United States Region 4 EPA 904/9-81-092
Environmental Protection 345 Courtland Street, NE January, 1982
Agency Atlanta, Ga 30365
<>EPA Environmental Final
Impact Statement
Mobil Chemical Company
South Fort Meade Mine
Polk County, Florida
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FINAL
ENVIRONMENTAL IMPACT STATEMENT
for
Proposed Issuance of a New Source National
Pollutant Discharge Elimination System Permit
U.S. Environmental Protection Agency
Region ivr Atlanta, Georgia 30365
cooperating agencies:
U.S. Army Corps of Engineers
Jacksonville District
Jacksonville, Florida 32201
U.S. Department of the Interior
Bureau of Land Management
Eastern States Office
Alexandria, Virginia 22304
Mobil Chemical Company has proposed an open pit phosphate mine,
beneficiation plant and transshipment facility on a 16,288-acre
site in southern Polk County, Florida* Mining would involve
15,194 acres, all of which would be reclaimed, and would
produce 77 million tons of phosphate products over a 25-year
period. The EIS examines alternatives, impacts and mitigative
measures related to air, geology, radiation, groundwater,
ecology and other natural and cultural systems.
Comments will be received through March 8, 1982. Comments or
inquiries should be directed to*
A. Jean Tolman, EIS Project Officer
U.S. Environmental Protection Agency - Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
(404) 881-7458
to
Mobil Chemical Company
South Fort Meade Mine
polk County, Florida
prepared by:
approved bys
Regional Administrator
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Summary Sheet
for
Environmental Impact Statement
Mobil Chemical Company
Phosphate Mine
( ) Draft
(X) Final
U.S. Environmental Protection Agency, Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
1. Type of Action: Administrative (X) Legislative ( )
2. Description of Action:
Mobil Chemical Company (Mobil) 1s proposing to construct and operate a phos-
phate mine and beneflciatlon plant 1n Polk County, Florida (Figure 1). The
EPA Region IV Administrator has declared the proposed facilities to be a new
source as defined in Section 306 of the Federal Clean Water Act.
In compliance with its responsibility under the National Environmental Policy
Act (NEPA) of 1969, EPA Region IV has determined that the issuance of a new
source National Pollutant Discharge Elimination System (NPDES) permit for the
proposed mining and beneflciatlon facility (the South Fort Meade Mine) would
constitute a major Federal action significantly affecting the quality of the
human environment. Therefore, this Environmental Impact Statement (EIS) has
been prepared 1n accordance with the requirements of NEPA and EPA regulations
1n 40 CFR Part 6. EPA will Issue, issue with conditions, or deny issuance of
the NPDES permit based on the review of the permit application and the
findings of this EIS.
The applicant's proposed mining operation, the South Fort Meade Mine, would
produce 77 million tons of wet phosphate rock over the 25-year life of the
mine. A total of 15,194 acres of the 16,288-acre tract would be disturbed
during mining. The mine would be designed to produce approximately 3.4 million
tons of phosphate rock annually and would be developed 1n two phases. Phase I
is scheduled to start up 1n 1984 following a 21-month construction period.
Phase I operations, with an estimated capacity of 1.7 million tons per year,
would include one dragline and an associated beneflciatlon plant. The start
up of Phase II is planned for 1987 following a similar 21-month construction
interval. Facilities comparable to Phase I would be developed in Phase II,
S-l
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FIGURE
LOCATION OF PROPOSED
SOUTH FORT MEADE MINE SITE
EECHOBEE CO
OCSOTO CO
SOURCE: MOBIL
S-2
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PROPOSED MOBIL SOUTH FORT MEADE MINE
MINING SEQUENCE
C^-jVfv LIME RCAC
1 MILE
OUTPARCELS (pfuvAIC' 1 OWHtD)
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increasing production capacity to 3.4 million tons per year. The mining
sequence, illustrated in Figure 2, is proposed to continue for 25 years with
reclamation activities extending 10 years beyond the life of the mine.
Equipment and procedures similar to those presently used in Mobil's two
Florida phosphate mines are proposed for the new facility. Land clearing
would involve harvesting or burning the vegetation on 50-acre parcels in
advance of the mining operation. At full production, two large walking
draglines would operate simultaneously, mining phosphate from separate areas.
Ore would be slurried and hydraulically transported in pipelines to the
beneficiation plant for washing to separate pebble product, clay, and fines,
and for flotation to recover additional phosphate product. Wet rock would be
stored in on-site stockpiles or loaded directly onto railroad cars for
transport to Mobil's existing rock-drying facilities in Nichols, Florida.
Waste clay and sand tailings from the beneficiation plant would be redeposited
on the property in clay impoundment areas and sand tailings backfill areas.
Mobil's proposed action includes utilizing the conventional clay settling
technique for waste disposal and reclamation. The Initial waste clay settling
areas would be built on unmined ground with dikes constructed of overburden
material. These settling areas, totaling 1,320 acres, would hold the waste
clays generated during the first four years of mining. All other waste
disposal areas would be constructed on mined land. The waste disposal plan
proposed by Mobil calls for 8,170 acres of above>grade clay settling areas,
1,513 acres of below-grade clay settling areas, 5,034 acres of below-grade
sand tailing fill areas with overburden cap, and 308 acres of overburden fill
areas. Sand tailings would be used to cap 1,489 acres of above-grade clay
settling areas.
Water uses and estimated flow requirements for the South Fort Meade Mine are
identified as follows: slurry water for slurrying and transporting the ore
from the mining area to the beneficiation plant (27.0 mgd), seal water for
transfer pumps (0.691 mgd), washing/dilution water for the washing facilities
(52.0 mgd), rinsing water for the feed preparation process (38.0 mgd), process
water for flotation (55.9 mgd), and miscellaneous potable water (0.022 mgd).
Most water required would be supplied from the recirculation system (157,2
mgd). Groundwater would be used to supply water to the flotation process
(12.3 mgd) and for makeup water (3.4 mgd), pump seal water (0.691 mgd), and
potable water (0.022 mgd). The total consumptive use of groundwater is pro-
jected to be 16.413 mgd.
Approximately seven percent of the site (1,094 acres) would not be disturbed
by the proposed mining operation (Figure 3). These undisturbed areas include
111 acres of freshwater swamp, 21 acres of freshwater marsh, 3 acres of
surface water (ponds), 664 acres of upland hardwood forest, 182 acres of
cutover forest, 108 acres of Improved pasture and 5 acres of upland mixed
forest.
The mined areas would be used for waste disposal, with sequential reclamation
following completion of the waste disposal activities in each disposal area.
The entire reclamation program would be completed 10 years after mining has
ceased (mine year 35). Mobil's proposal calls for the reclamation of approx-
imately 60,000 linear feet of stream channels and 1,912 acres of wetlands on
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UNDISTURBED AREAS
T33S
SOURCE: ZELLARS-WILLIAMS
I milt
LEGEND
ummstursed areas
WETLANDS TO REMAM
UNDISTURBED
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the site. The reclaimed stream channels would replace the disturbed tribu-
taries of the Peace River and Bowlegs Creek. The reclaimed site would contain
11,521 acres of improved pasture, 182 acres of cutover flatwoods, 664 acres of
upland hardwood forest, 1,276 acres of upland mixed forest, 453 acres of
planted pine, 3 acres of surface water areas (ponds), 277 acres of forested
stream channel, 589 acres of freshwater swamp, and 1,323 acres of freshwater
marsh.
3• Alternatives Considered:
Mobil's proposed mining and beneficiation operation is comprised of a number
of individual mining subsystems that, when combined, provide a total project
capable of satisfying Mobil's objectives. The identifiable subsystems
Included in the Mobil project are as follows:
Mining Method
Matrix Transfer
Matrix Processing
Waste Disposal
Reclamation
Water Sources
Plant Siting
Water Discharge
Product Transport
Various methods (i.e., alternatives) are available to satisfy the objectives
of each of these subsystems. The subsystems, objectives and alternatives are
identified 1n the following chart, and a brief description of each alternative
is presented in the succeeding paragraphs.
Mining Method
Dragline Mining: Mobil proposes to use two 45-cubic yard draglines for remov-
ing the overburden and mining the phosphate matrix. Both draglines would
operate independently, removing overburden and matrix in two separate mining
areas. This 1s the conventional mining method used by the Florida phosphate
industry.
Bucket Wheel: A bucket wheel excavator has a large rotating wheel with fixed
buckets attached on its periphery. The bucket wheel excavator would excavate
material and discharge it onto an associated conveyor belt system. Four
bucket wheel excavators would be required for the proposed mine operation; two
of the units would remove overburden while the other two units mined the ma-
trix.
Dredge: The dredge unit consists of equipment mounted on a barge for floating
and moving over the material to be excavated. The cutterhead dredge, consi-
dered the dredge unit best suited for mining phosphate in the central Florida
area, would excavate and pump materials from beneath the water to the surface
via a suction pipe. The South Fort Meade site would require two cutterhead
dredge units to remove overburden and mine the matrix.
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Mining
Subsystem
Objective
Alternatives
Considered
Mining Method
Matrix Transfer
Processing
Waste Disposal
Reclamation
Water Sources
Plant Siting
Water Discharge
Remove overburden and
deliver matrix to a
transport system.
Transport matrix from
the mine to the bene-
ficiation plant.
Process the matrix to
separate the phosphate
rock product from the
waste sand and clay.
Dispose of the waste
sand and clay generated
by matrix processing.
Return the mined site to
useful productivity.
Provide a continuous
source of freshwater
(about 16.413 mgd) for
use 1n matrix processing
and as makeup for losses
to the recirculation system.
Provide location which
conserves energy and
does not create en-
vironmental problems.
Provide location for
clear water pool
discharge.
Dragline *
Bucket Wheel
Dredge
Pipeline *
Conveyor Belt
Truck
Conventional Beneficiation*
Dry Separation
Conventional Clay Settling Case *
Sand/Clay Cap Case
Sand/Clay Mix Case
Overburden/Clay Mix Case
Conventional Plan *
Sand/Clay Cap Plan
Sand/CI ay Mix Plan
Overburden/Clay Mix
Groundwater *
Surface Water
Plan
Gilshey Branch Site *
Other On-site Locations
Peace River *
Bowlegs Creek
Product Transport Wet rock product transport
Railroad *
Truck
~Mobil's proposed action
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Matrix Transfer
Pipeline: The mined ore would be dumped by the dragline into a slurry pit for
di saggregation. Recirculation water (27 mgd) would be directed by hydraulic
guns to break up the material and slurry the matrix to a pumpable mixture.
Each mining operation would have a separate slurry system with booster pumps
to deliver the slurry to the plant. This is the conventional matrix transfer
method used in the Florida phosphate industry.
Conveyor Belt: A conveyor belt system would begin at the field feed hopper.
Ore woOT have to be transported from the mine area to the feed hopper. From
the hopper the ore would be placed on the conveyor belt to be transported to
the beneficiation plant. Two independent 36-inch conveyor systems would be
required to transfer the ore from the two mining areas to the beneficiation
plant.
Truck: Matrix transfer by diesel engine truck could be accomplished during
Phase I with 25-ton capacity trucks making 820 round trips per day. During
Phase II, 1,640 truck trips per day would be necessary using trucks with a
25-ton capacity.
Processing
Conventional Beneficiation: Conventional beneficiation operations at the mine
would include washing, feed preparation and flotation, each with the purpose
of separating phosphate rock from the associated organics and gangue minerals
(limestone cobbles, quartz sand and a mixture of clay minerals). This is the
only matrix processing method used in the Florida phosphate industry today.
Dry Separation: Dry separation is a process that involves drying, crushing
and sizing. After being dried with a rotary kiln and crushed with a
hammermlll, the matrix would be processed through several stages of air sepa-
ration to separate the pebble product from the finer materials. Additional
phosphate product would then be separated from the remaining material by an
electrostatic separator.
Waste Disposal
Conventional Clay Settling Case: Mobil proposes to use the conventional meth-
od of waste disposal as currently practiced at their existing mining opera-
tions in central Florida. The conventional plan calls for the separate dis-
posal of sand tailings and waste clay. The sand tailings would principally be
used to backfill mined areas (5,034 acres) and as fill in dike construction
for clay impoundment areas. Waste clays would be contained behind earthen
dams to be constructed on natural ground (1,320 acres) and in mined areas
(8,363 acres). A flow-through settling technique is commonly used with
conventional clay settling and would be implemented at the South Fort Meade
Mine. This technique 1s generally utilized for clay settling basins that are
located adjacent to each other. The procedure consists of introducing the
waste clay stream into a series of clay settling basins instead of a single
basin with all connected basins remaining active until the last basin is
filled and inactlved. The purpose of the flow-through technique is to achieve
S-8
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improved water clarification, clay compaction, and water management. Average
dike height for this waste disposal case would be 38.7 feet above grade.
Sand/Clay Cap Case: The sand/clay cap case would have above-grade clay
settling basin configurations similar to the conventional case; however, flow-
through settling would not be used with the sand/clay cap disposal method. A
five foot thick sand/clay cap (sand to clay ratio of 4:1) would be placed on
top of the clay settling areas (7,580 acres). In order to place the sand/clay
cap over the settling areas in a timely fashion, the basins would be taken out
of service after the initial fill and actively dewatered to develop a crust.
The average dike height for this case would be 36.7 feet. This waste disposal
case also calls for 1,513 acres of below-grade clay settling basins partially
capped with overburden, 590 acres of above-grade clay settling basins capped
with overburden, 5,079 acres of sand tailings fill areas capped with
overburden, and 308 acres of overburden fill areas.
Sand/Clay Mix Case: The sand/clay mix waste disposal method would involve
mixing gravity thickened clays with dewatered sand tailings and depositing the
mixture 1n mined areas for consolidation and stabilization. The clays would
be pumped from the settl1ng/th1cken1ng areas to the mix and disposal sites.
Sand to clay ratios of approximately 2:1 have been shown 1n experimental
studies to be the minimum acceptable for achieving significant consolidation
benefits. The high clay content and correspondingly low proportion of sand in
the South Fort Meade Mine matrix preclude the use of sand/clay mix waste dis-
posal techniques for the entire site. A combination of sand/clay mix areas
(3,512 acres), clay settling areas with a 2:1 sand/clay cap (3,185 acres),
graded spoil and overburden fill areas (1,571 acres), sand tailings fill areas
(3,020 acres) and conventional clay settling areas (3,737 acres) would have to
be utilized to dispose of the wastes. The average dike height for this case
would be 35 feet.
Overburden/Clay Mix Case: Since sufficient sand tailings are not available
from the matrix to accomplish a 2:1 sand/clay mix over the entire site,
overburden sand could be used as an additional source of sand to mix with the
waste clay. The overburden would be slurried and pumped to a field washer for
screening and washing. The recovered overburden sand would then be pumped to
the mixing station where 1t would be combined with thickened waste clay at a
2:1 sand to clay mixture for final disposal. This waste disposal case would
result 1n sand tailings fill areas (3,020 acres), 2:1 sand/clay mix areas
(5,492 acres), above-grade clay settling areas capped with 2:1 sand/clay mix
(2,847 acres), below-grade clay settling areas (2,095 acres) and overburden
fill areas (1,740 acres). The average dike height for this case would be 38
feet.
Reclamation
Conventional: Mobil's reclamation plan would reclaim the 15,194 acres
disturbed by mining as follows: improved pasture (11,413 acres) would be
developed on above-grade settling areas and sand tailings fill areas with
overburden cap; upland mixed forest (1,271 acres), planted pine (453 acres)
and forested stream channel (277 acres) would be developed in sand tailing
fill areas with overburden cap; freshwater swamp (478 acres) would be
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developed in above-grade clay settling areas, and freshwater marsh (1,302
acres) would be developed in below-grade clay settling areas capped with
overburden.
Sand/Clay Cap Plan: This plan would reclaim the 15,194-acre disturbed area as
follows: improved pasture (11,003 acres) would be developed in above-grade
clay settling areas capped with 4:1 sand/clay mix and sand tailings capped
with overburden; upland mixed forest (1,451 acres), planted pine (536 acres),
and forested stream channel (279 acres) would be developed in sand/tailings
capped with overburden; freshwater swamp (504 acres) would be developed in
above-qrade clay settling areas capped with 4:1 sand/clay mix; and freshwater
marsh (1,421 acres) would be developed in below-grade clay settling areas
capped with overburden.
Sand/Clay Mix Plan: This plan would reclaim the 15,194-acre disturbed area as
follows: improved pasture (10,313 acres) would be developed in above-grade
sand/clay mix (2:1) areas, clay settling areas, and sand tailings fill areas
capped with overburden; upland mixed forest (1,826 acres), planted pine (431
acres), and forested stream channel (263 acres) would be developed 1n sand
tailings fill areas with overburden; freshwater swamp (746 acres) would be
developed in sand/clay mix settling areas and in above-grade and below-grade
sand/clay mix (2:1) areas; and freshwater marsh (1,615 acres) would be
developed in below-grade clay settling areas partially capped with overburden.
Overburden/Clay Mix Plan: This plan would reclaim the 15,194-acre disturbed
area as follows: improved pasture (10,313 acres) would be developed in
sand/clay mix areas and sand tailings capped with overburden; upland mixed
forest (1,826 acres), planted pine (431 acres), and forested stream channel
(263 acres) would be developed in sand tailings capped with overburden;
freshwater swamp (746 acres) would be developed in above-grade and below-
grade sand/clay mix areas; and freshwater marsh (1,615 acres) would be
developed in below-grade clay settling areas partially capped with overburden.
Water Sources
Groundwater: Mobil proposes to utilize three deep wells (approximately 1,000
TeeF~deep) for the primary source of clean water for the flotation process and
as makeup water for the recirculation system. The Southwest Florida Water
Management District has granted a Consumptive Use Permit (CUP) for the with-
drawal of 16.413 mgd of groundwater (15.7 mgd from the lower Floridan Aquifer
and 0.713 mgd from the Upper Floridan Aquifer).
Surface Water: The 7-day 10-year low flow In Bowlegs Creek is zero mgd while
that in the Peace River Is 7.1 mgd. Since this is not sufficient to meet the
daily water requirements (16.413 mgd) of the mine, this alternative would re-
quire an impoundment be constructed on Bowlegs Creek. This source of water
would probably require treatment to upgrade the quality and could require
augmentation by groundwater withdrawal.
Plant Siting
6i1shey Branch Site: Mobil proposes to locate the benefielation plant on the
west side of Manley Road approximately two miles north of County Line Road.
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Mobil's main objective in siting the plant was to minimize the energy required
for matrix transfer by locating at the centroid of matrix pumping.
Other On-Site Locations: The proposed mine site was examined for other poten-
tial locations for the beneficiation plant. Objectives followed in attempting
to locate other sites were to maximize energy efficiency and minimize
disturbance of environmentally sensitive areas.
Water Discharge
Peace River; Under Mobil's proposed action, the clear water discharge would
gravity flow into the Peace River by way of a vegetated drainage swale
{outfall ditch) located along the railroad route draining to the Peace River.
The mining operation would have an intermittent discharge from the clear water
pool primarily between the months of May and October. The discharged volume
would be directly dependent on local rainfall trends and is expected to be the
greatest between June and September, a period when tropical storms are fre-
quent 1n Florida. During the wet season the normal and maximum discharge
volumes would be 9 mgd and 20 mgd, respectively.
Bowlegs Creek: Construction of a pump station and a transfer line from the
clear water pool to Bowlegs Creek would be necessary in order to implement the
alternative of discharging into Bowlegs Creek.
Product Transport
Railroad: Mobil proposes to transfer the wet phosphate rock produced at South
Fort Meade by rail cars to an existing rock drying facility at Nichols,
Florida. Mobil would construct a s1x-m1le rail spur from the plant site west
to the existing Seaboard Coast Line track. This would also require con-
struction of a bridge across the Peace River and a grade crossing on Mt.
Pisgah Road. During full production, 65 rail cars would be pushed from the
beneficiation plant to the main track and returned twice each day.
Truck: Product transport by dlesel truck could be accomplished during full
production with 25-ton capacity trucks making 520 round trips per day from the
South Fort Meade Mine site to Nichols.
The No Action Alternative
The no action alternative by EPA would be the denial of an NPDES permit for
the proposed project. The effect of permit denial would be to precipitate one
of three possible actions on the part of Mobil: (1) termination of the pro-
posed project, (2) indefinite postponement of the proposed project or (3) re-
structuring of the project to achieve zero discharge.
Termination of the planned project would allow the existing environment to
remain undisturbed and the gradual socio-economic and environmental trends
would continue as at present.
The project might be postponed for an indefinite time and then successfully
pursued by Mobil or another mining company. This might be expected to occur
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when high grade phosphate reserves are depleted and the resource retained on
the Mobil site becomes extremely valuable strategically as well as econo-
mically.
If EPA denies the NPDES permit, Mobil could still execute a mining project
provided the project could be performed with zero discharge. Under zero dis-
charge conditions, neither an NPDES permit nor an Environmental Impact
Statement would be required.
4. EPA's Preferred A1ternatiIves
The alternatives evaluation for the Mobil project is presented in detail in
Section 2,0 of the Draft Environmental Impact Statement (DEIS). Based on
analyses described in that section, the environmentally preferable alter-
native, EPA's preferred alternative, and Mobil's proposed action (including
mitigating measures presented as part of the proposed action), all coincide
with respect to the following project subsystems:
Mining Method (Dragline)
Matrix Transfer (Pipeline)
Processing (Conventional Beneficlation)
Water Sources (Groundwater Withdrawal)
Plant Siting (Gilshey Branch Site)
Water Discharge (Peace River)
Product Transport (Railroad)
However, they differ with respect to the waste disposal and reclamation
project plans. The analysis of waste disposal and reclamation alternatives
identified the 4:1 sand/clay cap waste disposal case and the corresponding
reclamation plan as the environmentally preferable (and therefore EPA's
preferred) alternatives. A summary of the evaluation of waste disposal and
reclamation alternatives is presented in Table 1.
The EPA preferred alternatives for waste disposal and reclamation have the
principal advantages of a lower (by two feet) average dike height, reduced
surface radiation levels, improved agronomic properties of the reclaimed
soils, establishment of a perched water table about five feet below the
surface of the reclaimed sand/clay cap areas (providing a plant growth zone),
reduced potential for dam failure because of decreased active settling
acreage, seven percent more reclaimed wetlands, and improved land use
potential with 4:1 sand/clay mix cap over the clay settling areas due to
increased structural stability. Mobil's proposed action for waste disposal
and reclamation has the principal advantages of significantly lower energy
consumption and the use of a proven technology.
Summary of the Environmental Impacts of the Alternatives
In order to make its determination regarding the NPDES permit application for
the Mobil project, EPA has developed a comparison between (1) Mobil's proposed
action, (2) EPA's preferred alternatives and recommended mitigating measures,
and (3) the no action alternative of permit denial by EPA, which could lead to
termination of the project, postponement of the project or restructuring of
the project to achieve zero discharge. This comparative analysis 1s presented
in Table 2.
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TABLE 1
SUMMARY OF WASTE DISPOSAL AND RECLAMATION ALTERNATIVE EVALUATION
Item
Conventional
Clay
Settling Plan
Average Dike Height of Above-Grade Basins
(feat) 39
Araa of Above-Grade Settling Basins,
clay and/or sand/clay mix (acres) 8,170
Area of Above-Grade Clay Settling Basins,
(capped or uncapped) 8,170
Area of Above-Grade Clay Settling Basins,
without cap (acres) 6,601
Areas of Sand Tailings and Overburden Fill
(acres) 5,511
Areas of Below-Grade Settling Basins
(acres) 1,513
Land Use Potential Rating (Existing • 10)
a. Structural Stability (Short-Term) 5.1
b. Structural Stability (Long-term) 5.6
c. Agronomic Value 5.8
Phosphate Resources in Waste Disposal
Areas, with clay (ratio of phosphate to
Sand/Clay
Cap
Plan
37
8,170
8,170
0
5,511
1.513
5.3
6.4
7.7
Sand/CI ay Overburden/
Mix Clay Nix
Plan Plan
35
a, 339
4,827
1,642
4,760
2,095
4.8
5.6
6.7
38
8,339
*»847
0
4,760
2,095
4.9
5.8
6.9
waste material)
0.44
0.35
0.24
0.15
Average Soil Rad1um-226 Levels of
Reclaimed Landform (pC1/g)
13.2
8.9
10.9
8.9
Groundwater Consumption
(mgd)
16.4
16.4
16.2
16.4+
Dike Failure Risk Rating
(4 • Highest Potential)
4
I
3
2
Reclaimed Wetland Areas and Reforested
Stream Channels (acres)
2.057
2,204
2,624
2,524
Reclaimed Upland Mixed Forested Areas
(acres)
1,271
1.451
1,826
1,825
Energy Consumption for Pumping
(10® KWh)
1.004
1,252
1,358
2,444
Technology Risks (number of processes
or operations not proven)
0
1
1
2
Possibility of Contamination by Seepage
from basins to groundwater
(4 « Greatest Probability)
1
2
3
4
Auction in Aquifer Recharge
(3 » Greatest Reduction)
3
3
2
*
SOURCE: STUDY DATA
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TABLE 2
COMPARISON OF THE ENVIRONMENTAL IMPACTS OF THE ALTERNATIVES
Dtsdpl tn»
Mr Quality,
Meteorology,
ano No*st
Geology and
Soils
Radiation
Groundwater
wool I t Proposed Action
Minor Increases In fu-
gitive dust emissions
and Millions from
internal combustion
engines, minor emis-
sions of volet II*
reagents; increastd
nois* levels in the
vicinity of operating
•qui (went.
Disruption of the
surface soils and over-
burden strata; removal
of 77 million tons
of phosphate rock;
Increased loading
to the Hawthorn of
17 pji; altering of site
topography; creation
of approximately 7000
A of structurally
and agroftamtcally In-
ferior land.
Disruption of the na-
tural distribution of
radioactive material
within the overburden
and matrix; increased
?Mma radiation
eveIt from reclaimed
surfaces and increased
soil radioactivity.
Lowering of the
pieiometrlc surface
of the Lower Floridan
Aquifer; lowering of the
Surflclal Aquifer near
active mine pits; 47
percent reduction In
natural recharge.
IPA's Preferred Alternetlves
Including Mitigation Meesures
Seme as Mobil's propoied
action.
Same as Mobi 1's proposed
action except: increased
loading to Hawthorn Forma-
tion of 16 psl; alteration
to topography not as great
(2 ft. less); possible fur-
ther decrease in lev*) of
CS-10; slightly Increase
future effort to recover
phosphate from watte day;
Improved structural and
agronomic characteristics
over the approximately
7000 A of land.
Same as Mobil's pro-
posed action, except that
reclaimed surfaces
would have lower overall
soil radioactivity
and gamna radiation levels.
Seme as Mobi1's proposed
action, except that a
perched water table would
be established about S feet
below the surface 1n the
reclaimed sand/clay cap
areas.
Termination
No change In
meteorology 1
noise levels;
possible air
quality changes
from other
sources.
No change in
geology; no
chenge in site
soils; preser-
vation of 77
million tons
of phosphate
rock reserves.
ho change in
radiation char-
acteristics
of the site.
No change In
existing
groundwater
quantity or
quality.
The No Action Altarnatlves
Postponement Achieve lero Discharge
Same as Mobil's
proposed action.
Possible in-
creased phos-
phate recovery
and more effec-
tive waste dis-
pose) , reclama-
tion, and wet-
lands restoration.
Same as Mobil1s
proposed action.
Possible reduction
in groundwater
withdrawals be-
cause of more
effective dewatering
of waste materials
resulting from future
process development.
Same as Mod Ir s pro-
posed action.
Increased dike heights
and water storage capa-
city; Infringement on
Bowlegs Creek preserved
area; less desirable
reclamation plan.
Probable increase In
area covered with weste
clays - the reclaimed
material having the
highest radioactivity
1 evels.
Possible reduction In
groundwater withdrawals
because of Increased
water storage.
Surface Water
Biology
Human Re
Olsruption of surface
water flows from the
mine site; minor alter,
atlon in flows fol-
lowing reclamation;
degradation of water
charges from the
mine water system.
Destruction of aqua-
tic and terrestrial
habitats on the mine
site; aquatic habitat
modification due to
reduced surface
water flows and addi-
tion of contamlnents;
loss of some
endangered species
Individuals; creation
of modified habitats
following reclamation.
Retention of existing
Jobs and develop-
ment of new jobs with
comparatively high in-
come i (d valorem and
teles tax revenue for
Polk Countyt severance
tax revenue for the state
Land Reclamation Trust
Fund, end Florid* Insti-
tute of Phosphate Re-
search; maintain employ-
ment for Mobil's Fort
Nad* personnel.
Sam* ts Mobil's proposed
action, except that dam
failure potential is
reduced because of de-
creased active settling
areas and J-foot lower dike
heights.
Same as Mobil's proposed
action, except 8 percent
more wetlands would be
reclaimed, improved soils
for restoration of
vegetation and habitats,
and grtattr protection of
listed species.
Seme as Mobil's proposed
action, except land us*
potential Improved by 4:1
sand/clay cap surface soil
over clay settling arees.
No change In
surface water
quantity; sur-
face water
quality would
b* dependent upon
future land uses in
th* art*.
No Cheng* In
existing aquatic
or terrestrial
ecology.
loss of Jots
which would b*
generated by
th* project;
loss of tax
revenue for
Polk County
and th* stste;
and a loss of
Mobil's Invest-
ment.
Sam* as Mobil's
proposed action.
Possibly more
effective
reclamation.
Potential in-
creased pro-
ject costs; loss
of Jobs.
£1 imlmton of surf tee
water quality impacts
resulting from discharge
from mine water system;
Increased probability
of dike failure Impacts.
ElIminatlon of habitat
modification resulting
from mine water
discharge; Ucreased
probablIity of dike
failure Impacts;
probable Increase in
reclaimed land areas
(waste clays) of limited
use (pasture).
Same as Mobil's proposed
action.
S-14
-------
6. Identified Issues arid Concerns
The DEIS was made available to the Council on Environmental Quality (CEQ)
and the public in September of 1981. A joint public hearing to receive
comments on the DEIS and the Draft NPDES permit and state certification was
held in Bartow, Florida on October 20, 1981. Written comments on the DEIS
were received from the following agencies and interested groups:
Federal Agencies
U.S. Department of Agriculture, Forest Service
U.S. Department of Agriculture, Soil Conservation Service
U.S. Department of Health and Human Services, Public Health Service
U.S. Department of Interior, Office of the Secretary, Southeast Region
State and Local Agencies
Florida Department of Environmental Regulation, Bureau of Air Quality
Management
Florida Office of the Governor
Florida Department of State
Polk County Board of County Commissioners
Interested Groups or Individuals
Mobil Chemical Company
Sierra Club, Florida Chapter, Polk Group
All questions and comments on the DEIS, written and verbal, are
individually addressed in Section 3, Public Participation, of the Final E1S
(FEIS). Comments that resulted in changes to EPA's recommendations are
discussed in the following paragraphs.
U.S.D.A. Forest Service comments on the DEIS resulted In the expansion of
NEPA requirement No. 6 of the Draft NPDES permit by the additional requirement
that Mobil coordinate with the District or State Forester regarding the
forestry aspects of the reclamation plan.
Although not submitted as a specific comment on the Mobil DEIS, an August
10, 1981 letter to EPA from the Florida State Museum (Appendix, page t>-2)
strongly urged that EIS's for mining projects 1n the Bone Valley district take
into account the potential for encountering valuable paleontological resour-
ces. EPA proposes to address the concern of the Florida State Museum by ad-
ding a permit condition (NEPA requirement No. 13 of the Draft NPDES permit)
requiring that Mobil provide access to bona fide researchers and professionals
for salvage of paleontological specimens and information.
7. Agency Decision
The Final Areawlde Environmental Impact Statement for the Central Florida
Phosphate Industry (AEIS), published by EPA in November 1978, established a
set of recommendations for future phosphate industry operations In Florida
S-15
-------
which was determined to be as compatible as practicable with other desired and
intended land uses. Section 6 of the Mobil DEIS provided a detailed
comparison between Mobil's proposed project, EPA's proposed action and re-
commended alternatives, and the AEIS recommendations.
The Mobil proposal deviates from the AEIS recommendations in two areas:
(1) elimination of conventional above-ground clay-disposal areas and (2) the
use of connector wells. However EPA's proposed action, embodied in the Draft
NPDES permit, deviates from the AEIS recommendations only with respect to the
use of connector wells. While the AEIS recommended the use of connector wells
to recharge the Surficial Aquifer, it also noted that the drained water should
be monitored to assure that it meets recommended drinking water criteria. In
the case of Mobil's proposed project, high gross alpha radiation levels, ex-
ceeding drinking water standards, were found in the Surficial Aquifer at the
South Fort Meade Mine site. Accordingly, Mobil does not propose to use con-
nector wells to recharge the Floridan Aquifer with groundwater from the
Surficial Aquifer, and the use of such wells is neither a condition of Mobil's
Southwest Florida Water Management District Consumptive Use Permit nor recom-
mended by EPA in this site-specific EIS.
Therefore, pursuant to provisions of the Clean Water Act of 1977, EPA
proposes to Issue an NPDES permit to Mobil for their proposed South Fort Meade
Mine in Polk County, Florida. The project authorized by the permit is to be
the sum of EPA's preferred subsystem alternatives (which is Mobil's proposed
action except in the case of waste disposal and reclamation). Further, EPA
proposes to Impose as permit conditions all the mitigating measures identified
as part of Mobil's proposed action (Section 2.1 of the DEIS and Chapter 2 of
the Supplemental Information Document [SID]) as well as all the mitigating
measures recommended by EPA, including the revisions and additions resulting
from comments on the DEIS.
S-16
-------
FINAL ENVIRONMENTAL IMPACT STATEMENT
TABLE OF CONTENTS
EaSi
Summary Sheet for Environmental Impact Statement S-l
1.0 Preface 1-1
2.0 Errata 2-1
3.0 Public Participation 3-1
3.1 Written Comments 3-1
3.2 Responses to Written Comnents 3-44
3.3 Hearing Transcript 3-67
3.4 Responses to Transcript Conments 3-88
4.0 Final Environmental Impact Statement Coordination List 4-1
5.0 List of Preparers 5-1
6.0 Appendix 6-1
6.1 Letter from Florida State Museum 6-1
6.2 Draft NPDES Permit 6-4
-------
1.0 PREFACE
In September of 1981, the Environmental Protection Agency published and
distributed a Draft Environmental Impact Statement (DEIS) on the proposed
Mobil Chemical Company South Fort Meade Mine. The DEIS was written pursuant
to the National Environmental Policy Act (NEPA) of 1969. While the DEIS was
a complete document, much of the detailed technical information and sup-
porting data were presented in a Supplemental Information Document (SID).
The DEIS was distributed to the appropriate Federal, state, and local
agencies and to interested individuals. The SID was available for review at
a number of locations and was distributed on a limited basis.
This Final Environmental Impact Statement (FEIS) has been prepared to conform
with the Council on Environmental Quality (CEQ) regulations (40 CFR Part 6)
for implementing NEPA. The essence of the NEPA decision process 1s contained
in the Summary Sheet for the FEIS; 1t describes the existing problem re-
quiring a decision, summarizes alternatives including mltigatlve measures
and their associated impacts, identifies major concerns and Issues, and
presents EPA's conclusions and decision.
In an effort to avoid excessive paperwork and costly reproduction, the DEIS
text has not been reprinted 1n the FEIS. The supporting Information
furnished in the DEIS and its SID should be reviewed and is incorporated
herein by reference.
Chapter 2, Errata, is comprised of the corrections to errors and omissions in
the DEIS and resource documents as well as all recognized typographical and
minor errors.
1-1
-------
Chapter 3 contains a description of the public participation program conduc-
ted for the EIS. Included in this chapter are copies of written communica-
tions submitted to EPA in response to the DEIS, followed by EPA's responses
to each individual comment. These are followed by a transcript of the public
hearing on the DEIS and EPA responses to the hearing comments.
Chapter 4 of the FEIS lists the agencies and groups to whom the FEIS will be
sent for review and comnent, and Chapter 5 identifies the individuals
involved in its preparation. Chapter 6 of the FEIS contains the Draft NPDES
permit. In accordance with CEQ regulations, there will be a 30-day review
and comment period following publication of this FEIS and its filing with the
CEQ.
1-2
-------
2.0 ERRATA
The following are corrections and revisions to the DEIS,
Page Paragraph Line Correction
2-119 3 7 Omit the hyphen in "Following"
3-51 Title 2 Omit "RAOON-226"; add "RADIUM-226"
3-72 3 4 4 5 Should read "...A summary of the data
from nine test wells sampled on the
site is presented..."
3-73 Table 3.4-1 Replace with table from following page.
2-1
-------
TABLE 3.4-1
CHEMICAL ANALYSIS OF GROUNDWATER
AT THE SOUTH FORT MEADE SITE
Constituents
Conductivity (i«fco/CM)
pH
Acidity (C.ilu.)
TotjI AtkalInfty (CaCo.,)
Total Hardness (CaCQ.)
lot a I Solids
TotJI Dissolved Solids (TOS)
Color (PCU)
Fluoride (F)
Total Phosphorus
Ortho Phosphate
Total fcjeldahl Nitrogen (TKN)
Amnonia (NH,
Florida
Groundwater
Class 1-8
Standard*
Nit rat*
Silica (Siof
Sulfate (SOJ)
Total Organic Carbon (TOC)
Aluminum (Al)
Arsenic (As)
Barium (Ba)
Cadalu* (Cd)
Calctun (Cat
Chrowtu* (Cr)
Copper (Cu)
Iron (Fa)
Lead (Pb)
N4j(i«slu* (Hg)
Morcury (Hg)
Nickel (Ml)
Potassiu« (K)
Selenium (Se)
Silver (Ag)
Sodium (Na)
Strontium (Sr)
Chloride (CI)
Pesticide Scan
Oil and Grease
Radium -22S (pCi/1)
Gross Alpha (pCi/1)
06
0
01
OS
OS
002
01
OS
EPA
Orlnfctnq Hater
Standard
8.5-8.S R
500 R
IS R
1.4-2.4 H
44 N
250 R
0.0S
1.0
0.01
200
O.OS
1.0
0.3
O.OS
US
0.002
0.01
O.OS
200
15
250
S
IS
Shallow
Aquifer0
181
5.5-8.5
;
51
88
500
134
220
0.72
1.98
0.49
0.51
O.SO
0.28
<0.01
11.6
9.4
12.8
J. 5
<0.0$
0.01
<0.01
14.2
<0.04
<0.03
2.18
<0.1
4.94
<0.001
<0.06
1.06
<0.01
<0.03
32.6
0.68
0.13
NO 2
<1-14.6
<0.4-97
Upper Florldan
Aquifer
Hell UF-10
(Sampled 2-29-aO)
480
7.5
3
156
204
328
316
30
1.8
0.02
0.01
0.4
0.33
0.3
<0.01
26.6
63.7
76.2
0.19
<0.004
<0.1
0.02
37.4
<0.05
0.07
0.98
<0.02
24.1
0.002
<0.06
4.9
<0.004
<0.03
24.2
13.8
17.6
NO 2
<0.2
4.4
4.8
Lower Floridan
Aqul fer
Well LF-6
(Sawled 2-15-80)
1130
7.6
13
130
648
966
961
S
0.60
0.02
0.01
0.3
0.16
<0.1
<0.01
23.3
530
60.6
0.29
<0.004
<0.1
0.10
117.,6
<0.0S
0.03
0.14
<0.04
56
0.002
<0.04
10.4
<0.004
<0.03
8.0
66.0
13.1
NO 2
<0.2
2.3
34
All constituents are given in otg/1 except pH and those noted.
NO - None Detected
4 FAC Chapter 17-3. Includes all groundwater with total dissolved solids less than 10.000 «g/l.
b EPA Primary and Secondary Standards (Partial List): K (Mandatory). R (Recoaiended).
c Mean value of 10 SMples collected frow 9 shallow wells February and Septenber 1980.
SOURCE: STUDY DATA
2-2
-------
3.0 PUBLIC PARTICIPATION
The Draft Environmental Impact Statement (DEIS) for Mobil's proposed South
Fort Meade Mine was made available to the Council on Environmental Quality and
the public in September 1981. The Federal Register (Volume 46, No. 181),
dated September 18, 1981, announced the availability of the DEIS, the proposed
issuance of an NPDES permit and the 45-day period for public comment on the
DEIS. The DEIS was provided to Federal, state, and local agencies as well as
concerned individuals, Interest groups and public officials.
Notice of the public hearing was published 1n the Polk County DEMOCRAT and the
Tampa TRIBUNE on September 10, 1981. Additionally, copies of the public
notice were mailed to Individuals on the EPA mailing 11st and to all ap-
propriate governmental agencies. A copy was also posted 1n the Bartow
Courthouse for thirty days prior to the hearing. The DEIS was available for
public review at libraries in Lakeland, Bartow, Wauchula, Sarasota, Bradenton
and Tampa, Florida. The public hearing was held October 20, 1981, 1n Bartow,
Florida and was attended by 54 participants.
Written public conments are presented In Section 3.1, Written Comments. The
public comments presented at the public hearing are Included 1n Section 3.3,
Hearing Transcript. The designations in the right margins of the letters (W-l
thru W-60) identify specific comments for which responses have been prepared.
These responses are located in Section 3.2, Responses to Written Comments.
The designations in the right margin of the hearing transcript (T-l and T-2)
identify the comments which have been responded to 1n Section 3.4, Responses
to Transcript Comments.
3.1 WRITTEN COMMENTS
3-1
-------
STATE OF FLORIDA
DEPARTMENT OF ENVIRONMENTAL REGULATION
TWIN TOWEMS OFFICE BUILDING
2600 BLAIR STONE ROAD
TALLAHASSEE. FLORIDA 32301
VICTORtA J. TSCHINKEL
SECRETARY
BOB GRAHAM
GOVERNOR
September 23, 1981
Ms. A. Jean Tolman
EIS Project Officer
Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Ms. Tolman:
The Bureau of Air Quality Management has reviewed the
Environmental Impact Statement for Mobil Chemical Company's
South Port Meade mine to determine if it will comply with
the State's regulations on air pollution.
The proposed mine will be a source of unconfined emissions
of particulate and subject to Chapter 17-2.610(3), FAC. This
regulation requires the source ..to use reasonable precautions
to minimize emissions of particulate matter. Mobil Chemical
plans to pave the roads to the beneficiation plant, maintain
vegetative cover on land where mining activity is not imminent,
and revegetate disturbed land. This will reduce unconfined
emissions. The company stated that natural seeding will re-
vegetate barren areas between the period of mining and re-
clamation. The Bureau believes Mobil should revegetate the ^
barren areas with grass as soon as the mining activity allows. i
This will provide a temporary cover until reclamation and help ^
minimize unconfined emissions.
Open burning during land clearing will occur at the mine.
Chapter 17-5, FAC, regulates open burning and the State will oi
require the Company to comply with these regulations. ^
The mine does not appear to have any point sources of
air pollution and, if so, will not be required to obtain a
State permit to construct an air pollution source. However,
they may be subject to other permitting requirements by the
Department. Mobil Chemical Company should contact the Department «
to see what State permits will be required for the mine. i
3-2
Protaetlna Florida and Your Quality of Lift
-------
Ms. A. Jean Tolman
Page- Two
September 23, 1981
The Bureau of Air Quality has no objection to Mobil
Chemical Company being allowed to construct the mine as
described in the Environmental Protection Agency's preferred
alternative plan.
Chief
Bureau of Air Quality Management
SS:caa
3-3
-------
United States
Department of
Agriculture
Forest Southeastern
Service Area
1720 Peachtree Road, NW
Atlanta, Georgia 30367
Reply to: 1950 (PP)
Date September 30, 1981
Ms. A. Jean Tolman, EIS Projeot Officer
Environmental Protection Agency
315 Courtland Street, N.E.
Atlanta, Georgia 30365
L
Dear Ms. Tolman:
We have reviewed the draft EIS for the Mobil Chemical Company South Fort
Meade Mine, Polk County, Florida and have the following oonnents:
1. Overall, the draft EIS, supplemental information dooument and a good
reclamation plan for the disturbed mined areas were well written. The
unique presentation, ie. giving the description of the resources followed
immediately by the environmental consequences greatly aided the reader in
the review process.
2. Mobil Chemloal Company plans to develop a phosphate mine and benefici-
ation plant on approximately 16,288 aores in Polk County. Approximately
15,19^ aores of vegetative communities will be affected by the proposed
mining plan. Of this area, 2,000 aores of forests and 1,780 aores of wet-
lands (swamps and marshes) will be disturbed* This loss of natural vegeta-
tion on these areas will have a larger negative impact on the terrestrial
ecology and wildlife habitat more so than the loss of pasture land. The
mining operation will result in the displacement and loss of numerous plant,
animal, bird and other wildlife species. The mitigative measures suggested
in the reclamation plan are excellent. We support the EPA preferred
alternative and reclamation plan. We hope the provisions of the plan are
carried out and that careful monitoring is conducted to see that this is
done. Although provisions were made in the plan to plant approximately 453
acres of slash pine, we would suggest establishing additional pine plantings ^
on good forest sites, especially in the upland mixed forest and pine 1
flatland sites. Plantations of eucalyptus might also be established. High
yielding, well managed pine plantations would produce at least 150 board
feet/per acre per year through a rotation.
m
Some mention should be made of plans to salvage commercial timber and pulp- 1
wood in areas that will be olearcut prior to mining operations. ^
It is suggested that MobU Chemical contact the District Forester or the ^
State Forester, Florida Division of Forestry to request assistance on the '
forestry recommendations of the reclamation plan and its implementation. >
The State Foresters address is Mr. John Bethea, Division of Forestry,
Florida Department of Agriculture and Consumer Services, Collins Building,
Tallahassee Fl. 32301.
3-4
FS-MBMKMOl)
-------
Ms. A. Jean Tolman
2
3* Another important concern, whioh wa have* is the effeot of the use of
large quantities of ground and surface water for the mining and beneficia-
tion process. The presented data shows there will be little affect on water
levels and water supplies neoessary for the mining prooess, as well as, the
irrigation systems and wells already in operation. However, if more mining
operations were started and more wells for irrigation drilled in Polk and
surrounding counties, there no doubt would be an adverse effeot on the water
tables, levels, and aquifers espeoially in times of low rainfall and drought.
Water levels and water quantities and qualities should be constantly monitored
to make certain that aquifers are being reoharged and not being destroyed
when actual mining operations are being oonduoted.
We appreciate the opportunity to review this draft SIS and look forward to
receiving a copy of the final when it is published.
Sincerely
Area Director
-------
FLORIDA DEPARTMENT OF STATE
George Firestone
Secretary of State
October 7 , 1981
In reply refer to:
Mr. Louis Tesar
Historic Sites Specialist
(904) 487-2333
Ms. A. Jean Tolman, EIS Project Officer
Environmental Protection Agency
Region IV
345 Courtland street, Northeast
Atlanta, Georgia 30365
Re: September 10, 1981 Letter and Attachments
Cultural Resource Assessment Request
Draft Environmental Impact Statement
Mobil Chemical Company, Pouth Port Meacle Mine
Polk County, Florida
Dear Ms. Tolmans
In accordance with the procedures contained in 36 C.F.R.,
Part 800 ("Procedures for the Protection of Historic and
Cultural Properties"), we have reviewed the above referenced
project for possible impact to archaeological and historical
sites or 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 Presiden-
tial Executive Order 11593 ("Protection and Enhancement of the
Cultural Environment").
As per our earlier December, 1980 review of the proposed
project area, and in consideration of the results of the archaeo-
logical and historic site assessment survey of that tract, it is
the opinion of this agency that the proposed project is unlikely to qg
affect any sites listed, or eligible for listing, on the National I
Register of Historic Places, and may proceed without further in- ^
volvement with this agency.
If you have any questions concerning our comments, please do
not hesitate to contact us.
3-6
FLORIDA-State of the Arts
-------
Ms. A. Jean Tolman
October 7, 1981
Page Two
On behalf of Secretary of State George Firestone, thank you
for your interest and cooperation in preserving Florida's historic
resources.
Deputy State Historic
Preservation Officer
GWP:Teh
3-7
ENVIRONMENTAL IMPACT STATEMENT
BRANCH
ifiiesEiimzEj
OCT 14 1981
[EisEirrauj
REGION IV - EPA
-------
United States
Department of
Agriculture
Soil
Conservation
Service
P. 0. Box 1208
Gainesville, FL 32602
Subject: EVT - Draft Environmental Impact Statements
Date: October 8, 1981
ro: A. Jean Tolman, EIS Project Officer
U.S. Environmental Protection Agency - Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
O)
We have no comments on the Draft Environmental Impact Statement for the ^
Mobile Chemical Company, South Fort Meade Mine, Polk County, Florida.
Mitchell
State Conservationist
cc: Norman Berg, Chief, NO, SCS, Washington, D.C.
wa2 ¦ ai M0irr-H
v
! .W'i.
I
.~.j ' -i w j 11,; '¦
lM3W"i^S iJ • v :¦ ¦ "
4
The Son Conservation Service
ib an igancy oI the
Department of Agriculture
3-8
-------
BOARD OF COUNTY COMMISSIONERS
POLK COUNTY
TELEPHONE (813) 833-1 Iflt
P.O. 80X 60
BARTOW, FLA. 33830
October 19, 1981
Ms. A. Jean Tolman, EIS Project Officer
Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Ms. Tolman:
Attached hereto is a copy of the Resolution as approved by the
Board of County Commissioners on September 22, 1981.
The plans submitted by Mobil include EPA's preferred waste disposal
and reclamation alternative, which involves a sand clay cap. Mobil
has also committed as a condition of its County Development Order to
review advances in waste disposal and reclamation technology and
incorporate advances that are feasible at a plant scale.
Furthermore, the company has agreed to study wetlands restoration
and conduct a pilot project so that the best possible wetlands reclam-
ation can be determined from actual field experience. Finally, the
plans proposed by Mobil emphasize the use of tailings fill in areas
along the Peace River and Mount Pisgah Road, which are most likely to
be in demand for a high variety of uses in the future. Clay disposal
areas, which have a more limited fanal land use, are restricted gene-
rally to interior portions of the tract and are planned for reclammation
to the best possible agricultural uses. This is consistent with local
land use planning desires.
Polk County has officially approved this project on the basis of O
plans consistent with those reviewed and recommended by EPA. We appre- 7
ciate your consideration of our comments.
Sincerely,
JS/mb
Attachment
3-9
BOARO OF COUNTY COMMISSIONERS
¦randa Taylor Prank "»uod«" Smith JackSlmmara Krnia Caldwail Weyea RaacSy
lukaiand, out. 1 Bartow, DM. 2 wintar hum, out. S Hainai city, out. a Ukaiand, out. S
-------
Exhibit A
Legal Description
South Fort Meade Mine
Mobil Chemical Company
Polk County
Al I in Township 32 S. Range 25E
Section 10 SE 1/l» of SE l/'k
Section 11 SW 1/4 of SW 1/4
NE 1/4 of SW 1/4 that pare east of Plsgah Road
West 1/2 of SE 1/4
E 1/4 of HE 1 A of SE 1A
Section 12 SW 1A less Oishong Road
S 1/2 of SE 1A lass Dishong Road
NW lA of SE 1/4 chat part soueh of Dishong Road
Section 13 All
Section 14 E 1/2
SW 1A less Mt. Pisgah Road
W 1/2 of SW lA of NW 1A
Section 1$ E 1/2
E 1/2 of NW 1/4
Section 22 E 1/2
NE 1/4 of SW 1/4
E 1/2 of NW 1/4 that part east of Peace River
Section 23 N 1/2 less Plsgah Road
W 1/2 of SW 1/4 less Plsgah Road and
less 6 acres in the SW 1/4 adjacent to Pisgah Road
NE 1/4 of SE 1/4
N 1/2 of NW1/4 of SE 1/4
N 1/4 of S 1/2 of NW 1/4 of SE 1/4
N 1/2 of NE 1/4 of SW 1/4 less Pisgah Road
Sec t ion 24 All
Section 25 All
3-10
-------
Section 26 E 1/2
E 1/4 of S 1/4 of SE 1/4 of SW 1/4
N 1/4 of NE l/A of SW 1/4 less Pisgah Road
E 3/4 of S 1/2 of H 1/2 of NE 1/4 of SW 1/4
S 1/2 of W 1/4 of S 1/2 of N 1/2 of NE 1/4 of SW 1/4
less Pisgah Road
E 1/2 of SE 1/4 of WW 1/4
S 1/2 of SW 1/4 of SE 1/4 of NW 1/4 less Pisgah Road
S 1/2 NE 1/4 SW 1/2
SE 1/2 of NE 1/4 of SW 1/4 of SE 1/4 of NU 1/4
S 1/2 of NE 1/4 of NW 1/4 less Pisgah Road
N 1/2 Of NW 1/4 of NW 1/4 less Pisgah Road
W 3/4 of SW 1/4 of NW 1/4
SW 1/4 of SW 1/4 less Pisgah Road
N 1/4 of NW 1/4 of SW 1/4 less Pisgah Road
W 3/4 of S 1/2 of N 1/2 of NW 1/4 of SW 1/4
N 3/4 of E 1/4 of S 1/2 of N 1/2 of NW 1/4 of SW 1/4
less Pisgah Road.
N 1/4 of W 3/4 of S 1/2 of NW 1/4 of SW 1/4
W 1/4 of SW 1/4 of NW 1/4 of SW 1/4
W 3/4 of E 1/2 of Sw 1/4 of NW 1/4 of SW 1/4
Section 27 NE 1/4 ©
N 1/2 of SE 1/4 I
SE 1/4 of SE 1/4 £
Section 34 E 1/2 of HE 1/4
E 1/2 of SE 1/4 less County Line Road and
Less the E 1/2 of SW 1/4 of SE 1/4 of SE 1/4 of Sc
1/4 and
Less the SE 1/4 of SE 1/4 of SE 1/4 of SE 1/4 and
Less the NE 1/4 of NE 1/4 of SE 1/4 of NE 1/4 of SE
1/4
Section 35 NE 1/4
E 1/2 of NE 1/4 of NW 1/4 less Pisgah Road
NW 1/4 of NW 1/4 less NE 1/4 less Pisgah Road
N 1/2 of SW 1/4 of NW 1/4 less Pisgah Road
W 1/2 of N 1/2 of S t/2 of SW 1/4 of NW 1/4
S 1/4 of SW 1/4 of NW 1/4 less Pisgah Road
SE 1/4 of NW 1/4
N 1/2 of NE 1/4 of SE 1/4
SE 1/4 of SE 1/4 less County Line Road
NW 1/4 of SE 1/4
NE 1/4 of SW 1/4 of SE 1/4
NE 1/4 of NW 1/4 of NW 1/4
East 7 acres of S 1/2 of N 1/2 of NE 1/4 of SW 1/4
S 1/4 of NW 1/4 of SW 1/4 less Pisgah Road
E 3/4 of N 1/2 of S 1/2 of NW 1/4 of SW 1/4 Lass
Pisgah Road
N 1/2 of NW 1/4 of SW 1/4 less Pisgah Road
Section 36 All less County Line Road
3-11
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All in Township 32 S. Range 26 E
Section 3
Section 4
Section 8
Section 9
Sec t i on 10
S t/4 less SE 1/4 of SE 1/4 of SE \/b and
Less Lake Buffum Road
NE 1/4 of SE 1/4 less Lake Buffum Road
S 3/4 of NW 1/4 of SE 1/4
S 1/2 of N 1/4 of NW 1/4 of SE 1/4
S 1/2 of SW 1/4
S 1/2 of NW 1/4 of SW 1/4
NE 1/4 of NE 1/4
E 1/2 of NW 1/4 of NE 1/4
S 1/2 of E 1/2 of W 1/2 of NW 1/2 of NE 1/2
N 3/4 of SE 1/4 of NE 1/4
NE 1/4 of SW 1/4 of HE 1/4
N 1/2 of SE 1/4 of SW 1/4 of NE 1/4
N 3/4 of E 1/2 of W 1/2 of SW 1/4 of NE 1/4
SE 1/4 of SE 1/4
NW 1/4
N 1/2 of NW 1/4 of SW 1/4
NW 1/4 of NE 1/4 of SW 1/4
SW 1/4 of SW 1/4
S 1/2 less Lake Buffum Road
NW 1/4
S 1/2 of NE 1/4 less Lake Buffum Road
NW 1/4 of NE 1/4 less SE 1/4
Section 14
Section 15
Section 16
Section 17
Section 18
Section 19
Section 20
NW 1/4 less Lake Buffum Road
N 3/4 of E 1/2 less Lake Buffum Road
W 1/2
A11
All
All
All
E 1/2
HE 1/4 of NW 1/4
W 1/4 of W 1/4
Section 21
A11
3-12
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Section 22 W 1/2
W 1/2 of SE 1/4
SE 1/4 of SE 1/4
Section 27 N 1/2 of NE 1/4
W 1/2
Section 28 N 1/2
SE 1/4
E 1/2 of SW 1/4
SW 1/4 of SW 1/4
Section 29 S 1/2
W 1/2 of NW 1/4
SE 1/4 of NW 1/4
Section 30 All
Section 31 All less County Line Road
Section 32 Ail less County Line Road O
*-
Section 33 All less County Line Road ^
Section 3^ W 1/2 less County Line Road
A 100.0 foot wide railroad right-of-way easement, 50.0 feet each side of a'
center-line described as follows:
Cormence at the intersection of the Easterly right-of-way of the Seaboard
Coastline Railroad and the South boundary of the North one-quarter of
Section 33, Township 32 South, Range 25 East, Polk County, Florida, run
thence North 07°32'40M East along the said right-of-way, 662.03 feet to the
Point of Beginning. Said Point of Beginning being on a curve concave to
the Northeast having a radius of 955.37 feet, thence Southeasterly along
said curve through a central angle of 5I°23'43", an1 arch distance of 356-98
feet to the South boundary of the North one-quarter of said Section and the
end of this description.
and
3-13
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Ccrcnence ac the intersection of the Easterly right-of-way of the Seaboard
Coastline Railroad and the South boundary of the North one-quarter of
Section 33, Township ]2 South, Range 25 East. Polk County, Florida, run
thence North 89°1*9,17" East along the South boundary of the North one-
quarter, 595-05 feet to the Point of Beginning. Said Point of Beginning
being on a curve concave to the Northeast having a radius of 955-37 feet,
thence Southeasterly along said curve through a central angle of
16°53119". an arc distance of 281.61 feet to the P.T. of said curve, thence
South SQ°2V43" East, 9^7.^2 feet to the P.C. of a curve concave to tr.e
North having a radius of 955-37 feet, thence Southeasterly along said curve
through a central angle of Q3°32'33", an arc distance of 59.06 feet to the
East boundary of the Southwest quarter of the Northeast quarter of said
Section 33 and the end of this description.
and
Commence at the Northwest corner of the Southeast quarter of the "ortheast
quarter of Section 33, Township 32 South, Range 25 East, Polk County,
Florida, run thence South 00°15'19" East along the West boundary of the
Southeast quarter of the Northeast quarter, 256.60 feet to the Point of
Beginning. Said Point of Beginning being on a curve concave to the North
having a radius of 955.37 feet, thence Easterly along said curve through a
central angle of 17°5^'28", an arc distance of 298.60 feet to the P.T. of
said curve, thence North 78o08'10" East, 352.3** feet to the P.C, of a curve
concave to the South having a radius of 955.37 feet, thence Easterly along
said curve through a central angle of 11°38'46", an arc distance of 19^.19
feet to the P.T. of said curve and the end of this description, being
located South 0Qo17'^3" East, 50•0 feet from the Northeast corner of the
Southeast quarter of the Northeast quarter of said Section 33-
and
Commence at the Northwest corner of the Southwest quarter of the Northwest
quarter of Section Township 32 South, Range 25 East. Polk County,
Florida, run thence South OOOiy'^B" East along the West boundary of the
Southwest quarter of the Northwest quarter, 50'0 .feet to the Point of
Beginning, run thence North 890^6'56" East, parallel with the North
boundary of the Southwest quarter of the Northwest quarter and the North
boundary of the Southeast quarter of the Northwest quarter, 26^6.56 feet to
a point South QQ0^^" East, 50.0 feet from the Northeast corner of the
Southeast quarter of the Northwest quarter of said Section and the end
of this description.
West 1/2 of Ea 51 1/2 of Section 3^»
and
Southwest lA of Southeast I/1* of Section 27,
and
3-14
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East 1/2 of Northwest 1/4 of Section 27,
and
Southeast 1/4 of Southwest 1/4 of Section 22, all lying in Township J2
South, Range 25 East, Polk County, Florida.
The West 1/2 of the East 1/2, east of Peace River, Section 34. T'no
Southwest 1/4 of Southeast 1/4, Section 27. That part of the South 1/2 of
Southwest 1/4 of Northwest 1/4, west of Mt. Pisgah Road In Section 35 of
approximately 7.5 acres.
All in Township 32 South, Range 25 East, Polk County, Florida.
South 3/4 of East 1/2 of West 1/2 of Section 20 and Northeast I/- of
Northwest 1/4 and Northeast 1/4 of Section 29, and Northwest 1/4 of
Southwest 1/4 of Section 28, alt being in Township 32 South, Range 26
All in Township 32 South, Range 25 East, Polk County, Florida, described as
follows:
Section 26 - V/ 1/2 of SE I/1* of SW 1/4 and the north 12 acres
of E 1/2 SE 1A SW 1/4 and the N 3/4 of W 1/2 of
SE 1/4 of NW V/4.
The S 1/2 or the NW 1/4 of the NW 1/4, Section 26, Township 32 South, Range
25 East, Polk County, Florida.
South 15 acres of NW 1/4 of SE 1/4
Lying in Section 26, Township 32 South, Range 25 East, Polk Councv.
Florida.
3-15
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RESOLUTION
A Resolution of the Board of County Commissioners
of Polk County, Florida, Issuing a development
order of approval with conditions for an applica-
tion for approval of a development of regional
Impact known as the South Fort Meade Phosphate
Mine, submitted by Mobil Chemical Company; setting
forth findings of fact, conclusions of law, and
conditions of approval pursuant to Chapter 380,
Florida Statutes.
WHEREAS, the Polk County Board of County Commissioners, hereafter
referred to as "the 8oard," as the governing body of local government having
jurisdiction pursuant to Section 380.06, Florida Statutes, is authorized and
empowered to consider applications for a development of regional Impact; and
WHEREAS, the Mobil Chemical Company, hereafter referred to as
"Mobil," has filed the following documents with the Board pursuant to Section
380.06, F.S.:
1. An Application for Development Approval, hereafter referred to as
"the Application," dated May 4, 1981 seeking approval of a phosphate
mine development of regional Impact;
2. Amendments to the Polk County mine site plan, hereafter referred to
as "Amendments," which conform the original site plan to the above-
referenced application, which amendments are dated August 28, 1981.
WHEREAS, the Board held a duly noticed public hearing on said applica-
tion on September IS, 1981 as required by Section 380.06, Florida Statutes; and
WHEREAS, Mobil, other units of Government, local agencies and Inter-
ested citizens were afforded the opportunity to participate 1n all proceedings
before the Board relating to the application and were provided the opportunity
to present witnesses, evidence and argument on all Issues, conduct
cross-examination, and submit rebuttal evidence; and
WHEREAS, the Board has reviewed all of the above referenced evidence.
NOW, THEREFORE BE IT RESOLVED BY THE BOARD OF COUNTY COMMISSIONERS OF POLK
COUNTY, FLORIDA, THAT THE APPLICATION AND AMENDMENTS SUBMITTED BY MOBIL CHEMICAL
COMPANY ARE HEREBY APPROVED WITH CONDITIONS, SAID APPROVAL BEING BASED UPON THE
FOLLOWING FINDINGS OF FACT AND CONCLUSIONS OF LAW.
I. FINDINGS OF FACT
A. Mobil submitted the application to the Board on May 12, 1981, said
application being Incorporated and made a part of this resolution by
reference.
B. The South Fort Meade Mine Involves approximately 16,288 acres which
are currently owned or controlled by Mobil. A complete legal
description is attached as exhibit A. Recovery of the reserves on
this tract will require the mining or disturbance of approximately
15,194 acres, with the remaining 1,094 acres left undisturbed
primarily due to environmental considerations.
C. The Application also Involves the construction of ore processing and
mine facilities. The first phase of mining 1s scheduled to begin
approximately two years after the initiation of construction at an
annual rate of about 1.7 million tons of product. The second phase
of construction will result in production capacity of approximately
3.4 million tons per year.
3-16
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0. The South Fort Meade Mine will replace production currently being
provided by Mobil's Fort Meade mine, which 1s expected to be mined
out in the near future.
E. The proposed development 1s not located 1n an area of critical
state concern as designated pursuant to Section 380.05, F.S.
F. Florida has adopted a statewide comprehensive Plan.
G. The Board has adopted a Comprehensive Plan for Polk County pursuant
to Section 163.3161, F.S., which Is applicable to the development
site.
H. The property encompassed by the proposed development 1s presently
zoned Rural Conservation (RC) and no specific rezonlng 1s required
for mining, provided that all other local permits, including an
up-to-date mine site plan, are approved by the Board.
1. The proposed development is a temporary land use and 1s compatible
with surrounding adjacent land uses, including citrus production
and other agricultural activities.
J. Subject to the conditions provided herein, the proposed development
will not have an unfavorable impact on the environment and natural
resources of the region.
K. The proposed development will have a favorable Impact on the economy
of the region.
L. The proposed development will not significantly burden the existing
public facilities of the region. Including transportation facilities.
M. The proposed development will not adversely affect the ability of O
people to find adequate housing reasonably accessible to their place ""j"
of employment. ^
N. Existing sources of energy are sufficient and will not be unduly
burdened by the proposed development.
0. Waste disposal and land reclamation technologies have been thoroughly
evaluated by Mobil and considered by the Board. Specifically, the
Board finds that:
1. The waste disposal and reclamation plan proposed by Mobil
Incorporates advanced technology In the form of a sand/clay cap,
which will promote reclamation of clay storage areas and provide
improved agronomic properties of the affected reclaimed areas;
2. The configuration of tailings fill areas proposed by Mobil pro-
vides a desirable buffer for the Peace River and Bowlegs Creek;
3. The tailings fill and overburden fill areas provide for a voHety
of ultimate land uses and have a more positive ad valorem tax
impact than those areas containing clay wastes;
4. There is insufficient sand available for a full-depth sand/clay
mix 1n all clay storage areas;
5. Other waste disposal technologies which were considered by Mobil,
such as the use of flocculents, have not been demonstrated as
feasible or beneficial at a plant scale;
6. Disregarding ultimate land use and related land planning concepts,
some above-grade settling could be reduced by distribution of
waste clays over a greater portion of the tract, however, this
distribution of clays is Inconsistent with local land use plan-
ning and is specifically rejected by Polk County.
3-17
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7. One of the proposed clay settling areas Is located within the
100 year floodplain of Bowlegs Creek and presents a potential
for Increased downstream flooding.
8. Mobil proposes to reclaim approximately 1,421 acres of non-
forested wetlands (freshwater marsh) but has not prepared any
specific revegetation plans. The application states that Mobil
will utilize the best state of the art technology available.
P. The property encompassed by the proposed development contains
several "out parcels" not owned or controlled by Mobil at the time
the application was made. These parcels are located within the
interior of the South Fort Meade Mine. Although the application
does not Include the mining of these "out parcels," Mobil does plan
to purchase and mine at least one of these parcels. Inclusion of
these parcels Into the mining plan and subsequent reclamation will
not result 1n any increased regional impacts.
Q. The data and information contained within the application were
sufficient for the Board to perform the impact review required by
Section 380.06, F.S.
R. On September 15, 1981 the Board convened the required public hearing
on the application, heard testimony and received evidence and docu-
ments pertaining to the application Including the report and
recommendation of the Central Florida Regional Planning Council and
the report and reconmendatlon of the Polk County Planning Department.
CONCLUSIONS OF LAW
A. The Boards' review of the application has been conducted pursuant to
and complied with the provisions of Chapter 380, F.S.
B. The application as submitted, complies with the requirements of
Section 380.06, F.S. and Chapter 22-F, Florida Administrative Code.
C. .The development, as modified by the conditions herein, 1s consistent
• with the report and reconmendatlon of the Central Florida Regional
Planning Council.
D. The development, as modified by the conditions herein, Is consistent
with the Polk County Comprehensive Plan and local land development
requlatlons.
E. The State Comprehensive Plan 1s advisory and Is not Inconsistent
with the proposed development.
F. All development activities described in the application shall be
subject to the terms of this development order and shall not be
Subject to future development of regional impact review pursuant to
Section 380.06. F.S. unless the Board determines that any proposed
changes to the development constitute a substantial deviation
pursuant to Section 380.06(17), F.S. and the conditions herein.
G. The provisions of this development order shall not be construed as
a waiver or exception of any rule, regulation, or ordinance of Polk
County and, therefore, any further review and approval required by
Polk County shall be subject to all such applicable rules, regula-
tions or ordinances 1n effect at the time of review.
H. The annual report of mining operations required by Polk County
regulations 1s an appropriate vehicle for monitoring the development,
as required by Section 380.06(14)(c>(1) and further is an appropriate
vehicle for the annual report required by Section 380.06(14)(c)(3),
and shall be utilized to satisfy those provisions of Chapter 380,
F.S.
I. The Polk County Code Enforcement Director shall be the local official
responsible for assuring compliance with this development order.
3-18
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BE IF FURTHER RESOLVED BY THE BOARD OF COUNTY COMMISSIONERS OF POLK COUNTY,
FLORIDA THAT THE APPLICATION IS APPROVED SUBJECT TO THE FOLLOWING CONDITIONS:
III. CONDITIONS
A. Location of Above Grade Clay Settling Areas
No above grade clay settling areas shall be allowed within the 100
year floodplaln of Bowlegs Creek.
B. Above Grade Storage Areas
Mobil Chemical Company will adopt advances 1n Technology concerning
waste disposal which are feasible on a plant scale and would result
1n a reduction of above grade storage of clay. Mobil will review
advances 1n technology which are feasible on a plant scale and
address their applicability 1n their annual report of the South Fort
Meade Mine Development of Regional Impact.
C. Reclamation of Freshwater Marsh
Prior to the commencement of the reclamation of 1,421 acres of non-
forested wetlands, Mobil Chemical Company shall design and conduct
a scientifically defensible study. This study shall evaluate water
quality and plant and animal species diversity of freshwater marshes
created using such techniques as natural revegetatlon, the trans-
planting of desired vegetation, and the utilization of substrate
from existing marshes as a seed source. The results of this study
shall be utltlllzed 1n determining Mobil's freshwater marsh reclama-
tion technology,
"• Substantial Deviations
1. Any proposal by Mobil to mine within the 25 year floodplaln of
Bowlegs Creek shall be considered by the Board as a substantial
deviation.
2. Any proposed changes to the application which Involve the
following shall be submitted to the Board for a determination
1f such change constitutes a substantial deviation and, there-
fore, requiring further review pursuant to Section 380.06, F.S.
a. Any Increase 1n the area to be mined except for any "out
parcels" located within the Mobil Tract.
b. Any increase 1n the above grade clay settling areas except
for waste clay disposal resulting from the mining of "out
parcels", provided such disposal and reclamation 1s
performed 1n the same methodology used for the South Fort
Meade Mine and otherwise compiles with the conditions of
this development order.
c. Any change which would result 1n an Increase 1n the regional
Impacts.
3. The following changes shall be presumed not to be substantial
deviations requiring further review.
a. Any decrease 1n the area used for above grade clay settling.
b. A decrease 1n the regional Impact of the development.
c. A change required by permit conditions or requirements
Imposed by the Department of Environmental Regulation, the
Department of Natural Resources, the Southwest Florida Water
Management District, or any of their successor agencies or
by any appropriate federal regulatory agency.
3-19
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E. Polk County Mining Regulation
This Development Order approves conceptual mining and reclamation
plans. Actual mining operation implementing these plans shall
comply with the Polk County mining ordinance 1n effect at the time
of mining. This condition shall not restrict or preclude Mobil
from participating fully in amendments to the Polk County mining
ordinance or adoption of new ordinances, or otherwise seek relief
from regulations imposed by the Board.
F. Annual Report
MbbiJ shall submit the annual report of mining operations as
required by Polk County regulations to the Polk County Code
Enforcement Director# the Central Florida Regional Planning
Council, the state planning agency, and all affected permit
agencies pursuant to Section 380.06(16), F.S. on or before the
fifteenth day of February of each year, beginning February 15,
1983.
6. Expiration
This development order shall take effect upon approval and shall
remain in effect for the life of the mine, not to exceed forty
(40) years.
H. Recording of Notice of Adoption
Notice of th« adoption of this development order shall be recorded
by Mobil 1n accordance with the provisions of Section 3S0.06(14)(d),
F.S. within 15 days after its adoption.
DULY PASSED AND ADOPTED BY THE BOARD OF COUNTY COMMISSIONERS OF POLK COUNTY,
FL0RI0A, THIS 22nd DAY OF September . 1981.
Boa ity Commissioners of Polk County
~Chairman \
ATTC5T:
E. 0. "Bud" Oixon, Clerk
3-20
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Mobil Chemical Company
PHOSPHORUS DIVISION
PO BOX 311
NICHOLS. FLORIDA 33863
TELEPHONE (813) 425-3011
October 22, 1981
Ms. A. Jean Tolman
Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Ms. Tolman:
Mobil Chemical Company respectfully submits its comments on the Draft Environ-
mental Impact Statement (DEIS) prepared for the proposed South Fort Meade Mine.
Mobil supports the overall analyses, conclusions and recommendations set forth
in the DEIS. We realize that it represents many months of intensive effort by
numerous expert consultants and EPA. The document presents a clear discussion
of phosphate mining, subsystem alternatives, and mitigation measures. This
presentation of material enables the public to have a better understanding and
awareness of the industry.
Mobil does express concern over the NPDES condition that the sand/clay cap
method of waste disposal and reclamation must be utilized. The sand/clay cap
method has never been practiced in full scale in the mining Industry. Based
on the paper evaluation the sand/clay cap plan appears to be feasible and
Mobil is committed to a full field scale program; however, as with any new
procedure there are always unforeseen problems and the risks and costs may be
greater than we now envision. Miobil will invest considerable funds to employ ^
this technique. However, if the sand/clay cap disposal technique should fail r-
Mobil would then request that EPA reconsider permit condition Bl. ^
The preparation of the EIS has already taken several years and delayed Mobil's
development schedules. Mobil desires to continue in this process as expedi-
tiously as possible within the requirements of the law. Any problems or
conflicts must be Immediately attended to and resolved with Mobil's commitment
to being responsive to the needs of EPA to bring this process to a timely end
point. Mobil urges the Agency to move with reasonable speed to respond to
public comments, prepare the final EIS and issue the final NPDES permit for
the discharge subject to appropriate conditions. Mobil is committed to com-
pliance with all applicable Federal, State and local environmental and land
use requirements.
Mobil Chemical Company
South Fort Meade Mine (Polk County, Florida)
Sincerely yours,
ec
REGION IV ¦ EPA
-------
DEPARTMENT OF HEALTH & HUMAN SERVICES
Public Health Service
Centers for Disease Control
Atlanta, Georgia 30333
(404) 262-6649
October 28, 1981
Ms. A. Jean Tolman
EIS Project Officer
U.S. Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Ms. Tolman:
We have reviewed the Draft Environmental Impact Statement for the Proposed
Issuance of a New Source National Pollutant Discharge Elimination System
(NPDES) Permit to the Mobil Chemical Company for the South Fort Meade Mine
in Polk County, Florida. We are responding on behalf of the Public Health
Service and are offering the following comments for your consideration in
preparing the Final EIS.
With some exceptions, it appears that the EIS has satisfactorily addressed
the environmental impacts of the proposed project. We believe the EIS
should still address: the project's effects upon local vector populations ^
and control efforts, cumulative effect of groundwater withdrawals from this o0
mine and any other existing or proposed mining activities in the area, and <*5
the status and effectiveness of State and Federal legislation and local T"„
planning efforts to prohibit noncompatible development of reclaimed, debris,
or unmined lands producing radiation (radon and radon progeny concentrations 1
and gamma exposure levels) in excess of applicable State and Federal guidelines. j£
Disposal basins, ponds, "shallow depressions," and overflow swales should be
designed and managed to prevent the increase of any vector populations that
have the potential to cause vectorborne disease or nuisance problems. The
capability of local health authorities and mining personnel to detect and
prevent excessive onsite breeding of problem vectors should be discussed. ^
Consideration should be given to incorporating the above recommendation on
vector management and control as a permit condition.
CM
*—
I
£
Under either Mobil's reclamation plan or EPA's preferred reclamation plan,
a considerable portion of the reclaimed Mobil site will still exceed the
recommended gamma exposure level limits and indoor radon working level (WL)
concentrations. Even though residential development of reclaimed lands is
not planned or anticipated, special measures must still be taken to assure
compatible use of these reclaimed lands in the future. Optimally, all re- y
claimed lands should be in compliance with applicable State and Federal «>
radiation guidelines and/or standards before being sold or transferred by
the applicant. Consideration should be given to placing a deed restriction
on the reclaimed lands that requires: (1) the property to be in compliance
3-22
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Page 2 - Ms. A. Jean Tolman
with applicable State and Federal radiation standards before any structures can
be constructed or (2) the use of special structural design features to permit
compliance with applicable standards.
in
Will Mobil's proposed project provide for recirculation of waters recovered y
from slimes and waste clays? While this is a recommendation of the areawlde >
EIS, it does not appear that the disposition of water from clay disposal (Table ^
2.1-3 Mine Water Balance) accounts for any recirculation of decanted waters
except for "waste clay ore water (non-supply)." Since substantial quantities
of water (11.6 ragd) would be entrained in the waste clays, has any consideration
been given to implementing measures to increase the solids concentrations for
faster recovery of entrained waters?
<0
The potential safety hazards of the proposed project activities and facilities, y
such as the waste clay disposal areas, should be discussed. Will all unsafe areas >
be fenced and posted? ^
We appreciate the opportunity to review this Draft EIS. Please send us one copy
of the Final EIS when it becomes available. Should you have any questions regarding
our comments, please call Robert Kay of my staff at FTS 236-6649.
Sincerely yours,
Chief, Environmental Affairs Group
Environmental Health Services Division
Center for Environmental Health
' V;- •
3-23
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203 Lake Pansy Drive
Winter Haven, Florida
33880
29 October 1981
Ms, A. Jean Tolman
EIS Project Officer
Environmental Protection Agency
Region IV
3^5 Courtland Street, N. E.
Atlanta, Georgia 303^5
Dear Ms. Tdraani
Enclosed are comments in regard to the Mobil Chemical
Company, South Fort Meade Mine, Polk County, Florida applic-
ation for NPDES permit and Draft EIS. The presentation of the
company case to permit conventional mining with conventional k
waste clay (slime) ponds represents a potential degradation to
the econ-systems of the area and further irreparable damage to >
the flood plain and downstream activities of the Pease River.
The technology for waste clay disposal without the creation oo
of huge above grade impoundments has now been accepted as an *["
industry practice inthis part of the state and should be adhered
to by all new mining operations. The failure to accept new methods
only represents a further diminution of the resurces available
for use by the citizens of this region. If new technology is not
to be used then the burden of profif of why not should rest with
the company to establish that both the decision to use older less
favorable processes is in fact economically necessary for the good
of the country and that the harm which this does after developing
alternative processes to mitigate impacts do not due harm over
and above that benefit to be gained by the activity for which
permits are being requested.
Accrodingly it is respectfully requested that the comp-
any be asked to submit a new EIS describing the use of presently
accepted best available practices or conclusively prove that the
methods selected are in the best interests of this region and
the people therein. Accordingly it is further requested that no t
NPDES permit be issued for the South Fort Meade Mine until such 5
time as all parties concerned are assur-ed that ' • permitting
this conventional process would be only for this mine and not
be a precedent setting decision for future mines in the Bone
Phosphate Valley.
Sincerely yours, .
Richard L. Coleman
Chairman, Polk Group
Florida Chapter ea
Sierra Club
ENVIRONMENTAL IMPACT statement
3-24
KEGlON IV • EPA
-------
Comments on Draft Envirnomental Impact Statement
Mobil Chemical Company, South Fort
Meade Mine, Polk County,Florida
The proposed South Fort Meade Mine is planned on 16,288
acres owned and controlled "by Mobil Chemical Company east of the
Peace River in southwest Polk County. §f this land 15,19^ acres
are proposed for disturbance. Of this disturbed area 13*3^° acres
are planned for actual mining. Of this mined area 91683 acres are
planned for conventional clay settling areas. This settling pnd
area for slimes would comprise 72.6% of the mined land and 61$^
of the disturbed area. The company has made a case for conventional
limes settling areas due to the matrix composition percentages of
slimes, phosphates and clays.
Conventional settling areas are already the bane of Polk
County and the earlier mined areas of all the counties in the phos-
phate district where mining has been dine since the advent of the
flotation process in the late forties as a commonly accepted pract-
ice. Of all the mined land to date over tow thirds of the land is
in these slime ponds which defy so far the use of the land for
other purposes. Although mining is claimed as a "temporary use
of the land" this use of the word temporary seems to be in a geologists'
sense of millions of years and eons of development. Since the land
covered with limes storage has not been used in the lifetimes of
the men who did tte mining and since this practice has denial the use
of the land for either economically viable purposes of for the re-
estabilshment of viabla eco-systems which would benefit the disturbed
areas then for all intents and purposes the proposal of Mobil's to
turn 72.6# of the mined land into slime ponds represents a perm-
anent use of these areas along the Peace River for the foreseeable
future. The tax structure of the Polk County system allows these
acres to be taxed at a very low rate of $50 per year assessed value
and thus no real economic incentive exists for the company to do
anything differently than what they have proposed for thier ben-
efit but to the detriment of the region.
There is continuing research into better waste clay disp-
osal methods which would do away with slime ponds other than the
initial pond. Research has shown that conventional ponds create a
crust of about J8% solids within three years and that the body
below the crust retains about 16-17% solids and does not thicken
further due to the closeout of evaporation routes and the sealing
of the dikes against the clay plates giving up moisture by fine
particles creeping into the sand containments ad forming a virtually
impenetrable boundary for the escape of water. Knowing these facts
about conventional slime ponds there is no need to perpetuate their
creation by approving of a proposal like the one Mobil has here
advanced. If there is sufficient matrix constituency to preclude the
use of present sand/clay mix technology then pilot efforts should
be initiated to determine the best methods for eliminating the
conventional ponds from the Mobil site and when those methods are
found then mining could be permitted ceteris parabus~
3-25
-------
Some regional counties have already eliminated the use
of conventional settling ponds from any mining proposals in their
areas. The only exception is the allowance of one initial settling
pond for the life of the mine for thickening of the clays to
prepare for the mixing with sand tailings. Pdk County does not
enforce this new technologically feasiBe position and this becomes
the only county in the state which allows mining to proceed on
the basis of outdated technology and methods. This procedure works
against the economics and well-being of the region and the citizens
of the area and the county. In this Mobil site the impacts are even
moBe telling due to the proximity to the Peace River and the effects
on the tributaries and the eco.-systems which cannot be restored
dme to the lack of incentive on the part of the county and the
company to proceed in a manner which would ultimately benefit the
county by having useable reclaimed land on which the taxes could
be collected and for the economic benefit of the citizens who would
have a functioning area which would support future activity in
lieu of being left fallow for several generations whi&e the land
tried to reconstitute itself into some useable form.
Since all of the recently permitted new mines have been
atoject to this provision of sand/clay mixing this mine should be
handled in the same way. If further effort is needed on the parffcf
the company to make assurances that the process will work then they
should be given that time to ascertain that and then resubmit
their proposal. If they cannot use the latest technology then they
should not be permitted to mine until they have mastered it. If
they are either unalbe or unwilling to mine in accordance with the
best available preactices then someone else vhoud be given the
oppostunity to operate a mine on the property. At any rate no
mining should be allowed on the property until assurances are rec-
eived from the miner that conventional slime ponds will not be
used and that modern technology will be employed that is now known
and that which may become available over the life of the mine will
be incorporated in the-operations.
The company argument about proportion of clays to sand in
the matrix are more meaningful if the constituent parts are known.
The relative amounts of apatite versus the amounts of atapulgite
and montmorilonite are importatn* to any meaningful analysis of
whether or not to use sand/clay mix process. Until this information
is supplied the decision to go with conventional settling ponds
would appear to be premature.
3-26
-------
STATE OF FLORIDA
®ffitt of tl}t (Sofcrmtcr
THE CAPITOL
TALLAHASSEE 32304
Bob Graham
GOVERNOR
October 29, 1981
/->
0
<0
1
Ms. A. Jean Tolman 3?
Eis Project Officer x:
Environmental Protection Agency
Region IV O
34 5 Courtland Street, N.E. £
Atlanta, Georgia 30 365 **
~
»
Dear Jean: ^
Reference our telephone discussion of today regarding the
EISs by this date as the Deparment of Environmental Regulation,
the lead agency, assures me that they will be able to conform
with this new deadline.
Thank you very much for your consideration. ^
Sirio^rely, 1 ^ ¦
/ A
//Avv
ifatfter'O. Kolb
Sr. Governmental Analyst
WK/mew
cc: John Outland
^ ¦ '/
ENVIRONMENTAL IMPACT STATEMENT
BRANCH
n)EiaEBQ/7em
5V NOV 0 2 1QR1 11
3-27
EC5IL'LrIi"Eliii
REGION IV ¦ EPA
?!
An Affirmative Action. Equal Opportunity Employer
-------
United States Department of the Interior
OFFICE OF THE SECRETARY
Southeast Region / Suite 1412 /Atlanta, Ga. 30303
Richard B. Russell Federal Building
75 Spring Street, S. W.
ER 81/1931 November 2, 1981
Ms. A. Jean Tolman
EIS Project Officer
Environmental Protection Agency,
Region XV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Ms. Tolman:
The Department of the Interior has reviewed the draft environmental statement
for the Mobil Chemical Company, South Fort Meade Mine, Polk County, Florida,
and offers the following comments for your consideration:
General Comments
We find the draft statement to be rather comprehensive but note some mistakes
in the analysis and discussion of wetlands and wildlife resources.
Specific Comments
Page 2-74. Paragraph 3. Section 2.6.1. Reclamation Alternatives. Specific
marsh and swamp reclamation plans should be submitted at the beginning of the
project. This should be accomplished so that the environmental agencies and
conservation organizations will know what to expect of Mobil. Also, Mobil
will know what it must accomplish at the end of the mining operations. It
should also be understood by Mobil that the State may require 50 percent
herbaceous cover of nonforested wetlands in the wetlands reclamation plan but
the Federal requirement may differ significantly. Since Mobil believes that
future reclamation techniques will differ from those used presently, the
reclamation plan should contain a stipulation that: "this will be the
reclamation procedure unless new and better procedures for the establishment
of wetlands and swamps are established prior to the onset of reclamation."
3-28
-------
2
Page 2-76. Paragraph 1. Section 2.6.1 Reclamation Alternatives. Intense
cattle grazing is not compatible with wildlife production after reclamation.
The paragraph should indicate that, with eventual cattle use, any benefits to I
the wildlife will be greatly reduced. 5
Page 2-113. Section 2.8.1.2. Environmental Consideration. Environmental W
Disadvantages. The environmental disadvantages of not mining the phosphate |
must be explained.
Page 2-115. Section 2.9.1.2. Environmental Considerations. Environmental
Disadvantages. Mass loadings of nutrients to the Peace River will be
increased by this action. Mass loadings are as Important as nutrient
concentrations and may adversely Impact the biota. Therefore, the following
statement should be Included in this paragraph: "The mass discharges of
pollutant constituents could adversely affect the water quality and biota of >
the river."
Page 2-119. Paragraph 2. Section 2.11.2. Biological Resources. The
proposed monitoring procedures should be more detailed at this time. If there
are reasons for altering these procedures irf the future, then they may be
changed at that time. The procedures should be more specific so that Mobil u)
and the concerned agencies know what to expect as a result of the wetland ^
destruction and the removal of the phosphate. The following items should be ^
added to the monitoring:
1. Comparison, based upon diversity and similarity Indices, of the
restored wetlands vegetation to premlning wetlands of the same type.
2. Diversity and similarity indices computation for macroinvertebrates
in the reclaimed areas.
3. Water quality sampling.
Long-term monitoring should continue on all three wetland areas to determine
success and feasibility of reclamation techniques in that situation. These
reclamation practices are new. Therefore, it is not possible to assume
success by studying a single area.
These recommendations are made because the wetlands on the area will be
eliminated. Specific guidelines and assurances should be built in to assure
that the wetlands and fish and wildlife resources that are going to be
reestablished are as good as or better than those which existed prior to
mining.
3-29
-------
3
£
Page 3-74. Paragraph 1. Section 3.4.1.3.3. Lower Florldan Aquifer, It is
stated on Page 3-74 that Table 3.4-1 is to show the results of chemical
analysis of the water collected at the end of a 10-day pumping test of the ®
Lower Floridan Aquifer. Apparently this reference should be either to Table I
6-10 of the supplemental document or to an omitted table. ^
Additionally, the lists of aquifer data on pages 3-69, 3-71 and 3-72 of the
statement should include the storativity values determined for the aquifers ^
beneath the site. Values in the literature range from 0.003 for the Estech
Duette mine about 10 miles southwest of the South Fort Meade Mine site
(Table 4.7-A of the draft statement for the Estech General Chemicals
Corporation Duette Mine, Manatee County, Florida) to 0.00003 for the Desota
County locations referred to on Page 3-71; the latter are about 30 miles or
more southeast of the South Fort Meade site (Wilson, W.E., 1977, Groundwater
resources of DeSota and Hardee Counties, Florida: Florida Bureau of Geology
Report of Investigations No. 83, p. 41, 90). Thus, the site values are
significant for impact assessment.
Page 3-139, Line 6. Section 3.6.2.2.1. Mining Method Alternatives. There <0
needs to be a statement as to whether or not the fill will be removed from
Bowlegs Creek and swamp species planted following use.
Page 3-139. Paragraph 1. Section 3.6.2.2.1. Mining Method Alternatives.
Adverse Impacts of the dragline crossing should include a statement that its c«j
construction will eliminate productivity at and adjacent to the fill site. ^
Page 4-4. Section 4.6.1. Biology Short-Term. This section leaves the
impression that the animals that migrate will survive in the adjacent habitat.
This should be changed to read like that on Page 3-136, Section 3.6.2.2.1, O
which states that the project will most likely result in a net loss of faunal
resources. «£
This section also lacks a discussion of the loss of productivity of the *"*
wetlands that will result from d©watering and mining. The final document
should discuss productivity that will be lost from the time mining begins
until restoration is complete. This loss may be a few years for some wetlands
but more than 20 for others.
Page 4-4. Section 4.6.2. Biology Long-Term. There should be a discussion of ^
the change in the vegetation mosaic from premining to the post-mining conflgu- j
ration. Elevated wetlands provide feeding and breeding areas for birds and •£
amphibians. The early drying of these areas fills a specific need in the
natural environment. The proposed reclamation plan eliminates these areas and
creates a more homogeneous area. A habitat diversity measure should be used
to express this difference between the pre and post-mining communities.
3-30
-------
4
Summary Comments
The draft statement does not present sufficient discussion of mitigation and
biological impacts. Accordingly, the comments on this draft statement do not
in any way preclude additional and separate evaluation and comments by the
Fish and Wildlife Service, pursuant to the Fish and Wildlife Coordination Act, ^
since project implementation will require a Federal permit pursuant to the t
Federal Water Pollution Control Act, as amended. In the review of the >
application for such a permit, the Fish and Wildlife Service may concur, with
or without stipulations, or object to the proposed work, depending on the
magnitude of project effects which may be Identified and evident at that time
on wildlife resources.
In closing, we are encouraged that a meeting between representatives of the
Mobil and Estech Chemical Corporations, and agencies responsible for actions
that may affect wildlife resources, will be held on November 9, 1981 . in
Tallahassee. Such a meeting will, hopefully, help to resolve the very serious
reservations we have about the proposed mining program. We hope these
comments will be helpful to you.
Sincerely yours
ENVIRONMENTAL IMPACT STATEMENT
BRANCH
3-31
REGION IV • EPA
-------
STATE OF FLORIDA
©ffice of the doiimtfli*
Bon Oka ham
GOVERNOR
THS CAPITOL
TALUAHA9SCC 92301
November 12, 1981
Mrs. A. Jean Tolman
EIS Project Officer
Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, GA 30365
Dear Ms. Tolman:
This office, functioning as the state planning and development clearinghouse,
pursuant to your request, has reviewed and coordinated a state agency
review of the Draft Environmental Impact Statements for Mississippi
Chemical Corporation, Phosphate Mine, Hardee County, SAI #FL8109010351E
and Mobil Chemical Company, South Fort Meade Phosphate Mine, Polk County,
SAI #FL8109230441E. Attached for your consideration are comments and
information regarding these proposals from the Departments of- Environmental
Regulation, State, Veterans and Community Affairs and the Florida Game
and Fresh Water Fish Ccnmission. These proposals will have significant
irrpact on Florida's natural and economic resources, therefore, we recarmend
that extreme care and caution be exercised in your review process.
Ihe affected agencies, in addition to expressing a variety of technical
concerns, have suggested alternative mining proposals and activities
which should be considered by your agency in the granting of any
permits.
The State of Florida welcomes the opportunity to work with your agency
and the companies in resolving our concerns. To meet your November 13
deadline and in the interest of time, I have requested that the Department
of Environmental Regulation forward directly to you their contents on
the Mississippi Chemical Corporation's phosphate mine impact statement.
Sincerely,
Walter 0. Kolh
Sr. Governmental Analyst
WQK:dmc
Enclosures
cc: Steve Fax
F. G. Banks
George Percy
3-32
An Affirmative Action/Equal Opportunity Employer
-------
STATE OF FLORIDA
DEPARTMENT OF ENVIRONMENTAL REGULATION
twin towers office building
MOO BLAIR STONE ROAD
Tallahassee, Florida 32301
VICTORIA J. TSCHINKBL
SECRETARY
SOB QRAHaM
GOVERNOR
November 10, 1981
Mr. Walt Kolb
Senior Governmental Analyst
Of£lce of Planning and Budgeting-
Office of the Governor
415 Carlton Building
Tallahassee, Florida 32301
NOV 10 1981
once Of. THE governor
Dear Walt:
Re: Draft Environmental Impact Statement for Mobil Chemical's
South Fort Meade Phosphate Mine, Polk County, Florida
The draft environmental document was prepared pursuant to EPA1s
determination that the issuance of a new source National Pollution
Discharge Elimination System (NPDES) permit to Mobil Chemical Company
would constitute a major federal action significantly impacting the
quality of the environment. The document has been prepared in accordance
with HEPA requirements.
According to the document, Mobil Chemical's proposed mining operation
would produce 77 million tons of wet phosphate rock over the 25-year
life of the mine. A total of 15,194 acres of the 16,288 acre tract
would be disturbed by mining operations. The mine is designed to produce
3.4 million tons of phosphate rock annually and developed in two phases.
Mobil Chemical's mining and processing includes dragline mining,
pipeline slurry transport, beneficiationj sand/clay mix for waste disposal,
conventional reclamation of clay settling areas, groundwater withdrawal,
surface water discharge and wet rock transport. The proposed mining re-
operation is typical of the existing Central Florida Phosphate District
and exhibits no innovative technology for groundwater conservation or 3*
clay settling area reclamation.
The proposed milling plan anticipates disturbing 15,194 acres or 93
percent of the South Fort Meade mine site, including 2,055 acres of
wetlands and streambeds. Only 132 acres of wetlands consisting of a 75
acre cypress dome and buffer strips (25-year flood plain) along portions
of the Peace River and Bowlegs Creek are scheduled for preservation.
True preservation of these areas, however, is unlikely as drainage of 10
nearby areas associated with mining activities will deprive these wetlands cp
of water contributions from surface runoff and from the surrounding >
surficial aquifer causing them to dry up.
3-33
Protecting Florida and Your Quality of Life
-------
Mr. Walt Kolb
Page Two
November 10, 1981
Wetlands proposed for mining include 60,000 linear feet {11.36
miles) of tributary streams to the Peace River and Bowlegs Creek and
scattered freshwater swamps and marshes. The EIS justifies the elimination
of these aquatic systems by mining for the following reasons: 1. the
area has been disturbed by man-induced activities (drainage works and
cattle grazing), 2. species similarity between tributaries and receiving
systems was low, 3. species interchange between systems appeared minimal,
and 4. contribution of materials and species from the smaller tributaries
to the much larger river and creek systems was minimal.
A review of the Aquatic Biology Section of the environmental report
by our Biology Section in Tallahassee and our Technical Service Section
in Tampa raise questions concerning the biological data gathering methodology
and, therefore, the conclusions reached as to the ecological importance
of tho Poace River and contributary systems on the Mobil site. We
believe that the low faunal diversity (42 species) found by the investi-
gators in the Peace River and presented in Tables 8-10 and 11 of the ^
report is probably due to inappropriate sampling techniques (ponar eo
dredge grab sampling) for collecting invertebrates which are found on a J
variety of substrates, many clinging or attached to log surfaces and
rocks on or above the substrate. A more representative list of macro-
invertebrate species (110) was collected by DER from the Peace River
near the Polk-Hardee County line using artificial substrates, grab
samples and qualitative samples taken in composite. Another reason for
the contrast in the data may be due to the location of the sampling
site. A great deal of variability can be found in bottom grabs taken
from clean sand bottoms, leaf packs, pooled areas out of flow, gravel or
rock, etc. The Peace River, for example, depending on flow conditions,
may exhibit varying substrates which influence the presence or absence
of certain organisms. This, however, should not be taken as an indication
that most of the organisms have been "flushed" from the area. We believe
the use of artificial substrates during the same sampling period would
have helped to overcome an apparent sampling bias and possibly produce a
picture of a more stable aquatic environment. Moreover, the validity of
the Florida Biotic Index is questioned when only using grab samples
taken in lotic environments, but should be derived from ponar and/or
artificial substrates and composite qualitative sampling. Noteworthy,
is that Florida indices reported by Mobil ranged from values as high as
10 and as low as 0, whereas DER biological sampling using the methods
described above resulted in Florida indices ranging from 26 to 48. This
data is available from our PNS network files in Tampa.
Similarly, we also question the comparison of small tributary K
systems such as Gilshey, Gurr and Stephens Branches with a limited range ^
of habitat to larger streams such as Bowlegs Creek and the Peace River
which have a diversity of habitats. A more equitable approach would
have been to compare the small tributaries with each other. Using the
3-34
-------
Mr. Walt Kolb
Page Three
November 10, 1981
EIS comparison it would seem only logical that species composition would
not be exactly the same. Nevertheless, it should not lead us to believe
the contribution by the small tributaries to the larger Peace River and
Bowlegs Creek to be negligible unless the tributaries contained very few
of the aquatic fauna found in the riverine environment.
A review of the species found in Gilshey Branch by DER (see table 8
enclosed) reveals that nearly every aquatic invertebrate found in Gilshey
Branch is also found in the Peace River and, additionally, that many of CO
these invertebrates were found in drift net samples indicating some |
downstream movement and therefore potential contribution to the riverine jj
food web. Additionally, many of the organisms collected from Gilshey
Branch were early life stages indicating that the tributary is used as a
nursery area for many aquatic invertebrates that ultimately drift down-
stream to continue their adult lives in the river.
The Peace River system has been environmentally degraded, particularly
in its headwater reaches, by industrial, agricultural and residential
development. Typically, headwater reaches of riverine systems have the
most diverse fauna and downstream drift from these areas are very important
recruitment sources for invertebrates which are an integral part of the
riverine food web. Although much of the recruitment source has been
removed from the Peace River System the river continues to exhibit
moderate species richness, particularly in the Polk-Hardee County vicinity.
We believe one important contributing factor in maintaining the species
diversity in the river is recruitment from the tributaries. These small
tributaries are allochthonous systems dependent on the overhead canopy
for their source of detritus and shielding from the sun to deter extensive
periphyton growth. We believe that the removal of these tributaries,
even with some type of reclamation attempt, (which to date is an unproven
science) would reduce food and faunal recruitment to the river and, ®
thereby, its water quality. Finally, without a realistic handle on the |
existing aquatic resources of the site and an inequitable comparison of <£
the tributary systems, it appears that there is not sufficient information
on which to adequately assess the impacts of the mining and/or discharge
on the water quality or biological integrity of the river.
A review of the document indicates that much of the site's aquatic
resources, particularly the streams and contiguous wetlands, scheduled
for mining are within the Department's dredge and fill jurisdiction
pursuant to Chapters 353 and 403, Florida Statutes. Permits would be Q
required prior to mining in areas determined to be waters of the State. ^
Applications for permits to mine such areas are routinely subjected to *
biological/ecological appraisals and a hydrographic review. Based on >
our review of this document and on past agency decisions concerning
mining in areas exhibiting good water quality and providing essential
fish and wildlife habitat, am application can be expected to receive a
negative assessment.
3-35
-------
Mr. Walt Kolb
Page Four
November 10, 1981
The project proposes periodic discharges to the Peace River from
the 45-acre clear water pool adjacent to the processing facility via an
outfall ditch constructed parallel to the railroad corridor. Our Water
Analysis Section indicates that the water quality assessment presented
in the environmental impact statement is based on an adequate data base.
However, until a wasteload allocation has been determined for the discharge,
a conclusion on specific effluent limits cannot be made. Furthermore,
as indicated in the document analysis, several water quality criteria,
specifically D.O., fluoride, sulfate and specific conductance, are ^
already being violated in the receiving stream. Therefore, before any
effluent limits can be developed for pollutants that might contribute to i
these violations, some form of relief from the State's water quality ^
criteria would have to be entertained by the applicant. -These issues
will bo addressed further in the State's NPDES certification process.
Additionally, our Technical Service Section reveals that section
7.1.4.1.2 lumps that portion of the Peace River adjacent to the Mobil
site into what the FDER, 1980 report calls poor water quality in the
upper reaches of the river. We contend that upper river portions (North ^
of SR 640) periodically do exhibit relatively poor water quality that in ««t
most cases can be attributed to specific sources. However, the river in >
lower Polk County should be included as that part of the river exhibiting ^
considerable recovery; this recovery is particularly evident when faunal
assembledges are cbmpared between Polk-Hardee County line areas and
upstream locations.
Our Groundwater Section reports that the document provided an
overall good discussion of the groundwater issues. Although it failed,
in their opinion, to address the long-term and regional impact of "mining"
the groundwater for 100 percent of the mine's water needs. They felt a CO
better plan would have used at least some surface water instead of ^
relying totally on groundwater. This is especially significant since j;
recharge of the confined Floridan Aquifer is a slow process at best, and
the dewatering of the surficial aquifer coupled with paving of other
recharge areas would contribute further to reducing the recharge to the
Floridan. Enclosed is a copy of more detailed comments on the groundwater
section prepared by Department staff.
The mining of the site's wetland communities, including the tributary
stream channels and contiguous wetlands, will result in the loss of
aquatic soils, plants, animals and habitat and inturn affect receiving
stream water quality." Furthermore, in light of reclamation technology
it is unlikely that the site's aquatic resources can be returned to
their pre-mining function. Moreover, even if reclamation is capable of
replacing some kind of aquatic habitat, the loss of natural wetland ^
functions in providing fish and wildlife habitat and maintaining water |
quality will be lost essentially for the life of the mine, and possibly
forever.
3-36
-------
Mr. Walt Kolb
Page Five
November 10, 1981
For the above reasons, we recommend that the tributary systems to
the Peace River be preserved. This includes the submerged portions and
contiguous wetlands. Additionally, seasonal water flows to stream ^
systems should be maintained to offset the loss of water contribution <4-
from the water table aquifer. Buffer areas should be established adjacent •
to each tributary to reduce the dewatering impact of mining the surficial ^
aquifer. Finally, upland reclamation should be consistent with Department
of Natural Resources' Rule 16C-16, Florida Administrative Code.
SJF/job
Enclosures
cc: Bill Hennessey
Bill Kutash
Mickey Bryant
Steve Palmer
Larry Olsen
Rodney DeHan
Andy Feinstein
Permitting
3-37
-------
DER TABLE 1
SPECIES LIST
Peace River @ Polk/Hardee County Line
(Hester Dendy, Ponar Grabs, Qualitative)
110 species
Planarian
Limondrilus hoffmeisteri
Pristina longisoraa
UID Tubificid w/capilliform setae
Batracobdella phalera
Helobdella elongata
Helobdella triserialis
»
Hyalella azteca
Asellus racovitzai
Asellus sp.
Palaeroonetes paludosus
Procambarus fallax
Baetis intercalaris
Baetis pygmaeus
Baetis ephippiatus
Baetis propiaquus
Brachycercus maculatus
Caenis dirainuta
Callibaetis floridanus
Centroptilum hobbsi
Centroptilum viridocularis
Pseudocloeon alachua
Stenacron interpunctatun
Stenonema exiguum
Tricorythodes albilineatus
Argia sedula
Argia fumipennis
Argia moesta
Enallagma cardcnium
Enallagma pollutum
Hetaerina titia
Ischnura posita
Ischnura ramburi
Boyeria vinosa
Epicordulia princeps
Goraphus dilatatus
Gomphus minutus
Goraphus plagiatus
Hagenius brevistylis
Libellua sp.
Macromia georgina
Macromia taeniolata
Tetragonuria sp.
Corydalus cornutus
Cheumatopsyche sp.
Cyrnellus fraternus
Hydropsyche sp.
Hydroptilia sp.
Nectopsyche exquisita (nr.)
Nectopsyche pavida
Oecetis spp.(3)
Oxyethira sp.
Polycentropus cinereus
Parapoynx sp.
Chaoborus sp.
Ceratopogonid spp.(3)
Dasyhelila sp.
Empididae sp.
Ablabesmyia mallochi
Ablabesmyia parajanta
Ablabesmyia tarella
Chironomus sp.
Cladotanytarsus spp.(2)
Coelotanypus tricolor
Corynoneura sp.
Corynoneura taris
Cricotopus sp.I Beck
Cricotopus bicinctus
Cryptochironomus blarina
Cryptochironomus. fulvus
Cryptochironomus sp.
Dicrotendipes modestus
Dicrotendipes neomodestus
Labrundinia floridana
Micropsectra spp.(2)
Paralauterborniella nigrohalteralis
Paratanytarsus sp.
Pedionomus beckae
Pentaneura inculta
Polypedilum convictum
Polypedilum halterale
Polypedilum illinoense
Procladius sp.
Pseudochironomus fulviventris
Rheotanytarsus exiguus
Tanytarsus spp.(2)
Thienemanniella xena
Tribelos fusicornis
3-38
-------
Dineutus sp.
Dubiraphia sp.
Hallplus »p.
Hydrophilus sp.
Microcylloepus pusillus
Stendinis sp.
Ferrissia sp.
Helisoma duryi (near)
Hydrobiidae sp.
Physa sp.
Pomacae sp.
Viviparus sp.
Corbicula manilensis
Pisidium sp.
Sphaerium sp.
Villosa amygdala
-------
MACROINVERTEBRATE PARAMETERS VS TIME
STATION NO.: 25.02.0008 NATURAL SUBSTRATE DIVERSITY
BOOY OF WATER: PEACE RIVER ARTIFICIAL SUBSTRATE DIVERSITY
BIOT1C INOEX (» FLORIDA INOEX)
w
<
I
J
6-i
5-
— 4-
ho
£ 3H
M
*
Q
2A
1-
K
i >
i
/ Y
t
'
F W SP S
73 74
-J——4—£
-.4
1 » I 1 1 1 1 1 1 - - t. ¦ T— I I '
F W SP S F WSP S F W SP S F W SP
75 76
Quarters and Years
77
78
-------
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Dr. Rodney S. DeHan
Page 2
October 14, 1981
There were a number of "corrections" to the raw data that were insufficiently
defined in the text. Regarding the Maddox reference well, for instance, 7 miles Y
from Mobil's pumped well, we don't know what pumping may have gone on around it. 3>
Then there is the matter of ground water quality.& During the pumping test,
SO4 concentrations rose from 255 to 500 ppm, and conductivity from 790 to 1042
U mhos/cm. Water quality sampling during reverse air drilling yielded S04 con- o
centrations of lOOppm at 800' well depth, 650ppm at 1200', and L650ppm at 1400' f
This deep well was plugged back ultimately to 1000' and a 3 day pumping test
was conducted with the same water quality results. None of this is particularly
suggestive of a "tight" anhydrite lower confining layer which would prevent the
long term deterioration of water quality locally due to pumping for mining
activities.
Finally, while it has been argued that large pumping drawdowns (despite their
other negative impacts) would increase the potential for recharging the deeper
artesian aquifers (Mobil claims an increase of 0.2'Vyear from its projected 3.3'
drawdown),. Figure 4-3 suggests a 46Z reduction in recharge since 9700 acres of
relatively "impermeable" slime ponds would be emplaced on Mobil's 16,300 acre ^
tract. And of course complete dewatering of the water table aquifer during, to
mining would preclude recharging in that area. Then I believe that a certain J
amount of that Hawthorn/Tampa clay dewatering (sacrificing storage to give up *
some of that 10~^gpd/ft^/ft. leakance observed during the L. Floridan pumping
test) would be irreversible.-7 This means that recharge capacity from ground
surface would never again be as great as at present even though mining activities
were to cease after 25 years. Water level recovery, and an increment of potential,
water quality recovery would never approach 100% therefore.
All in all I'm not sure that EPA's preferred-alternative of 100% ground ^
water 3se, instead of surface water use', or partial use, of renewable surface W
waters from Bowlegs Creek and the Peace River, is wise when viewed both from the >
long term and regional standpoints.
DK/ek-cs
1. One must be always aware that the number of "aquifers" encountered is a
function of the test design, that the aquifer is undoubtedly more complex than
is indicated in subject .document (3 heads, 3 chemical profiles, etc. become the u>
3 zones sampled). Several more reasonably independent "aquifers" might have been I
defined through a more elaborate test design, although the characterization %•
presented is entirely valid and reasonably adequate so long as one keeps in mind
that at least 2 of the "aquifers" therein defined are composites.
*
2. Floridan aquifer properties in the Mobil region of S.W. Florida have been f
scan to vary by as much as 100% between maximum and minimum valves.
3. This valve is for the L. Floridan only, without even the benefit of the 10
lower 200 to 300' above the Lake City!
*
3-42
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Dr. Rodney S. DeHan
Page 3
October 14, 1981
4. The 3"/year of E rainfall "leaking" into the "L. Floridan, as claimed by Mobil, and
consistent with a 10~^gpd /. ft2/ft k'/h1 in that direction, may be excessive. No leakance
at all was detected- during the Swift Chemical (Cstech) or C. F. Industries pumping tests,
which may indicate that long term drawdown stability had not been reached during Mobil's
10 day pumping test. ' Indeed, the 1.1 to 5.1 + 1U gpd / ft*/fC k'/b' observed in wells ®
LF-5, LF-6, LF-11, and LF-I3 (Table 6-4) is excessive by an order of magnitude or more I
for "leakance" from ground surface (and by 2 orders of magnitude to be consistent with 5
the Swift and C. F. Industries experiences), but instead undoubtedly represents pump
test derived leakance mostly from the U Floridan section, with a minor contribution from
the supposedly "tight" lower anhydrite "confining layer" of the L. Floridan, which
contribution was not observed at either Swift or C. F. Industries.
When one considers the leakance valve of 4,5xl0~^gpd/ft^/ft observed for well LF-L2 |s.
(Table 6-4), which well had been drilled to 1400' but was later plugged back to 1200',
one wonders about the hydraulic conditions in the vicinity of well LF-12 (or about the ^
quality of the "plug").
5. It is indicative that a 3* drawdown, after 10 days, was observed in well LF-il at
1000' from the pumped well, while in well LF-12 at 500' a drawdown of only 2.2' was observed
(Speaking of local anisotropics)! Such a well was encountered during C. F. Industries'
pumping test also, which indicated a T in that direction of several million gpd/ft^.
It would have been helpful if the drawdown*curves for wells LF-5, and LF-B had been J
included in subject document, although a drawdown of 2.1' for well LF-5, at 5100', *
can l)i! interred from the long term regional watcrluvel trend in Figure 6-1'. That no
well lofcjsi ut all were Included in subject document const itucea a monument: a I over-
sight (hopefully not a deficiency)!
6. The L. Floridan, pumped for 10 days, produced water whose Cd content was 10002 uf §
FAC standards for V-B waters; gross alpha content was 200%, Cr and Hg - 1002, Pb - I
80%, Ag 60%, and Se 40%. &
7. I've observed such clay dewatering in strain guage and narrow monitoring zone well
response performances at both the C. F. Industries and USGS Osceala National Forrest
pumping tests.
3-43
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3.2 RESPONSES TO WRITTEN COMMENTS
Response W-l
The proposed action and EPA's preferred alternative both envision recla-
mation activities to begin on a mined area as soon as technically feasible.
Since essentially all mined land 1s to be used for waste disposal, 1t 1s Im-
practical to consider reseedlng with grass until these operations are com-
pleted. Once waste disposal 1s completed, reclamation begins essentially
immediately for the sand tailings and overburden fill areas. In the case of
both the sand/clay capped clay settling areas and the uncapped clay settling
areas, reclamation must await consolidation of the clays. After the reworking
of the land forms, the reclamation process moves on to planned revegetatlon as
described in the DEIS. Virtually no time would elapse between the end of
waste disposal and the beginning of reclamation 1n a given area. Of course,
some lands would be barren for a period of time before being reworked. It is
believed, however, that natural revegetatlon combined with other natural
factors, as described below, will be sufficiently effective controls for fugi-
tive dust to assure that Florida and National Ambient A1r Quality Standards
are not exceeded.
A publication by the U.S. Department of Agriculture (Chepll, W.S., 1958)
provides an 1n-depth discussion of the effect of surface soil moisture on soil
erodabmty. Simply put, surface watering causes, 1n addition to the cohesive
effect of a moisture film, the formation of a thin surface crust which 1s more
mechanically stable than the underlying soil and more resistant to dust forma-
tion. Frequent watering maintains these properties 1n the soil. At the South
Fort Meade Mine site, precipitation averages over 50 Inches per year, thus
providing soil crust formation and high soil moisture, both of which tend to
reduce fugitive dust formation. Additionally, these mined areas are not
subject to any vehicular traffic which would generate dust by breaking up the
surface crust on the soil.
3-44
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It 1s expected that reseeding all disturbed areas of the mine site with
grass prior to formal reclamation would not significantly reduce fugitive dust
emissions, which are expected to be low In any case. Further, as reclamation
would generally proceed rapidly after closure of a particular mined area, in
many cases the reseeded areas would simply be plowed under shortly after
planting as reclamation activities begin. Thus, EPA does not consider it
necessary to condition Mobil's NPDES permit Issuance on Immediate grass seed-
ing of disturbed areas. If fugitive dust from the mine does cause a problem
off-site, Florida and Federal regulations provide sufficient authority to
require Mobil to implement corrective measures.
Response W-2
Open burning Is regulated by the State. This was discussed in Section
3.1.2.2.1 of the DEIS and addressed by NEPA requirement No. 14 of the Draft
NPDES Permit.
Response W-3
The applicable Florida air pollution control regulations were listed in
Section 3.1.1.2.1 of the DEIS. Mobil Chemical Company Is responsible for
obtaining the applicable state air control permits and complying with all
state air pollution control regulations as addressed by NEPA requirement No.
14 of the Draft NPDES permit.
Response W-4
The proposed reclamation plan, as presented in the DEIS (page 2-77),
calls for reestablishment of 453 acres of planted pine. Mobil plans to assess
the sllvlcultural potential of Its land by utilizing the 453 acres as test
plantings. If the pine plantings are successful, then Mobil may amend Its
proposed plan to Include more pine plantings 1n the latter stages of mine
life. Additionally, slash pine Is proposed for plantings as part of the up-
land mixed forest and stream-side revegetatlon plans. The proposed recla-
mation plan would attempt to maximize the amount of mixed forest lands to
encourage the formation of preferred wildlife habitat as recommended by EPA
and the F1sh and Wildlife Service.
3-45
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Response W-5
Commercial timber and pulpwood would be harvested prior to land clearing
as indicated on pages 2-17 and 3-140 of the DEIS.
Response M-6
Mobil has contacted and would continue to maintain contact with the
District and State Foresters during the development of their reclamation plan.
EPA has expanded proposed NEPA condition No. 6 of the Draft NPDES permit to
require that Mobil contact the District or State Forester (Florida Forest
Service) for assistance In development of the reforestation plan.
Response W-7
Mobil would monitor the water levels and water quality 1n the three aqui-
fers present at the site (Shallow, Upper Florldan and Lower Florldan). As re-
quired by the Southwest Florida Water Management District (SWFWMD), data from
the 12 wells specified 1n the Mobil Consumptive Use Permit (No. 205403) would
be reported to SWFWMD on a monthly basis. Additional continuous water level
data would be obtained by Mobil from Wells UF-5 and SA-5.
SWFWMD exercises regulatory jurisdiction related to the consumptive use
of water over substantially all of the Central Florida Phosphate mining re-
gion. As a result of Mobil's Intensive investigations on the property, and
the subsequent evaluation of the technical Information, SWFWMD Issued a Con-
sumptive Use Permit to Mobil in October 1980. An applicant for a SWFWMD
Consumptive Use Permit must demonstrate that the Intended use would be
reasonable and beneficial, consistent with the public Interest and not
Interfere with any legal use of water existing at the time of application.
Issuance of the permit would have been denied 1f the Intended withdrawal would
cause any of the following results:
o Violation of minimum regulatory levels established for the flow of a
stream or other water course, for the potentlometrlc surface or for
surface water
o Saltwater encroachment
o Lowering of the water table so that the lake stages or vegetation
will be adversely and significantly affected on lands other than
those owned, leased or otherwise controlled by the applicant
3-46
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o Reduce the rate of flow of a stream or other water course by more
than five percent at the time and point of withdrawal
o Cause the level of the potentlometric surface under lands not owned»
leased or otherwise controlled by the applicant to be lowered by more
than five feet
o Cause the level of the water table of such lands to be lowerer by
more than three feet
o Cause the level of the surface of water in any lake or other impound-
ment to be lowered by more than one foot unless the lake or impound-
ment is wholly owned, leased or otherwise controlled by the applicant
o Cause the potentiometr1c surface to be lowered below sea level
For good cause shown, however, SWFWMD may grant exceptions to the cri-
teria listed above, when, after consideration of all data presented, Including
economic information, it finds that an exception is consistent with the public
interest.
Water from the Mobil production wells within the lower Florldan Aquifer
would be collected monthly and analyzed for sulfates, chlorides and total dis-
solved solids, Well LF-11 would be sampled quarterly by a "thief" sampler and
the water analyzed for the same three parameters,
NEPA requirement No. 12 of the Draft NPDES permit requires Mobil to moni-
tor the Shallow Aquifer to assess the effectiveness of the perimeter ditch in
preventing dewatering of the preserved area during mining activities conducted
near the Bowlegs Creek preserved area. Mobil shall not allow the Shallow
Aquifer, in the preserved area, to be lowered more than three feet due to
mining activities.
Response W-8
Ho response is required.
Response W-9
No response is required.
3-47
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Response W-10
No response is required.
Response U-ll
Any permitee has the right to request reconsideration of any of the NPDES
permit conditions should new information become available.
Response W-12
Polk County Health Department officials have indicated that wetland crea-
tion during reclamation has increased mosquito populations in some localities.
Vector-borne diseases do not appear to be centered around phosphate mines.
Polk County maintains flocks of chickens which are periodically tested for the
presence of a mosquito-borne virus. Hardee County officials have indicated
the lack of known vector-borne diseases in the area.
RESPONSE W-13
The Final Environmental Impact Statement for Central Florida Phosphate
Industry (EPA 1978) requires that new sources meet SWFWMD Consumptive Use
Permit requirements. Mobil has met these requirements and obtained a permit.
In addition, see Response W-7.
Response W-14
As discussed in the DEIS, approximately 60 percent of the reclaimed lands
which possibly could be used for residential development (excluding reclaimed
wetlands) exceed the EPA recommended indoor radon progeny levels of 0.009
Workiny Levels (ML). It should be noted, however, that those reclaimed lands
which exceed the recommended WL are also those which are the least desirable
for construction of structures on either a short-term or long-term basis (see
Tables 2.6-7 and 2.6-8 of the DEIS). All reclaimed lands on the South Fort
Meade site which are rated as having the highest potential value for con-
struction of buildings have projected indoor radon progeny levels for slab-on-
grade structures of less than 0.009 WL. Thus, there would not be any need for
deed restrictions to limit land use or set construction standards for the
lands most likely to be used for residential development. In the case of
those reclaimed lands exceeding the recommended WL, current research, as
described below, is likely to have established the necessary building codes by
the time sufficient demand develops for residential use of these areas.
3-48
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In the spring of 1980, the State of Florida established a phosphate-
related Task Force to identify problems resulting from construction of homes
on phosphate mined and reclaimed lands and to recommend appropriate solutions.
One of the problems identified was the potential for high levels of radon and
radon progeny accumulating 1n such homes. As a result of its investigations,
which are still underway, the Task Force 1s expected to produce recommended
State of Florida guidelines for radon exposure levels in homes build on re-
claimed lands.
In December of 1980, EPA initiated a study entitled "Program for Control
of Indoor Radon Levels - Common Building Practices and Soil Gas Entry Routes
1n Central Florida." This study, which 1s scheduled to take place over a 12-
to 15-month period, 1s aimed at determining appropriate remedial measures for
homes already constructed on reclaimed lands. The study also will address
recommended building practices for the construction of new homes on reclaimed
lands.
The results of EPA's study will be made available to the State of
Florida, and 1t is expected that the Task Force will use the Information in
its development of state building codes for construction of homes on reclaimed
lands. It also 1s fully anticipated that Florida's guidelines for radon expo-
sure levels and building'codes will be completed and adopted well 1n advance
of the time that the South Fort Meade site would be considered for residential
development.
In view of these facts, EPA does not consider 1t necessary or appropriate
to condition the Mobil Draft NPDES permit to require the recording of deed
restrictions for the mine property.
Response W-15
Weiter would be recovered from the waste clays and used in the water
recirculation system. Water management techniques, as described 1n Sections
2.1, 2.5, 2.7, 3.5 and 6.1 of the DEIS, would permit water to be recovered for
reuse from ore transportation, washing, feed preparation, flotation processes
and waste disposal, thus minimizing effluent discharge and consumptive uses.
3-49
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The flow requirements for each source of water, listed in Table 2.1-2 of the
DEIS, indicate a total of 16.413 MGD of new water and 157.2 MGD of recycled
water. This is an effective recycle rate of greater than ninety percent.
Response W-16
The proposed mine would be operated 24-hours a day, 7-days a week. The
dikes are inspected daily as described on page 3-145 of the DEIS. Mobil is
subject to the requirements of the Federal Mine Safety and Health Act of 1977.
Accordingly, the property would be posted "No Trespassing", and all persons on
the site would either have had safety training or be escorted by a person with
safety training.
Response W-17
EPA has recognized the problems with conventional clay settling areas as
identified in the Areawide EIS (EPA, 1978). EPA has addressed this concern
through the development of alternative methods of waste disposal (DEIS Section
2.5). EPA's Preferred Alternatives and Recommended Action, DEIS Section 2.13,
differed from the company's proposed action. The sand/clay cap plan consists
of placing a mixture of sand and clay as the surface land forms as Identified
in Section 2.6.2 of the DEIS. The impacts on the surface water and biological
resources were Identified 1n Sections 3.5.2 and 3.6.2 of the DEIS.
Response W-18
A number of alternatives for waste disposal and reclamation were evalua-
ted 1n the DEIS Sections 2.5 and 2.6. NEPA requirement No. 1 stipulates that
Mobil employ the sand/clay cap waste disposal and reclamation plans instead of
the conventional waste disposal and reclamation presented as Mobil's proposed
action. Mobil has agreed to Implement these Innovative mining techniques.
NEPA permit condition No. 14 requires Mobil to meet all state and local
requirements for the mining operation.
Response W-19
EPA is the agency responsible for preparation of the DEIS. The DEIS has
presented an evaluation of Mobil's proposed action and of alternative actions
developed by EPA. Through the NPDES permit, EPA can require that an alterna-
tive waste disposal and reclamation plan be utilized, as stipulated 1n NEPA
3-50
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requirement No. 1. EPA does not propose to Issue an NPDES permit for con-
vention! waste disposal which was presented as Mobil's proposed action. The
alternatives chosen by EPA as the preferred action are contained 1n the NEPA
permit requirements. Selection of this preferred combination of alternatives
would not require preparation of a new EIS.
Response W-20
The A-95 Clearinghouse comments received November 13, 1981, were accepted
into the record.
Response W-21
Mobil would Include specific marsh revegetatlon methods when reclamation
plans are submitted to the state for approval. These specific methods would
be based upon the best state-of-the-art technology at that time. Present
approaches to marsh revegetatlon have been Identified in the DEIS (page 2-74)
and Include use of substrates from existing marshes as a seed and vegetative
propagule source, the transplanting of the desired vegetation from existing
marshes and allowing areas to naturally revegetate. Additionally, NEPA condi-
tion No. 14 requires Mobil to perform Its reclamation 1n accordance with local
and/or state rules and regulations, one of which 1s to provide a 50 percent
herbaceous cover on all non-forested wetlands (DEIS, page 2-74).
Response W-22
The validity of the comment is acknowledged. The wildlife habitat at the
proposed mine site has already been altered by the existing cattle usage, as
described 1n Section 3.6.1.2.1 of the DEIS. No intensive cattle usage Is
proposed as a post-reclamation land use; 1t 1s assumed that cattle usage would
be similar to that which presently exists.
Response W-23
Failure to mine the phosphate ore under the plant site would Increase the
energy requirements of future recovery of the ore.
Response W-24
EPA addressed mass loadings as part of the evaluation for setting permit
conditions (DEIS Sections 3.5.2.2.7 and 3.6.2.2.7). Those parameters which
3-51
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would possibly exceed pollution limits were stipulated 1n the effluent limi-
tations of the Draft NPDES Permit. The permit conditions are developed to
minimize adverse effects on the total environment.
Response W-25
Monitoring of wetland areas for vegetation and macrolnvertebrates is
addressed in NEPA requirement No. 11. Data to be collected would be adequate
to calculate various environmental indices. EPA will evaluate the success of
the wetland re-creation. Water quality monitoring programs are stipulated as
part of the Draft NPDES permit and state requirements.
In responding to this comment, it 1s appropriate to explain the rationale
behind the development of the monitoring program required 1n NEPA requirement
No. 11. The monitoring program was not meant to serve as a quantitative study
of wetlands restoration, but rather it was meant to give an early indication
of the results being achieved at the Mobil site so that the Mobil restoration
program could be refined and improved for the remainder of the site. While no
assumption is made that wetlands re-creation in a given area will be com-
pletely successful at the first attempt, it is important to recognize that
Mobil is mandated by state reclamation requirements as well as the conditions
of the NPDES permit to successfully restore the specified acreages of
wetlands. If the restoration effort does not "take" In certain areas, these
areas will have to be redone until satisfactory results are achieved.
Temporal aspects of the reclamation plan strongly influenced the develop-
ment of the assessment program 1n NEPA requirement No. 11. One of each of the
wetland re-creation types (forested stream channel, depression wetland and
forested wetland) was naturally selected for study and, of each type, the ear-
liest area available for study was selected. Examination of Figure 2.6-F and
Table 2.6-3 of the DEIS shows that Maron Run (in TF-1, TF-2 and TF-4,
reclaimed 1n mine years 8, 9 and 11, respectively) 1s the earliest reclaimed
forested stream channel and, therefore, the one selected for study.
Similarily, CS-1 (reclaimed in mine year 14) contains the earliest reclaimed
depression wetland. The third type of wetland re-creation, reforestation of
wetlands, would only be performed on 504 acres of graded spoils occurring 1n
3-52
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the below-grade clay settling area CS-14. Since CS-14 is not reclaimed until
mine year 34, it was not considered a feasible candidate for the long term
monitoring to take place during the life of the mine.
The most critical aspects of the depression wetland (Its relative depth
and any elevation changes due to subsidence) will be monitored over the
five-year life of the original permit, which Includes the time Interval in
which the majority of the subsidence would be expected to occur. Moreover, by
the time the year-long monitoring program for the depression wetland 1s com-
pleted (around mine year 15) 1t would be possible for EPA to make an informed
decision concerning the need for long-term monitoring of Maron Run.
Response W-26
This correction appears 1n Chapter 2.0, Errata of the FEIS. Table 6-6
from the SID was to have been used as Table 3.4-1 for the DEIS.
Response W-27
The storatlvlty (storage) value for the Lower Florldan Aquifer was deter-
mined, by testing, to be 0.0002 (dlmenslonless). Tests to determine the stor-
ativlty values of the Shallow Aquifer and the Upper Florldan Aquifer were not
considered necessary. An estimate of the storatlvity of the Shallow Aquifer
was made based on the sieve analysis of the soil samples. This estimate
averaged 0.20. No estimate of the storatlvlty of the Upper Florldan Aquifer
was made. The Information 1s discussed in 6.1 of the SID.
Response W-28
The DEIS addresses the dragline crossing activities (page 2-19, 3-138 and
3-139) on Bowlegs Creek. A culvert would be placed 1n the creek with earth
back-filled around it. The source of fill would not be Bowlegs Creek proper.
After the second dragline crossing In 2002 the culvert would be removed and
the stream channel re-established. Re-establishment of the channel would
Include removal of the fill. The revegetatlon plans propose planting of tree
species characteristic of wetlands after crossings are complete vrtilch would
result In a relatively higher productive system than that which presently
exists.
3-53
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Response W-29
The location of the proposed dragline crossing of Bowlegs Creek 1s at an
existing ford used by vehicles and cattle (DEIS page 2-19). There are no
trees near the ford since the land is used for pasture. The stream banks have
been altered, and the water is shallow. The stream bottom 1s currently dis-
rupted by crossings; therefore stream productivity 1s minimal at best. The
impacts are discussed 1n DEIS Section 3.6.2.1.
Response W-30
Animals that migrate would survive for the short-term. However, if adja-
cent areas are at carrying-capacity, then net loss of faunal resources would
be realized over the long-term. This 1s identified 1n the DEIS (pages 3-136
and 4-4).
Response W-31
Productivity of wetlands proposed to be mined was found to be minimal
(DEIS, page 3-142). Key wetlands that were found to be unique or having
aquatic system value and regional significance would be preserved with
adequate buffer strips and associated rim ditches (DEIS, page 3-143).
The active clay settling areas provide Interim aquatic habitats during
mining. These areas would support common marsh species as volunteer plants
invade them and would provide food sources for wildlife. This 1s described on
page 3-147 of the DEIS and Is common to all cases.
Response W-32
A discussion of the pre-mlnlng condition Is addressed in the DEIS (pages
3-134 and 3-142) with post-mining conditions for the EPA preferred alternative
addressed in the DEIS (pages 3-80, 3-81, 3-151 and 3-152). Table 3.6-4 pre-
sents the comparison of existing vegetative cover types and those proposed for
the preferred alternative. The comments concerning wetlands are addressed 1n
comments W-21 and W-31.
Response W-33
The comment 1s acknowledged and concerns are addressed 1n Responses W-21
through W-32.
3-54
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Response W-34
Alternatives for groundwater conservation and clay settling area
reclamation, as well as the other mining subsystems, were thoroughly evaluated
in the DEIS. Use of innovative technology was a part of the EIS process, and
where innovative technology was shown to have an environmental advantage over
the other alternatives being considered, then 1t became EPA's preferred
alternative.
Mobil's proposed action for mining the South Fort Meade site is typical
of the existing mining practices in the central Florida Phosphate District.
However, EPA's preferred alternatives and mitigation measures, which are part
of the Draft NPDES permit, require Mobil to use innovative technology, i.e.,
dredge mixing of sand and clay and distributing the mixture over dewatered
clay settling areas. The sand/clay cap method of waste disposal and
reclamation has never been practiced on a production scale basis and does
constitute innovative technology. This method 1s discussed in Sections 2.5.2
and 2.6.2 of the DEIS.
Mobil is also conducting pilot scale studies of stream restoration tech-
niques (Sink Branch Study). The results of this study would be used to
develop optimum stream restoration procedures for restoring disturbed
tributaries on the South Fort Meade site. A more complete discussion on the
Sink Branch Study can be found In Section 2.6.1.1 of the DEIS.
Water management techniques at the South Fort Meade Mine would permit
water to be recovered from ore transportation, washing, feed preparation,
flotation process and waste disposal, thus minimizing effluent discharges and
consumptive uses. Approximately 90 percent of the water usage In Mobil's
mining operation would be recycled water.
Response VI-35
Mitlgative measures are required as NEPA conditions to protect the pre-
served wetlands. The 75-acre cypress dome on the east side of the property 1s
not scheduled for mining. Only a very small portion of the drainage basin to
this wetland would be disturbed, thereby minimizing the effects of reduction
3-55
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in surface runoff contributions to this wetland. Rim ditches would be con-
structed along preserved areas to prevent changes in the water table level in
the surficial aquifer (NEPA requirement No. 12). There would be reduction in
surface runoff contribution to the Peace River and Bowlegs Creek during phases
of the mining. The maximum reduction in flow to the Peace River would be 8.5
cfs or 4.6 percent of the flow in the Peace River directly below the site.
Maximum average flow reduction to Bowlegs Creek would be approximately 8 cfs
or 17.4 percent of the flow in Bowlegs Creek as it leaves the property (SID,
page 7-23).
The buffer strips along the Peace River and Bowlegs Creek are not
comprised of wetlands designated for preservation, but rather are areas which
are designed to protect the preserved wetlands, thus the designation "buffer"
strips. The width of the Bowlegs Creek buffer zone was determined by means of
drawdown curves to assure that any dewatering effect would not reach the pre-
served wetlands of the creek or the creek channel.
Response W-36
The ponar grab was considered to the best standard sampling device for
benthic macroinvertebrates for the study. The procedure for sampling (SID,
page 8-51) was to collect six grabs per replicate, sampling along a bank-to-
bank diagonal transect passing through each replicate collection zone to in-
sure that all habitat types (pools, riffles, root mats, littoral zones) were
sampled. The six grabs per replicate and sampling method were designed to
reduce variability associated with habitat types. Variation in sampling
results is not attributed entirely to "flushing" of organisms, but rather to a
number of possible causes including seasonal shifts in population levels,
sampling efficiency and substrate scouring (SID, page 8-24).
Presentation of a comprehensive species list and reliance on one environ-
mental index does not necessarily provide sufficient information for evaluat-
ing benthic faunal communities; a variety of indices in combination provides a
better framework for evaluating community stability. For the study site, ben-
thic data were analyzed using the following indices.
o Species richness
o Total number of organisms
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o Species diversity
o Equitability
o Florida index
o Percentage ollgomixity
o Faunal similarity
o Faunal density
These data analysis methods are presented in the SID (pages 8-51 and
8-62). Results of the analyses are presented in the SID (pages 8-26, 8-30,
8-35, 8-101, 8-102, 8-105 and 8-108).
NEPA requirement No. 14 provides for Mobil's compliance with state and
local regulations, which can and may include benthic macroinvertebrate
monitoring for biological integrity. However, EPA's judgment is that such a
program as a condition of the NPDES permit is not necessary.
Response W-37
Relative ecological attributes were assessed for the on-site tributaries,
Peace River and Bowlegs Creek. Biotic contribution of the small tributaries
was estimated using Czekanowski's fauna similarity index (Boesch 1977) for
comparing species occurrence among the streams. The similarity of species oc-
currence (as based on presence/absence) was found to be 59.1 percent between
the Peace River and Gilshey Branch and 52 percent between Bowlegs Creek and
the Peace River (SID, pages 8-31 and 8-34). Additionally, 1t was recognized
that Bowlegs Creek, Gilshey Branch and the other small tributaries on site
could potentially serve as sources of colonizer organisms should an adverse
event occur In the Peace River (SID, page 8-31). Consequently, those portions
of the on-site tributary systems that would provide a useful function to their
respective receiving streams were preserved (SID, page 8-45). The preserved
sections of these tributaries would Include the lower 520 feet for those
flowing into Bowlegs Creek, and the lower 450 feet for those entering the
Peace River.
Response W-38
A comparison of macrolnvertebrates collected 1n Gilshey Branch (SID, page
8-107) with those collected in the Peace River (DER Table 1) indicates that
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similarity (based on presence/absence) is approximately 61 percent. As men-
tioned in response to comment W-37, the smaller tributaries could potentially
serve as a source of colonizer organisms should an adverse event occur in the
Peace River.
Response W-39
The wetlands functional study (SID, page 8-45) resulted in the EPA
determination that only the flood backwater areas of the tributary streams
contribute significantly to their respective receiving streams. This area
is included in the Category 1 classification which 1s not to be mined.
Therefore, it was determined that no significant loss of food and faunal
recruitment to the river would be realized. Additionally, a reclamation study
for stream channels 1s presently being conducted by Mobil at Sink Branch near
Ft. Meade, Florida. Initial results indicate that diversion of the stream had
no adverse impact on the stream's water quality (SID, page 2-45).
Response W-40
A determination of FDER's dredge and fill jurisdiction pursuant to
Chapters 253 and 403 of Florida Statutes has not been conducted on the Mobil
site. NEPA requirement No. 14 stipulates that Mobil would be responsible for
meeting any additional or more stringent conditions which may be required by
any local or state regulatory agency or governmental agency.
Response W-41
The data collected do reflect a limited number of days when observed
water quality was lower than specified by Florida Administrative Code and EPA
criteria. The proposed periodic discharges to the Peace River system by the
South Fort Meade Mine are not expected to contribute further to these aberra-
tions for several reasons. First, the Mobil Fort Meade Mine discharges oc-
curring upstream would cease as closure occurs coincident with start up of the
South Fort Meade Mine. Second, the current excursions from water quality
standards occur during low flow periods when discharges from the South Fort
Meade Mine would be limited. Third, the discharge from the South Fort Meade
Mine cannot exceed 20 percent of the Peace River flow (at any time) so Impacts
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on the river system will be minimized. NEPA requirement No. 14 of the Draft
NPDES permit provides for meeting water quality criteria as Imposed by the
state regulatory agency.
Response W-42
S1te-spec1f1c data are presented 1n SID Table 7-5 and Indicate an
Increase downstream In dissolved solids, total phosphorus, fluoride and
sulfate. A Water Quality Index of -1.90 Indicates poorer than average state-
wide water quality (SID page 7-13). The portion of the Peace River adjacent
to the proposed mine site could be considered to be a recovery zone since the
channel Is more Incised causing a higher water velocity. Sedimentation 1s
less of a problem than 1n upstream or downstream sections as discussed 1n SID
Section 8.1.4.1. Characteristics associated with the Peace River's benthlc
community Indicate a low diversity and potentially stressed community (SID
page 8-27).
Response W-43
Groundwater mining 1s a process 1n which withdrawals are 1n excess of
recharge, resulting 1'n a loss of physical water storage within the aquifer and
continuous water-level declines. At the Mobil site, as with most of Florida,
groundwater mining does not occur. Water levels are maintained above the
confining units precluding the actual loss of storage volume.
Impacts of the withdrawal of groundwater are limited to the life of the
mine as discussed In Section 3.4.2.2.3 of the DEIS. As shown 1n Figure 3.4-C
of the DEIS these Impacts are substantially contained on the mine site and,
therefore, do not constitute regional Impacts. The cumulative effect of
groundwater withdrawals of all the mines 1n the area does constitute a
regional impact. The regional and cumulative aspects of phosphate mining in
Central Florida are addressed 1n the 1978 Area wide EIS.
There 1s no proposed action which Indicates large-scale or even signi-
ficant "paving of other recharge areas" within the project region. Recharge
would be reduced as described in Section 3.4.2.2.5 of the DEIS by the place-
ment of clay wastes regardless of the source of water supply. Withdrawal of
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groundwater would tend to offset the impact of dewatering the shallow aquifer
by inducing additional recharge, as indicated in Section 3.4.2.2.6 of the
DEIS.
Response W-44
Refer to response W-39.
Response W-45
The DEIS and SID have presented material indicating that the functional
value of these tributaries is low and can be recreated without significant
impact. EPA has set restrictions to minimize the impacts of mining, and the
information obtained by EPA does not support a requirement for complete
preservation. EPA recognizes the authority of the state to place additional
restrictions on Mobil. As identified 1n NEPA requirement No. 14, EPA has
reinforced through the NPDES permit the requirement that Mobil comply with any
other state or local requirements.
Response W-46
The groundwater field study actually consisted of ten water-table
(Shallow Aquifer), nine Upper Floridan and six Lower Florldan wells. The
separation of the hydrogeologic system into three separate units was based
primarily on potentlometrlc heads and reaction to the pumping at Well LF-6.
Figure 3.4-B 1n the DEIS demonstrates this very well. This 1s discussed at
length in Section 6 of the SID.
The Upper Floridan was "slug tested" at Wells UF-1 and UF-7 and "draw-
down" tested at Well UF-10. The Lower Floridan aquifer was pumped for ten
days. The drawdown/time curves contained in Figures 6-K through 6-N of the
SID include those of the pumped Well LF-6 (Figure 6-M). During well start-up
a number of adjustments take place within the aquifer and at the well. One of
these adjustments 1s the alteration of the pump speed to maintain the required
flow rate. This adjustment 1s needed due to the sudden increase 1n pumping
lift resulting from the withdrawal of a large volume of water (6.48 million
gallons per day). The time/drawdown graphs of Well LF-11 (Figures 6-K and
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6-L) of the SID do not indicate a substantial variation from the theoretical
curve after the first minute. Therefore, the transmissivlty values calculated
in the SID are considered to be reliable.
Response M-47
Figure 6-A of the SID indicates that wells penetrating the Lower Floridan
aquifer were located both east (LF-12, LF-11, LF-8 and LF-5) and south (LF-13)
of the pumped well (LF-6). Data presented in Table 6-4 of the SID indicate
that the calculated aquifer values at Well LF-13 south of the pumping well are
very similar to those of Wells LF-11, LF-8 and LF-5 along the easterly line.
These data do not support the hypothesis that there is any substantial
local anlsotropy. They do, however, support the use of the regional trans-
misslvlty value of 1,300,000 gpd/ft and, therefore, the calculation of the
average 3.3 foot decline 1n potentlometric levels during mine operations.
Response W-48
The annual fluctuation of the Lower Floridan aquifer potentlometric
levels is shown in Figure 3.4-B of the DEIS. The range is confirmed by a
review of the U.S. Geological Survey maps as shown in Figure 6-0 of the SID.
Regardless of the expected range of fluctuation, the calculated average of 3.3
feet of potentiometric decline over the property for a 15.7 MGD withdrawal
from the Lower Floridan aquifer would be valid. Naturally, greater drawdowns
would be experienced close to the pumping wells and lesser drawdowns at
greater distances (DEIS Figure 3.4-C). The data collected and presented In
the DEIS, SID and other supporting documentation indicate that the trans-
missivity values determined during the test are valid.
The projected drawdowns shown 1n Figure 3.4-C of the DEIS 1s considered
an accurate representation of the Lower Floridan response to the production of
15.7 MGD. This figure illustrates that the effects of groundwater withdrawal
do not violate the SWFWMD regulations.
The measured drawdown 1n the pumping well at the end of the test was 8.0
feet. The corrections to compensate for regional water-level trends adjusted
this drawdown to 8.2 feet as 1s indicted on page 6-16 of the SID.
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Response W-49
Corrections to the observed drawdowns were made using data from numerous
wells including the Maddox Well. Water levels in the LF observation wells
before and after the test were correlated with this well and the relationships
were found to be consistent. This Indicates that the use of this well as the
primary indicator of regional water-level trends was appropriate and reliable.
Response W-50
No site-specific hydraulic data were obtained on the evaporite-rlch
portion of the Lake City Formation. This formation was located at about 1400
feet below land surface, and the water-quality and geophysical Information
support this location. Section 6.1.6.1 of the SID contains additional detail
on the location of this formation. This formation has been tested at the
Estech site and in northern Pasco County, and the results were essentially
identical. There is no geologic nor hydrogeologlc reason to believe 1t is
other than a very "tight" formation. The water-quality data at the Mobil site
are similar to those In the zones above the Lake City Formation at Estech. A
complete discussion of the water quality in the Lower Floridan aquifer 1s
contained in Section 6.1.7.3 of the SID.
Response W-51
The projected 0.2 inches/year of Increased recharge due to the lower-
ing of the Floridan Aquifer potentlometric surface would be balanced by a
decrease in recharge due to the dewaterlng of the pits, as explained 1n
Section 3.4.2.2.6 of the DEIS. The total long-range Impact is a reduction in
recharge of 1.4 inches/year over the 16,300-acre site as a result of the clay
setting areas. The recharge capacity would, therefore, be reduced as 1s
described in Section 3.4.2.2.5 of the DEIS.
The leakance Indicated during the test of the Lower Floridan aquifer
comes primarily from the Upper Floridan aquifer. As such, there should be no
dewaterlng of the Hawthorne/Tampa clays.
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Response W-52
The DEIS evaluated the environmental Impacts of both groundwater and
surface water as alternative water sources for the South Fort Meade Mine
(Section 2.7). The use of surface water would reduce downstream flows 1n the
Peace River resulting 1n disturbances of the natural floodplalns, wetland
areas and aquatic systems. Since the low flow values for Bowlegs Creek and
the Peace River are not sufficient to meet the dally water requirements of the
mine, construction of an Impoundment was considered for Bowlegs Creek. Use of
Bowlegs Creek as part of a surface water Impoundment alternative for water
supply, would result 1n adverse environmental Impacts. First and most
obvious, Is disruption of wetland communities designated as Class 1 (pre-
serve). Secondly, there would be a conversion of a predominately lotlc
community to a lenthlc community with subsequent changes 1n flora and fauna.
Impoundment of Bowlegs Creek would reduce flows to the Peace River and their
contribution of detrltal material and drift macrolnvertebrates to down stream
areas. Even with the surface Impoundment, groundwater withdrawal would still
be required to supply the water needs of the mine. The primary environmental
Impact associated with utilizing groundwater withdrawal 1s the lowering of the
plezometrlc surface of the Lower Florldan aquifer. This effect and the
demands of other users have been evaluated by the SVIFVIMD which 1s responsible
for determining the permissible amounts of water to be withdrawn by all major
users 1n the SWFWMD region. The fact that Mobil was granted a Consumptive Use
Permit by SWFWMD Is judged to represent their determination that the
anticipated effect on the Florldan Aquifer Is acceptable. Given all other
environmental considerations relative to the two methods, groundwater
withdrawal 1s considered by EPA to be the environmentally preferred
alternative.
Response W-53
As described In Response W-46, three distinct aquifers were determined
using many criteria. It 1s unlikely that "several more reasonably Independent
aquifers" might have been defined.
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Response W-54
Local anisotropy and heterogeneity can account for large directional
variations in aquifer values, primarily transmissivity. No such conditions,
however, were noted at this site (see Response W-47).
Response W-55
The transmissivity value of 1,300,000 gpd/ft shown on page 3-77 of the
DEIS is for the Lower Floridan aquifer above the confining units of the Lake
City Formation. The pumping and observation wells were not fully penetrating
due to water-quality considerations.
Response W-56
The calculation of recharge to the artesian aquifers from rainfall was
made using a leakance of 0.0001 gpd/ft'*. This value is consistent with the
values estimated at Estech and with the values given by W. E. Wilson (USGS)
for this area of the phosphate region. The fact that no leakage was deter-
mined during tests in other areas does not invalidate observations made at the
Mobil site. There was stability in the observed water levels as shown in
Figures 6-K through 6-N of the SID.
The high values of leakance (0.001 to 0.005 gpd/ft3) demonstrate the
movement of water primarily from the Upper Floridan to the Lower Floridan
aquifers. The Upper Floridan aquifer exhibited drawdowns of approximately
one-third of those in the Lower Floridan aquifers as indicated on page 6-15 of
the SID. This is consistent with a high leakance coefficient between these
two zones. Although no data were collected on the response of the Lake City
Formation at the Mobil site, it is believed, based on tests of this zone at
Estech, that there was very little effect.
Response W-57
The aquifer values for Well LF-12 are not consistent with the values at
the other wells. It is believed that this is due to the proximity of this
observation well to the pumping well (500 feet), the partial-penetration
effects related to this distance, as well as some local heterogeneity. Well
LF-12 was plugged twice, the second time from 1200 to 1000 feet between the
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10-day and 3-day tests, as indicated on page 6-31 of the SID. The aquifer
coefficients obtained for each test were essentially the same as is described
on page 6-31 of the SID. This suggests that the first plugging (1400-1200
feet) was not the cause of the different response of Well LF-12.
Response W-58
The indication that Well LF-12 had only 2.2 feet of drawdown is
incorrect. Well LF-12 had 2.9 feet of drawdown as did Well LF-11 (Figures 6-L
and 6-N of the SID). Well LF-13 at a distance of 1100 feet from Well LF-6 but
to the south, had a drawdown 2.8 feet. This indicates local heterogeneity,
and not anisotropy, because similar drawdowns occur at the same distance in
two different directions. The drawdown at Well LF-5 was not 2.1 feet but
rather was approximately 1.8 feet as shown in Figure 3.4-B of the DEIS.
The geologic logs, geophysical logs and drawdown curves for all of the
wells were not placed in the DEIS or SID due to printing limitations. These
data are available and a copy has been provided to Dr. Rodney S. DeHan and Don
Kell of the FDER Groundwater Section.
Response W-59
Water-quality standards for Class V-B waters are defined by Chapter
17-3.11 of the FAC as those for Class I-B. The constituents listed in this
comment are cadmium, chromium, mercury, lead, silver, selenium and gross
alpha. Of these seven constituents, only cadmium and gross alpha exceed the
Class I-B standards. The other constituents met or were below the standards.
A discussion of the water-quality is Included 1n Section 6.1.7 of the SID.
Response W-60
As discussed in Response W-51, dewatering of the "Hawthorne/Tampa" clay
is not anticipated as a result of this project.
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References
Chepil, W. S. 1958. Soil Conditions that Influence Wind Erosion, U.S.
Department of Agriculture, Tech. Bulletin No. 1185.
U.S. EPA. 1978. Final Environmental Impact Statement, Central Florida
Phosphate Industry, Volume I, Impacts of Proposed Action.
Wilson, W.E. 1977. Groundwater Resources of Oe Soto and Hardee Counties,
Florida, U.S. Geological Survey Report of Investigation, No. 83.
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HEARING TRANSCRIPT
PUBLIC HEARING
U.S. ENVIRONMENTAL PROTECTION AGENCY
REGION IV
in conjunction with
FLORIDA DEPARTMENT OF ENVIRONMENTAL REGULATION
on
DRAFT ENVIRONMENTAL IMPACT STATEMENT
MOBIL CHEMICAL COMPANY
PROPOSED SOUTH FORT MEADE PHOSPHATE MINE
POLK COUNTY, FLORIDA
OCTOBER 20, 1981
7:30 P.M.
Bartow County Civic Center
2250 Floral Avenue
Bartow, Florida
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APPEARANCES:
The Chairman: Howard D. Zeller, Acting Director
Enforcement Division
U.S. Environmental Protection Agency,
Region IV
Atlanta, Georgia
The Panel: A. Jean Tolman, Project Officer
EIS Branch, EPA Region IV
Atlanta, Georgia
Lionel Alexander
Consolidated Permits Branch, EPA
Region IV
Atlanta, Georgia
Mickey Bryant, Administrator
NPDES Section
Florida Department of Environmental
Regulation
Tallahassee, Florida
GOVERNMENTAL SPEAKERS TRANSCRIPT PAGE NUMBER
Howard D. Zeller 1, 10, 17
Mickey Bryant 3
A. Jean Tolman 5
Lionel Alexander 8
PUBLIC SPEAKERS
R. E. Schulz 11
Frank Smith, Jr. 16
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MR, ZELLER: Good evening, Ladies and Gentlemen. My name is Howard Zeller
and I am the Acting Assistant Regional Administrator of the U.S. Environmen-
tal Protection Agency, Region IV, with our headquarters in Atlanta, Georgia.
With me this evening is Mr. Mickey Bryant, from the Department of En-
vironmental Regulation, also Ms. Jean Tolman, who is Project Officer for the
Environmental Impact Statement, and on my left, is Mr. Lionel Alexander, who
is Environmental Engineer with the permits program. He was instrumental in
developing the permit that appears tonight in the EIS.
This evening's hearing will be to address possible actions by EPA with
respect to Mobil Chemical Company's proposed phosphate mine and beneficiation
plant to be constructed and operated 1n southern Polk County, Florida.
The hearing is for the purpose of receiving comments on the Draft
Environmental Impact Statement, on the proposed issuance of National
Pollutant Discharge Elimination System or NPDES permit, and consideration for
State Certification of the Permit. Now, under Section 401 of the Clean Water
Act, the State of Florida has been requested to certify that the proposed
permit will not cause violations of Florida's Water Quality Standards.
The NPDES permit application which we received describes one proposed
discharge point from the facility which would discharge from the clear water
pond by way of a vegetated drainage swale to the Peace River, near the mouth
of Gllshey Branch.
The Federal Water Pollution Control Act, commonly referred to as the
Clean Water Act, has an explicit goal for the "elimination of the discharge
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2
of pollutants" by 1985. Now, to achieve this goal, the Act created the
National Pollutant Discharge Elimination System, a national permit program to
control the discharge of pollutants into the nation's waters. Under this
permit program, anyone who proposes to discharge wastes into waters of the
United States must receive a permit setting limits and conditions on the
discharge of pollutants. The permit is the basic regulatory tool for water
pollution abatement under Federal law. The applicant must be in compliance
with its permit effluent limits upon initiation of its discharge. Any
violations of the terms, limits or conditions of the permit will subject the
discharger to civil or criminal penalties.
The proposed project was determined by the Regional Administrator of EPA
to constitute a "New Source" as that 1s defined under Section 306 of the
Clean Water Act, (33 U.S.C. 1316) requiring issuance of an NPDES permit. We
also determined that the issuance of the permit is subject to all the
provisions of the National Environmental Policy Act of 1969, and that's 42
U.S. Code 433.
The Draft NPDES Permit proposed for Mobil Chemical Company was prepared
by the staff of Region IV, using applicable guidelines and standards for the
phosphate mine and beneficlation plant subcategory and Florida Water Quality
Standards.
We have made available for distribution this evening, copies of the
Public Notice and the Fact Sheet. A few copies of the Draft EIS are
available also. These documents, as well as other relevant documentation and
all comments received tonight or submitted 1n writing by November 2, 1981,
will become a part of the administrative record of this proceeding. The
information in the record will be used in evaluating the Draft Permit and 1n
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either preparing a Final Permit or denying the applicant a permit for the
proposed discharges. Permit issuance would not occur before release of the
Final Environmental Impact Statement. In addition, you should be aware that
all public comments on the Mobil Chemical Company facility and the Draft EIS,
whether received here tonight and transcribed for the record or submitted in
writing directly to the Environmental Protection Agency, will be summarized
and will be addressed in the Final Environmental Impact Statement. A copy of
the Final Permit will be included in that document.
This hearing is to be an EPA public information hearing and is conducted
in accordance with 40 CFR 124.42(b) of our regulations.
Notice of the hearing was published in the Polk County DEMOCRAT and
Tampa TRIBUNE. This was done on September 10, 1981. Additionally, copies of
the public notice were mailed to individuals and organizations on the EPA
mailing list and to all appropriate governmental agencies. A copy was also
posted in the Bartow Courthouse for thirty days.
Now, at this time, I would like to ask Mr. Mickey D. Bryant, Florida
Department of Environmental Regulation, to make any comments he has relative
to the State 401 Certification. Mr. Bryant.
MR. BRYANT: Thank you, Mr. Zeller. I would also like to, on behalf of
the State of Florida and Governor Graham and Secretary Tschinkel, welcome
everybody to tonight's hearing. The Department of Environmental Regulation
is the state agency given the responsibility to process applications for
state certification of NPDES permits. Under Section 401 of the Federal Water
Pollution Control Act, as amended, requires 402 NPDES and 404 applicants to
obtain state certification of their project. The NPDES section of the
Department's Bureau of Permitting has been assigned the responsibility for
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handling state certification activities for Section 402 permits (the NPDES
permits). The terms and conditions of state certification are guided by
Section 401 of the Act. Section 402 authorizes, I mean, excuse me, Section
401 authorizes the state to evaluate projects requiring Federal permits and
to determine whether said projects will comply with Sections 301, 302, 303,
306 and 307 of the Act and with appropriate requirements of state law. In
Issuing certifications, the Department will, of course, assign terms or
conditions under which the project is certified. Requirements of state
certifications issued are ultimately attached to and become requirements of
the Federal permit.
An applicant, or citizen, may challenge the denial or issuance of state
certification through the formal administrative hearing process in the State
of Florida in accordance with Chapter 120 of the Florida Statutes and with
Chapter 17-1 of the Florida Administrative Code.
Before issuing state certification, the department must, it must have
been demonstrated to the department that the project will comply with
applicable state and Federal regulations. Among other things, the applicant
must have provided reasonable assurance that the proposed project, during all
phases of proposed construction, operation, and discharge, will not discharge
pollutants in violation of state water quality standards assigned to the
receiving stream.
State water quality standards apply at points of discharge unless mixing
zones have been obtained in accordance with department rules. Certain
minimum criteria also apply within the mixing zone. If there are any water
quality parameters in the receiving stream that fall to meet existing state
water quality standards, the applicant may need to seek site-specific
alternative criteria for those parameters.
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5
The Department has not yet established a position on certification of
this proposed new source phosphate mine. Public comments received during
tonight's hearing will be reviewed and considered prior to taking final
action.
Are there any questions concerning the function the state assumes in the
NPDES process? If not, I have no further comments at this time.
MR. ZELLEH: Thank you, Mr. Bryant. Next, I'd like to ask Jean Tolman
to give us comments relative to the interplay of NEPA 1n the process of the
National Environmental Policy Act and to review the Environmental Impact
Statement. Ms. Tolman.
MS. TOLMAN: Thank you, Mr. Zeller, and good evening, ladies and
gentlemen. As Mr. Zeller indicated in his opening statement, EPA Region IV
has determined that the proposed mining operation constitutes a "new source"
as defined in Section 306 of the Clean Water Act. EPA Region IV further
determined that Issuance of a new source NPDES Permit for the proposed
facility would constitute a major Federal action significantly affecting the
environment - excuse me - the quality of the human environment and subject to
the provisions of the National Environmental Policy Act requiring preparation
of an Environmental Impact Statement, or EIS. EPA's Notice of Intent to
prepare an EIS for the proposed project appeared in the October 16, 1979
Federal Register, and Notice of Availability of the Draft EIS appeared in the
Federal Register on September 18, 1981.
The Mobil Draft EIS was prepared using the so-called third-party EIS
process. Under this arrangement, Mobil retained a consultant to prepare the
EIS under EPA's close direction. Engineering-Science, Inc. of Atlanta was
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nominated by Mobil and approved by EPA as the third-party consultant to
prepare the Mobil EIS. Ultimate responsibility for the content of the EIS
rests with EPA.
The purpose of the EIS is to provide governmental agencies and the
public with information to assure that a thorough review of the environ-
mental impacts of the proposed Federal action is included in the
decision-making process.
To comply with the goals of the National Environmental Policy Act
(abbreviated NEPA), the EIS must:
1. Provide a thorough description of the environmental background and
setting;
2. Evaluate all reasonable alternatives which meet project objectives,
as well as the no action alternative;
3. Address the environmental impacts of the alternatives; and
4. Identify all potentially adverse impacts and evaluate means to
mitigate these impacts.
The Council on Environmental Quality Guidelines for implementing NEPA
further specify that an EIS should focus on the major issues associated with
a proposed project. The major issues identified with respect to Mobil's
proposed mining operation included possible impacts from radiation, impacts
to surface water and groundwater quality, the preservation and/or restoration
of wetlands, and post-reclamation land use potential. The Mobil EIS
accordingly has concentrated on identifying and evaluating alternatives which
would serve to minimize adverse effects in these particular areas.
Also, the Final Areawide EIS for the Central Florida Phosphate Industry
published by EPA in 1978 contained several recommendations for future
phosphate mining operations. These guidelines were kept closely in mind in
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evaluating Mobil's proposed project and in developing and evaluating
alternatives and mitigating measures. The key alternatives addressed in the
Mobil EIS were waste disposal plans and reclamation plans as well as the
no-action alternative of permit denial. Other alternatives addressed in the
HIS, but recelvlntj less emphasis, included location of the benefication
facility, matrix transport and processing methods, mining methods, sources of
water, location of water discharges, and product transport methods.
EPA's recommendations and proposed agency action are embodied in the
Draft NPDES Permit contained in the Draft EIS, specifically in the 13 NEPA-
generated permit conditions found in the last 6 pages of the Draft Permit.
These permit conditions accomplish two purposes. They either 1) enforce the
project's planned conformance with the recommendations of the areawide EIS,
or 2) require the Implementation of alternatives or mitigating measures
recommended by EPA. Briefly, conditions 3, 4, 5, 6, 7, 10 and 13 are of the
first type and are presented 1n the same order as the corresponding
recommendations given 1n the areawide EIS. The remaining conditions,
developed through the Mobil site-specific EIS, I will discuss briefly at this
time.
Condition #1 of the Draft NPDES Permit requires Mobil to adopt the
sand/clay cap waste disposal and reclamation plan identified 1n the Draft EIS
as EPA's preferred alternative.
Condition #2 requires Mobil to employ high profile overburden stacking
during mining so as to maximize below-ground storage and minimize the
reclamation elevation.
Conditions 8 and 9 were developed through consultation with the U.S.
Fish and Wildlife Service and provide for the protection of threatened and
endangered species on or near the mine property.
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8
Condition #11 requires that Mobil conduct a program to monitor the
effectiveness of the planned wetlands restoration and re-creation effort at
the proposed South Fort Meade Mine.
Condition #12 requires monitoring of the surficial aquifer within the
Bowlegs Creek preserved area and prohibits lowering of the shallow aquifer by
more than three feet due to the adjacent mining activities.
Finally, condition #13 is what might be described as a general condition
and commits Mobil to carrying out their project in accordance with the plans
evaluated in the EIS including all the mitigating measures Mobil identified
as being part of their proposed plan.
Thank you for your attention. I will now return the microphone to Mr.
Zeller.
MR. ZELLER: Thank you, Ms. Tolman. Next I will ask Lionel Alexander to
discuss the NPDES Permit. Mr. Alexander.
MR. ALEXANDER: Thank you, Mr. Zeller. The Draft National Pollutant
Discharge Elimination System (NPDES) permit for Mobil Chemical Company was
developed by the Permit Processing section of EPA's Consolidated Permits
Branch. It is our responsibility to insure that the requirements of the
Clean Water Act are carried out.
As Mr. Zeller has stated, the proposed project was determined by the
Regional Administrator to be a "new source" under Section 306 of the Clean
Water Act. For this reason, the environmental aspects of the project are
subject to review procedures specified in the National Environmental Policy
Act (NEPA Act). The review process, as Jean Tolman discussed, is directed by
our EIS Branch. The NPDES permit Issuance process is conducted in conjunc-
tion with this review process.
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9
In this regard, effluent guidelines have been published to address the
wastewater generated from this facility. However, in some cases, effluent
guidelines requirements alone are not enough to protect the integrity of
water quality within the receiving stream. This brings me to my discussion
of the terms and conditions of the proposed permit. There Is a copy of this
permit in the back of the Draft EIS that some of you have.
The effluent limits on page 1-1 are applicable to wastewater discharges
dependent on heavy rainfall events, which will result in a noncontinuous
discharge. Discharge 001 will consist of overflow from the waste clay
settling area to the Peace River. Effluent guidelines for this Industry,
Phosphate Rock Subcategory of the Mineral Mining and Process Category, only
identify total suspended solids and pH as parameters warranting permit
conditions. Suspended sol Ids Include both organic and inorganic. Inorganics
being sand, silt, and clay. These solids may settle out very rapidly. As I
stated before, these effluent guidelines alone will not protect the water
quality within the Peace River. The creek is classified as Class III, which
is waters suitable for contact recreation and the management and propagation
of fish and wildlife; therefore, additional parameters 1n the draft permit
are specific conductance and combined radium 226 and 228. State of Florida -
the State of Florida standards for Class III waters require 1n-stream
measurement of specific conductance not to be raised above a maximum level.
By the way, specific conductance 1s a measure of the ability of water to
conduct electricity. This measurement can be used to Indicate the amount of
total dissolved sol Ids or just dissolved solids present. State standards
also required the radium limits and the more stringent upper pH limit of 8.5.
The effluent guidelines upper pH limit is 9.0.
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Also, on page 1-2 is a statement which will relieve the company from
complying with the Total Suspended Solids and pH permit conditions during a
rainfall event which might occur once in 10 years if the treatment facility
is constructed to meet certain criteria.
Finally, the permit conditions I have just discussed constitute a
principal part of the permit from an NPDES standpoint. However, as
previously explained, a "new source" such as Mobil Chemical is subject to
additional environmental requirements under NEPA.
Thank you, Mr. Zeller.
MR. ZELLER: Thank you, Mr. Alexander.
Those of you who registered received a copy of the fact sheet intended
to give you a short summary of what the permit contains and some of the
requirements of the permit. I encourage you to look at that and if you have
any questions that develop after this hearing, I hope you will contact me or
Mr. Alexander or any one here for any further edification.
This concludes the statements by the involved governmental agencies. We
now want to go to the principal purpose of this hearing, which is to receive
public comments. A goal of the Clean Water Act and the National Environmen-
tal Policy Act is to encourage and provide for public participation in the
decision making process for actions authorized by these acts, and to encour-
age governmental responsiveness to public concerns. We want to promote a
greater public awareness of the actions proposed by EPA.
We have asked all of you here to register so that we may have a record
of those in attendance, and also so that we can send you a notice of our
determination regarding the permit. If you have not already registered and
wish to make an oral statement tonight, would you please register your Intent
at this time.
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If you have a lengthy statement, I'd ask that your oral presentation be
summarized if at all possible. Your oral presentation should be limited to
about 5 minutes, if possible.
Members of this panel may ask questions of persons presenting oral
comments where it is felt necessary to clarify the nature or substance of the
comments. I would like to emphasize that persons commenting for the record
will not be expected nor required to respond to questions from the public.
I would ask that each person making a statement please step to the
microphone, which is over there by that podium, state your name and the
interest or organization that you represent. This hearing 1s being recorded
and will be made a part of the public record 1n the Final EIS. In addition
to any oral or written comments submitted this evening, the comment period on
the Draft EIS will remain open until November 2, 1981. A written record of
this hearing and any other comments received will be held as a matter of
public record at the regional office of the Environmental Protection Agency
1n Atlanta.
At this time I would like to recognize the Mobil Chemical Company
representative who would like to make a statement regarding the facility, and
I believe that's Mr. R. E. Schulz. Mr. Schulz.
MR. SCHULZ; Good evening ladies and gentlemen, my name 1s R. E. Schulz,
I reside 1n Bartow, Florida and I am employed by Mobil Chemical Company as
Venture Manager for the South Fort Meade Mine project. I've lived 1n Bartow
since 1958 and have worked 1n phosphate mining for the last 23 years.
We welcome this opportunity to appear at this joint hearing as the
applicant for the permits that are necessary to operate the proposed South
Fort Meade Mine. The Issues that we are here to address tonight are part of
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several areas of government authorizations required under various statutes
and regulations for construction and operation of phosphate rock mine. As
you have been advised, the Environmental Protection Agency has determined
that the project constitutes a "new source" under the Clean Water Act of
1977, and the requlrements of the National Environmental Policy Act must,
therefore, be met. In addition, the South Kort Meade Mine project hcis been
reviewed under the Florida statutes governing development of regional impacts
and both the Central Florida Regional Planning Council and the Polk County
Board of County Commissioners have approved the project. Those approvals
were granted after public hearings were held by those bodies on August 26,
1981, and September 15, 1981, respectively, in Bartow, Florida.
Mobil Chemical Company and Its predecessor companies, the Virginia
Carolina Chemical Company, the Phosphate Mining Company, and the Charleston
Mining Company have mined phosphate rock 1n Polk County since the early
1900's. Mobil presently operates two Polk County mines: the Nichols Mine
southwest of Mulberry, and the Fort Meade Mine adjacent to the City of Fort
Meade. Mobil's present mining operations employ some 570 Floridlans and have
a combined annual payroll of approximately $15 million. The existing Fort
Meade Mine, which started up in 1966, will be exhausted around the year 1988.
The proposed South Fort Meade Mine 1s intended as a replacement for the
existing Fort Meade Mine rather than as an extension. The mine will produce
approximately 3.5 million tons of phosphate rock per year when fully
operational.
Mobil proposes to use proven equipment and process technology utilized
by current surface mining operations 1n central Florida. The phosphate ore
will be mined by dragline and transported by pipeline to the plant, where the
sand and clay will be separated from phoshate rock by screening and
flotation.
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13
The wet rock will be temporarily stored on site and then shipped by rail to
the existing preparation facilities located at Nichols. The clay and sand
will be stored on site and reclaimed as part of the approved land use plan.
We want to construct and operate the new mine in a manner that will
achieve our production goals and minimize adverse impacts on the environment.
Therefore, environmental considerations have been a key factor 1n developing
plans for the new mine.
Our mining plan calls for reclamation of all mined land, preserving
productive wetland areas on the site, restoration of disturbed wetland
acreage, and improving the productive value of the land by providing greater
acreage of improved pasture. We will also use the leach zone management
technique of mining to reduce the surface radiation levels in reclaimed
areas. Water circulation methods will be utilized to reduce water consump-
tion during mining. These are only a few of the 30 environmental mitigation
measures discussed 1n the Environmental Impact Statement that Mobil plans to
use to minimize the impacts of the new mine on the environment.
The environmental impact of Mobil's proposed action and alternatives to
our proposed action have been evaluated through the EIS process. In each
case, except for waste disposal and reclamation, EPA has agreed that Mobil's
proposed action has less adverse Impact on the environment than the
alternatives considered, EPA's preferred waste disposal and reclamation
method is the sand/clay cap plan described 1n the Draft EIS document.
According to the EPA evaluation, the sand/clay cap plan has the potential
advantages of reducing average dike height, reducing surface radiation levels
on reclaimed lands, Improving agronomic properties of reclaimed soils,
reducing the potential for dam failure, providing more wetland areas, and
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improving land use potential as compared to Mobil's proposed conventional
waste disposal and reclamation plan. These are environmental benefits;
however, implementing the sand/clay cap plan does require additional effort
and resources. As an example, the sand/clay cap plan would utilize more
equipment for handling and transporting the sand and clay, more operating and
maintenance labor, and greater energy consumption.
The sand/clay cap method of waste disposal and reclamation has never
been practiced on a full-scale basis 1n the phosphate mining Industry. As
with any new technique, there are always unforeseen problems that could
develop when the plan is put into practice. There may be unforeseen risks
and possibly even greater costs than we now envision.
In spite of these risks, Mobil is committed to implementing the
sand/clay cap plan as recommended by EPA for the proposed South Fort Meade
Mine.
The revised waste disposal/reclamation plan calls for tailings fill in
those areas that are primarily in environmentally sensitive areas along the
Peace River and Bowlegs Creek, and along roads. Some of these areas should
be suitable for buildings in the future. The Plan calls for waste disposal
areas to be capped with a mixture of 4 parts sand and 1 part clay to a depth
of 4 to 6 feet. This should produce a very productive loamy agricultural
soil 1n the elevated settling areas and be a substantial improvement in waste
disposal technology.
Today the predominant on-site economic use 1s agricultural, principally
grazing. Our reclamation plan returns most reclaimed land to improved
pasture and other agricultural uses.
The project's contribution to the area 1n the form of taxes, continued
employment of our people, payroll, and other economic contributions to Polk
County and the State of Florida are extremely significant.
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15
I would like to re-emphas1ze that the Mobil project is not an expansion,
but rather is a replacement for the existing mine that will allow Mobil to
continue in a business that it has been in for over 75 years in Polk County.
Approval of the project will give somewhat of a guarantee that better than
200 people will have work at the new mine after 1988. Mobil Chemical Company
and the responsible local, state and Federal agencies have thoroughly studied
and evaluated the environmental, economic and other consequences of con-
structing and operating the South Fort Meade Mine. We believe that these
evaluations clearly demonstrate that the necessary permits and authorizations
should be granted as expeditiously as practicable. We strongly support the
issuance and state certification of the National Pollutant Discharge
Elimination System Permit and finalizatlon of the Environmental Impact
Statement for this facility.
In closing, I would like to note that during the course of the
permitting process, we have had the opportunity to deal with various
representatives of county, state and Federal government agencies. Without
the cooperation of these individuals it is likely that we would not be at the
point 1n the process that we are today. On behalf of Mobil Chemical Company,
I would like to publicly express our sincere appreciation to all those
individuals who played a role 1n reviewing the South Fort Meade Mine. Mr.
Zeller, that concludes my statement for the evening. Thank you.
MR. ZELLEft: Thank you, Mr. Schulz. Let me ask if there Is any member
of the panel that would Hke to raise a question at this time. (No
response). Thank you very much.
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16
I also have a card from the registration from Pat Kitchen, from Mobil
Chemical Corporation, who also asked to make a statement.
MR. KITCHEN: I think all my comments have already been made. Thank
you.
MR. ZELLER: Thank you. This is all of the cards that I have as a
result of the registration where individuals have indicated that they wanted
to make a statement. Is there anyone present who did not so Indicate at the
registration who would like to make a statement now?
MR. SMITH: I apologize for not filling the card out. The pencil
wouldn't write. My name is Frank B. Smith, Jr. and I'm a member of the Board
of County Commissioners of Polk County, Florida.
MR. ZELLER: Glad to have you.
MR. SMITH: I have with me, for Ms. Tolman, a copy, a letter signed by
the chairman of the Board of County Commissi oners that basically confirms
that the Board, on September 22, 1981, finally approved the plans of Mobil,
through their order and that was after the Central Florida Regional Planning
Council had done its work. Those recommendations came to us and those
recommendations, along with our planning staff recommendations, were included
in that final order. I'm sure that you have gotten a copy of that but I'm
going to give you another copy before I leave here. I understand that the
plans are, included 1n those plans are EPA's preferred waste disposal that
you have heard many comments about tonight that included the sand/clay cap.
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17
We note, and Mobil officials have told us, that they understand the tech-
nologies and that they understand and agree that any new technology that
comes down the pike in the next 15 or 20 years that the proposal will be
running, that they will address themselves to those technologies and do, if
they can, those new things that we hope will eventually get done with clay
settling areas. They are also going to study the wetlands restoration. They
are going to do a pilot project to be sure that, you know, they can do 1t
almost as good as God can do 1t. We are not sure that they can, but we
appreciate very much their committment to do that. We know that the clays
will be, will be on the interior of that property and will not be along Mt.
Pisgah Road, not along the Peace River, where, quite frankly, we are going to
have people live one day and we appreciate that. In short, I would like to
give you this letter, signed by the chairman, that outlines many of those
comments and thank you for coming and having this presentation.
MR. ZELLER: Thank you. Thank you for your comments. Those are
important to us 1n the course of this hearing.
Is there anyone else who would like to make a statement at this time?
(No response). Well, if not, let me go ahead and close out the hearing. I
want to thank you for your attendance, for your participation.
The record of this hearing and comment period will remain open through
the close of business on November 2, 1981. This will allow anyone wishing to
submit additional statements sufficient time to do so, I believe. Further
submissions to be included in the official record must be 1n writing and they
should be sent to the attention of Jean Tolman, EIS Branch, EPA, Region IV,
345 Courtland St, N.E., Atlanta, Georgia 30365.
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18
The company will have to agree to comply with all ElS-related NPDES
permit conditions, and only construction activities of a reversible nature
will be allowed. The text of any agreement that we might work out has not
yet been finalized pending conments at this hearing which may affect some of
those conditions imposed by the Environmental Impactment Statement.
After consideration of all the written conments and of the requirements
and policies in the Act and appropriate regulations, the EPA Regional
Actoinistrator will make determinations regarding permit issuance. If the
determinations are substantially unchanged, the Regional Administrator will
so notify all persons making oral statements tonight and all persons
submitting written comments. If the determinations are substantially
changed, the Regional Administrator will Issue public notice indicating the
revised determinations.
Now, within 30 days of receipt of the final determination or the date of
the public notice, any Interested party may request an evidentiary hearing on
the EPA determination.
Requests for an evidentiary hearing should be addressed to the EPA
Regional Hearing Clerk for Region IV. The procedures for filing evidentiary
hearing requests are set out 1n Title 40, Code of Federal Regulations.
Please note that any Issues posed by an evidentiary hearing request must have
previously been raised by the requestor during the public comment period or
at the public hearing.
Unless a request for an evidentiary hearing 1s granted, our deter-
mination will be the final action of the Environmental Protection Agency.
Pending final agency action on an evidentiary hearing concerning this
facility which is granted by the Regional Administrator, the applicant would
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19
be without a permit, as the project for which the permit has been applied for
1s, of course, a new source, as we mentioned several times tonight.
The record upon which the determination to issue is made will include
both comments received at this hearing and received 1n response to the public
notice. The Final Permit will be issued no sooner than thirty days after
issuance of the Final Environmental Impact Statement, in accordance with 40
CFR 124.61.
Again, let me thank you for your participation 1n this hearing tonight,
and as there are no further comments, 1 now declare this hearing closed.
(Hearing concluded)
3-87
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3.4 RESPONSES TO TRANSCRIPT COMMENTS
RESPONSE T-l
No response is required.
RESPONSE T-2
No response 1s required. The material provided appears as written comment
W-10.
3-88
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4.0 FINAL ENVIRONMENTAL IMPACT STATEMENT
COORDINATION LIST
The following Federal, state and local agencies, public officials, organiza-
tions, and interested groups have been requested to comment on this impact
statement.
Federal Agencies
Bureau of Mines
Coast Guard
Corps of Engineers
Council on Environmental Quality
Department of Agriculture
Department of Conmerce
Department of Education
Department of Interior
Department of Transportation
Department of Health and Human
Services
Department of Housing and Urban
Development
Department of Energy
Federal Highway Administration
Fish and Wildlife Service
Food and Drug Administration
Forest Service
Geological Survey
National Park Service
Economic Development Administration
Soil Conservation Service
Members of Congress
Honorable Lawton Chiles Honorable Paula Hawkins
United States Senate United States Senate
Honorable Sam Gibbons Honorable Andy P. Ireland
U.S. House of Representatives U.S. House of Representatives
Honorable L.A. Bafalis
U.S. House of Representatives
4-1
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State of Florida
Honorable D. Robert Graham
Governor
Department of Natural Resources
Department of Agriculture and
Consumer Services
Department of Community Affairs
Game and Freshwater Fish
Comnission
Department of Administration
Department of State
Environmental Regulation Committee
Department of Commerce
Department of Health and
Rehabilitative Services
Department of Environmental
Regulation
Department of Transportation
Polk County Commission
Manatee County Comnission
Sarasota County Commission
Hardee County Commission
Polk County Health Department
Polk County Building and
Zoning Department
City of Bartow
Local and Regional
Tampa Port Authority
Central Florida Regional
Planning Council
Southwest Florida Water
Management District
Hardee County Zoning and
Building Department
Interested Groups
The Fertilizer Institute
Florida Phosphate Council
Florida Audubon Society
Florida Sierra Club
Manasota 88
Florida Defenders of the
Environment
Izaak Walton League of
America
Florida Wildlife Federation
4-2
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5.0 LIST OF PREPARERS
The following EPA officials participated in developing this EIS
Name
Responsibility
A. Jean Tolman
Lionel Alexander, III
D. Brian Mitchell
Louis Nagler
Doyle Brittain
James E. Orban
A, Eugene Coker
H. Richard Payne
Curtis F. Fehn
Thomas R. Cavinder
John T. Marlar
William L. Kruczynski
Delbert B. Hicks
EIS Project Officer
NPDES Permit Coordinator
A1r Quality
A1r Quality
Air Quality
Noise
Geology and Groundwater
Radiation
Groundwater
Surface Water
Surface Water
Biology and Ecology
Biology and Ecology
For information on the material presented 1n this section, contact A, Jean
Tolman at (404) 881-7458 (FTS/257-7458).
The EIS for the Mobil South Fort Meade project was prepared by EPA with
consultant assistance from Engineering-Science, Inc. (ES) of Atlanta, Georgia,
using the third-party EIS preparation method. The names and qualifications of
the ES project team on this EIS are presented 1n Table 5.0-1. Data presented
1n the EIS were gathered as a joint effort by the U.S. Environmental
Protection Agency, Mobil Chemical Company, and the consultants listed 1n Table
5.0-2. ES was responsible for evaluating the plans and quality assurance
provisions of the data gathering consultants. The data were provided to ES in
an uninterpreted form.
5-1
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TABLE 5.0-1
NAMES, RESPONSIBILITIES, AND QUALIFICATIONS OF PERSONS
PRIMARILY RESPONSIBLE FOR PREPARING THE MOBIL
ENVIRONMENTAL IMPACT STATEMENT
Name
Andrew W. Lovun
ThoitdS M. Sarcjent
Ernest J. Schroeder
Brian U. Moreth
J. Kenneth Allison
Frank R. t'.ruM
Earnest f. Gloyiu
Resj)ons1btJUjr
Principal-in-Charge
Project mrector
Project Manager
Deputy Project Manager
Air quality, Meteorology
tioolouy (ind Uruundwaler
Radiation
Benjtrain W. Brecdlove Biology
Ual f. Ttschler
T.M. Gurr
Stephen Noeley
Ruth E. Maclin
Surface Water
Radiation
Reclamation and Mine
Plan Evaluation
Hunan Resources
Editor
Qualifications
Ph.D. Physical Chemistry; Principal and Group Vice President,
Engineering-Science, Inc., 21 years experience including the
direction of interdlscipline studies for environmental
assessments and Industrial facility siting studies.
M.S. Environmental Engineering; Associate and Manager of
Engineering Development, Engineering-Science, Inc., 14 years
experience in the direction of interdisclpline studies with
emphasis in environmental studies and permit preparation.
M.S. Civil Environmental Engineering; Associate,
Engineering-Science, Inc., 14 years experience In environmental
studies with emphasis In plant siting and development of
pollution abatement programs for Industrial facilities.
B.s. Forest Science and B.s. Zoology; Project Scientist,
Engineering-Science, Inc., 10 years experience in the preparation
of environmental impact statements for a wide variety of projects
including phosphate mines.
M.S. Meteorology; Senior Meteorologist/Scientist,
Engineering-Science, Inc., 28 years experience in environmental
studies including meteorology, air quality and air diffusion
Including Impact studies.
B.S. Geology; Vice President and Director, Leggette, Brashears
and Graham, Inc., 22 years experience in geological
investigations and groundwater studies for projects Including
phosphate mining operations investigations.
Dr. Eng. Sanitary Engineering and Water Resources;
Special Consultant, Engineering-Science, Inc., 36 years
experience In waste management Including radioactive waste
disposal consulting with National Academy of Sciences.
M.S.P.H. Pyblic Health and Environmental Biology; Principal,
Breedlove Associates, Inc., 12 years experience in biological
research studies Including aquatic ecology, limnology,
terrestrial ecology, water quality evaluations and ecosystem
analyses.
Ph.D. Civil (Environmental Health) Engineering;
Principal and Vice President. Engineering-Science, Inc., 17 years
experience in water quality modeling and impact assessment,
evaluation of radiological health impacts.
M.A., Geology; Associate Scientist, Dames and Moore,
IS years experience in geological and mining studies in
the Central Florida Phosphate District Including nine planning,
exploration, reclamation, economic geology and environmental
permitting.
B.l.S. Environmental Management; Staff Scientist, Engineering-
Science, Inc., 4 years experience in socio-economic (human
resources) analyses prep-aratton as part of comprehensive
environmental studies.
B.A. English; Editor, Engineering-Science, Inc., 3 years
experience editing reports, manuals, and selected publications.
5-2
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TABLE 5.0-2
ORGANIZATIONS RESPONSIBLE FOR GATHERING
THE BASIC DATA USED IN PREPARING
THE MOBIL ENVIRONMENTAL IMPACT STATEMENT*
ORGANIZATION
AREA(S) OF
RESPONSIBILITY
Dames & Moore
Lakeland, FL
Surface Water
Soils and Geology
Groundwater
Geraghty ft Miller, Inc.
Tampa, FL
Post, Buckley, Schuh & Jernlgan
Orlando, FL
Groundwater
Radiation
NUS Corporation
Rockvllle, MD
Human Resources
Archaeology
Water and A1r Research, Inc.
Biology
Gainesville, FL
Zel1ars-W11l1ams, Inc. Soils and Geology
Lakeland, FL
Environmental Science and Engineering, Inc. A1r
Gainesville, FL
*The data gathering effort was overseen by Engineering-Science, Inc. of Atlanta,
Georgia, the third-party consultant working under the direction of the U.S.
Environmental Protection Agency.
5-3
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6.0 APPENDIX
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6.1 Letter from Florida State Museum
6-1
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THE FLORIDA STATE MUSEUM
UNIVERSITY OF FLORIDA
DEPARTMENT OF NATURAL SCIENCES
the florida
state museum
museum road
university
of florida
gainesville
32611
904/392-1721
August 10, 1981
Ms. A. Jean Tolman
U.S. Environmental Protection
Agency
EIS Branch
345 Courtland Street, NE
Atlanta, Georgia 30365
Dear Ms. Tolman:
On several occasions recently, we have received inquiries as
to the paleontological resources of the phosphatic sediments of
the Bone Valley Mining District of central Florida. To date this
district has been centered 1n Polk and Hillsborough counties, but
now, as you know, it 1s rapidly extending southward Into Manatee,
Hardee, and Sarasota counties. In view of this pattern of activity,
I believe it may be worth stating directly to you the paleontological
importance of this area.
The Bone Valley District has produced a rich series of samples
of fossil vertebrates ranging in age from late Miocene through late
Pleistocene. The importance of these samples stems from the fact
that for most ages they are among the richest in eastern North
America. They are also important for their ecological relationships
which span from terrestrial through estuarlne to marine habitats.
The basic outline of this rich series of fossil samples had been
established by 1930 (see especially Simpson, 1930). Nonetheless,
many new discoveries have been added 1n recent years (e.g. Webb 1973;
MacFadden and Waldrop, 1980). And, so great Is the potential of
this area, according to the judgement of paleontologists, that two
current grants from the National Science Foundation feature new
collecting efforts throughout the marine and terrestrial sediments
of the Bone Valley District (NSF grants to Daryl Domning, Howard
University, 1981; Webb and MacFadden, University of Florida, 1979).
Thus, there is every reason to expect Important paleontological
discoveries 1n this district.
In the newer southern extension of this district, there 1s only
a limited basis for predicting exact locations of fossil concentrations.
The few exposures that have occurred, such as the Manatee County Dam
Site (Webb and Tessman, 1968), have encouraged great expectations.
In general, the phosphatic formations are widespread laterally, so
that the few known localities probably are generally indicative of
fossilifero'us terrain.
6-2
A UNIVERSITY MUSEUM WITH RESEARCH EMPHASIS ON CARIBBEAN NATURAL AND SOCIAL HISTORY
EQUAL KM PLOY MS NT OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER
-------
Ms. A. Jean Tolman
Page Two
August 10, 1981
For these reasons we strongly urge that any environmental
impact statements in the Bone Valley Phosphate Mining District
or its southward extensions in Hardee, Manatee, and Sarasota
counties, be required to take into account the potential for
valuable paleontological resources.
If you wish to discuss these matters further, please let
us know.
References Cited:
MacFadden, B.J. and J.S. Waldrop. 1980. Nannippus phleqon (Mammalia,
Equidae) from the PIio-Pleistocene (Blancan) of Florida.
Bulletin Florida State Museum, Biological Sciences, vol. 25,
Simpson, G.G. 1930. Tertiary Land Mammals of Florida. Bull. Amer.
Mus. Nat. Hist., 59:149-211.
Webb, S.D. 1973. Pliocene Pronghorns of Florida. Journal of Mammalogy.
54:203-221.
Webb, S.D. and N. Tessman. 1968. A Pliocene vertebrate fauna from
Manatee County, Florida. American Journal of Science, 266:777-811.
SDW:BJM:map
Curators of Fossil Vertebrates
Florida State Museum
6-3
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Draft NPDES Permit
-------
Permit No.: FL0037958
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
Ms coufm_ANo sTKrrr
ATLANTA. OCOROtA 101M
AUTHORIZATION TO DISCHARGE UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance vieh th« provisions of the Clean Water Act, as amended
(33 D.S.C. 1251 at. saq; tba "Act"),
Mobil Chemical Co. - South Fort Meade Mine
is auchorizsd to diacharge from a facility located at
Latitude - 27° 39' 26
to receiving watara named
The Peace River
in accordanca with affluent limitations, monitoring requirements and
other conditions sat forth in Parts 1, IX, and III harsof. The permit
consists of this cover sheet, Part I 3 pages(s), Part II 12 page(s)
Longitude - 81° 46 08
tl
and Part III 6 page(a).
This permit shall become affective on
This permit and the authorization to discharge shall expire at
midnight,
Date Signed
6-5
Paul J. Traina
Director
Water Management Division
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A. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
During the period beginning on the effective date of this permit end lasting through the term of thia permit,
the permittee is authorized to discharge from outfall(s) serial number(s) 001 - process generated wastewater.
Such discharges shall be limited and monitored by the permittee as specified below:
Effluent Characteristic
Flow—ms/Day (MGD)
Total Suspended
Solids
Specific Conductance
Radium:*
Discharge Limitations Monitoring Requirements
kg/day (lbs/day) Other Units (Specify)
Measurement Sample
Daily Avg Daily Max Daily Avg
Daily Max Frequency Type
(during discharge)
— Continuous** Recorder
30 mg/l 60 mg/1 l/veek Composite
550 inhos/cm 1000 jimhos/cm 1/week Composite
5 pci/1 10 pci/1 1/week Composite
*Cosri>ined Radium 226 & 228
The pH shall not be less than 6.0 standard units nor greater than 8 • 5 standard units and shall be monitored once per
week with a grab tuple. ,
There shaH be no discharge of floating solids or visible foam in other than trace amounts. t
z
c
Samples taken in compliance with the monitoring requirements specified above shall be taken at the following loc--iiion(i): ^
nearest accessible point after final treatment but prior to actual discharge or mixing with g
the receiving waters. 2
**The discharge flow shall not exceed 20 percent the flow in the Peace River.
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B. EFFLUENT LIMITATIONS AND MONITORING REQUIREMENTS
Any overflow from facilities designated, constructed and maintained to contain
or treat the volume of wastewater which would result from a "10-year, 24-hour
precipitation event shall not be subject to the suspended solids limitation
or the pH limitation liated on the preceeding pages. Monitoring and reporting
shall be required for all other parameters.
The effluent limits and any additional requirements specified in the state
certification supersede any less stringent effluent limits listed above. During
any time period in which more stringent state certification effluent limits are
stayed or inoperable, the effluent liaita liated above shall be in effect and
fully enforceable.
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PARTI
Page 1-3
Permit No. FL0037958
B. SCHEDULE OF COMPLIANCE
1. The permittee thill achieve compliance with the effluent limitations specified for
discharges in accordance with the following schedule:
2. The permittee shall comply with the effluent limits by the
effective date of the permit*
2. No later than 14 calendar days following a date identified in the above schedule of
compliance, the permittee shall submit either • report of progress or, in the case of
specific actions being required by identified dates, a written notice of compliance or
noncompliance. In the latter case, the notice shall include the cause of noncompliance,
any remedial actions taken, and the probability of meeting the next scheduled
requirement.
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Part II
Page II-l
A. MANAGEMENT REQUIREMENTS
1. Discharge Violations
All discharges authorized herein shall be consistent with the terms
and conditions of this permit. The discharge of any pollutant more
frequently than, or at a level in excess of, that identified and
authorized by this permit constitutes a violation of the terms and
conditions of this permit. Such a violation may result in the
imposition of civil and/or criminal penalties as provided in Section
309 of the Act.
2. Change in Discharge
Any anticipated facility expansions, production increases, or process
modifications which will result in new, different, or increased
discharges of pollutanta must be reported by submission of a new
NPDES application at least 180 days prior to commencement of such
discharge. Any other activity which would constitute cause for
modification or revocation and reissuance of this permit, as
described in Part II (B) (4) of this permit, shall be reported to the
Permit Issuing Authority.
3. Noncompliance Notification
a. Instances of noncompliance involving toxic or hazardous pollutants
should be reported as outlined in Condition 3c. . All other instances
of noncompliance should be reported as described in Condition 3b.
b. If for any reason, the permittee does not comply with or will be
unable to comply with any discharge limitation specified in the
permit, the permittee shall provide the Permit Issuing Authority
with the following information at the time when the next Discharge
Monitoring Report is submitted.
(1) A description of the discharge and cause of noncompliance;
(2) The period of noncompliance, including exact dates and times
and/or anticipated time when the discharge will return to
compliance; and
(3) Steps taken to reduce, eliminate, and prevent recurrence of
the noncomplying discharge.
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Part II
Page II-2
c. Toxic or hazardous discharges as defined below shall be reported
by telephone within 24 hours after permittee becomes aware of the
circumstances and followed up with information in writing as
set forth in Condition 3b. within 5 days, unless this requirement
is otherwise waived by the Permit Issuing Authority:
(1) Noncomplying discharges subject to any applicable toxic
pollutant effluent standard under Section 307(a) of the Act;
(2) Discharges which could constitute a threat to human health,
welfare or the environment. These include unusual or extra-
ordinary discharges such as those which could result from
bypasses, treatment failure or objectionable substances
passing through the treatment plant. These include Section
311 pollutants or pollutants which could cause a threat to
public drinking water supplies.
d. Nothing in this permit shall be construed to relieve the permittee
from civil or criminal penalties for noncompliance.
Facilities Operation
All waste collection and treatment facilities shall be operated in
a manner consistent with the following:
a. The facilities shall at all times be maintained in a good
working order and operated as efficiently as possible. This
includes but is not limited to effective performance based on
design facility removals, adequate funding, effective management,
adequate operator staffing and training, and adequate laboratory
and process controls (including appropriate quality assurance
procedures); and
b. Any maintenance of facilities, which might necessitate unavoidable
interruption of operation and degradation of effluent quality,
shall be scheduled during noncritical water quality periods and
carried out in a manner approved by the Permit Issuing Authority.
c. The permittee, in order to maintain compliance with this permit
shall control production and all discharges upon reduction, loss,
or failure of the treatment facility until the facility is
restored or an alternative method of treatment is provided.
Adverse Impact
The permittee shall take all reasonable steps to minimise any
adverse impact to waters of the United States resulting from
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Part II
Page II-3
noncompliance with any effluent limitations specified in this
permit, including such accelerated or additional monitoring as
necessary to determine the nature of the noncomplying discharge.
6. Bypassing
"Bypassing" means the intentional diversion of untreated or partially
treated wastes to waters of the United States from any portion of a
treatment facility. Bypassing of wastewaters is prohibited unless
all of the following conditions are met:
a. The bypass is unavoidable-i.e. required to prevent loss of life,
personal injury or severe property damage;
b. There are no feasible alternatives stich as use of auxiliary
treatment facilities, retention of untreated wastes, or
maintenance during normal periods of equipment down time;
c. The permittee reports (via telephone) to the Permit Issuing
Authority any unanticipated bypass within 24 hours after
becoming aware of it and follows up with written notification
in 5 days. Where the necessity of a bypass is known (or should
be known) in advance, prior notification shall be submitted to
the Permit Issuing Authority for approval at least 10 days
beforehand, if possible. All written notifications shall contain
information as required in Part II (A)(3)(b); and
d. The bypass is allowed under conditions determined to be necessary
by the Permit Issuing Authority to minimize any adverse effects.
The public shall be notified and given an opportunity to comment
on bypass incidents of significant duration to the extent
feasible.
This requirement is waived where infiltration/inflow analyses are
scheduled to be performed as part of an Environmental Protection
Agency facilities planning project.
7. Removed Substances
Solids, sludges, filter backwash, or other pollutants removed in
the course of treatment or control of wastewaters shall be disposed
of in a manner such as to prevent any pollutant from such materials
from entering waters of the United States.
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Part II
Page II-4
8. Power Failures
The permittee is responsible for maintaining adequate safeguards to
prevent the discharge of untreated or inadequately treated wastes
during electrical power failures either by means of alternate power
sources, standby generators or retention of inadequately treated
effluent. Should the treatment works not include the above
capabilities at time of permit issuance, the permittee must furnish
within six months to the Permit Issuing Authority, for approval, an
implementation schedule for their installation, or documentation
demonstrating that such measures are not necessary to prevent discharge
of untreated or inadequately treated wastes. Such documentation
shall include frequency and duration of power failures and an estimate
of retention capacity of untreated effluent.
9. Onshore or Offshore Construction
This permit does not authorize or approve the construction of any
onshore or offshore physical structures or facilities or the
undertaking of any work in any waters of the United States.
B. RESPONSIBILITIES
1. Right of Entry
The permittee shall allow the Permit Issuing Authority and/or
authorized representatives (upon presentation of credentials and
such other documents as may be required by law) to:
a. Enter upon the permittee's premises where an effluent source
is located or in which any records are required to be kept under
the terms and conditions of this permit;
b. Have access to and copy at reasonable times any records required
to be kept under the terms and conditions of this permit;
c. Inspect at reasonable times any monitoring equipment or
monitoring method required in this permit;
d. Inspect at reasonable times any collection, treatment, pollution
management or discharge facilities required under the permit; or
e. Sample at reasonable times any discharge of pollutants.
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Part II
Page II-5
2. Transfer of Ownership or Control
A permit may be transferred to another party under the following
conditions:
a. The permittee notifies the Permit Issuing Authority of the
proposed transfer;
b. A written agreement is submitted to the Permit Issuing Authority
containing the specific transfer date and acknowledgement that
the existing permittee is responsible for violations up to that
date and the new permittee liable thereafter.
Transfers are not effective if, within 30 days of receipt of proposal,
the Permit Issuing Authority disagrees and notifies the current
permitttee and the new permittee of the intent to modify, revoke and
reissue, or terminate the permit and to require that a new application
be filed.
3. Availability of Reports
Except for data determined to be confidential under Section 308
of the Act, (33 U.S.C. 1318) all reports prepared in accordance with
the terms of this permit shall be available for public inspection at
the offices of the State water pollution control agency and the Permit
Issuing Authority. As required by the Act, effluent data shall not
be considered confidential. Knowingly making any false statement on
any such report may result in the imposition of criminal penalties
as provided for in Section 309 of the Act (33 U.S.C. 1319).
4. Permit Modification
After notice and opportunity for a hearing, this permit may be modified,
terminated or revoked for cause (as described in 40 CFR 122.15 et seq)
including, but not limited to, the following:
a. Violation of any terms or conditions of this permit;
b. Obtaining this permit by misrepresentation or failure to
disclose fully all relevant facts;
c. A change in any condition that requires either temporary
interruption or elimination of the permitted discharge; or
d. Information newly acquired by the Agency indicating the
discharge poses a threat to human health or welfare.
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Part II
Page II"-6
If Che permittee believes that any past or planned activity would
be cause for modification or revocation and reissuance under
40 CFR 122.15 et seq, the permittee must report such information to
the Permit Issuing Authority. The submission of a new application
may be required of the permittee.
5. Toxic Pollutants
a. Notwithstanding Part II (B)(4) above, if a toxic effluent
standard or prohibition (including any schedule of compliance
specified in such effluent standard or prohibition) is established
under Section 307(a) of the Act for a toxic pollutant which is
present in the discharge authorized herein and such standard
or prohibition is more stringent than any limitation for such
pollutant in this permit, this permit shall be revoked and
reissued or modified in accordance with the toxic effluent
standard or prohibition and the permittee so notified.
b. An effluent standard established for a pollutant which is
injurious to human health is effective and enforceable by the
time set forth in the promulgated standard, even though this
permit has not as yet been modified as outlined in Condition 5a.
6. Civil and Criminal Liability
Except as provided in permit conditions on "Bypassing", Part II
(A) (6), nothing in this permit shall be construed to relieve the
permittee from civil or criminal penalties for noncompliance.
7. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the
institution of any legal action or relieve the permittee from
any responsibilities, liabilities, or penalties to which the
permittee is or may be subject under Section 311 of the Act
(33 U.S.C. 1321).
8. State Laws
Nothing in this permit shall be construed to preclude the
institution of any legal action or relieve the permittee from
any responsibilities, liabilities, or penalties established
pursuant to any applicable State law or regulation under authority
preserved by Section 510 of the Act.
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Part II
Page II-7
9. Property Rights
The issuance of this permit does not convey any property rights in
either real or personal property, or any exclusive privileges, nor
does it authorize any injury to private property or any invasion of
personal rights, nor any infringement of Federal, State, or local
laws or regulations.
10. Severability
The provisions of this permit are severable, and if any provision
of this permit, or the application of any provision of this permit
to any circumstance, is held invalid, the application of such
provision to other circumstances, and the remainder of this permit
shall not be affected thereby.
11. Permit Continuation
A new application shall be submitted at least 180 days before the
expiration date of this permit. Where EPA is the Permit Issuing
Authority, the terms and conditions of this permit are automatically
continued in accordance with 40 CFR 122.5, provided that the permittee
has submitted a timely and sufficient application for a renewal permit
and the Permit Issuing Authority is unable through no fault of the
permittee to issue a new permit before the expiration date.
C. MONITORING AND REPORTING
1. Representative Sampling
Samples and measurements taken as required herein shall be
representative of the volume and nature of the monitored discharge.
2. Reporting
Monitoring results obtained during each calendar month shall be
summarized for each month and reported on a Discharge Monitoring
Report Form (EPA No. 3320-1). Forms shall be submitted at the end
of each calendar quarter and shall be postmarked no later than the
28th day of the month following the end of the quarter. The first
report is due by the 28th day of the month following the first full
quarter after the effective date of this permit.
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Part II
Page II-8
Signed copies of these, and all other reports required herein, shall
be submitted to the Permit Issuing Authority at the following
address(es):
Permit Compliance Branch
Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Florida Department of Environmental
Regulation
Division of Environmental Programs
Twin Towers Office Building
2600 Blair Stone Road
Tallahassee, Florida 32301
Test Procedures
Test procedures for the analysis of pollutants shall conform to all
regulations published pursuant to Section 304(h) of the Clean Water
Act, as amended (40 CFR 136, "Guidelines Establishing Test Procedures
for the Analysis of Pollutants").
Recording of Results
For each measurement or sample taken pursuant to the requirements
of this permit, the permittee shall record the following information:
a. The exact place, date, and time of sampling;
b. The person(s) who obtained the samples or measurements;
c. The dates the analyses were performed;
d. The person(s) who performed the analyses;
e. The analytical techniques or methods used; and
f. The results of all required analyses.
Additional Monitoring by Permittee
If the permittee monitors any pollutant at the location(s)
designated herein more frequently than required by this permit,
using approved analytical methods as specified above, the results
of such monitoring shall be included in the calculation and reporting
of the values required in the Discharge Monitoring Report Form
(EPA No. 3320-1). Such increased frequency shall also be indicated.
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Part II
Page II-9
6. Records Retention
The permittee shall maintain records of all monitoring including:
sampling dates and times, sampling methods used, persons obtaining
samples or measurements, analyses dates and times, persons performing
analyses, and results of analyses and measurements. Records shall
be maintained for three years or longer if there is unresolved
litigation or if requested by the Permit Issuing Authority.
D. DEFINITIONS
1. Permit Issuing Authority
The Regional Administrator of CPA Region IV or designee.
2. Act
"Act" means the Clean Water Act (formerly referred to as the Federal
Water Pollution Control Act) Public Law 92-500, as amended by Public
Law 95-217 and Public Law 95-576, 33 U.S.C. 1251 et seq.
3. Mass/Day Measurements
a. The "average monthly discharge" is defined as the total mass of
all daily discharges sampled and/or measured during a calendar
month on which daily discharges are sampled and measured, divided
by the number of daily discharges sampled and/or measured during
such month. It is, therefore, an arithmetic mean found by adding
the weights of the pollutant found each day of the month and then
dividing this sum by the number of days the tests were reported.
This limitation is identified as "Daily Average" or "Monthly
Average" in Part I of the permit and the average monthly discharge
value is reported in the "Average" column under "Quantity" on
the Discharge Monitoring Report (DMR).
b. The "average weekly discharge" is defined as the total mass of
all daily discharges sampled and/or measured during a calendar
week on which daily discharges are sampled and/or measured
divided by the number of daily discharges sampled and/or measured
during such week. It is, therefore, an arithmetic mean found by
adding the weights of pollutants found each day of the week and
then dividing this sum by the number of days the tests were
reported. This limitation is identified as "Weekly Average" in
Part I of the permit and the average weekly discharge value is
reported in the "Maximum" column under "Quantity" on the DMR.
c. The "maximum daily discharge" is the total mass (weight) of a
pollutant discharged during a calendar day. If only one
sample is taken during any calendar day the weight of pollutant
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Part II
Page 11-10
calculated from it is the "maximum daily discharge". This
limitation is identified as "Daily Maximum," in Part I of the
permit and the highest such value recorded during the reporting
period is reported in the "Maximum" column under "Quantity"
on the DMR.
4. Concentration Measurements
a. The "average monthly concentration," other than for fecal
coliform bacteria, is the concentration of all daily discharges
sampled and/or measured during a calendar month on which daily
discharges are sampled and measured divided by the number of
daily discharges sampled and/or measured during such month
(arithmetic mean of the daily concentration values). The daily
concentration value is equal to the concentration of a composite
sample or in the case of grab samples is the arithmetic mean
(weighted by flow value) of all the samples collected during
that calendar day. The average monthly count for fecal coliform
bacteria is the geometric mean of the counts for samples collected
during a calendar month. This limitation is identified as
"Monthly Average" or "Daily Average" under "Other Limits" in
Part I of the permit and the average monthly concentration value
is reported under the "Average" column under "Quality" on the DMR.
b. The "average weekly concentration," other than for fecal coliform
bacteria, is the concentration of all daily discharges sampled
and/or measured during a calendar week on which daily discharges
are sampled and measured divided by the number of daily discharges
sampled and/or measured during such week (arithmetic mean of the
daily concentration values). The daily concentration value is
equal to the concentration of a composite sample or in the case of
grab samples is the arithmetic mean (weighted by flow value) of
all samples collected during that calendar day. The average
weekly count for fecal coliform bacteria is the geometric mean
of the counts for samples collected during a calendar week. This
limitation is identified as "Weekly Average" under "Other Limits"
in Part I of the permit and the average weekly concentration
value is reported under the "Maximum" column under "Quality" on
the DMR.
c. The "maximum daily concentration" is the concentration of a
pollutant discharged during a calendar day. It is identified
as "Daily Maximum" under "Other Limits" in Part I of the permit
and the highest such value recorded during the reporting period
is reported under the "Maximum" column under "Quality" on the
DMR.
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Part II
Page 11-11
5. Other Measurements
a. The effluent flow expressed as M-Vday (MGD) is the 24 hour
average flow averaged monthly. It is the arithmetic mean of
the total daily flows recorded during the calendar month.
Where monitoring requirements for flow are specified in Part I
of the permit the flow rate values are reported in the "Average"
column under "Quantity" on the DMR.
b. Where monitoring requirements for pH, dissolved oxygen or fecal
coliform are specified in Part I of the permit the values are
generally reported in the "Quality or Concentration" column on
the DMR.
6. Types of Samples
a. Composite Sample - A "composite sample" is any of the following:
(1) Not less than four influent or effluent portions collected
at regular intervals over a period of 8 hours and composited
in proportion to flow.
(2) Not less than four equal volume influent or effluent
portions collected over a period of 8 hours at intervals
proportional to the flow.
(3) An influent or effluent portion collected continuously
over a period of 24 hours at a rate proportional to the flow.
b. Grab Sample: A "grab sample" is a single influent or effluent
portion which is not a composite sample. The sample(s) shall be
collected at the period(s) most representative of the total
discharge.
7. Calculation of Means
a. Arithmetic Mean: The arithmetic mean of any set of values is
the summation of the individual values divided by the number
of individual values.
b. Geometric Mean: The geometric mean of any set of values is the
Nth root of the product of the individual values where N is equal
to the number of individual values. The geometric mean is
equivalent to the antilog of the arithmetic mean of the logarithms
of the individual values. For purposes of calculating the
geometric mean, values of zero (0) shall be considered to be one (1).
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Part II
Page 11-12
c. Weighted by Flow Value: Weighted by flow value means the
summation of each concentration times its respective flow
divided by the summation of the respective flows.
8. Calendar Day
a. A calendar day is defined as the period from midnight of one
day until midnight of the next day. However, for purposes of
this permit, any consecutive 24-hour period that reasonably
represents the calendar day may be used for sampling.
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Part III
Page III-l
Permit No. FL0037958
PART III
OTHER REQUIREMENTS
A. In accordance with Section 306(d) of the Federal Water Pollution
Control Act (PL 92-500) the standards of performance for conventional
Pollutions as contained in this permit shall not be made any more
stringent during a ten year period beginning on the date of completion
of construction or during the period of depreciation of amortization
of such facility for the purposes of Section 167 or 169 (or both) of
the Internal Revenue (Jode of 1954, whichever period ends first. The
provisions of Section 306(d) do not limit the authority of the
Environmental Protection Agency to modify the permit to require
compliance with a toxic effluent limitation. Promulgated under BAT
or Toxic Pollutant Standard established under Section 307(a) of the
FWPCA.
B. National Environmental Policy Act: (NEPA) Requirements
The below listed requirements, conditions and limitations were
recommended in the site specific Environmental Impact Statement
for the Mobil Chemical Company South Port Meade Mine, and are
hereby incorporated into National Pollutant Discharge
Elimination System Permit No. FL0037958 in accordance with 40
CFR 122.62(d)(9).
1. Mobil shall employ the sand/clay cap waste disposal plan
and the sand/clay cap reclamation plan described in the EIS
and identified as EPA's preferred alternatives for waste
disposal and reclamation.
2. Mobil shall employ high profile overburden stacking in the
mining of the area covered by Clay Settling Area 10 (CS-10)
to the maximum extent compatible with toe spoiling of the
leach zone. If any increase in waste storage volume is
realized by the use of this technique, it shall be
reflected in a lower reclaimed elevation for the area
rather than an increase in clay storage within CS-10.
3. Mobil shall meet the requirements of its Southwest Florida
Water Management District (SWFWMD) Consumptive Use Permit.
4. Mobil shall provide storage that allows recirculation of
water recovered from slimes. The water circulation system
and storage capacity shall be as described in the EIS for
Mobil's proposed project.
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Part III
Page III-2
Permit No. FL00379
5. During the dragline mining activity, Mobil shall, in
accordance with its proposed action in the EIS, employ the
technique o£ leach zone management by toe spoiling, i.e.,
overburden from near the interface with the matrix shall be
placed at the toe of the spoil pile and covered with
overburden from upper strata.
6. Mobil shall meet county and state reclamation require-
ments. Mobil shall contact the District Forester or the
State Forester, Florida Forest Service, for assistance in
the forestry aspects of the reclamation program.
7. Mobil shall preserve from mining, or any other disturbance
not essential to and unavoidable for the mining operation,
the areas designated for preservation in Mobil's proposed
action in the EIS. Specifically, the total of 1094 acres
thus preserved shall include a minimum of 182 acres of
cutover flatwoods, 664 acres of upland hardwood forest, 5
acres of upland mixed forest, 111 acres of freshwater
swamp, and 21 acres of freshwater marsh, all in the
locations depicted in the attached Figure 1.
8. Before beginning any land-disturbing activities, Mobil
shall develop a program whereby indigo snakes encountered
in the work area are captured and turned over to the FGFWFC
Endangered Species Coordinator for relocation fco other
suitable habitats in the region. (The technique for
handling and keeping this species until the FGFWFC arrives
is to place the snake in a cloth sack, out of the sun,
preferably in an air conditioned building.) The program
shall include informing Mobil workers of the importance of
the indigo snake, familiarizing them with its appearance
and instructing them as to its preservation. In addition,
the gopher tortoise population in the site area shall be
protected to the extent possible. Mobil shall maintain a
record of the program to be submitted to the U.S. Fish and
Wildlife Service office in Jacksonville, Florida.
9. Mobil shall not conduct any mining, or any activity
associated with its mining operation, within 1500 feet in
any direction of the bald eagle nest located in T32S, R26E,
Section 9. Beginning four years prior to site preparation
activities preceding mining of the areas closest to the
eagle nest (to the east, south and west), Mobil shall
provide for a field study to be performed by a qualified
biologist to determine the area(s) being utilized for
feeding by the eagles. Observations shall be conducted
from January 1st through April 15 of the specified year.
Since young may or may not be produced in any given year,
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Part III
Page III-3
Permit No. FL0037958
Mobil shall attempt to provide data for at least one
successful nestling period during the referenced four
years. Specifics of the study shall be coordinated with
and reviewed by the USF&WS office in Jacksonville,
Florida. If it appears at the onset of the study year that
the subject eagle nest is no .longer in existence, that fact
must be confirmed by a letter from the USFfcWS. If the
results of the study reveal that the eagles are utilizing
an area on the Mobil property for feeding, Mobil shall
preserve that area from disturbance.
10. Mobil shall comply with the categorization of wetlands
present on the mine property as set forth in the EIS and
illustrated in Figure 2, attached. In summary, within
Category 1 wetlands, Mobil shall not mine, shall limit
activities to those essential to and unavoidable for the
mining operation, and shall otherwise take all reasonable
measures to preserve all Category 1 wetlands. In addition,
Mobil shall restore the total acreage of Category 2
wetlands disturbed by mining.
11. Mobil shall conduct a monitoring program to assess the
wetlands restoration and re-creation effort at the South
Fort Meade Mine. Three wetland re-creation areas (a
depression wetland in sand/clay capped area CS-1, the
reforested stream channel of Maron Run, and the forested
wetland in sand/clay capped area CS-14) shall be monitored
for one year according to the following program: (1)
Beginning 12 weeks after completion of the reclamation of
each respective area, the water level shall be monitored
biweekly; and (2) Following the first full growing season,
a biological assessment shall be performed by a degreed
biologist for each of the three areas; the assessment shall
include a listing of wetland plant species present, mapping
of their location, a visual estimate of the amount of cover
provided by the wetland species, and sampling of the
benthic macroinvertebrates to yield a list of the species
collected and their density. After the above-described
monitoring program is performed for both the sand/clay
depression area and the forested stream channel, one area
shall be selected by EPA for long-term monitoring by
Mobil. This long-term monitoring program shall consist of
a yearly biological assessment by a degreed biologist to
include the items in (2) above. In addition, in order to
determine the degree of subsidence occurring, if any, the
maximum depth of the marsh depression area relative to a
fixed elevation point shall be monitored quarterly for the
life of this permit. Mobil shall submit annual reports of
the described monitoring program to the EPA Region IV
Ecology Branch.
6-23
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Part III
Page III-4
Permit No. FL0037958
12. During the raining activities conducted near the Bowlegs
Creek preserved area, Mobil shall monitor the Shallow
Aquifer to assess the effectiveness of the perimeter ditch
in preventing dewatering of the preserved area. This
monitoring program shall consist of using the existing well
#SA-3 to perform weekly manual water level measurements
during the first sixteen weeks of mining near Bowlegs Creek
and monthly thereafter until the mining pit immediately
adjacent to the preserved area is closed. Mobil shall not
allow the Shallow Aquifer in this preserved area to be
lowered more than three feet due to the mining activites.
13. Mobil shall provide bona fide researchers reasonable
opportunity to salvage paleontological specimens and
information for the duration of mining operations on the
Mobil site. Prospective collectors availing themselves of
this provision must have credentials verified by the
Florida state Museum. Such individuals shall be allowed
regular entry to accessible dragline spoil windrows and ore
residue sites, on a strictly not-to-interfere with mining
basis. Such individuals must furnish current certificates
of compliance with the training requirements of the Federal
Mine Safety and Health Act of 1977, P.L. 91-173 as amended
by p.L. 95-164. Such training shall be equal to that
required in the act for the category of Miner. Further,
such individuals that avail themselves of this provision
shall be subject to MobiJ'a requirements for safety and
visitor accountability. FatJure to comply with any of the
requirements set forth in this provision will result in the
revocation of the individual's access privilege as granted
under this provision.
14. Unless specified otherwise by a preceding condition in this
permit, Mobil shall perform its mining project in complete
accordance with the applicant's proposed action described
and evaluated in the Mobil South Fort Meade Mine GIS and
Supplemental Information Document (SID), including the
employment of all mitigating measures presented as part of
the proposed action. However, this shall not preclude the
imposition of any additional or more stringent conditions
which may be required by any local or state regulatory
agency or governmental entity.
6-24
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Figore 1
UNDISTURBED AREAS
T32S
T33S
SOURCE: ZELLARS-WILLIAMS
0 1/2 / mite
LEGEND
UNDISTURBED AREAS
# WETLANDS TO REMAIN
UNDISTURBED
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Figure 2
WETLAND DELMEATION MAP
PROPOSED SOUTH FORT MEADE MNE SITE
MOBL CHEMCAL COMPANY
EPA APPROVED
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