the EIS study area.
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There were two plans that were prepared, both under
the direction of Pine lias County, and they were the north
Pine lias and central Pine lias County 201 plans.
The north Pine lias County plan was completed in May
of '78, and the central Pine lias County plan was completed
In April of 1979.
The 201 plan's recommendations generally proposed
that all nearshore surface water discharges be replaced by
several deep well injection and spray irrigation alternatives.
Additionally, Gulf outfall was proposed as a primary disposal
option for some discharges and as a back-up for others.
EPA's review of the 201 plans raisedsubstantive
questions concerning the deep well injection and the Gulf
outfall alternatives.
Additionally, the lack of approved wasteload alloca-
tions for nearshore wastewater discharges and the Impact
considering the environmentally sensitive area east' of Lake
Tarpon were additional concerns that were raised in EPA's
review of< the plans.
To address these concerns, EPA determined that it was
necessary to prepare an environmental impact statement, and in
May of 1979 the EIS Notice of Intent was issued, and the EIS
was initiated.
The issues that were determined to be Important and
to be addressed in the EIS, as identified through a scoping
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process that we were Involved with, Included four major
issues. They Include wastewater disposal alternatives for
northern Pine lias County, wastewater management alternatives
for the area east of Lake Tarpon, the consideration of Gulf
outfall, as well as the consideration of the reuse of treated
wastewater.
To get a better fix or better handle on what the
existing situation is like, I can refer you to Table i and
Figure 1 of the handout in which we outline and summarize the
status of existing wastewater facilities in the area.
Very briefly, we're dealing with eight municipal
wastewater treatment plants with a 1984 capacity of roughly
33 million gallons per day.
In summary, the Clearwater East Sewage Treatment Plant
discharges to Old Tampa Bay; the Clearwater Marshall Street
Sewage Treatment Plant discharges to Stevenson Creek and then
to Clearwater Harbor; the Clearwater Northeast Plant now dis-
charges to the Clearwater East outfall; the Dunedin Mainland
Plant discharges to St. Joseph Sound; the Oldsmar Sewage Treat-
ment Plant discharges to evaporation-percolation ponds on site;
Safety Harbor discharges to Mullet Creek and then to Old Tampa
Bay; the Tarpon Springs facility discharges to Anclote River,
and the area east of Lake Tarpon is served by on-lot systems
or by package plants with a combination of holding ponds and
then spray irrigation on golf courses and other open lands.
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Toward the bottom of the page of the first page of
the summary, a bulleted item under Alternatives, In develop-
ing alternatives for the study area six basic alternatives
were considered, including continued discharge to nearshore
coastal waters, the Gulf outfall, deep well injection, land
application, wastewater reuse, and the no-federal action
alternative.
In applying these alternatives to the study area,
several subareas were delineated in conducting the EIS. For
example, the Oldsmar, the Clearwater Northeast Plant, and the
Clearwater East Plant were grouped together to form what we
call the Old Tampa Bay Subarea, because they all discharge to
the Old Tampa Bay drainage area.
The Dunedin and the Clearwater Marshall Street treat-
ment plants were grouped together on the other side of the
mainland in what we call the Clearwater Harbor, St. Joseph
Sound Subarea.
The North Pinellas County Treatment Facility was its
own North Pinellas County Subarea, as well as the Tarpon
Springs facility was in the Tarpon Springs Subarea.
Next we were somewhat limited in how far we could take
*
the alternatives in the evaluation process, since approved
waste load allocations from Florida DER were not available for
most of Pinellas County surface waters, with the exception of
wasteload allocation for Tarpon Springs, Anclote River.
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Therefore, a range of treatment levels from secondary
to advanced treatment and a series of combinations from in-
dividual sewage treatment plants to sub-regional treatment
plants, meaning two or more treatment facilities, and finally,
regional alternatives which would involve all facilities com-
bined were considered.
The alternatives were then screened on the basis of
cost, Impact, operability, implementability, to determine
which of those should be carried on for further consideration,
and because of those factors, many of the alternatives either
for high cost or implementability concerns or environmental
impact concerns were dropped from further consideration.
Costs for the least cost disposal options for each
of the subareas and the overall cost of the range of alterna-
tives were also determined. For example, on the handout on
page 2 in the middle of the page, individual service area
alternatives — that is, each treatment facility maintaining
its own service area uncombined with anyone else but with
secondary treatment to continue discharges to near surface —
excuse me -- discharge to nearshore surface waters -- came out
with a present worth cost in the neighborhood of 48 million
dollars.
Next came maintaining the individual service area
alternatives but increasing the level of treatment to advanced
treatment continued with nearshore surface water discharge
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Increased the cose to 86 million dollars. I
A system of reuse in which reuse would be instituted I
i
at each of the treatment facilities but with treatment levels
at secondary plus filtration resulted In a cost of 96 million
dollars .
A regional Gulf outfall -- that is, combining all
uastewater in the area and discharging it through a single
Gulf outfall -- results in a cost of roughly 101 million
dollars.
A regional deep well injection alternative sees an
increase to a cost of 105 million dollars; and finally, a
system of reuse but increasing the level of treatment to
advanced treatment would see a cost of 121 million dollars.
In addition to cost, as 1 mentioned, we did look at
implementability, operability, environmental impact factors
for the disposal alternatives. Rather than go at this time
into the details of the results of those evaluations, I refer
you at your leisure to Table ii in the handout. You've
probably reviewed the information from the EIS already, but
for tonight I've summarized and concluded in that table.
In considering the factors of the alternatives'
evaluation process and without approved wasteload allocations
for most of Pinellas County surface waters, we came to the
conclusion very quickly that a study area-wide alternative
that can be considered the most cost-effective environmentally
sound wastewater management option for north Pinellas County
cannot at this time be selected.
The EIS can, however, narrow the field -- I should
say the EIS has rather than can -- has, however, narrowed the
field of reasonable alternatives, presents costs and impacts
associated with various effluent limitation combinations and
identifies constraints or limitations of the alternatives.
On the third page of the handout, continuing with
the conclusions of the EIS, we point out that decisions in
Tarpon Springs for the area east of Lake Tarpon and the north
Pinellas service area can be made and are not dependent on
forthcoming wasteload allocations.
EPA funding participation in the area east of Lake
Tarpon Is limited by both regulation and policy. I'll expound
on that in a few moments .
The environmental cost conclusions can be offered
concerning the Gulf outfall extending from northern Pinellas
County and, finally, an area-wide environmentally-preferred
alternative can be and is identified in the EIS.
And what I'd like to do with the few minutes remaining
and the few pages left in the handout is to go over what we
consider to be the recommendations of the Draft EIS at this
time and probably those recommendations that you'll be com-
menting on in just a few moments.
The first recommendation deals with wastewater reuse.
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The wastewater reuse alternative for each service area Is
identified as the environmentally-preferred disposal alterna-
tive. Reuse Is the only management option that responds to
the area's surface water quality problems while addressing
groundwater supply limitations.
The costs, the advantages, and the disadvantages
should be clearly outlined to the community and local de-
cision makers. The need for a vet-weather back-up for waste-
water that cannot be reused Is likely to exist. Potentially
feasible back-up options Include continued but Intermittent
surface water discharges or deep well Injection. It should
be noted that this recommendation Is to Identify the environ-
mentally-preferred alternative and Is not necessarily the
fundable alternative, the EPA fundable alternative.
The fundable alternatives for both Clearwater Harbor
and St. Joseph Sound and the Old Tampa Bay subareaa will be
selected upon completion of the wasteload allocation process.
Additionally, Identification of the environmentally-preferred
alternative does not preclude the consideration of other
disposal options.
Deep well injection is a disposal option that has beer
considered as both a primary and a back-up disposal option.
Local agencies may wish to pursue further deep well injection
Investigations to determine its feasibility as a disposal
option and its relationship to a reuse alternative. In this
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regard, potential reuse distribution sites and distribution
lines are shown on Figure 2 of tonight's handout.
The second recommendation deals with the Tarpon
Springs subarea. Discharge to the Anclote River of advanced
secondary treated effluent la the recommended alternative
for Tarpon Springs In accordance with the approved wasteload
allocation, and in fact the project for Tarpon Springs has
been broken out of the EIS and is proceeding.
Recommendation number three, the north Pinellas sub- ;
area. Land application of the existing site and at the i
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Innisbrook Country Club has been shown to be the most cost- '
effective environmentally-sound option available. Regardless
of wasteload allocations, land application is the recommended
alternative for north Pinellas subarea.
Recommendations four and five combined deal with the
Clearwater Harbor/St. Joseph Sound subarea and the Old Tampa
Bay subarea. In the absence of wasteload allocation for these
subareas, numerous alternatives remain viable for the Dunedln,
Marshall Street, Oldsmar, the Clearwater Northeast and Clear-
water East service areas.
The information from the EIS process is available to
the state for their use In decisions, for their decisions.
Upon completion of the wasteload allocation process, the most
cost-effective, environmentally-sound option for funding
eligibility can then be selected.
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Recommendation number six deals with the area east of
Lake Tarpon. EPA's policy and regulations concerning funding
facilities in environmentally-sensitive areas and funding
capacity for future flows do not allow funding assistance In
the area east of Lake Tarpon.
The reasonable alternatives of on-lot systems, package
plants, and land application or connection to the Oldsmar
Sewage Treatment Plant have been evaluated In terms of cost,
Impact, reliability, and Implementablllty. This Information {
(
Is available to the county and private developers for local j
decision making. I
EPA encourages governing bodies within the study area j
to consider the function and value of environmentally-sensitive
undeveloped areas east of Lake Tarpon, and that Is groundwater,
recharge areas, wetlands, flood plains in future planning and
development decisions.
EPA's construction grants regulations allow the agency
to fund facilities only to serve capacity for flows existing
on the date of a Step Three grant; that is, for construction
but not to exceed the year 1990 flows.
Since the basis for many of the alternatives for the
area east of Lake Tarpon is to serve future development, EPA
will not participate in funding wastewater facilities in this
area.
Recommendation number seven deals with the Gulf
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outfall, and I refer you to Figure Number 3 In the handout.
As part of this EIS, a marine measurement and sampling
program was conducted during 1980 to better define existing
environmental and physiographic conditions In the nearshore
Gulf of Mexico off northern Pine lias County.
The data collected during the sampling program were
utilized to assist in evaluating the Gulf outfall wastewater
disposal alternative and to generically demonstrate the
methodology that should be used in considering the Gulf outfall.
The general findings related to the Gulf outfall from
northern Pine lias County are as follows:
It would provide the area with a reliable, long-term
wastewater disposal option. It would require a major invest-
ment of capital in a disposal option that would tend to
discourage the environmentally-preferred alternative of waste-
water reuse. It would Involve the environmental tradeoffs of
minimizing Impacts to nearshore waters while increasing im-
pacts to the Gulf. It would remove a development constraint
that would potentially promote higher density development and
development in environmentally-sensitive areas which are not
suitable for on-lot or recycle wastewater management.
Secondary treatment and disinfection of wastewater
would be necessary to minimize impacts of an outfall on local
beaches.
Station 3F, which is shown on Figure 3, is roughly
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19
four miles offshore from Honeymoon Island and was selected
for additional study to further demonstrate the methodology
for evaluating the Gulf outfall.
The area of Station 3F was found to be less environ-
mentally sensitive than other sites located closer to shore
that were evaluated during the marine sampling program.
Station 3F appears to be the most cost-effective, more cost-
effective than other stations evaluated during the marine
sampling program based on estimated costs and combined impacts
to public health, the St. Joseph Sound estuary and natural
. hardbottom reef habitat.
Nearshore Gulf currents vary such that predictions
of effluent movement from a discharge are uncertain. Dye
discharged in the area of Station 3F during the marine
sampling program generally moved in a south, southwesterly
direction.
A discharge plume In the area of Station 3F would be
expected to have minimal impact on area beaches. Any further !
consideration of discharge sites near Station 3F should focus
on areas slightly north of the exact study location to further
minimize potential impacts to usage of the Dunedln Artificial
Reef.
A precise outfall alignment and point of discharge
would require additional site-specific analyses; that is,
•
Site-specific studies to select the exact outfall route, the
discharge point, and any required mitigation. Any further
consideration of Station 3F or any other potential Gulf out-
fall site would be subject to permit administrative review
and approval.
The final recommendation in the EIS deals with water
conservation. Due to the potential reductions in water
consumption and reductions in potential wastewater management
costs, local governments are encouraged to pursue a water
conservation program.
And finally, I'd like to indicate where we go from !
here and what our general time frame with the EIS process is. ;
I Indicate that the Draft EIS comment period closes on June j
25th, two weeks from this evening. It is proposed that the
final EIS be Issued in September of 1985.
I think it's important to note that upon completion
and approval of waste load allocations for Pine Has County
surface waters, an EIS supplement may be necessary, to outline
selected and EPA fundable wastewater management alternative
options for north Pine Has County when that Information is
made available.
My comments, my brief comments, are concluded. I turn
the meeting back over to Bob.
HEARING OFFICER:
Thank you for your brief comments, Ron.
I'd like to now ask Doug Bramlett of the DER for some
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comments from DER.
MR. BRAMLETT:
My name Is Doug Bramlett. I represent the Tampa
District Office of DER.
Just a couple brief statements about the waste load
allocation studies that are needed to be completed as soon as
possible. I know that it's been some time since we've started
these studies, and in talking to my bureau of water quality
management this morning, the dates that they give me for
completion for the final draft of the Tampa Bay wasteload
allocation study will be in the summer of 1985. They cannot
give me a month. I'm assuming they mean July or August of
1985. That'll be the final allocation study for Tampa Bay.
For the St. Joseph Sound and Clearwater Harbor study,
they are projecting that a draft will be ready the first
quarter of 1986, and a final allocation will be issued in the
spring of 1986.
That basically is the only information I have about
the studies and the completion dates.
If I can answer questions, I'll be glad to do the best
that I can. I have not done these studies myself. I would
probably have to just field your questions and then go to
Tallahassee and try to get the answers for you.
HEARING OFFICER:
Thank you, Doug.
I just want to remark a little bit about the process
of wasteload allocations. It is not a very simple process,
and when you're dealing with a system such as Tampa Bay with
the resources that are there and the wastewater discharges
we're talking about, it is not a very simple process, and I
think we all should appreciate that this process does take
quite a while to come to a conclusion.
Thank you, Doug.
I just want to encourage anybody who hasn't already
done so, or if Lawrence Benander didn't catch you as you came
in, to please register before you leave this evening. We'd
like to have a complete record of everyone who was here.
Also, if you wish to speak and did not register, if
you would let me know after the other speakers have talked,
and I will call on you to speak.
I think, with the number of speakers that we have
registered, I'm not going to limit any of the speakers in the
length of their comments. I would say that if any speaker
starts taking a great deal of time and the comments get very,
very detailed, I may ask that you summarize your comments and
please give us your more detailed comments in writing.
Also, if any of you have a written text of your
comments as you're giving your comments, if you have an extra
copy, please give us a copy so we can follow along, or after
you've made your comments, if you could give us your written
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text, we'd appreciate that.
One other thing before we get started, when I call on
people, If you'll please just come up and give me your name,
and if you represent anyone, please just let us know who you
represent, any group or organization.
And with that, let me call on our first speaker, Mary
Mosley, representing CCAW.
MS. MOSLEY:
Mary Mosley, CCAW. I'd like to ask a question before
we get started about Table 1. Am I led to believe that this
Is a little over 3 million gallons written here for the City
of Tarpon Springs?
HEARING OFFICER:
What we have on this table, If you're looking In the
first column, 1984 Capacity In MGD over 1984 Flow In MGD --
MS. MOSLEY:
Uh-huh (affirmatively).
HEARING OFFICER:
-- what we have there Is, and let me make sure that I
have this correct, the first number Is the capacity of the
plant; the second number Is the actual flow that's In the
plant.
23 MS. MOSLEY:
Well, EPA, that Is not possible. I'm Just I would
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like to be on record that the Tarpon Springs wastewater
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treatment plant was peaking at over 4 million in 1981, and I
would just love to have EPA come and take a look at what's
going on. It can't happen Just bypassing in Pasco County.
I Just want to ask one other question. We understand
that EPA may be coming to Florida and perhaps our county -- is
that true -- maybe putting a regional office?
HEARING OFFICER:
That's not true as far as I know.
bE . MOSLEY :
That's too bad. We really need a responsible and
responsive agency here. Elected officials swear when they
take office that they will protect the public health and
welfare.
As you enter this county, you can see that the
opposite holds true. Severe traffic problems, public service
inadequacies, air pollution, and water restrictions are the
norm. There are higher taxes and less of those reasons that
we chose to live here.
A Gulf outfall would solve the politician's headache
of what to do with wastewater from rampant, uncontrolled
growth, but this could prove economically and environmentally
disastrous.
This county's input at the public hearing that was hel
regarding the proposed state land use plan was to object to
any outside control. This attitude has caused a systematic
CCAW-l. The values presented in Table i represent average flow,
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and ongoing wasting of our natural resources. Repair to a
transmission line results In tens of thousands of gallons of
raw sewage being released to the bay.
A Gulf outfall could have potential Impacts to beaches
resulting In their being closed. Bacterial and viral con-
tamination, over-enrichment with nutrients resulting In exces-
sive phytoplankton growth impacts to reefs and marine systems
may occur even with the best Intentions.
Our number one Industry, tourism, would be seriously
affected resulting In millions of dollars' revenue lost.
For years the Environmental Protection Agency and the
Department of Environmental Regulation have been aware as to
the seriousness of water shortage. What would be more cost-
effective and protect our Florida waters would be the reuse
of water.
We urge you to Implement this concept. The time for
this Idea Is now, not after the developers have gone, and In
their green wake they have left millions of new residents.
Emergency measures never consider the environment. If the
county lays? new pipes for new development, why not lay the
grounds for reuse.
Thank you.
HEARING OFFICER:
Thank you, Ms. Mosley.
My next speaker, I have a maybe listed here, so I'll
CCAW-2. 'EPA Is not aware of raw sewage being discharged to Anclote
Sound.
CCAW-3. These impacts are addressed in the Draft BIS.
CCAW-4. Comment noted.
CCAW-5. Conraent noted.
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go ahead and ask if they'd still like to speak.
Don McCullers?
MR. MCCULLERS:
I would like to wait and hear all the comments tonight
HEARING OFFICER:
All right. I'll put you at the bottom of the list
and call on you at the end.
The next speaker Is Joe Preston.
MR. PRESTON:
My name Is Joe Preston. I live In Eastlake, And I
guess I'm more concerned about the statements that policy and
regulations preclude any action by you people with respect to
the discharge of effluent.
We're going to go from ten thousand people to eighty
thousand people In a very short time. Studies that were
conducted sometime ago by the county Indicated that this
explosion of eighty to a hundred thousand people will come
sometime In the year 2000. It's happening right now. I think
that my studies would show that probably, If not here now,
It's going to occur by 1990.
I can't understand — and this Is a question -- how
you think, how you come to the conclusion that this is a
future development. The people are moving In now. The five
small treatment plants out there are keeping abreast of the
situation, but every day they're moving In -- not hundreds of
JP-1.
Population projections established by the Plnellas County
Planning Department were used In the E1S.
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people yet, but it's going to come, because there are --
developments are there, and the people are building.
May I ask that question now? What promoted this
conclusion that this Is a future development, quotes, future?
HEARING OFFICER:
The conclusion comes from our population projections
based on our existing population in the area and the fact
that the existing populations are being served by existing
treatment systems, which seem to be adequate at the time, and
the need for additional capacity and additional facilities
are based on population projections beyond that of 1990,
population estimate.
MR. PRESTON:
Are you saying 1990 is the future?
HEARING OFFICER:
1990 is the cutoff date for the availability of
federal funds for any kind of wastewater treatment facilities.
MR. PRESTON:
If we have a hundred thousand people in the area by
1990, then the government's certainly missed the ball, and I
don't know how you did your study, if you just took the sta-
tistics or if you cruised along in your car on 77 between
State Route 582 and State Route 584; first of all, you'd
probably be run over by the trucks that are supplying the
construction in that area.
JP-2.
JP-3.
The conclusion Is based on the fact that existing populations
are being served by existing waatewater treatment systems which
appear adequate. The focus of facilities and capacity that is
referred to In this comment are foi future development, not
existing development.
Based on the recent Amendments to the Clean Water Act, EPA'n
Construction Grants Regulations allow EPA to fund facilities for
flows existing on the date of Step 3 (construction) grant award,
but not to exceed the year 1990 flows.
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And everybody, It seems, except the federal government
knows that that's the fastest growing area In Pine lias County,
so here we are with barely enough treatment plants. Just
recently, In addition to the five that we're talking about,
just recently Oldsmar has announced that they are at capacity,
and I think Clearwater's in the same spot, and I would exoect
to hear tonight that Ounedin is in trouble, too.
Here we have this north, as I understand it, i>i the
northern Pine lias area that you're studying that You're
playing brinkmanship with this, and if you wait till 1990,
you're going to be trying to play catch up, and I don't think
you're ever going to make it, and I guess it's like being
left alone in a raft without a paddle out there.
We Just don't know — We can't understand your con-
clusions. I've been coming to these meetings since 1968. It
seems that your study has been, what I pick up, I can't fault
that but -- and you've come to the conclusion, I think, that
there's something needed, particularly in Eastlake, is that
true? Is there something needed now in your opinion?
HEARING OFFICER:
I think our conclusion was that now the current system:
that are in that area are providing satisfactory treatment.
MR. PRESTON:
Also in wet weather? I can't believe that. I can't
believe you've come to that conclusion.
JP-4.
The conclusion Is that the current systems in the area cast of
Lake Tarpon are providing satisfactory vastewater treatment.
JP-5.
Although it is generally recognized that It may be desirable
In the Study Area to have a wet weather back-up, no data were found
which showed the systems are not working satiofactorlly during wet
weather conditions.
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HEARING OFFICER:
We don't have any Information that disputes that.
MR. PRESTON:
Well, whatever, I
5 HEARING OFFICER:
6 We'd be happy to receive any Information that you
might have.
MR. PRESTON:
' II Well, I'm a private citizen. I'm going on my own
10 Investigations and comments from various people who manage
n these wastewater treatment plants.
12 And, for an example, I believe ten years ago It'was
13 recognized In that area, when the population was much less,
u that the treatment plant, one treatment plant, particularly
15 In the Tarpon Lake Village Golf Course, was considered
IA Inadequate at that time, and there were plans to transport
17 the wastewater, I guess to the Gulf, but certainly not on
ia toward Clearwater and out through — out toward St. Joseph
19 Sound.
20 It seems that my Information leads me to believe that
2t the experts In Pine lias County believe that not only do we
22 have to have something, some way of discharging the effluent,
23 which Is another matter, but we also have to have an Improve-
24 ment In the plant. Consolidation of the five plants perhaps 1
25 || an answer. I gather that that's entirely out of your scope of
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concern, Is that true?
HEARING OFFICER:
I might just remark that the overall construction
grants program Is based on a system of setting priorities at
the state level. Those priorities are weighted based on
existing problems for the most part. That Is where they are
having severe water quality or public health kinds of problems
and with the reduced amount of funding that we're having now
coming from the Congress and the emphasis on cutting back on
the role that the federal government's playing In this area,
we're just seeing the priorities going to existing problems
rather than providing additional funding to support growth
and development In developing areas. It's just a fact of life
t oday.
MR. PRESTON:
In answer to that comment, would the federal govern-
ment consider designating Florida, and perhaps the north
Pinelias County, as being no longer available for development
Would you legislate against development there?
HEARING OFFICER:
EPA Is not In the business of legislating for —
MR. PRESTON:
Well, wait. I didn't ---
HEARING OFFICER:
-- or against development.
JP-6. Consideration In the BIS wa« given to vastevater treatment
plant consolidation.
jp-7. EPA does not nor does EPA possess the authority to legislate
for or against development.
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MR. PRESTON:
I didn't say EPA. You allude to the government --
HEARING OFFICER:
What we've come here —
MR. PRESTON:
-- and you said the government's policy. Go ahead,
sir. I'm sorry. I'm just trying to keep you under government
policy, not on EPA.
HEARING OFFICER:
Right. What I'm trying to tell you is that EPA's
policy regarding the funding and the use of 201 construction
grants funds is that it will be used to correct existing
problems, and it will not be used in the future for promoting
and providing for future development.
MR. PRESTON:
I won't say it again. I just argue that we have an
existing problem, not a 1990 problem, and regardless -- 'cause
your opinion and my opinion differ, of course. In your opin-
ion, there Is no existing problem. In my opinion, Che problem
is there and it exists today.
Well, the other problem that I see is in the transport
of effluent somewhere into the Gulf waters or into -- by means
of deep well injection.
Well, first of all, deep well injection In Eastlake
doesn't seem to be feasible because that is very environmental
JP-8.
Coment noted.
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sensitive, as you probably know, and again I'm not the expert
on that, so the alternative, as this other lady said, of
transporting It into the Gulf depends on other studies, I
gather, Is that true?
In other words Let me try to simplify that ques-
tion. To discharge effluent Into the Gulf four miles west of
Honeymoon is not a proven solution, is it? Is it feasible?
Is it environmentally sound?
HEARING OFFICER:
What we came up with is that, in the cost evaluation
and the evaluation of environmental impacts comparing the
discharge of wastewater to the Gulf versus the wastewater
reuse alternative, we found the wastewater reuse alternative
to be cost competitive and environmentally preferable.
MR. PRESTON:
Yes, but again, to make sure that I understand, that
is with the exception of during the wet periods, because we
can't do anything with it. We have no storage area in East-
lake. Is that true?
HEARING OFFICER:
I think we recognize that at some point In time there
will have to be some accommodations made for some wet weather
discharge.
MR. PRESTON:
Well, I'll say it. It can't be deep well. I'll say
JP-9.
JP-10.
The Draft EIS presents costs, environmental Impacts and opera-
tion and Implementation factors of Gulf outfall alternatives KB
well as other alternatives which were considered. The EIS contains
several environmental statements concerning a Gulf outfall alterna-
tive (see page 12 of this document); however, no Gulf outfalls nnw
exist In Region IV.
The Draft EIS recognizes that some accommodations will have to
be made for wet weather discharges In the future.
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It again, and the only other alternative is into the Gulf,
and I don't think you've answered my question as to whether
that ia environmentally feasible.
HEARING OFFICER:
We don't have also wasteload allocations for dis-
charge to nearshore surface waters for wet weather periods
either. I think there are more than Just the one alternative
for Gulf outfall that you have suggested.
MR. PRESTON:
What are they? Have you mentioned them? Have I
missed something? You said there are other alternatives?
HEARING OFFICER:
Nearshore discharges to surface waters and — .
Ron, do you have any help on that?
MR. MIKULAK:
Specifically, the intermittent discharge to nearshore
surface waters, which hasn't yet been addressed by DER, and
the wasteload allocation process may be an opportunity that
HEARING OFFICER:
I might remark one other thing on this whole area of
wet weather discharge in the area, particularly east of Lake
Tarpon.
This area's also a low lying area. It's one that has a
number of wetlands. It's one that is an environmentally sens itivle
area, and 1 think the point here is that in the development of
JP-11. Potential back-up alternatives Include deep well injection (if
proven feasible), intermittent surface water discharges (pending
the availability of wasteload allocations) or the discharge of
wastewater via a Gulf outfall.
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chat area and the provision of wastewater facilities, I think
It is a Local Issue and a local problem of coming up with the
options and the approach to deal with that area If the local
government wishes to develop that area.
MR. PRESTON:
Well, It's a disappointment that after -- what Is It -
eight years of study, I think If not the most environmentally
sensitive area, it's certainly among the most environmentally
sensitive areas, and we're going to be faced, I gather, with
having a lot of effluent, and we don't know what to do with
It, and you people have studied it for eight years. It's not,
in my opinion, a commendable conclusion, recognizing again
the depth of your study and the things that you've done.
However, It seems that my investigation reveals that
ten years ago that we could've come to the same conclusion
with respect to Eastlake if not with respect to the rest of
the north Pine lias area.
So it just seems -- and because of Eastlake, you can
appreciate my concern -- a very insensitive approach. There's
nothing You're saying you're going to create it, and
you're going to have to do something with it.
HEARING OFFICER:
What I'm saying, too, Is also that for the provision
of wastewater facilities and for development, the local govern
ment has permitting responsibilities, the state has permitting
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responsibilities, and those permitting responsibilities are
designed to protect environmentally sensitive areas and to
approve or disapprove for the provision of wastewater facil-
ities, and I am not in the position here to be challenging
the authorities or the abilities of the local and state
governments to meet that challenge.
MR. PRESTON:
Well, I understand that with respect to the grants—-
I'm not going to say I understand. It seems to me that some
place in this consideration that there Is room for federal
grant assistance, if not specifically for Eastlake, for the
north Pine lias situation, and as I described earlier, it's not
only Eastlake that we're talking about. The problem -- and I
do recognize that you are looking forward to further action,
I believe, with the Oldsmar, Dunedln, and Clearwater problem
with respect to wastewater -- management of wastewater .treat-
ment plants. Is that right? I Just want to be fair to you.
HEARING OFFICER:
I think at this point in time we don't anticipate any-
thing until we may have some wasteload allocations in
MR. PRESTON:
I understand that, but that's why I Included future
development, and that's a year away, and with the development
Impact that we expect Immediately, your problem is going to be
Increased at least 15 or 207. within the next year. And after
JP-12.
Conclusions and any grant assistance can not be made until
wasteload allocations are available.
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eight years' study, you can understand our concern about the
lack of action In preparing for a problem of this tyoe.
Finally, one good size body of water is a considera-
tion, Lake Tarpon. There's no way in my opinion, and I've
been here for ten years, that unless something is done with
the effluent that Lake Tarpon is going to suffer pollution,
and whether that's a concern of yours, I'm not sure. You
already said that's a local action.
But again, this study has been conducted, and my
feeling is that it really hasn't in eight years produced any-
thing of consequence, anything of benefit to the citizens of
this particular part of the community.
HEARING OFFICER:
Thank you, Mr. Preston.
I think I might remark about this, that anytime we
come to the conclusion that we're not going to be providing
facilities or trying to promote or trying to support or even
to solve the problems for future development, we have the same
kind of issue and the same kind of concern, and I think that
is the way that the 201 program and federal funding for waste-
water facilities is going, and that is the Intent and desire
at this time of Congress, and this is not the same kind of
construction grants program that we had, say, five or ten years
ago.
Our next speaker is Dr. Robert J. --
JP-13.
Comment noted.
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DR. KUESTER:
Kuester.
HEARING OFFICER:
-- Kuester. Thank you very much.
DR. KUESTER:
My name is Dr. Robert Kuester. I'm from Dunedin,
Florida. I've been civically active with the EIS program for
practically since the time they came out, and I would like to
take this opportunity to welcome you to the Suncoast.
We may be severe with you, but we also do It with the
purpose, the same purpose, I'm sure, the reason you're here.
I am, now that I've welcomed you, I'm going to proceed to lay
you out. All right.
I'm rather disturbed that there are no elected offi-
cials here defensing the problem through the community. I
don't know where they are, but they weren't here five years
ago during the Carter times when this EIS came about, and they
aren't here again, so apparently somebody in this county
doesn't care about this water problem or isn't courageous to
be a representative for us.
I'm also a little bit disturbed at the lack of publi-
city that you people have put forth. I don't know what your
publicity program is, but when you're speaking to a bunch of
empty seats on probably one of the most important issues ever
to come before the Suncoast, it bothers me, sir.
RK-l. Over 400 copies of the Draft EIS and announcement of the
Public Hearing were sent out. Legal notices of the public hearing
were published In local papers twice.
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I would like to see you go out and make another public
approach to a meeting and have one more meeting here and let
some people come out here and hear what's going on, because
not only are you developing a program, you have to educate the
public, and If you don't educate the public to support you,
you're not going to have any support. You've got to have
support, don't you? And if you're going to play to empty
seats, you're not going to get that kind of support.
I asked you five years ago, In my environmental con-
cerns In Orlando, and I ask you now to please stop thinking
In terms of turning one of Florida's most valuable assets,
the Gulf of Mexico, Into the world's largest swill pond, all
rIght ?
Number one, we don't need to contaminate the environ-
ment from the Environmental Protection Agency. I suggested
then that you might be re-named the Environmental Destruction
Agency, and here you are again doing the same thing. I object
to It, and I'll tell you why In a minute.
Your newest EIS about north Pinellas County Is a very
Incomplete document, even from a rank amateur in environmental
problems. It Is not the kind of document that should act as a
nucleus or basis from which to determine wastewater management
Into the next century.
The concluslonary research facts are glaringly absent,
being substituted by guesses and surmises and postulatlons and
HK-2. The EIS process ta Intended to both educate and Involve the
community in local wastewater management decisions. This effort
culminates In the Issuance of the Draft EIS for review and comment.
The purpose of the Public Hearing is to receive comments on the
Draft EIS.
RK-3.
Comment noted.
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theories, maybes, would've's, could've's, should've's. I
mean, we need some facts here that will give us long-range
conclusions that will be publicly acceptable.
I grieve when I talk to a municipal engineer who
looks at this Environmental Impact Statement and says it's an
atrocious document. I feel badly that more intense research
is not or has not been done up to this point.
I could go through this whole book, but I want to
give you Just one or two little items of what I'm talking
about, and I'll be glad to meet with you at greater length.
Take this one. Wide-ranging and absolute conclusions
cannot be made about effects of nearshore hydrodynamics on
potential movement of a wastewater plume.
You're going to put the water out in the Gulf of
Mexico and you don't know where it's going, and you're telling
me that's what you've got cost basis on? I can't buy It, sir.
You're going to have to tell me more about what's happening,
what's happening hydrodynamlcally out there, or you're not
going to go out there.
One other ---I could go for hours on this. We talked
about —- You talked about things here that you admit to. Data
from less than ten days during only one spring and one full
season was available; three sampling transects are ten miles
apart on the north side of our axis; dye releases were not
monitored during all types of wind conditions; nearshore water
RK-4. The costs are based on a large number of factors Including:
level of treatment, outfall size, length of outfall, construction
technique (burled or unburled), etc. The cost factois can be
developed to setvc as a basis of comparison in order to compare the
Gulf outfall alternative with other disposal alternatives.
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movements have been measured by metered data and have been
found to be highly variable; variable conditions are evident -j-
so on and so on.
How can you do anything about a Gulf outfall when you
talk about the preponderance of limitations and dangers but
not positive proven facts that lead to proper conclusions?
You can't do that to us.
Now, if ever there was an ideal time, a point in time
in history for you to come to the Suncoast, I think you've
picked it. I think you really nailed it right on the head.
Right now the Suncoast quality of life is eroding for
lack of water during the present drought that is absolutely
probably the worst one we've had this century, not necessarily
the worst drought but the worst to make people suffer because
we've got so many people here now, you see.
Now, you simply cannot afford the luxury of dumping
reusable wastewater into the Gulf until such a time you can
prove the hydrodynamic and economic feasibility and until we
can come up with a new water supply. We cannot afford to
waste water that is reusable in anything, especially since
we're short of water now. Does it make sense, or am I talk-
ing on something, you know, I'm way out in left field on?
HEARING OFFICER:
I'm very glad that you're supporting our conclusions.
DR. KUESTER:
RK-5. A marine sampling and measurement program off Northern
Plnellas County (Florida) was conducted to provide baseline
information for the assessment of environmental impacts from n
proposed offshore sewage outfall (one of the alternatives being
considered for handling the wastewater of North Plnellas County).
The program collected physical, meteorological, chemical,
biological and sediment data from a 512 square kilometer Study Area
in the Gulf of Mexico from Anclote Key (ncprth) to Belleair Causeway
(south) and up to 16 kilometers offshore from the barrier Islands
off Northern Pinellas County. Specifically, physical studies
Included description of bathymetry and bottom habitnta, and the
measurement of currents (speed and direction) in llie StuJy Area.
Meteorological measurements Included wind speed and direction, air
and surface water temperature, and cloud cover. Chemical studies
Included the measurement of dissolved oxygen, salinity,
temperature, biochemical oxygen demand (BOD2Q), total suspended
solids (TSS), and mlcronutrients (nitrogen and phosphorus).
Biological studies Included the genernl biological characterization
of habitats, a description of rare, threatened and endangered
species, fecal and total collform bacteria, chlorophyll 'a1 and
phytoplankton, zooplankton, benthlc fauna and a description of the
four artificial reefs In the Study Area. Sediment atuJli/s Included
the description of granulometry (grain size distribution) and
volatile organic content. Depth profile measurements were made for
chemical and current studies. Data were collected from three
east-west transects within the Study Area (except for the
artificial reefs study and the current study, whure two additional
transects were sampled).
Data from the sampling program can he utilized to describe the
local Gulf environment and to make prcllminaiy conditions
concerning a Gulf outfall. The study limitations need to be
clearly understood In order ro properly use the data generated by
the sampling program.
The E1S also points out that additional site specific studies
concerning outfall alignments, and point of discharge and that
additional permit/administrative reviews and approvals would be
needed if a Gulf outfall alternative would receive further
consideration. Any additional efforts would then supplement the
EIS sampling program and would likely address the EIS study
limitations.
RK-6. The EIS identifies the wastewater reuse alternative as the
environmentally preferred alternative.
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The conclusion here la wrong. Now, you've still got
this Gulf outfall here as a backup outfall, and I suspect
that's where It's all going to go eventually, because five
years ago you fellows had everything going Into the Honeymoon
Island outfall from Tarpon, Oldsmar, Safety Harbor, Clearwater
and It looks like that's going to be a backup once again,
right?
And the present drought has proven beyond a doubt
that Florida's wells and aquifers cannot be depended upon to
provide all the needed water In the future, especially since
potable water requirements are constantly Increasing because
of rapid growth of the area, and, sir, I appreciate you;
putting down here that you are going to do something here
that removes development constraints. My god, please take
a walk around or ride around Pinellas County. We've already
become a stuffed sardine can with development.
We've got all these comprehensive land use plans, and
all they do Is juggle them around and do anything they wanted
to, and they rape our environment, they clutter us with roads,
they clutter us with these sewage problems, they constantly
go forever without conclusion, satisfactory conclusions.
I recommend, sir, that you help us develop new water
supplies. That's number one. If we don't have new water,
we're not going to have anything to dump. I mean, the present
aquifers and well systems are inadequate, all right, so help
RK-7. Potential wet weather back-ups Include deep well injection,
Intermittent surface water discharges or a Gulf outfall. Numerous
factors including technical feasibility, Institutional constraints,
water quality Impacts, and cost will determine the moat appropriate
back-up alternative. A reuse alternative would not necessarily
utilize a Gulf outfall as a back-up discharge method.
RK-8.
Potential disadvantages and advantages of all alternatives
are recognlred In the Draft EIS.
RK-9.
EPA has no program and no authority directed toward the
development of new water supplies.
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us develop new water supplies Co meet human needs, and then
In the Interim I want you to do everything you can to conserve'
every drop of wastewater, at least until such time an abun- j
dance of potable water supply has been developed. '
Accordingly, I sincerely request that you stop all i
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wastewater dumping Into the Gulf of Mexico under any and all
circumstances, and I'll be glad to answer any questions.
There Is one thing here. The gentleman asked a ques-
tion about what the other alternatives were. Well, you and
1 know we do have limited alternatives, but that doesn't mean
we can't expand them, and the alternatives are recharging
groundwater areas and recharging wetlands, which we haven't
even touched yet, and recharging flood plains.
And I want to thank you again for taking my recommenda
tlon to start recharging wells, but don't forget to purify
the water before you put It in there, because it's not going
to leach out, all right?
Thank you.
HEARING OFFICER:
Thank you, Mr. Kuester.
Again, I want to say that EPA fully supports the
comments that Dr. Kuester has made, that our conclusions are
that yes, indeed, this is an area where wastewater reuse and
conservation are very important issues, and I, too, am dis-
appointed that we don't have more of a turnout. I appreciate
RK-IO.
Current-ly, wastewater is not being dloclinrged Into the Gulf of
Mexico off of the coast of Florida.
RK-11.
Comment noted.
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your comments.
I have another maybe. Mr. Todd Tanberg, do you wish
to make any comments?
MR. TANBERG:
Maybe after. Let me hold my comments.
HEARING OFFICER :
Maybe later. I have another maybe, Mary James.
MS. JAMES:
I have no comment at this time. I'd like you to keep
on. I wish you'd get the county commission out here.
HEARING OFFICER :
Would you like for me to come back to you at the end,
or
MS. JAMES:
No. That's all right.
HEARING OFFICER:
Mr. Robert Williams? I might make one other comment
while you're coming up, and that is EPA does not have any
authority to develop water supplies. We have no program that's
involved in developing water supplies, although for the area
it sounds like it might be a very good idea.
DR. KUESTER:
Time to start.
HEARING OFFICER:
Mr. Williams?
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MR. WILLIAMS:
Mr. Chairman, Mr. Mikulak, Mr. Bramlett —-
My name is Robert L. Williams, and I'm a PE but not
appearing in that capacity. I am president of the Northeast
Pinellas County Water/Sewer Authority. Unofficially I repre-
sent the mayor of Oldsmar, who happens to be my wife, and I
want to apologize for her. She has to preside over the City
Council tonight and could not be here nor could any of the
elected officials be here because of shirking their regular
duties, so that's one of the reasons I'm here.
Just a little bit of background. I am perhaps one of
the most intensely interested participants in the entire
original 201 study. I was mayor of Oldsmar at that time and
one of the four major participants.
I was very happy to see that in your EIS you use the
logical engineering conclusions from the 201 and not that
aborted last-minute attempt to change it.
Oldsmar's interest is perhaps more intense than any
other people in this room. We're in the area that's growing
fast, and we are involved in both, I believe you call your
Tampa Bay area and your Eastlake area, and no matter what one
says, you can no more stop the development in that area than
the guy who is holding back the tide in the old fairy story.
I have to agree with Mr. Preston on the needs in that
area and that they are here now, and if we can get funded for
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Che 1990 Level, we will be happy, because by chat time Ic's
going Co be so far out of these projections. Now, as 1 said,
I'm Intimately familiar with the 201. I know what the projec-
tions were based on.
We engineers at that time knew that they were far
below what we knew were going to be there as local people, but
I agree that that's the rules, and in order for the study to
be representative of the entire area, everyone used those rule:
The Oldsmar plant was built and approved back in Che
early sevencies as a regional advanced water treatment plant.
It was built on the bay because AWT was to be discharged into
the bay. We were misled. That plant was designed and partial
ly built with a capacity of 12 million gallons a day. AC Chat
time of the study, we were 1 million gallons a day. We were
not AWT, but we do treat our water, and I think Mr. Bramlett
can testify to this, at far higher levels than our permit
requires and would continue to do so regardless of our size.
Our plant was built with no federal funds. Everybody
else In the area has federal funds in their plant. Our poor
people are having to pay for it, and I was bitterly disappointed
when the 201 study was derailed, but we do need federal funds
in order Co be cost effective with our neighbors.
I'm glad chat you recognize Che difficulties In Che
Eastlake area, and Eastlake just comes right on down to us. I
don't know exactly where you draw the line between Eastlake and
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Tampa Bay, but we do need some workable answers to that area,
and we need them now.
Again, I might say -- someone said earlier — Mr.
Preston recognized that we are up against the wall right now.
It's growing faster than we had anticipated and having no
federal funds, the town having no money until it did grow, we
couldn't prepare in advance, although we knew full well, and I
worked hard on this for three and a half years while I was
mayor, and I could get nowhere except our own little things
that we could do. We dug our ponds a little bigger. We built
our berms and things like that in order to try to do what we
could to hold back the tide that was coming, but we have no
places to put our water now.
We have considered various alternatives. We agreed
with the 201 study that the land reuse was the most desirable,
still is the most desirable. We don't want to put our water
in the bay even accidentally. We want to reuse it. The area
to the north of us is the only place that's viable for reuse.
Our groundwater table is only about 3 feet, maybe 4 at the mos
below the surface which doesn't give us much room for percola-
tion.
We do have ponds, 16 acres of ponds, where we can store
some water. We would hope to be able to pump that out into
that East lake area, spread it out, and make some use of it, at
the same time serving our purpose.
co-i.
Comment noted.
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We don't really want to take the nitrogen and phospho-
rous out of It either, because that's what makes things grow.
We have people all over our area, Including my own wife, that'js
asked me why can't I have some of that water; we'll reuse it.
Our ordinances and our subdivision development regula-
tions, and Bill, you might correct me if I'm wrong. I believe
they now include requirements for a gray water distribution
system in new subdivisions, looking toward this reuse of water
We have the problem, as I said, immediately, though,
and again we don't want to send it to the bay, although we are
interested as a, shall we say, a near-term solution. We had
hoped that we could get some type of wasteload out of that
Tampa Bay study, but I don't know whether that's going to come
in time to help us or not, and I don'-t know that we are still
in the study even. I might ask that question if Mr. Bramlett
knows. I have heard rumors that Oldsmar was just out of it.
MR. BRAMLETT:
That you're out of the study for Tampa Bay, out of the
allocation study?
MR. WILLIAMS:
Out of the possibility of receiving
MR. BRAMLETT:
I'm not aware of that. There's a draft allocation out
which calls for no discharge, but that's not the final document
As I said before, the final document should be out in July or
co-2.
See Mr. Bramlett's responses on page:; 60-61.
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August of this year.
MR. WILLIAMS:
Is there anything that would make us think that final
document might be different?
MR. BRAMLETT:
No, sir, not to my knowledge.
MR. WILLIAMS:
That's what I was afraid of. So that's not an answer.
We have to have a different answer. We are working with the
developers in this area. As I said, they're coming Just like
the tide comes. They are being very cooperative. They have
asked us what they need to do to help us.
We are attempting to work something with them, but our
hands are tied unless the wetlands and the general distribution
of water in the sensitive area is brought on line, and that's
our major concern right now.
We don't want to discharge it, spray irrigation, 200
feet from the bay. 250, I believe, is the minimum. We don't
want to put it there. We want to put it further upstream. If
it ever does get to the bay, and to my knowledge nobody has
ever made a study and showed that we have ever polluted the bay
at that point, and we'd like to return to the land, and I don't
see anything in the EIS study that encourages that there might
be some further interest on the part of the federal government
in that area. I wish there were, and I would hope that perhaps
co-3.
See Mr. Bratnlett's response on this page.
CO-4.
Both land application and reuse alternatives are considered In
the EIS, with the wastewater reuse alternative being Identified as
the environmentally preferred alternative.
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you could carry that back, because I think this is a legitimate
concern both to us locally and to the federal government from
the standpoint that there are a lot of people, there are in-
dustries and there are business concerns there.
We don't have enough money to just stay around and wait
for the solution of some of these things. We need some solu-
tions now. We have obligated ourselves to a bond issue to
complete some of the structures in our plant, to rehabilitate
some of the structures in our plant and to provide some pro-
visions for effluent. We'd like'to see that effluent go north
in a permanent way rather than just spraying it willy-nilly.
Land for doing this is not really available. If it is,
it's at a premium, which the city can't afford, so again this
comes back to the federal government's concern with people who
are poor and can't afford things. 1 think we'll qualify.
There is a possibility of cooperation with large land
owners north of the town in the Eastlake area, and finally I
might say, go on record, it's my opinion that the solution to
this is none of the above. The solution is building a water
treatment plant right next to our sewage treatment plant and
reusing the water. We have the land for it, and we'd like to
have the funds for it.
Thank you.
HEARING OFFICER:
Thank you, Mr. Williams.
CO-5.
Comment noted.
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Another thing I might remark on regarding this rela-
tionship between water supply and wastewater disposal, some of
the information that we received regarding this area and the
use of water supply indicates that somewhere between a quarter
and a third or maybe as much as 407. of the water usage In this
area is related to watering of grass and outdoor use of water,
which is non-potable uses of water, and this is one large area
with wastewater reuse that potentially could be tapped.
I am now back to the first maybe. Don McCullers, did
you want to say something?
MR. MCCULLERS:
I have some comments I'd like to make and also ask a
couple questions if I possibly can.
HEARING OFFICER:
You may ask them. I'm not sure we can answer them.
MR. MCCULLERS:
Okay. That's fine. I'd like to ask them anyway. You
said that the wasteload allocation of upper Tampa Bay would be
completed sometime this summer. I'd like to know If your de-
partment will hold back on your final draft of the EIS until
that wasteload allocation is approved.
HEARING OFFICER:
All I can say is we're going to close the comment
period on June 25th. We intend to go ahead and finalize the
EIS. If the state is particularly interested in its services
CO-6. EPA Intends to finalize the EIS. If needed, the HIS will be
supplemented when wasteload allocations for Finellas County surface
waters are available.
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to us to maybe consider some other option, we may consider that.
We have been keeping this EIS open for quite a long time. We
have a contractor that we've been dealing with, that we've been
keeping on for quite a long time, and for our own reasons and
our own needs, we would like to move on to complete this EIS.
We would be in a position, when we do have wasteload
allocations, we have a position where we can make some final
conclusions, that we would be moving to make those conclusions
So that's about all I can say on that.
MR. MCCULLERS:
One of my concerns is the area east of Lake Tarpon, am
there appears to be quite a few concerns of the audience to-
night. It's one of the most environmentally sensitive lands
that Pine lias County has left.
Yet, in the draft EIS, and maybe this is a good time fo
somebody to stand up and go against possibly their own policy,
in the draft EIS it says you would not recommend any funding
of the EPA monies to the area east of Lake Tarpon and made the
comment tonight that the only way anybody could get any funding
from EPA, which seems to hold true, is that you have to have
a problem.
I'd like to kind of try to see that role reversed so tha
we could take care of the problems before we present the prob-
lems . Maybe that would be a good time to have -- to recommend
to EPA that you fund some of these areas. Reuse, without a
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doubt, you're going to have to get Into a reusettype situation
Like quite a few people have stated tonight, you've got, you
know, one of the worst dry spells that we've been through In
a few years In this area.
Go Into the possibility of spray irrigation on the land.
Go --- Think of the possibility of recharging Cypress Head so
that our forestry people here don't have to go out and fight
the fires, that if you had some of this water there available,
you would not have half these problems, but at the same time
why not get EPA's Involvement in your most envircnmentally
sensitive lands before you have a problem, so that the environ-
mentally preferred alternatives, which is what everything Is
about in this study, can be enacted before you have to come
back and correct the problems at a higher cost. Then you coulc
go in and you could do a very sufficient job of doing now.
I think that the role on that should actually be reversed
a little bit. Why don't you stop the problem before you create
a problem.
HEARING OFFICER:
I might ask, I've been hearing this all along, that
there's going to be a big problem, and I might just ask, we
have local ordinances and requirements regarding the use of
on-lot systems. We have permitting responsibilities from the
State of Florida on surface water discharges, and It is not
clear to me what kind of a problem It Is that we're really
co_7. The Clean Water Act and EPA Construction Grants Regulations
are specific in that EPA grant funds are available to assist
municipalities in correcting existing water quality and public
health problems. Wastewater flows existing at the time of Step 3
grant (construction) award, but not to exceed the year 1990 flows
are eligible for EPA funding.
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talking about in the future for this area, and maybe I Just
don't understand.
MR. MCCULLERS:
Well, Mr. Bisterfeld when he first started this whole
study, he did not either until one day we took him to the
area, and he says Wow, is that the area that I looked at a
year and a half ago? You know, the rapid growth of all of
Pinellas County as well as Florida is so tremendous that what
Mr. Williams got through saying, I do not perceive far down
the road. You're going to treat wastewater here. You're goln
to have to recycle it back out through a public plant. I
mean, the times are coming.
There is technology that can be done for that. In
reality it's been done for years, and the public is Just not
aware about it.
The reuse estimates for the spray irrigation, are those
updated costs or are these still the 1980 figures?
HEARING OFFICER:
(Nods head affirmatively)
MR. MCCULLERS:
They're the 1980 figures? The package plants —
MR. MIKULAK:
Don, if I might inject something. All costs that we
discuss in the EIS at this tine are the 1980 figures and have
not been updated —
CO-8.
Comment noted.
CO-9.
The costs presented for spray irrigation are 1980 costs.
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MR. MCCULLERS:
I thought they were.
MR. MIKULAK:
-- updated at all.
MR. MCCULLERS:
I've seen that some of the flows and some of the other
numbers In the study had been, It appeared to me, that they
had been adjusted.
MR. MIKULAK:
The flows have been corrected, but to go back and re-
adjust all the costs of the alternatives did not seem to be a
cost-effective activity involved, but the costs are still
internally consistent; that is, when you compare the cost of
one alternative to another and try to .rank them, they're still
internally consistent, but they are still 1980 dollars.
MR. MCCULLERS:
There's one statement in here, and maybe I'd like to
speak to Mr. Bramlett about this if I could possibly, is —
And I'm not out to throw any stones at anybody. I want every-
body to be understanding of that.
The Clearwater Northeast plant, will that be allowed to
discharge their effluent from that plant through the Clearwater
East plant, or is that considered a new discharge?
MR. BRAMLETT:
Will be allowed to discharge if the allocation allows the
CO-10.
See Mr. Bramlett's response nil pn^ef d/-lill.
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discharge, you mean?
MR. MCCULLERS:
The way it's presently operating, yes, sir.
MR. BRAMLETT:
If the allocation gives them a discharge, I'm assuming
that it would.
MR. MCCULLERS: i
Would that constitute --
MR. BRAMLETT:
I don't know --
MR. MCCULLERS:
--in your office --
MR. BRAMLETT:
-- for a fact, though.
MR. MCCULLERS :
-- a new discharge? Although you've got one treatment
plant to the south, you've got a treatment plant to the north,
you've created a new treatment plant to the north after certain
rules and regulations were in effect.
MR. BRAMLETT:
Right.
MR. MCCULLERS:
Will that now be considered a new discharge through the
Clearwater East plant on the Courtney-Campbell Causeway?
MR. BRAMLETT:
CO-U.
Sec Mr. Bramlett's response on pages fiB-69.
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I don't think I can answer that. I don't know the
answer. I can find out for you.
MR. MCCULLERS:
Can you find out for me, please?
MR. BRAMLETT:
Yes.
MR. MCCULLERS:
I've been trying to get that answer for sonetijne, and I
cannot. I would like to know that.
I would still like to express my opinion. I think that
the track of effluent reuse is the only way that you have to
go that has to be wet-weather back-up alternatives. Everybody
has proven that. I mean, it's a growing way, with the rapid
people and the amount of people that's moving into the State
of Florida everyday, particularly to Pine lias County and the
Tampa Bay area, I'D kind of disappointed that the EIS, and
this has been quite a concern in the past, it does not include
more than just Pine lias County. I think it should Include
the whole Tampa Bay nucleus area, from Oldsmar to Tampa to
Safety Harbor, Palm Harbor, and Clearwater. I think the
whole thing should be considered, but I would really like to
see the wording in the drafted EIS change so that EPA is
recommending to EPA that they do fund the areas east of Lake
Tarpon, so that the environmentally preferred alternatives
can be initiated.
CO-I2.
Conment noted.
CO-13. The EIS covers the entire North Plnellas County 201 Study Area.
and the Clearwater and Safety Harbor portions of the Central
Pinellas County 201 Study Area.
CO-14. The environmentally preferred alternative is for thp most part
now being Implemented In the area east of Lake Tarpon by several
existing facilities. Tills practice can and will likely continue
without EPA funding. In addition to the eligibility limitations of
future facilities, EPA policy and regulations also address funding
in environmentally sensitive ateas. The area east of Lake Tarpon
is comprised of roughly 30 percent ot wetlands and floodplains.
County wellflelds and groundwater recharge areas are also located
here. The presence of these environmentally sensitive feature?
further limits F.PA's participation in funding wastewater facilities.
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Wastewater reuse is very costly; once It's implemented,
it's probably the greatest thing that there is. It is very,
very costly. The figures on the flows have been updated.
The costs on the installation of these systems have not been
updated. I think that's very misleading.
I think it's also misleading to try to finalize this
statement seeing as how we Everybody has put so much
effort into this over the past few years that we're so close
now to possibly having a wasteload allocation in the bay, you
cannot make any determined findings on this document here
until the Department of Environmental Regulation completes
the wasteload allocation study of Tampa Bay.
Thank you.
HEARING OFFICER:
Thank you, Don.
Mr. Tanberg, do you now wish to make any comments?
MR. TANBERG:
My name is Todd Tanberg. I'm the director of the Pinel-
las County Sewer Department.
As we understood the purpose of the EIS as originally
stated some six-odd years ago, was for the purpose of confirm-
ing the recommendations of the north Pine lias 201 facilities
planning study.
That final recommendation, of course, was for water reuse
spray irrigation if you will, with a back-up method of effluent
CO-IS. The costs are still internally consistent, that Is, when you
compare the cost of one alternative to another and try to rank
them, they are still Internally consistent.
CO-16. As Indicated by Mr. Bramlett, the Tampa Bay wasteland alloca-
tion is expected to be available sometime later in 1985 and the
Clearwater Harbor - St. Joseph Sound wastelond allocation will not
be available at least until the middle of 1986. Oner there are ap-
proved vasteload allocations, conclusions can be made for Lhe
remaining subareas. If necessary, an EIS supplement will he
prepared Incorporating approved wasteload alloc.it ions.
PCSS-1. The purpose of the EIS is not to confirm the 201 Plnn
recommendations, but rather to develop and evaluate wastewater
management alleiuallves leading to the selection of the most, cost
effective environmentally sound alternative.
-------
9
10
I I
12
13
14
15
16
17
18
19
20
21
22
23
14
25
disposal being Gulf outfall.
The EIS, draft EIS, as we review it, In our opinion,
does not fulfill the purpose of that original -- the original
purpose of proceeding with the EIS.
We are operators of wastewater treatment facilities.
We don't control growth. However, we are scrambling to pro-
vide services for those who are coming Into the county to
live.
Eastlake Tarpon Is an area that is the most rapidly
growing in the county, and this is where our attentions are
being focused today. This area of the county is notable In
the EIS and by lack of being addressed In detail In the
document. The county endorses water reuse, and we Intend to
reuse that treated effluent wherever possible.
However, we do need to have defined for us that inter-
mittent discharge that we can use during wet weather. Histor-
ically, 50% of the county's rainfall comes In three or four
months a year, summer months. During those months, we can't
force effluent out of the bay on the people who use It through-
out the year.
We are experiencing right now some severe droughtcon-
ditions. Everybody is screaming for treated effluent; we'd
love to have It. Number one, there's a lot of rain. Golf
courses don't want any more than Mother Nature gives them, and
that's our problem. In those times we need intermittent
PCSS-2 Wastewater management alternatives for the nrea east of l.,ike
Tarpon are addressed In the F.JS. The No Federal Action alternative
has been selected for this portion of the Study Area. Tho
selection of the No Federal Action alternative slioujrt not be
construed as being addressed In Insufficient detail.
PCSS-3.
Comment noted.
-------
10
11
12
13
14
15
16
17
IS
19
JO
21
22
23
24
25
59
discharge.
i
We are enthusiastic about other alternatives for dis-
posal of effluent. Dr. Kuester mentioned wetlands discharge '
of effluent. We have looked into that. We have looked into
a number of other alternatives. Unfortunately, we are being ,
discouraged and frustrated by the current rules, regulations,
and policies of the state. !
I
We had hoped that the EIS would resolve some of these
types of issues. We had no approved intermittent back-up
method of discharge after the 201 was completed.
Now, after the six-year effort on the EIS, we still
are left without an approved back-up method for effluent
disposal during those months of the year when water reuse is
not practical.
I think in conclusion I'd just like to say that due to
the study, in our opinion, not fulfilling the original intendec
purpose -- that is, to confirm the recommendations of the
north Pinellas 201 plan -- Pinellas County will not be able to
endorse this EIS document.
Thank you.
HEARING OFFICER:
Thank you, Mr. Tanberg.
I have to agree with, I think, most of the comments that
I'm hearing here, except for a couple of them, and the only
reason I won't agree with them is that I can't agree with them,:
i
PCSS-4.
Comment noted.
PCSS-5. Tills type of alternative can not he fully roiisldereil until
approved wastuload allocations are available.
PCSS-6.
Comment noted.
-------
60
i
2
3
4
5
6
7
a
9
10
II
12
13
14
15
16
17
18
19
20
21
22
23
24
25
because I am limited by our policy and the directions of •
Congress.
But I would like to say that what I've heard this even-
Ing, or at least what I believe I've heard this evening, Is j
that everyone who's spoken has endorsed the concept of re-
cycling and reusing wastewater, that there Is a direct re-
i
latlonshlp and a link In this area between water supply and
wastewater supplies and wastewater reuse, and that I thought
I heard everyone say that yes, this Is the way that this par-
ticular Issue's been going.
I think, If you look at the conclusions In the ElS.you
will find that that Is the heart of the EIS and the recommenda
tlons that are contained therein, and I'm very pleased that
we're hearing support for that conclusion.
I think also, regarding Mr. Tanberg's comments that we
don't yet have all the answers that we'd like to have, I think
we share, and I think the state shares some of that same
disappointment as we are here today, that we don't have those
answers, and this is not a simple particular issue. I think
if it had been simple, it would've been answered.
We are hopeful that with the availability of wasteload
allocations in the very near future that we may be able to
reach conclusions and come to answers regarding the questions
that you had.
With that, I'll just ask if there's anyone else who
-------
didn't register to speak that maybe, hearing all the dtscus-
!
sion and comments that've been made, if now they might like tot
stand up and have a few words. Is there anyone else who might!
Like to ---
10
ii
i?
13
15
18
20
21
22
23
24
25
Yes, sir. Would you state your name and who you repre-
sent if you represent anyone?
MR. BOYD:
Mr. Mikulak, Mr. Howard, Mr. Bramlett, my name is Alfred
Boyd. I am very familiar with the Eastlake area. I had one
tract of land out there, and my ownership was 6,000 acres.
My dad had 16,000 acres in the Eastlake area.
We know the situation quite well. Now, I think that
perhaps you gentlemen working under the Environmental Protec-
tion Agency are charged with protecting our environment.
I would like to ask you, have you studied the source of
much of our contamination in Lake Tarpon? Your maps — I
have not had a chance to study this book; I just picked it up
this evening, but so far I have not been able to find anything
that you have Investigated across the Hillsborough County line
Today Lake Tarpon is covered with algae in much of the
area, which is showing pollution. It may not yet be dangerous
to human habitants of the area, and yet it can be. That's one
main point I think that you might have missed.
There is a drop from the source of Booker Creek which
flows into Lake Tarpon approximately 33 feet. The flow in the
AB-l. The E1S covers the entire North Pincllns County 201 Study Area
and the Clenrwater and Safety Harbor portion of the Centra)
Plnellas County 201 Study Area.
-------
wet season Is tremendous. All the effluent from the septic
tanks and discharge from various sources are gfolng to flow
down Booker Creek and Into Lake Tarpon, out the outfall canal
Into Old Tampa Bay. That cannot be disputed.
The Pine Has County Commission has recently purchased ,
i
considerable acreage In that area for environmental protection>
I
Now, I charge you men to Investigate our source of much
pollution and see If we can eliminate some of that through
cooperation with Hlllsborough County. We have been at war
more or less with the Hlllsborough County Commissioners over
the possible pollution of our water supply In the Eldrldge wll<
fields.
Now, Booker Creek flows very close to that water supply
that we are drinking everyday. I think It behooves us to work
on protecting our drinking water supply first and foremost.
Thank you, sir.
HEARING OFFICER:
Thank you.
Is there anyone else who, hearing these comments, would
like to stand up and make some additional comments?
(No response)
I want to say I appreciate all the speakers standing up
and talking with us, and this public hearing record will retna Ir
open until June 25th, 1985, and I would encourage anyone here
who would like to, to please provide your comments In writing.
AB-2.
To date, there has not been a documented problem with septic
tank effluent reaching Brooker Creek. Treatment plants do nut
discharge treated effluent to Brooker Creek.
AB-3.
Comment noted.
-------
9
10
]l
I?
13
14
15
16
17
18
19
30
21
22
24
25
63
If you have any other comments that you'd like to make that
you either didn't think of here or come to you after this
meeting, please contact us with those comments by June 25th.
All written comments received will be considered as
part of the record, and you should forward them to Mr. Mlkulak
His address Is on the bottom of your agenda, your handout,
that you have received.
I want to thank you again for coming. I really do ap-
preciate your coming. Atlanta Is a long way from Clearwater,
north PineUas area, and without your coming and talking to
us, it makes our job much more difficult.
The final EIS that will be coming out in September will
consist of the agency's final decision , a summary of the draft
EIS, any pertinent additional information or evaluations that
are developed since the draft is published, revisions to the
draft, comments that were received on the draft and the EPA's
responses to those comments, and a transcript of this hearing.
Those of you who commented here tonight will receive a
copy of the final EIS. I'd also like to thank Pine lias County
for making these facilities available. They're fine facilities
and we really do appreciate it.
Again, thank you for your attendance, and this hearing
is adjourned.
(Whereupon, the above-entitled
public hearing was concluded at 9:10 p.m.)
CERTIFICATE OF REPORTER
This Is to certify that the attached proceedings before
THE UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
PineUas County Courthouse
Clearwater, Florida
7:30 p.m.
June 11, 1985
were held as herein appears and that this is the
official transcript of the proceedings for the file
of the Agency.
ANNE JAPOUR
Certified Verbatim Reporter
BAY PARK RFPORTINC
C')U»I HEPOHTINC
II fuiUlH STUFfT NORTH
-------
TABLE 4
INDEX TO WRITTEN COMMENTS ON NORTH PINELLAS COUNTY DRAFT EIS
Comment
Code
DER-1
TBRPC-1
TBRPC-2
TBRPC-3
TBRPC-4
TBRPC-5
TBRPC-6
TBRPC-7
TBRPC-8
TBRPC-9
PCSS-1
PCSS-2
PCSS-3
PCSS-4
PCSS-5
PCSS-6
Page(s)
83
85
86
86
86
86
87
87
87
87
88
88
88
88
88
88
Commentor
Florida Department of Environ-
mental Resources
Tampa Bay Regional Planning
Commission
Tampa Bay Regional Planning
Commission
Tampa Bay Regional Planning
Commission
Tampa Bay Regional Planning
Commission
Tampa Bay Regional Planning
Commission
Tampa Bay Regional Planning
Commission
Tampa Bay Regional Planning
Commission
Tampa Bay Regional Planning
Commission
Tampa Bay Regional Planning
Commission
Pine lias County Sewer System
Pinellas County Sewer System
Pinellas County Sewer System
Pinellas County Sewer System
Pinellas County Sewer System
Pinellas County Sewer System
Nature of Comment
Support reuse
Consistency with Council policies
Review of discharge to coastal waters
Review of discharge to Gulf
Review of deep well injection
Review of land application
Review of reuse
Expand reuse alternative
Support reuse with deepwell backup
Consideration of local comments
Accomplishment of EIS purposes
Accomplishment of EIS purposes
Area east of Lake Tarpon recommendations
Intermittent wet weather discharge
Ownership of small plants
EIS recommendations
-------
TABLE 4 (Cont'd.)
INDEX TO WRITTEN COMMENTS ON NORTH PINELLAS COUNTY DRAFT EIS
Comment
Code
CD-I
CD-2
CC-1
CC-2
CC-3
CC-4
CC-5
CC-6
CC-7
CC-8
CC-9
CC-10
CC-11
CC-1 2
CC-13
CC-1 4
CC-15
CC-16
CC-17
CC-1 8
CC-19
CC-20
CC-21
CC-2 2
CC-23
CC-24
Page(s)
89
89
90
90
90
90
91
91
91
91
91
91
91
91
92
92
92
92
92
92
92
92
93
93
93
93
Commentor
City of Dunedin
City of Dunedin
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
Nature of Comment
Support of alternative
Support of reuse
EIS recommendations
EIS emphasis
Funding of wasteload allocation studies
Delay Final EIS
Consideration of private treatment plants
Consideration of private treatment plants
Existing land application site
Connection/impact fees
Wasteload allocation process
Safety Harbor wastewater treatment plant
Wastewater disposal alternatives considered
Intermittent wet weather discharge
Support basis of wasteload allocation
studies
Safety Harbor wastewater treatment plant
Relevance of management findings
Land application design
Intermittent wet weather discharge
Description of treatment plant
Description of treatment plant
Land application operation
Screening of wastewater disposal
alternatives
Wastewater disposal alternatives considered
Outdated costs
User charge variance
-------
TABLE 4 (Cont'd.)
INDEX TO WRITTEN COMMENTS ON NORTH PINELLAS COUNTY DRAFT EIS
Comment
Code
CC-25
CC-26
CC-27
CC-28
CC-29
CC-30
CC-31
CC-32
CC-33
CC-34
CC-35
CC-36
CC-37
CC-38
CC-39
CC-40
CC-41
CC-42
CC-43
NMFS-1
Page(s)
93
93
93
93
93
93
94
94
94
94
94
94
94
94
94
94
94
95
95
96
Commentor
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
City of Clearwater
National Marine Fisheries Service
Nature of Comment
Outdated costs
Gulf outfall impacts
Existing land application sites
Safety Harbor wastewater treatment plant
Outdated data
Outdated data
Gulf outfall effluent additional treatment
Outfall location
Degree of initial dilution
Coliform concentrations
Fundable alternative definition
Long-term reliable disposal option
Support of Gulf outfall as a reliable
alternative
Commitment to reuse with Gulf outfall
alternative
Growth controlling factors
Gulf outfall effluent quality
Gulf outfall effluent quality
Environmental sensitivity of Gulf outfall
route
Tampa Bay water quality
Preferred alternatives for wastewater
SFWMD-1
97
Southwest Florida Water Management
District
disposal
Confining layer definition
-------
TABLE 4 (Cont'd.)
INDEX TO WRITTEN COMMENTS ON NORTH PINELLAS COUNTY DRAFT EIS
Comment
Code
Page(s)
Commentor
Nature of Comment
oo
o
SFWMD-2
SFWMD-3
SFWMD-4
SFWMD-5
USPHS-1
USPHS-2
USPHS-3
USPHS-4
SOLID-1
SOLID-2
SGSC-1
SGSC-2
SGSC-3
SGSC-4
NOAA-1
97
97
98
98
99
99
99
100
101
101
102
102
102
103
105
Southwest Florida Water Management
District
Southwest Florida Water Management
District
Southwest Florida Water Management
District
Southwest Florida Water Management
District
United States Public Health Service
United States Public Health Service
United States Public Health Service
United States Public Health Service
Save Our Lakes Invite Discussion
Save Our Lakes Invite Discussion
Suncoast Girl Scout Council
Suncoast Girl Scout Council
Suncoast Girl Scout Council
Suncoast Girl Scout Council
National Oceanic and Atmospheric
Administration
Confining layer definition
Status of existing injection facilities
Update of existing injection facilities
Deep well injection monitoring costs
Lack of wasteload allocations
Environmental and public health impacts
Potential for adverse environmental and
public health impacts
Require studies and data to determine
impacts
Oppose Gulf outfall
Support reuse
Oppose Gulf outfall
Oppose Gulf outfall as a wet weather
disposal alternative
Support percolation ponds
Oppose Gulf outfall as a wet weather
disposal alternative
Movement of geodetic control survey monu-
ments
-------
TABLE 4 (Cont'd.)
INDEX TO WRITTEN COMMENTS ON NORTH PINELLAS COUNTY DRAFT EIS
Comment
Code
Page(s)
Commentor
Nature of Comment
oo
CO-1
CO-2
CO-3
DOI-1
DOI-2
DO I-3
DOI-4
DOI-5
DOI-6
DOH-1
DOH-2
DOH-3
DOH-A
DNR-1
DNR-2
106
107
107
109
109
109
109
109
109
111
112
112
112
118
118
City of Oldsmar
City of Oldsmar
City of Oldsmar
Department of the Interior
Department of the Interior
Department of the Interior
Department of the Interior
Department of the Interior
Department of the Interior
Department of Housing and
Urban Development
Department of Housing and
Urban Development
Department of Housing and
Urban Development
Department of Housing and
Urban Development
Department of Natural Resources
Department of Natural Resources
Population projections
Grants to correct existing problems
Wasteload allocation process
Mineral resource impacts
Support elimination of discharges into
estuaries
Support reuse
Support deep-well injection and spray
irrigation
Groundwater export impacts
Deep-well injection monitoring
Wasteload allocation process
Water conservation
Water conservation
Water conservation
EIS emphasis
Agency coordination
-------
SUMMARY OF GENERAL
TABLE 5
TOPICS COVERED
BY WRITTEN COMMENTS
'3P1CS
-3VESED
REJSE
'SRPC "O^iC"
DISPOSAL ALTERNATIVES
"UBL'.r °A9';C.°A'iON
EiS "URPOSES
EiS RE--3MMENDA';ONS
WEA'HER DISCHARGE
WA^E «*ER 'SEGMENT
"3NSI3ERED
E.S £1PHAS',S
WASTE -O.AO ALLOCA'iONS
E.S C31PLE".ON
PLANTS
..AND A°PLiCATiON
-iNANCIAc IMPACTS
SA'E'T HARBOR
'RE4T1E«(r PLANT
3UTDA'ED DA' A
OUTOA'ED COS'S
-J^- OUTFALL iMPAC'S
GJL.r OUT-ALL
AL'ERNA';/E -JND;NG
rA1PA 9A" WA'FR
SJALl"
DEE" WE^L ;NJEC'I3N.
D3PJL.A';3N "ROJEC'IONS
E=A -RAMTS
,1PA-'S
WA'^ C3NSFRVA-3N
SOURCE 3F COMMENTS
DEPARTMENT OF
FNVIRONMFNTAL RESOURCFS
;
TAMPA BAY REGIONAL
PLANNING COUNCIL
8
i
2.3.*.
9
PiNELLAS COUNTY
SEWFR DEPARTMENT
1 .2
3.6
4
5
CITY OF
DUNFDIN
2
1
CITY OF
CLEARWATER
38
1
12. \7
i 8 . . 9
"«"
2
3.9. ,3
20
4
5,6
7 . ; 6 . 2
7
8.24
10. ,*•
28
,3.29.
30
23.25
26.3; .
33.34.
39.4Q.
4 I .42
32 . 36
35. 3T
43
1
u_
UJ O
— ^
0= K
•CU.
C u:
-1 W
< UJ
z —
OK
— Ui
•— X
< tr
U-
1
1
SOUTHWEST FLORIDA
WATER MANAGEMENT
DISTRICT
•,.2.3.
UNITED STATES
PUBLIC HEALTH SERVICE
2. 3. '
SAVE OUR LAKE
INVITE DISCUSSION
2
I
SUNCOAS' GIRL
SCOUT COUNCIL
3
1.2.4
NAMONAL OCFANIC
AND ATMOSPHFRIC
ADMINISTRAMON
1
CITY OF
OLDSMAR
3
:
2
DEPARTMENT OF
THF INTERIOR
3
2
4
4 . S . 6
DEPARTMENT OF
HOUSING AND URBAN
DEVELOPMENT
'
2.3.4
DEPARTMENT OF
NATURAL RFSOURCFS
1 • 2
32
-------
STATE OF FLORIDA
DEPARTMENT OF ENVIRONMENTAL REGULATION
TWIN TOWERS ornct SUILOINO
1600 BLAIR STONE ROAD
TALLAHASSEE. FLORID* M10I »41
Mr. Ronald J. Mikulak
Project Officer
Environmental Assessment Branch
U. S. Environmental Protection
Agency, Region IV
345 Court land Street N.E.
Atlanta, Georgia 30365
BOOORAMAM
GOVERNOR
VICTORIA J. TSCHINKEL
SECRETARY
kt-^>
RE: EIS-North Pinellai County Waatewater Facilitiea
00 Dear Mr. Mikulak:
Because of the tack of approved waateload allocations for the
majority of Pine lias County's surface watera, the EI8 necessarily
recommends: (1) no federal action, (2) a Gulf outfall, or (3) a
wastewater reuse program.
The reuse option responds potentially to the area'a surface water
quality problems, while addreaaing ground water supply limitations at a
time of increasing disputes over inter-county water transfers and water
DKK-ll rights. Of the three options, wastewater reuae (3) appears to be the
I most appropriate^
DER-1.
Comment noted.
Sincerely,
Rodney S. DeHan, Ph.D.
Administrator
Groundwater Section
RSD/dks
Protecting Florida and Your Quality ol Life
-------
9455 Kogvr Boutevanj
SI Petersburg. FL 33702-24(11
(013)577.5151 Tampa 224-9380
Suncom 506-3217
Chairman
Mr Joseph McFaf 'and
Vice Chairman
Commissioner
WestwoocJH Fietcrw Jr
Secretary Treasurer
Councilman William Vannalta
Executive Director
CHyoterademon
Councilwoman Saund'a Rahn
Crtyofdeerweief
Commissioner James L Berlteid
OlyotDadeCrly
Commissioner Lawrence Puckefl
CAyofOunedtn
Commisaioner Donald R Shatter
CityotGuHport
CommissK)n«r George Prigun
HMatMrough County
xanders Byine
^* Mr Joe ChHIura Ji
Mr Joseph WcFariand
Commissioner Jan K Platl
Mr Robert W Saunders. Sr
OryolLtrgo
Mayor George C McGough
Manata* County
Commissioner
Weslwood H Fletcher jr
Ms Patricia M Glass
CHy of New Port Rtehey
Councilman Robert G Pno'
CilyolOldtmar
Mayor Grace F
CityofPabnaiio
Mayor Robert E Hurt
Paaco County
Mr Philip MisNtin
Commissioner Sylvia Young
PmHlat County
Mr Contad Bansoach Jr
Ms BemFrterson
Cfxnmssioner George C Greei
Reverend Preston Leonard
Mr Michael Zaqo'ac J*
Crly otPiorta* Park
Councilman Wniiam Vannalta
City of SI Petersburg
Councilman Dejn Slipbe< is
City of Tfjmpto Terrace
C«jnc I'mjn .jnr-' Ki-g
June 3, 1985
Mr. Ronald J. Mlkulak, Project Officer
Environmental Assessment Branch
U.S. EPA - Region IV
345 Oourtland Street, N.E.
Atlanta, Georgia 30365
Subjecti ICSR »97-85; Draft EIS North Pinellas Wastewater
Facilities, Pinellas County
Dear Mr. Mlkulak:
The enclosed agenda item regarding the above referenced matter '(as
considered and approved by the Clearinghouse Review Committee of
the Tampa Day Regional Planning Council at its Hay 28, 1985 meeting.
Please contact the Council staff if further information regarding
this item is desired.
f
Sheila Benz
DRI Coordinator
SB/Ik
Enclosure
cc: Ron Fahs
-------
CO
en
TBRPC-1
IC*R 197-85) Draft Environmental Impact Statement, North Plnellas
Wastewater Facility, Northern Pinellas County
ICARinGHOUfC REVIEW!
The U.S. Environmental Protection Agency has requested review and comment
on a draft of an Bnviromental Impact Statement (BIS) addressing proposed
alternative* for wastewater treatment facilities in North Plnellas County.
The study area Includes Clearwater, Oldsmar, Dunedln, Tarpon Springs and
unincorporated area. Location: North Plnellas Countyi Agencyt U.S.
Environmental Protection Agency.
Local Contents Requested From
Pinellas County Department of Public Works: Correspondence received Hay
20, 1985. Letter attached.
City of Dunedin Planning and Conminity Services Departmentt Correspondence
received May 17, 1985. Letter attached.
City of Oldsmar Public Works Department
28, 1985.
No
City of Tarpon Springs Planning Departmenti No
28, 1985.
Pinellas County Planning Department:
1985.
Pinellas County Environmental Manage
28, 1985.
tents received as of May
mts received as of May
No comments received as of May 28,
mts received as of May
enti
No
City of Clearwater Planning Department: No comments received as of May 28,
1985.
Council Cuimiints and Re
endationst
This project has been reviewed for consistency with the Council's adopted
growth policy, the future of the Region. The proposal has been found to be
consistent with Council policy to encourage the protection of ground water
recharge areas, wetlands and flood plains while encouraging a continuing
supply of good potable water for the entire Tampa Bay Region.
This draft Environmental Impact Statement (EIS) is designed to address the
wastewater effluent alternatives for the Northern Plnellas County 201 Study
area. Six basic wastewater disposal alternatives were evaluated for the
existing municipal facilitiest
TBRPC-1.
Comment noted.
tompo boy regional planning council
9455 Koger Boulevard St Petersburg, Fl_ 33702 I813}577 5151 /Tampa 22-1 9380
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TBRPC-2
TBRPC-3
00
TBRPC-4
TBRPC-5
• Discharge to coastal waters (Old Tampa Bay, clearwater Harbor-st. Joseph
Sound or the Anclote River)i
This municipal wastewater disposal option to discharge into coastal waters
is currently being practiced in many areas. The EIS draft recognizes the
detrimental effects that the wastewater effluent has on the coastal
environment. Council policy supports all measures to minimize discharge
into coastal water that may jeopardize this natural resource. (Future of
the Region, 2.701, 2.702, 3.101, 3.012, and 3.6.) The draft lists this
alternative aa the laast expensive option, considering that effluent dis-
charge is currently taking place in the majority of municipal treatment
plants.
A Gulf outfall extending from Clearwater Beach Island,
or the mainland north of Honeymoon Island:
Honeymoon Island
Extensive research and development on the Gulf outfall as a wastewater
discharge option was accomplished in detail, the installation of a 60-inch
discharge pipe 4 miles Northwestward of Honeymoon Island is extremely
expensive, has a high environmental impact potential, and can be a public
health hazard. The Gulf outfall alternative does not conform with Council
policies with regard to the coastal zone, and preservation of Class II
waters, marine grass beds, and Gulf and eatuarine beaches. (Future of the
Region, 2.791 and 3.601).
• Deep well injection at the Marshall St. Plant or south of the Study Area
possibly at the County's McKay Creek Wastewater Treatment Plan and
injection sites
Deep well injection has been tried on an experimental basis and results are
outlined in the EIS draft. This option is expensive but can be utilized as
a short term solution to the wastewater effluent problem. It Is likely
that pumping pressure will need to increase over time as wastewater is
pumped between two subsurface confining layers. This is an environmentally
suitable option as a back-up method especially during wet weather when
other disposal methods are not feasible.
Slow rate (spray Irrigation) or rapid rate I rapid
applicationi
infiltration) land
Slow rate (spray irrigation) or rapid rate (rapid infiltration) land appli-
cation as a means of effluent disposal is dependent upon acreage and soil
characteristics. Suitable land is necessary to accept the volume of
effluent without ponding runoff from the site or the contamination from the
effluent Itself. Secondary municipal effluents contain concentrations of
nutrients that are beneficial to plant growth and it enriches the soil.
Spray irrigation using effluent ideally recharges the aquifer and removes
some burden from the aquifer as a potable water source. This option is not
feasible, however, in wetlands or areas with poor drainage, or during wet
climate conditions, and is not recommended for the 201 study area.
• Wastewater reuse of nonpotable wastewater for irrigating recreational or
other open land areas and industial cooling and service water:
TBRPC-2.
Comment noted.
TBRPC-3.
Comment noted.
TBRPC-4.
Comment noted.
TBRPC-5.
Comment noted.
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TBRPC-6
Wastewatar reuia is the only management option that reipondi to Pinellas
County's surface water quality problems while considering water supply
limitations. This environmentally preferred method of wastewatec effluent
disposal IK outlined in the BIS for the Northern County araa specifically
for parks and golf courses. Reuse was not considered for individual homes,
businesses and subdivisions due to 'preliminary cost and available land
estimates". City of St. Petersburg individual property owners already have
access to treated wastewater if the owner pays a hook-up tee. With 25
percent of tha land in Northern Pinellas County used as residential,
serious consideration should be given to broadening the availability of
wastewatar effluent reuse. Potential benefits from wastewater reuse
includei
1. Water is reused for irrigation, including during drought conditions;
2. Water supply and aquifer demands are reduced;
3. Wastewater discharge to nearshore coastal waters are reduced;
4. Potential recharge of the aquifer; and
5. Wastewater effluent contains nutrients beneficial to plant growth and
as a soil additive.
TBRPC-7 I It is recommended that future wastewater effluent alternative evaluations
I explore the potential for commercial and private water reuse programs.
I Council policy section 3.103 states that wastewater renovation and non-
potable reuse programs should be implemented where practical.
Comments from Pinallas County Indicate that the specific recommendations
for each sub-area were based solely on Federal fundabllity and that there
2 were no recommendations for the East Lake Tarpon sub-area other than
limiting development. Further the attached letter states that no
consideration was given to the need for wet weather discharges. The EPA's
policy and regulations do not allow funding for development In the environ-
mentally sensitive areas east of Lake Tarpon. Construction grants will not
provide funding for future wastewater facilities in this area. Development
in this area will be dependent upon small wastewater package plants which
have a record for poor treatment, untrained staff, and little environmental
monitoring on effluents.
TBRPC-8 I The Council encourages EPA to find a viable solution to wastewater effluent
I east of Lake Tarpon area. In addition, based on the above, it Is
I recommended that the alternative of wastewater reuse, with deep well Injec-
tion as a back-up method in wet conditions, ultimately be approved.
TBRPC-9 I Further, it Is recommended that any additional comments addressing local
(concerns be considered prior to approval.
Committee ado/ted May.28,
—JOVA l/As**l~' AC
1985.
Acting Chairman
"KestwooA B. Fletcher, Jr., Chairman
Clearinghouse Review Committee
Please notet Unless otherwise notified, action by the Clearinghouse Review
Committee is final. Please append a copy to your application to indicate
compliance with clearinghouse requirements. The committee's comments con-
stitute compliance with Florida's Intergovernmental Coordination and Review
process only.
TBRPC-6.
nt noted.
TBRPC-7.
Comment noted.
TBRPC-8. The No Federal Action alternative has been identified as. the
EIS selected wastewater management alternative for the area east of
Lake Tarpon. Future planning and development decisions in this
area are the responsibility of local governing bodies. Reuse
comment noted.
TBRPC-9.
All comments received before July 26, 1985 are considered.
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OF* COUNTY
PINILLAI COUNTY SCWCR •YCTtM
3IO COURT STREET
CLCARWATCR. FLORIDA 33316
COMMISWONfnm
flftUCE TVNOALL. CMAIBMAN
CHARLES £ RAINEV.victCH«ip
JOHN CHESNUT. JR.
GEORGEGRECR
BARBARA SHEEN TODO
Hay 20, 1985
Ms. Ellen C. Cohen
IC&R Coordinator
Tampa Bay Regional Planning Council
9455 Koger Boulevard, Suite 219
St. Petersburg, Florida 33702
Re:
IC&R 197-85
Draft EIS, North Pinellaa County
Dear Ms. Cohen:
PCSS- 1 I The original purpose of this Environmental Impact Statement was to confirm the
I preferred alternatives for effluent disposal in the North Pinellas County 201
I Study Area. The factors to be considered were cost, environmental impacts,
operability considerations and implementability factors. The study area was
divided into a number of sub-areas. These sub-areas were chosen such that the
reoornnendatlons for effluent disposal could be generalized for that sub-area.
2 I it appears that the purpose of the EIS was not completely fulfilled since the
I specific recommendations for each sub-area were based solely on Federal
'3 I fundability. In addition, we are disappointed that there was no recommenda-
I tions for the East Lake Tarpon sub-area other than limiting development, and
that no consideration was given to the need for wet weather discharges.
oo
oo
PCSS
PCSS-
PCSS-
-*l
rcss-5 I It should also be pointed cut that the package treatment plants in the East
I Lake Tarpon sub-area are county owned and operated and not privately owned as
I stated in the report.
l'CSS-6 I It is unfortunate that the EIS offers no relief with respect to identifying an
environmentally preferred effluent disposal option that Is suitable for year
(round use. Pinellas County and the municipalities who operate wastewater
treatment facilities will suffer as a result of the failure of EPA to fulfill
the purpose and intent of the EIS.
Sincerely yours,
Todd L. Tanberg, P.E.
Director^of SeMDC-Syatgm
PCSS-l. The purpose of the EIS Is not to confirm the 701 Plan recom-
mendations but rather to develop and evaluate wastevatrr n.inagcr.iciii
alternatives leading to the selection ot the must cost effective
environmentally sound alternative.
PCSS-2. An Important element In selecting an KIM preferred alternativt
is Implementability. Funding sources and eligibility for EPA fund-
ing are key factors In determining ImplemenlabilIry.
PCSS-3. The No Federal Action alternative lias been identified as the
EIS selected wastewater nanagcment alternative for the area past ol
Lake Tarpon. Future planning and development decisions In this
area ate the responsibility of local governing bodies.
PCSS-4. The selection of wet weather discharges cannot occur until
approved waateload allocations are available.
PCSS-5. The EIS will be revised to show County ownership.
PCSS-6. Potential reuse back-ups have been identified as deep well
injection, Intermittent surface uacvr dischargf.s or Gulf outfall.
Additional Investigations and information Including approved
wasteload allocations .ire needed before an appiopiiate hark-up can
be selected.
TLT:nk
PINELLAS CCUNTY IS AN EQUAL OPPORTUNITY EMPLOYER
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MEMORANDUM
TOt Rosemarie Fallen, Dlv. Director, Planning
FROM: John HerrlcW, City Engineer
DATE: May 13, 198)
SUBJECT: Environmental Impact Statement Draft EIS
North Pinellaj County Wastewater Facilities
oo
The subject document discusses three wastewater disposal alternatives for the City of
Dunedin. This is to advise that we concur with two of these alternatives as follows:
I. Continue existing discharge to St. Joseph Sound, and
2. Distribution of reusable wastewater to parks, golf courses and other lands for
nonpotable uses.
The third alternative of a gulf outfall would be a viable alternative II Federal Funding was
provided.
The recommendation of reuse plus secondary treatment and filtration is preferred by the
City of Dunedin.
CD-I.
Comment noted.
CD-2.
Comment noted.
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CITY OF CLEAR WAT E R
POST OFFICE BOX 4748
CLEARWATER, FLORIDA 33518-4748
Mr. Robert B. Howard, Chief
NEPA Compliance Section
Environmental Protection Agency - Region IV
345 Court land St. N.E.
Atlanta, Georgia 30365
RE: North Pinellas County, Florida
Draft Environmental Impact Statement (EIS)
Review Comments
Dear Mr. Howard:
Following is a list of review comments for the North Pinellas County Draft
Environmental Impact Statement. We certainly appreciate this opportunity to
respond.
Prior to expressing the enumerated enclosed considerations I want to specifically
emphasize that the City of Clearwater's principal difficulty with the Draft EIS
is that, contrary to what we clearly believed to be a primary objective of the
report, no indication is offered as to what direction Clearwater might possibly
pursue with any degree of anticipated regulatory approval relative to the permitting
and funding of a permanent effluent disposal method.
Clearwater originally requested inclusion in the EIS study specifically for the
determination of a viable effluent disposal method and made request to EPA that
particular emphasis be given in the CIS study to the Gulf Outfall disposal method.
The Draft EIS clearly states that insufficient acreage is available for total
effluent land disposal and that EPA has previously rejected deepwell injection
for Clearwater. The remaining disposal options are only Gulf Outfall and local
surface water discharge. Of these two options, EPA is threatening legal action
against Clearwater for non-compliance of "zero discharge" determination to local
surface waters and EPA gives no indication that approval or funding could ever be
obtained for the Gulf Outfall.
Clearwater, therefore, finds itself in a dilemmu which the Draft EIS makes no
mention of. We strongly urge, therefore, that the EPA coordinate and fund the
Florida Dept. of Environmental Regulation Wasteload Allocation Study now being
prepared for local surface waters, and which is required by the EIS report.
We further request that approval of the Final EIS report await the results of the
above wasteload allocation study and that these results be included in the Final
EIS. This information should provide a firm basis for the EPA to make final
recommendation in the EIS for a workable effluent disposal method for the City of
Clearwater's sewage treatment plants. Anything short of a logical conclusion of
the EIS will render the study's large cost and many yeara of study totally useless.
CC-l. A wastewater management alternative csn not he sc-lected until
approved wastelond allocations are available lor old 'i ,imp,-> day and
Clearwater Hatbor - St. Joseph Sound.
CC-2. A Gulf outfall alternative was considered equally with other
effluent disposal alternatives.
CC-3. Wasteload allocation studies which are the responsibility of
the State of Florida die currt-ntly underway.
CC-4. Since conclusions can be made for several r.uharens within the
F.IS St'idy Arpn, a Final EIS will be published. Om:e approved
wasteload allocations are available for Old Tampa Bay and
Clearwater Harbor - St. Joseph Sound, conclusion.-, can be made for
the remaining subareas. U needed, au F1S oupplcn.ent incorporating
the wasteluad allocation results will be prepared.
Employment and Affirmativf Action limptoycr"
(continued)
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CC-5
CC-6
CC-7
Mr. Robert B. Howard, Chief
NEPA Compliance Section
EFA Agency - Region IV, Atlanta, Georgia
June 4, 1985
Pag* - 2 (continued)
Further specific comments follow:
1. No mention ia nade in thia report of the numerous private treatment
facilities throughout Pinellaa County which aerve condominiums, nobile
hone parka and aubdiviaiona. Soot of theae treatment facilitiea are
targe, for example: Curlew City, Top-of-the-World Condoaiinium and
Dynaflo. No proviaiona are stated for their future operation. As is
common with these type of facilitiea, their effluent outfall ia invariably
to the nearest drainage channel auch as the Dynaflo outfall to Curlew
Creek. Actions and recommendations contained in thia report should
address private faciltiea as well.
2. Figure ii shows NEPCF irrigating Top-of-the-World golf course. This
is already being done by the Top-of-the-World treatment facility.
13. No provision is made for the costs of future development capacity being
assessed to future system users by connection/impact fees. This method
will greatly lower the exiating uaer chargea in Table 5 with or without
,O the availability of federal funding.
CC-9 I 4. During the late 1970's, Clearwater was repeatedly told that the EIS
would identify the appropriate method for diacharge of the City'a
I effluent. This goal has still not been achieved, presumably because
waateload allocations for Pinellaa County surface watera have not yet
been developed and approved. We feel that the six yeara since the EIS
was initiated should have been more than aufficient for EPA and DER to
have coordinated and accomplished thia plus any other taak eaaential to
aatiafactory completion of the EIS.
5. On page vi, Safety Harbor is incorrectly identified as having a direct
discharge, when in fact, their raw wastewater is processed at the
Clearwater Northeaat plant.
6. Table iii on page xvii presents data on management alternativea for
the area east of Lake Tarpon, but does not include treatment of flows
from that area at the Clearwater Northeast plant (which is the method
finally recommended in the North Pinellas 201 Plan).
7. On page xx, waatewater reuse (for irrigation and other non-potable
purposes) is cited aa the preferred disposal alternative. That discussion
includes the statement that "the need for a w«t weather backup for waste-
water that cannot be reused is likely to exist". In our opinion, this
statement should be strengthened considerably by saying that the need for
a backup disposal method is essential. (Very amall facilitiea or other
unique situations may be an exception). A similar statement is made in
the next to last paragraph of page 92.
cc-io
CC-ll
CC- 12
CC-5. An Inventory of private treatment facilities was presented in
the Inventory Task Report.
CC-6. • The focus of the EIS was the development and evaluation of
wastewatcr disposal alternatives for municipal facilities In the
Study Area. The disposition of the email private fuHHticH (I.e.
hook-up to tlia municipal facilities 01 coulinueJ diacharge) Is a
local decision to be addressed through local wnstewater management
planning.
CC-7. The site was Indicated as a poosible ulte. This listing did
not Imply tliat the Owner agreed (a jccopt wawlewater eUluent lion.
the Clearwater Northeast unstcwstev treatment plant.
CC-8. The locnl government would be responsible for setting connec-
tion/impact fees.
CC-9. A waatewater management alternative can not be selected until
approved wasteload allocations are available Cor Clc-arwalei Harbor
St. Joseph Sound and Tampa Bay. The respnusilil lity fnv developing
wasteload allocations Is with Florida DHR. F.PA docs li.ive review
and approval aulliotity.
CC-10. Page vl will be revised to state that the City of Safety
Harbor is served by the Clearwater Northeast wasttwater treatment
plant.
CC-ll. After the completion of the 201 Plan, Pinellaa County and the
City of Oldsmar agteetl upon the area of east of lake- Tarpon which
will be served by Oldsmnr. If the remaining area oast of Lake
Tarpon is served by an existing treatment plant, cither Tarpon
Springs or Oldsmar would be selected because of the shorter
transmission distance and associated oists.
CC-12. Comment noted.
(continued)
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Mr. Robert B. Howard, Chief
NEPA Compliance Section
EPA Agency - Region IV, Atlanta, Georgia
June it, 1985
Page 3 (continued)
CC-l/i
IsJ
CC-15
<:c-lh
a:-17
CC-18
a:-19
cc-.'O
8. The last paragraph of page 7 provides a brief statement of the
complex regulatory situation involving Pinellas County surface
waters. Effluent discharge to some of these waters is restricted by
no less than three separate laws or rules as follows:
- a "no-discharge" wasteload allocation issued by DER in 1978.
- a designation of Outstanding Florida Waters (OFW) which has
been illogically set to coincide with a county boundary line.
a classification of Class II waters for shellfish harvesting
and propagation.
Despite the existence of these regulations, DER is currently conduct-
ing new wasteload allocation studies. The City of Clearwater agrees
with this approach, and firmly believes that decisions on effluent
discharges must be made strictly on the merits of water quality and
other technical factors, and not on the basis of arbitrarily established
regulations.
9. The second wastewater management finding on page 10 should state that
the City of Safety Harbor is already being served by the Clearwater
Northeast plant.
10. The last three management findings on page 11 are ancient history and
of no importance to today's situation.
11. The table of land irrigation system characteristics on page 1* implies
that underdrains are not needed for either slow or rapid rate systems.
At the application rates cited( and with the soils and groundwater table
conditions that typically prevail in Northern Pinellas County, underdrains
would be required more often than not.
12. The first paragraph of page IS provides an unqualified statement that a
backup method of disposal is necessary because of wet weather limitations
on land disposal. While this has always been a fact, both EPA and DER
have been reluctant to admit it in the past. It is noteworthy that a
more realistic view has now been taken.
13. On page IS, the McKay Creek plant is incorrectly identified aa being
in Largo.
14. On page 16, effluent from the Albert Whitted plant is incorrectly
indicated as being transferred to McKay Creek.
IS. On page 16, we do not understand the statement about "the system operat-
ing SO percent of the available time", aa a part of the description of
the difference between land application and water reuse. Clarification
would be appreciated.
CC-13. Comment noted.
CC-14. Page 10 will be revised to state that the City of Safety
Harbor Is served by the Clearwater Northeast plant.
CC-15. Comment noted.
CC-16. Additional site specific studies would be required before
implementation.
CC-17. Comment noted.
CC-18. Page 15 will be revised to reflect unincorporated area of
North Pinellas County.
CC-19. Page 16 will be revised to reflect the Albert Whlttcd plnnt Is
proposing two 10-Inch JianieLiM Injection wells tor effluent
dispOFd1.
CC-20. The land would be idle M) percent of the time.
(continued)
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Mr. Robert B. Howard, Chief
NEPA Compliance Section
EPA Agency - Region IV, Atlanta, Georgia
June It, 1985
Page - 4 (continued)
CC-21 I 16. In Table 1 starting on page 20, there is no explanation of the many
missing numerical designations of disposal alternativea, or why
I these alternatives were eliminated from further consideration.
CC-22 17. On page 25, clarification is needed with regard to the statement that
"Sewers from the area east of Lake Tarpon connected to any treatment
plant other than either the Oldsmar or the Tarpon Spring* WWTP would be
costly or result in operational concerns". This and following statements
are contrary to a concluaion of the 201 Plan (which suggests treatment
at Clearwater Northeast) without explaining why.
18. On page 26 and 27, it is stated that the cost figures are based on
1980 values and that facility construction is/was astuned to take
place in 1984. These costs are outdated.
CC-24 I 19. In Table 5 on page 34, it is unclear why the user charge estimates are
| so much higher for Northeaat than for the other two Clearwater plants.
CC-25 I 20. It is suggested that Table 5 contain a statement to the effect that
| the cost* are outdated.
21. Page 36 contains a statement about a Gulf outfall which expresses the
concern of "questionable acceptance by the public or any regulatory
agency, in light of the uncertain likelihood that discharged effluent
CC-26 would adversely affect barrier island beaches". The statement is both
ambiguous and unnecessarily inflammatory. In addition, it contradicts
many other comments in the report which conclude that the effluent would
not be expected to reach the beaches, and that pollutant concentrations
would probably be indistinguishable from background levels even if it did.
CC-27 22. Table 6 and Figure I indicate that the Clearwater Cast WHIP could or should
supply affluent for irrigation to the Cove Cay Coif Club and the St. Petersburg/
Clearwater Airport. Both of these properties are located well to the south
of Clearwater within the service area of the City of Largo. While Cove Csy
i* about equidistant from the two treatment plant*, the airport i* immediately
east of the Largo facility and just north of other properties already receiv-
ing their effluent. In any event, the airport ha* already indicated that
they do not wish to utilise effluent for this purpose.
CC-28 I 23. On page 44, reference i* made to the discharge from the Safety Harbor plant
I which haa been abandoned for several years.
CC-29 I 24. On page 54, statistic* on commercial fishing are cited from 1976. Since
| this is of no pertinence today, the figures should be updated or deleted.
The economics and employment statistic* quoted on page 59 ire too old
(1977 to 1980) to be of any interest at this time.
CC-21.
CC-22.
CC-23.
CC-24.
CC-25.
CC-26.
CC-27.
CC-28.
CC-29.
CC-30.
CC-30
r
The number designations were presented In the Alternative*
Development Task Report. The reasons for eliminating net tain
alternatives from further consideration were presented In the
Alternatives Development and Evaluation Took Reports.
After the completion of the 201 Plan, Plnellas County and
Oldsmar agreed upon the area east of Lake Tnrpon which will be
served by Oldsmar. If the remaining area of Lake Tnrpon is nerved
by an existing treatment plant, either larpon Springs oe 01
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Mr. Robert B. Howard, Chief
NEPA Compliance Section
EPA Agency - Region IV, Atlanta, Georgia
June 4, 1985
Page - 5 (continued)
26. Table 11 on page 76 includes this statement about Gulf outfalls.
"As a vastewater plume would rise, dilution would allow water quality
criteria for all waatewater constituents except phosphorus to be met
within SO feet of an outfall." It should be noted that if phosphorus
is of real concern, that levels in Che effluent could be readily reduced
prior to discharge.
27. On page 78 and 79, information on the predicted dilution of effluents
from a Gulf outfall is provided. However, this analysis is apparently
based on discharge into IS feet of water, whereas about 30 feet of water
actually exists at the locations which night be considered for discharge.
The use of 30 rather than IS feet would result in a considerably higher
degree of initial dilution.
28. In footnote (1) of Table 12, the cited concentrations of total and fecal
coliforms are much higher than should be considered typical of properly
disinfected secondary effluents.
CC-J5 I 29. On page 93, the tern "fundable" alternative needs to be defined.
30. Page 96 states that a Gulf outfall would provide-the area with a reliable
long-term disposal option. He feel that reliable long-term disposal of
some sort is absolutely essential to the area, that land application
schemes do not fulfill that need, and that injection wells may not either.
Therefore, if outfall discharges to near-shore waters such as Old Tampa
Bay, St. Joseph Sound and Clearwater Harbor are prohibited, a Gulf outfall
would be the only alternative capable of providing that necessity..
31. Page 96 also states that an investment in a Gulf outfall would tend to
I discourage effluent reuse. We do not necessarily agree and feel that a
committment to effluent reuse could be worked out during the various
permitting processes.
32. Page 96 also states that a Gulf outfall could promote higher density
development, and development in environmentally sensitive areas which
I are not suitable for on-lot or recycle wastewater management. We feel
that growth should be (and usually is) managed by zoning, land use and
other factors which have nothing to do with wastewater handling.
33. Page 96 also states that uae of a Gulf outfall would require secondary
treatment and disinfection of wastewater to mininize adverse impacts on
CC-40 I local beaches. Since this level of treatment is required for any discharge,
I we do not understand the point being made here. In any event, we feel that
CC-41 I the secondary effluent should also be filtered prior to use of a Gulf
I outfall as an added safety factor.
(continued)
CO jfi
VO
CC-31. Additional treatment could be Included to remove phosphorous
or other wastewater constituents. This additional treatment would
result in additional costs.
CC-32. Fifteen feet was selected to demonstrate the results of
mathematical simulations to determine probable dilution rates.
CC-33. The use of 30 feet would likely result in a higher degree of
Initial dilution.
CC-34. Comment noted.
CC-35. The funjable alternative la the most cost effective,
environmentally sound disposal alternative that would ho cllgiblr
to receive EPA construction grant funds.
CC-36. Comment noted.
CC-37. Comment noted.
CC-38. There would be little incentive to invest in a major reuse
alternative If investment was made in a Culf outfiill alternative.
CC-39. EPA agrees that zoning, land use and ott.er similar activities
are local governing bodies responsibilities, iiowcver, the
availability of wastewatel handling can certainly remove a develop-
ment constraint.
CC-40. The purpose Is to define the level of treatment.
CC-41. Filtration has been considered and could possibly be provided
if a Cull outfnll is recommended once approved wasteload
nllocatlons are available.
-------
Mr. Robert B. Howard, Chief
NEPA Compliance Section
EPA Agency - Region IV, Atlanta, Georgia
June 4, 1985
Page - 6 (continued)
34. Although the EIS states that Gulf outfall station 3F (4 nilea west
of Honeymoon Iiland) wai found to be leǤ environmentally icnaitive
than site* closer to shore, we could not locate clearcut supporting
evidence for this conclusion either in the EIS or in the report* on
sampling and dye movement prepared by Mote Marine Laboratory.
35. The next to last paragraph on page 43 relative to the average dissolved
oxygen of "more than 7.0 .ngl" in Old Tanpa Bay is somewhat misleading
inasmuch as bottom samples in that same area may be near xero.
We appreciate the opportunity to respond to the report and hope that you will
closely examine our poaition in this nose important matter.
copies: E. S. Haeseker, Asit. City Manager
F. J. Janocha, Water Pollution Control
William C. Baker, Director of Public Work*
John Dennis, Briley, Wild and Aisoc.
CC-42. The statement was made based on bottom habitat, the presence
of hard bottoms and current data which were presented in the Marine
Sampling Program repotts.
CC-41. The statement was not written to mean that all samples show
dissolved oxygen values of more than 7.0 mgl.
-------
UNITED STATES DEPARTMENT OF COMMERCE
Nation*! OcMitle end Atmo*ph«ri« AdminiMrrtlan
NATIONAL MARINE FISHERIES SERVICE
Southeast Regional Office
9450 Koger Boulevard
St. Petersburg, Fl. 33702
June 7, 1985
F/Sr.RI I.VWMT
904-214-5061
wirs-i
Mr. Jack K;ivan
U.S. (:.PA - Region IV
3.15 Court land St. , N.E.
Atlanta, C,;i. SOJhS
Dear Mr. Rnvnn:
The National Marine Fisheries Service has reviewed the Draft Environmental
Impact Statement for North Pinellas County, Florida regarding the proposed
wastewatcr management facilities for northern Pinellas County, Florida.
Our preferred alternatives for disposal of treated wastewater are:
deep well injection, land application and water reuse, and on-lot systems
with assurances of proper installation and operation. Outfall(s) to the
Gulf of Mexico would be acceptable providing the effluent is adequately
treated to avoid any degradation of the receiving waterbody.
We appreciate the opportunity to provide these comments. If you
have any questions, please contact Mr. Mark Thompson of our Panama City,
Florida Area Office at 904-234-5061.
Sincerely yours,
NMFS-1.
Comments noted.
Richard •). Moogland
Chief, F.nvironmental Assessment Branch
.. iV
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SOUTHWEST FLORIDA WATER MAN AGEMENT DISTRICT
2379 BROAD STREET. BHOOKSVILLE. FLORIDA 33SI297I2
PHONE (904) 796-7211 SONCOM 684-0111
BRUCE A. SAMION CA*rff*«i. Ttnvf Mm 0 STU8BS. JR Via O*n»»>. OtOf City
MARY A KUMPE. bcrrrm. S»«tM RONALD I LAMSE H t tnwn*. HvjtXvil
DONALD R CRANE If . Annum Sxrrrov Si 'imtvf MICHAEL ZAGOUAC JH . /Iniuni TUMani.
WALTER H MARKAIA. «*ii Orx IACK STHAUCHN. H'nlft Hntn JAMES P TAFT. Crylfj' «
-------
Mr. Robert Howard
June 11, 1985
SKWMD-4
SI WMII-'I
well construction problems or inadequate confinement, effluent is leaking to the
overlying aquifer. McKay Creek and South Cross Bayou are inoperative at present
and testing is scheduled to determine if these facilites are leaking. In addition, the
Albert Whit ted WWTP is proposing to construct two 30 inch diameter injection wells
for the purpose of effluent disposal.
Tables Z and 3 (pages 30, 31) illustrate the present worth cost summary for the Old
Tampa Bay Sub-area and the Clearwater Harbor/St. Joseph Sound Sub-area.
However, due to the extensive monitoring which may be required, both onsite and
offsite to monitor any adverse impact* on wellfields and surrounding water
resources, by regulatory agencies, these tables may not reflect true total costs.
The staff comments stated above have not been presented to the District Governing
Board. This review does not stand in lieu of normal permitting procedures, nor does it
necessarily represent the position or opinion of the Governing Board.
Thank you for this opportunity to comment. If I may be of further assistance, please feel
free to contact me.
Sincerely,
SWFMD-4.
Page 15 will be updated fo reflect current information.
SWFMD-5.
Comment noted.
PHILLIP W. WALDRON
Planner
Planning Section
00
PWWipam
-------
DEPARTMENT OF HEALTH 4 HUMAN SERVICES
Public
Centtrt for D'UJM
AilinnGA 30333
June 14, 1985
VO
USPMS-I
USIMIS-2
...iiC.
Mr. Robert B. Howard " . JM** • '
Chief, NEPA Compliance Section
Environmental Protection Ap«"-'.
345 Court land Street, N.E.
Atlanta, Georgia 30365
Dear Mr. Howard:
We have reviewed the Draft Environmental Impact Statement (EIS) for Waatewater
Facllitiea, North Pinellaa County, Florida. We are responding on behalf of the
U.S. Public Health Service and are offering the following comments for your
conaideration in preparing the Final EIS.
The Draft EIS, aa presently written, ii a preliminary report which doea not
present » preferred alternative due to the lack of approved waateload alloca-
tions for moit of Pinellaa County's surface waters. He agree that prudent
waatewater management decisions must wait for the issuance of wasteload
allocations and that to recommend an alternative now would riak noncompllance
with future regulatory guidelines. Clearly, we also cannot comment on
allocation-dependent issues/alternatives until such allocations are established.
Therefore, we isuat reaerve our Agency's comments until we receive the necessary
information delineating both the wasteload allocation* and the preferred manage-
ment alternative. He truat this information can be provided soon.
He can comment at this time, however, on the aervice areas whose waatewater
management alternativea are basically independent of wasteload allocations.
The environmentally preferred alternative for sewered areas of North Pinellaa
County has been identified as reuse of wastewater for non-potable applications.
There should be minimal environmental or public health impacts reaulting from
the implementation of thia alternative provided that waatewattrs are adequately
treated (treatment dictated by intended application) prior to reuse. The chosen
alternative for the area east of Lake Tarpon is to not provide funding for
wastewater facilities In order to discourage development in this environmentally
sensitive area. Existing waatewater management methods around Lake Tarpon
include aeptic tanks with absorption fields and private package plants facilitat-
ing land application aitea. The deciaion to "administratively" discourage
future development in thia sensitive area is commendable; however, improper
location and/or mismanagement of individual on-site and small land application
processes could result in severe environmental and public health impacts.
Considering that future development east of Lake Tarpon will rely excluaively
on such systems, the Final EIS should address the potential for adverse environ-
mental and public health impacts related to continued growth in this area.
USPHS-1.
Comment noted.
tlSPHS-2.
USPHS-3.
Comment noted.
If wastewntur management activities continue in the future- as
they have in tlii past. 7.PA docs not expect i potential for
environmental and public health impacts whicli .lie related to
growth.
-------
Page 2 - Hr. Robert B. Howard
O
O
As suggested by the Draft EIS, the Gulf outfall alternative requires further
study. Public health and environmental impacts of thia proposal are not
easily addressed in general terms, especially becauae complex water movements
make predictions of impacts on Gulf beaches very uncertain. Public health
impacts are further complicated by the implications of researchers currently
reviewing marine water quality. Recent studies have suggested that wastewater
outfalls near marine recreational areas nay be associated with significant
health risks to bathers. Furthermore, indicator organisms other than the
traditional coliforms may be necessary to accurately quantify the degree of
exposure. Therefore, we feel that any comments on the environmental and public
health significance of a Gulf outfall would be inappropriate without specific
site information (e.g. modeling studies, construction details, background
sampling data, etc.).
We appreciate the opportunity to review the Draft EIS and would like to
receive a copy of the supplemental information concerning waateload allocations
and the preferred management alternative, •• well a* a copy of the Final EIS,
when these materials become available. If you have any question! regarding
our comments, pleaae contact Hr. Bob Williams, P.E., of our staff at 432-4161.
Sincerely yours,
Stephen Hargolis, Ph.D.
Chief, Environmental Affairs Group
Center for Environmental Health
USPHS-4. As indicated in the Draft F.IS, additlor.nl site sprcliK
analyses ai;d (jtimit/aJminlstrnHvp review end approval wt.uld be
needed if a Uulf outfall alternative wtre to rcd-lve further
consideration.
-------
6-15-85 -k>ti
S.O.L.I.D. ' ' ' .'V^J
Mr. Rafcert B. H*war4
Chiaf ' .
Napa Cemplianae Seo. .
I.P.A. R*(i*n 4
345 Caartland St. N.J.
Atlanta. Oa. 30365
Dear Sin
Thank y*a f »r the *pp*rtiuiity t* b* *n racard that "Sara Otr Uk*
sol in-1 |lnTit« Diaoaaelen" with 145 »ai4 B*»**ra ar* acalnat th* eatfall to
|th* fulf, far wast* water traatnaut.
sol 111-2 I Th* ii«°»*»l»n r*|ar41nt and th* argaacnt far th* r*-uae *f vatar
| far Pinallai Caunty la an *»*ll*nt an*. It la tin* Plnallaa Caunty la
ma4* ta lira within th* r**Ia *f o*nal4aratl*n far th* •nriranmant. Th*
•san* on Laka Taryan far thr** daya tola aanth 414 nat (*t nawa e*r*raf*
•r waa any Pinallaa Caanty warnlnc iaaa*d far health and walfar* e*na*m
far th* aapilatlan *f th* area.
T* (rant than thia aatfall raqaaat w*«14 **pvOata tha Caanty *r*n
o*r* *ino* thara w*«14 a* n* iladtinf faatar.
£ iaat Rnaraa
SOLID-1. Comment noted.
SOLIU-2. Comment noted.
Marfant 0. Fa«c«tt, 9*o.
•lav* 0«r Uk* Inrlt* Ola«aaai*n<
1820 Rlahar* Irrin Farkway
Tary*n Jpringa, Via. 33589
CCi 0*T*rn*r •*• Orahaa
-------
8uneo*>l
Olrl •eout Council. Inc.
3711 Walroul »v«nu«
Timpl. Florid! 33629
June 18, 1985
Ronald J. Mikulak, Project Officer
Environmental Assessment Branch
EPA, Region IV
3«5 Courtland Street, N.E.
Atlanta, GA 30365
Re:
North Plnellas County, Florida, Draft Environmental Impact
Statement For Proposed Wastewater Facilities
Dear Mr. Mikulak:
Suncoast Girl Scout Council, Inc. is strongly opposed to Gulf
outfall as a system for effluent disposal, as recommended in the
draft of the North Pinellas County Environmental Impact Statement
For Proposed Wastewater Facilities. We feel that such a method
of effluent disposal is potentially hazardous to the health and
welfare of girls and adults using Girl Scout Camp Wai Lani, which
is located in Palm Harbor and situated on the Gulf of Mexico.
We realize that spray irrigation is the primary method of
effluent disposal recommended by the 201 Plan and contained in
the draft of the Environmental Impact Statement presented
Tuesday, June 11, 1985 at the Public Hearing at the Pinellas
County Courthouse, Clearwater, Florida. However, the
recommendation of Gulf outfall as the backup method for effluent
disposal from the North Pinellas County Plant, located just east
of Girl Scout Camp Wai lani , and from the Tarpon Springs Plant,
located to the north of Wai Lani is totally unacceptable to
Suncoast Girl Scout Council, Inc. We urge that you consider
percolation ponds as a backup method of effluent disposal, as you
have recommended for the Oldsmar Plant, or other methods of
wastewater disposal more beneficial to the environment and more
acceptable to the public.
SGSC-I.
A Gulf outfall alternative w.is evalinted :><: ,n wnntfw.itcr
disposal option an were sevia.i! oilier alternative!,. The c.ili
outfall alternative Is not voruiuincudcd .IK the env I rimn.'in > I ly
preferred E1S alternative. Costs ?nd en« lronmunt.il st.iti>m"nts
concerning a Gulf outfall are, however, presented.
SCSC-3.
A Gulf outfall, tc ueivc as a b.icV-up method for effluent dis-
posal In not recommended in the fir-.ft KIS. Tlie termium-mlo!
alternative for latin.n upriuga i:. c!I:;crnrp.r to chi/ Auclutr River.
Percolation pon.-ls arc not recommended :»•-• T hack-up In the
EIS. Potential back-tips for Hie env irontnenLal ly preferred
alternative ol w.-istewater reuse include deep well Injection,
intermittent surlnce v»ter ciischiirge or ;i Culf outf.iH.
T.l.phon. Hllltborough (8131 253-0691. Pm«IIM (813) 442.7104
Swing H.rn«ndo. HilltDorouglt. Pnco ltd PimllM CouMlM
-------
Ronald J. Mikulak
June 18, 1985
Page two
SCSC-4
Suncoast Girl Scout Council, Inc. has a membership representing
approximately 15,000 families In the Tampa Bay area. In the
early 1970's, the Council took a position opposing the disposal
of effluent through a Gulf outfall system. We continue to uphold
that position. We strongly urge you to reconsider the 201 Plan
recommendation that a Gulf outfall system be used as the backup
method for effluent disposal from the North Plnellas County and
Tarpon Springs Plants and to develop, before the final proposal
Is published, alternative methods for effluent disposal at these
locations.
Yours sincerely,
SCSC-4. Alternative methods for vastewnter disposal have been
developed. A Gulf outfall disposal alternative is not tecomnended
for either Tarpon Springs or the North Pine)Ins County vnotcwutcr
treatment plants.
Patricia H. Allison
Executive Director
djt
O
UJ
Suncoasl Girl Scout Council. Inc.
3711 Watrous Avenue. Tampa. Fiorldi 33629
-------
UNITED STATES DEPARTMENT OF COMMERCE
National Oceanic and Atmospheric Administration
W.isti.M it-"' 'i r, ."',' \<»
June 19, I 985
: '
Mr. Robert B. Howord
Chief, NEPA Compliance Section
Environmental Protection Agency
Region IV
3*5 Courtland Street
Atlanta, Georgia 30365
Dear Mr. Howard:
Enclosed are additional comments from the National Oceanic and Atmospheric
Administration for the North Pinella County, Florida Wastewater Project. Comments
from the Southeast National Marine Fisheries Region were sent to you earlier.
We hope our comments will assist you.
Sincerely,
Oavid Cottinghom
Ecology and Conservation Division
Enclosure
-------
UNITED STATES DEPARTMENT OF COMMERCE
National Oeiinlo and Atmotphtrle Administration
NATIONAL OCEAN SERVICE ^*'
• i.h.ngnn. DC ?0?]
-------
City of Oldsmar
June 24, 1985
co-i
Mr. Ronald J. Kikulak, Project Officer
Environmental Assessment Branch
U.S. EPA - Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Reference: Comments on North Pinellas County
Environmental Impact Statement.
Dear Mr. Mikulak:
The City of Oldsmar has been working diligently for years to develop
an environmentally sound plan for wastewater management which would
serve the City's needs through the foreseeable future. We have
participated to the fullest extent possible in the preparation of
the Pinellas County 201 Study and supported the study until its last
minute change by certain parties which did not seem to have the best
interests of the City of Oldsmar in mind. Although the City has had
problems with their present wastewater treatment plant for several
years, it has restrained itself in proceeding with necessary
modifications to the facility, awaiting the outcome of the Environ-
mental Impact Statement in order that the City did not proceed down
the wrong avenue and be forced at a later date to revise or reverse
its plan with the subsequent waste of funds which the city can ill
afford.
The City and the surrounding area is presently experiencing unpre-
cedented growth and the forecast is that this growth will continue,
not only here but across the whole state for the next several years.
'The present population within the Oldsmar service area and the East
Lake service area, to which we are expected to provide service, is
significantly in excess of that projected in the Pinellas County 201
Study.
The City is constantly approached by adjacent land owners wishing to
annex their property into the City of Oldsmar. If we accept these
properties into the City, we must be in a position to provide all
municipal services, including wastewater treatment and disposal. We
are unable to formulate plans for accomplishing this as long as the issue
of wastewater treatment and disposal is not resolved.
CO-1.
Comment noted.
COUNCIL -MAMAl.il• H •!•-<
O. BOX I'll) OULXjWAH. ILOFIirM .
-------
Ronald J. Mikulak, Project Officer
Environmental Assessment Branch
N. Pinellas County EIS
June 24, 1985
Page Two
We attended the draft EIS presentation meeting on June 11, 1985,
confident that at last we were going to receive some guidance
from EPA regarding the service area we would be committed to serve
and a recommended plan for effluent disposal which would allow us
to proceed with resolving our current problems and provide direction
for planning for our future wastewater needs. Unfortunately, that
was not to be, and we left the meeting knowing little more than when
we entered.
We have since reviewed the draft of the referenced document and would
like to offer the following comments on behalf of the City of Oldsmar.
O
-j
CD-2
The draft EIS provides absolutely no guidelines or recommendations
for the City of Oldsmar. This is predicated on a statement on page
91 which says that the EPA will not recommend wastewater management
alternatives for areas contiguous to waters which have not yet had an
approved wasteload allocation study completed. This is because EPA
does not want to recommend alternatives which may later not be in
accord with these allocations. We certainly understand this position
because we have been in that same position for several years, however,
please realize that the lack of a plan for effluent disposal approved
by FDER and EPA completely precludes our receiving any grant funding
for correcting our existing problems.
It is our understanding that a draft version of the wasteload allocation
study has been completed and that it will effectively preclude Oldsmar
discharging into Upper Old Tampa Bay, including Mobbly Bay. The
statements in the last paragraph of page 7 of the Draft EIS regarding
denial of NPDES permits for facilities which discharge into Class II
waters and which have also been classified as "Outstanding Florida
Waters" would certainly apply to the Bay waters adjacent to Oldsmar. It,
therefore, seems to be a rather shallow decision on EPA's part to
avoid providing recommendations for the City of Oldsmar while waiting
on the final version of a study which has a 99.91 chance of denying any
discharge from the City of Oldsmar WWTP into the Bay.
To compound our concern, we are presently faced with a moratorium on
connections to our existing wastewater treatment facility requiring
Florida Department of Environmental Regulation's approval because of
problems with our existing effluent disposal facilities. We withheld
taking action to upgrade our existing facility and correcting our
effluent disposal problems for several years waiting upon the completion
of EPA and DER studies and we are now at the point where we have to do
something now or shut down our City.
I We are, therefore, requesting that EPA immediately confer with the
Florida Department of Environmental Regulation to resolve the wasteload
allocation question and then provide the City with recommendations for
CO-2.
Coranent noted.
CO-3.
F.FA has reviuwpd the Drift WasteUnid Allocation Report for
Tampa Bay and provided comments to Florida DI.K. Kr"A uill continue
to work w)tl> r»KR inuil the r 111.1! W/i.ste Allocation Report )s
submitted to and approved by KM.
-------
Ronald J. Mikulak, Project Officer
Environmental Assessment Branch
N. Pinellas County EIS
June 24, 1985
Page Three
our wastewater management problem. If you will contact Mr. Steve
Palmer, with FDER in Tallahassee, he will confirm our statements
regarding the wasteload allocation matter.
We have worked patiently with the regulatory agencies for years
waiting for direction and we have completely run out of time.
We need direction immediately and will appreciate everything EPA
can do to expedite providing such direction.
Sincerely ,
*
GRACE F. WILLIAMS, MAYOR
CITY OF OLDSMAR, FLORIDA
GFW/cdm
O
00
-------
United States Department of the Interior
OFFICE OF ENVIRONMENTAL PROJECT REVIEW
SoulhriM Rrgiun / Suite 1360
Richinl B Rmicll FrJrril Buildini
75 Sprni) Sltrn. S.W. / Acldiili. Oi JOJ03
Telrphimc 404/221-4524 . F1S 242-4524
m i 4 1985
noi-2
1)01-1
DOI-4
D01-5
DOI-6
ER-85/656
Mr. Jack E. Ravan
Regional Administrator
Environmental Protection Agency
345 Courtland Street, NE
Atlanta, Georgia 3036S
Dear Mr. Ravan:
The Department of the Interior has reviewed the draft environmental
Impact statement (EIS) for Wastewater Facilities, North Plnellas
County, Florida, and has the following comments.
Known mineral resources In the project area Include limestone, marl,
shell, clay, and sand and gravel. In the past, limestone and sand and
gravel have been produced. Local clay appears suitable for use as a
light-weight aggregate and may have possible uses as fuller's earth.
Owing to non site-specific information In the DES, It Is difficult to
assess impacts on mineral resources in the area. Still, because of
the Increasingly urban nature of the project area and the Inherent
restrictions that have already been placed on mineral development, the
Impact on mineral resources near the proposed project would probably
be minimal. For completeness, however, subsequent versions of the DES
should describe mineral resources In the area and provide a statement
regarding Impacts, If any, that would occur as a result of project
I Implementation. If no significant Impacts are anticipated, then a
statement to that effect should be Included.
I The Fish and Wildlife Service supports effluent disposal methods which
I eliminate discharges into estuarine habitat. The FWS agrees with your
I assessment that wastewater reuse would be the environmentally
preferred disposal alternative. Other acceptable disposal methods
i Include deep-well Injection and spray Irrigation.
(The statement should evaluate the effects of Increased export of
ground water under the Gulf outfall alternative. He suggest that
(monitoring during deep-well Injection should Include continuous
recording of pressures and Injection rates for each Injection well.
DOl-l.
No significant impacts arc put frlp.itod.
DOI-?. Comment noted.
DOI-3. Comment noted.
DOI-4. Comment noted.
UOI-5. The "export" of groundwater from the Study Area Is not United
to the Gulf outtall alternative, but is common to .ill surface water
discharge alternatives. Surface watet discharge in the current
disposal practice for all but two discharges. A Gulf outfall
alternative shuuld, therefore, not be expected to significantly
Increase the level of "export" of groundwater beyond current levels.
DOI-ft.
Comment noted.
-------
Monitoring pressures and injection rates will aid in early detection
of accidental hydraulic fracturing, formation plugging, or breaks in
the casing or injection piping.
Thank you for this opportunity to comment on this document.
Sincerely yours,
'James H. Lee
Regional Environmental Officer
o
-------
U.S. Department e uvnilahle until
the miiidlp <-f 11)86.
-------
B. Water Conservation:
1)011-2
mm-3
IXMI-4
On page XXIV, the EIS draft appropriately encourages water
conservation and Indicates that, "local plumbing codes may require
revisions." It Is recommended that those words be deleted unless It Is
known specifically that that code would require revision. Many local
plumbing codes seem to allow additional water conservation devices. It
would be desirable If a sentence were added Indicating that a county
ordinance Is all that would be necessary for this very Important low
cost/benefit concept. It Is further recommended that this page refer to
possible energy savings possible from reduced dally consumption of hot
water. A smaller utility and electrical monthly bill over the mortgage
period Is highly favored In HUD housing since such savings easily off-set
any relatively small Initial costs. Maintaining a non-excessive water
pressure (20 ps1 at the tap) should be emphasized on this page as a
recommendation for water conservation equal to other water conservation
measures listed.
It Is hoped that these comments are helpful during this EIS comment
period.
\S1ncere1y, .
\ ,.- \
'- »<{.£ Kd'/l
Ivar 0. tverson
Regional Environmental Officer
DOH-2.
It is suggested that local plumbing codes are T"ieweci to
ensure thai water conservation requirements are conslsrent.
DOH-3. Page 19 of the Draft EIS refers to tlie 1983 state law.
DOH-4. Energy savings ware addressee' In the Alternatives Pcvelopment
Task Report.
-------
i HI OHAHAM
0$fftcp of tljc (iolieruor
IN, OntOt
TALLAHASSCI 1IJOI
July 25. 1985
STATE OF *o«c* | <^ i fl|jsA, j FLORIDA DEPARTMENT OF AGRICULTURE & CONSUMER SERVICES
rone cow** coMmsoNm * 3<» CONNER BLVD. TAUAHASMC snot Division of Forestry
May 10, 1985
Mr. Ronald J. Mikulak
Project Officer
Environmental Assessment Branch
U.S. EPA - Region IV
345 Courtland Street, NE
Atlanta, Georgia 30365
Dear Mr. Mikulakt
This Office has submitted your agency's Draft Environmental
Impact Statement, North Pinellas.County, Florida Wastewater
Facilities to state agencies for review and evaluation.
Attached are comments from the Departments of Agriculture
and Consumer Services, Community Affairs, Natural Resources,
and State. We request that you consider their comments
when preparing your final document for this project.
Sin
WOK/jkc
Attachments
Walter 0. Kolb
Sr. Governmental Analyst
<4r. Halter Kolb
Office of Planning and Budgeting
Office of the Governor
The Capitol
Tallahassee, Florida 32301
Dear Walt:
We have reviewed the EIS referral transmitted In your letter
of April 25, 1985 on 3AI Project »FL 8504231134E, North Pi.iellaa
County Florida Wastewater Facilities, and arc a.lvisinft you that
the Division of Forestry has no adverse comment.
If we can be of further assistance, please give us a call.
Sincerely yours.
George L. Relnert
Chief, FREF Bureau
A88-6591
An Affirmative Aclion'Equal Opportunity Employer
-------
STATE OF FLORIDA
DEPARTMENT OF
COMMUNITY AFFAIRS
DIVISION OF RESOURCE PLANNING AND MANAGEMENT
BOB GRAHAM
MEMORANDUM
JOHN M DcOROVE
Walter Kolb
Paul Darst
TO:
FROM:
SIIR.JFCT: Fl. 85042311 34E, North Pinellas
Iv'astewater facilities
DATE:
2 May 1985
We have reviewed 'he referenced document and have
no comment on it.
BUREAU OF LAND AND WATER MANAGEMENT
i EXECUTIVE CENTER URI.LE. EAST • TALLAHASSEE. FIDRIDA nw\ • <9W488-4925
State of Florida
DEPARTMENT OF NATURAL RESOURCES
OR ELTON I GISSFSIMNMR
E \ecunte Director
Minorx Sloncmin Dn.iilax Bmliiinf
WtOCummnnwfilth rl->ukiiird. lallj
BOB GRAHAM
GEORGE FIRESTONE
Snnan nl Suit
JIM SMITH
Attnrnrv G«n«t«l
GERALD A. LEWIS
C..mplit>U.r
BILLUUNTER
Trvuur.r
DOYI.E CONNER
CnmmiMioncr of Afncultur*
RALPH D. TURLINGTON
Commtttlcnvr nt Education
June 10, 1985
TOi Halt Kolb, Senior Governmental Analyst
Office of Planning and Budgeting
FROM< Dale Adams
Executive Staff Directo
SUBJECT! Draft BIS for North PineMas County
wastewater Facilities FL8504231134C
Attached are comments on the referenced Eis, as provided
by Frank Courtney of the Bureau of Marine Research. It
should be clearly noted that from the shellfish sanita-
tion perspective elimination of discharge is the best
alternative.
DA/am
DIVISIONS / ADMI!
STATfc I.ANRS
-------
State of Florida
Department of Natural Resources^
Interoffice Memorandum
DATE : May 20, 1985
TO : Dale Adams, Administrative Assistant
Division of Resource Management
FROM : Frank Courtney y£
Pinellas County Revegetation Coordinator
Bureau of Marine Research
SUBJECT : Review EIS - FL 8504231134E
North Pinellas County Wastewater Facilities
Enclosed please find my review on the above report.
Let me know if you need additional information.
FXCrmaw
Enclosure
cc: Charles F. Futch
David C. Heil
Karen A. Steidinger
Alan Huff
Frank Courtney
REVIEW EIS - FL 8504231134 E
North Pinellas County Mastowater Facilitjes
The EPA Draft EIS report for Wastewater Treatment-Disposal
Options for northern Pinellas County evaluated five basic waste-
water disposal options; discharge to nearshore coastal waters,
Gulf outfall, land application, deep-well injection and wastewater
reuse.
Discharge to coastal waters is the wastowater disposal option
currently utilized by the Cities of Clearwatcr (East, Marshall St.,
and Northeast Plants), Dunedin and Tarpon Springs. This method is
the "least cost" alternative and results in the greatest degree of
environmental damage due to continued degradion of water quality,
losses of elements of the estuarine food chain and fisheries habitat
declines in commercial and recreational fisheries yield including
areas of shellfish harvesting, and restrictions to recreational
contact.
The waters of Pinellas County are currently classified as
Outstanding Florida Waters, the majority of which are Class II and
as such the discharge of sewage effluent is not permitted. However,
the "No Discharge" wasteload allocation established by DER hast
yet not been enforced.
This policy should apply to extension of estuari-,e outfall as
well as Gulf outfall. The r,ulf outfall alternative is simply an
environmental trade-off, substituting degraded estuarine water
quality for degraded coastal water quality and has been inadequately
-recycled
1 of 6
-------
studied wit.!: ro?[juct to the long term effects of continuous
outfill and pp.-veil '. ing south or southwesterly wind conditions.
Furthermore, the Ciulf outfall alternative promotes development
in r^r ii'.nmcntal ly sensitive lands by removing development
constraints and discouraging environmentally preferred alternatives.
After formulation of North and Central Pinellas 201 wastewater
facilities plans the EPA decided that a finding of "No significant
Impact" could be issued for the Gulf outfall alternative. Con-
senvently, I do not feel that further consideration should be
given to primary or back-up discharges of secondarily treated
wautewater to surface waters inshore or by Gulf outfall, as these
methods would cause the continued decline of water quality at an
incrr-asinrj rate due to expanding population.
The DIP for North Pinellas County has identified Reuse as the
"etwironm"ntai ly preferred" alternative for the disposal of 2
treated wauterwator in seven of the eight individual wastewater
treatment plants. The eighth, the North Pinellas subarea has
been identified as suitable for continued land application at the
Innisbrook Country Club. (p. 92) To summarize the EIS recom-
mendations: reuse is the only management option that responds to
this region's surface water quality problems while addressing
goundwater supply limitations. The advantages in wastewater reuse
include:
1) potentially high public accetance,
2) reduced reliance on surface water discharges (and resultant
water quality improvements) and
2 of 6
3) reduced strain on limited public groundwater suj.plies.
The disavantages are:
ai high cost (41-48 million dollars beyond surface water
effluent discharge calculated for al eight WWTP'S),
b) the need for wet-weather back-ups, and
c) operability considerations including soil variations and
the need for maintenance at numerous dispersed sites, and
d) amount of wastewater reused is dependent upon private
decisions and commitments.
The report goes on to state that although reuse is the
environmentally preferred alternative, the "fundabJc- alternative"
will be selected following completion of wasteload allocation
studies for Tampa Bay, Clearwater Harbor - St. Joseph Sound and
Boca Ciega Bay.
The Tampa Bay Regional Planning Council has recently reviewed
the draft Tampa Bay 205 (j) Wasteload Allocation Studv prepared
by DER and found this document to be inadequate for making re-
quired management decisions. The Florida DER ha,s already permitted
discharges of secondarily treated effluent to the Anclotc River
by Tarpon Springs WWTP based on wasteload allocation studies
of 6 mg/L BOD-, 6 mg/L SS, 6 mg/L total nitrogen, and 3 mg/L of
total phosphorus. These permitted values are in excess of those
allowable for advanced wastewater treatment of 5 mg/L BOD-,
5 mg/L SS, 3 mg/L total nitrogen, and 1 mg/L total phosphurus.
Presently, secondary wastewater treatment is defined as removal
of 901! of BOD and suspended solids.
3 of 6
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Safety Harbor and Tarpon Springs NWTP's have been found
in periodic violation of state secondary wastewater treatment
standards and with closer monitoring other plants would be found
at least in temporary violation.
In light of the unacceptable quality of the Tampa Bay Wasteload
Allocation Study currently under review, it is unlikely that the
Clearwater Harbor - St. Joseph Sound Wasteload Allocation Study
will generate the type of data for EPA to determine "acceptable"
levels for disposal of secondarily treated effluent to these
surface waters. Likewise it is untenable that DER would consider
it feasible to enforce these levels if they were thought to place
undue economic burden on these WWTP's. Ke can no longer afford
to sacrifice environmental quality for monetary convenience.
Deep-well injection is presently being considered for both
primary and back-up effluent disposal in areas where there are
2 geologic confining layers separating deep stata of suitable
transmissivity and storage capacity from the Florida Aquifer and
the ground water table. The. depth of this confining layer has been .
found to be less that SO ft in the EIS Study Area, with the exception
of the southwest portion {Clearwater Marshall St. WWTP). South
of the Study Area, the depth of the confining layer exceeds 50 feet.
This layer of impervious clay is occasionally perforated by
fractures.
p. 82 "With the stipulation that deep-well injection only
be permitted where a confining layer of at least 50 feet is present,
impacts of injected wastewater on potable water supplies would
Page 4 of 6
not be felt for many years, assuming the wastewator is not
transported through any confining layer fractures. Even if
pressure is available to push injected wastewater toward a
potable supply, approximately 480 years would be required to push
the wastewater through 50 feet of an unfractured confining layer,
assuming the vertical hydraulic conductivity of the confining
layer is 10 centimeters per second (which is typical for claylike
formations)."
In this case EIS report implies that the danger of polluting
the Floridan aquifer which has already been impacted due to draw-
downs from excessive pumping and corresponding saltwater intrusion
at a rate of 0.3 to 0.4 ft per year is simply a matter of time.
While several generations may not feel the impact of such a decision
we can not responsibly live with such a legacy. Thus, deep-well
injection should be considered experimental and only utilized on
an experimental trial basis. 28-month monitoring periods for
deep-well testing using limited volumes of effluent (3.5 MGD)
will not adequately address the environmental effects of this
alternative.
Lastly, the area east of Lake Tarpon has been identified
as environmentally sensitive due to very critical solids, low
lying wetlands and floodplains which allow extensive groundwater
recharge. Approximately 33% of this area is the Booker Creek
drainage basin. For this reason neither land application or
wastewater reuse should bo considered. The most environmentally
attractive alternative for this largely undeveloped area would
Paoe 5 of 6
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DNR-1
DNR-2
be to transport wastewater from this area to the Clearwater
Northeast NWTP. This should also be considered for the Oldsmar
WWTP as periodic dike failures of evaporation-percolation ponds
have found their way to Mobbly Bay.
Although this is just a draft report it appears that the
primary concern of the EPA is the cost of the environmentally
preferred alternative rather than the continued health, safety
and quality of life available to the residents of the North
Pinellas Region. The EPA, DER and DNR should collaborate to
ensure the continued improvement of coastal, fresh and groundwater
supplies. I would recommend that available federal funding be
applied to the most environmentally sound alternative.
DNR-1. The Draft EIS presents costB. environmental impacts and
operation and implementation factors for all alternatives which
were considered. The EIS has identified the environmentally
preferred alternative and upon availability of approved wasteload
allocations, EPA can select the noat cost effective environmentally
sound alternative.
DNR-2. Comment noted.
on
Frank Courtney/maw
May 20, 1985
Page 6 of 6
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FLORIDA DEPARTMENTOFSTATE
George Firestone
Secretary* Slur
DIVISION OF ARCHIVES,
HISTORY AMD RECORDS MANAGEMENT
The Capitol. Tallahassee. Florida 32301-8020
(904)488-1480
June 6, 1985
In Reply Refer to:
Mike Wisenbaker
Historic Site* Specialist
(904) 487-2333
Mr. Walter Kolb
Office of the Governor
The Capitol
Tallahassee, Florida 32301
RE: Your Memorandum of April 25, 1985
Cultural Resource Assessment Request
SAI NO. FL8504231134'*sEnvironmental Impact Statement,
North Pinellas County Florida Wastewater Facilities
Dear Mr. Kolb:
In accordance with the procedures contained in 36 C.F.R., Part
800 ("Procedures for the Protection of Cultural and Historic Proper-
ties"), we have reviewed the above referenced project for possible
impact to archaeological and historical sites and properties listed,
or eligible for listing in the National Register of Historic Places.
The authorities for these procedures are the National Historic
Preservation Act of 1966 (Public Law 89-665) as amended by P.L.
91-243, P.L. 93-54, P.L. 94-422, P.L. 94-458 and P.L. 96-515,.and
Presidential Executive Order 11593 ("Protection and Enhancement of
the Cultural Environment").
A review of the Florida Master Site File and the National Register
of Historic Places indicates the presence of 60 recorded sites within
tKe North Pinellas Service area, with four of these 60 sites being
listed in the National Register of Historic Places.
For this reason, we concur with the information contained in the
EIS that interceptor lines, pump stations and spray irrigation fields
may impact significant culture resources in this area.
FUORIDA-State of the Arts
Mr. Ualter Xolb
June 6, 1985
Page Two
Therefore, it is our recommendation that this office be provided
copies of any final plans and/or alternatives plans so that we can
assess the effects these projects will have on cultural resources in
the project area.
If you have any questions concerning our comments, please do
not hesitate to contact us.
your interest and cooperation in helping to protect Florida's
archaeological and historical resources are appreciated.
Sincerely,
GWP/Wkp
W. Percy
State Historic
Preservation Officer
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CHAPTER V
LIST OF PREPARERS
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CHAPTER V
LIST OF EIS PREPARERS
PROJECT PERSONNEL
U.S. ENVIRONMENTAL PROTECTION AGENCY
Robert B. Howard
F. Theodore Bisterfeld
Ronald J. Mikulak
Philip Vorsatz
Artie Buff
Eugene Coker
Chief, NEPA Compliance Section
EPA Project Officer, June 1979 -
November 1983
EPA Project Officer, November 1983 -
Present
North Pinellas 201, Project Engineer
Central Pinellas 201, Project Engineer
Engineer, Water Supply Branch
GANNETT FLEMING CORDDRY AND CARPENTER, INC.
Thomas M. Rachford, P.E., Ph.D.
Laurence E. Benander, P.E.
David B. Babcock, P.E.
James R. Fuller
John W. Jacobs
Amy E. Lucas
P. Andre DeGeorges
W. Peter Wickwire, P.E.
Senior Project Manager
Project Manager
Assistant Project Manager
Engineer
Soils Scientist
Environmental Scientist
Environmental Scientist
Engineer
CTA ENVIRONMENTAL, INC.
Claude E. Terry, Ph.D.
R. Gregory Bourne
Craig H. Wolfgang
Thomas C. Mather
James C. Hodges
President
Project Manager
Environmental Planner
Environmental Scientist
Environmental Scientist
PINELLAS COUNTY PARK DEPARTMENT
Cover Photo of Brooker Creek Park Courtesy of the Department,
121
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