United States Region 4 EPA 904/9-82-104
Environmental Protection 345 Courtland Street, NE December, 1982
Agency Atlanta, Ga. 30365
Environmental Draft
Impact Statement
Supplement
Estech, Inc.
Duette Mine
Manatee County, Florida
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y p-z-ion iy
Q . ,-i * Section Agency
--..ixu street
Borgia 30308
SUPPLEMENT TO FINAL
ENVIRONMENTAL IMPACT STATEMENT
for
Proposed Issuance of a New Source National
Pollutant Discharge Elimination System Permit
Estech, Inc.'s
Duette Mine
Manatee County, Florida
prepared by:
U.S. Environmental Protection Agency
Region IV, Atlanta, Georgia 30365
Estech, Inc. has proposed an open pit phosphate mine,
beneficiation plant, and rock dryer on a 10,394-acre site
in northeastern Manatee County, Florida. The proposed project
was addressed in an Environmental Impact Statement prepared
by EPA. Since publication of the Final EIS in September
1980, Estech has made several revisions in their project
plans. This Supplement to the Final EIS examines the new and
revised project alternatives, impacts of the alternatives,
and mitigative measures to avoid or minimize adverse impacts.
Comments will be received until MAR 0 J 1983
Comments or inquiries should be directed to
A. Jean Tolman, EIS Project Officer
U.S. Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, Georgia 30365
(404) 881-3776
approved by:
to
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Summary Sheet for Supplement to
Final Environmental Impact Statement
Duette Phosphate Mine
Estech, Incorporated
(X) Draft
( ) Final
U.S. Environmental Protection Agency, Region IV
34b Courtland Street NE
Atlanta, Georgia 3036b
1. Type of Action: Administrative (X) Legislative ( )
2. Brief Description of Action:
The proposed action addressed in this Supplement is essentially
the same as described in the Final Environmental Impact Statement
(Final EIS) published in September 1980. It is the proposed
issuance by EPA of a new source NPDES permit to Estech, Inc. for
their proposed phosphate mining operation in Manatee County,
Florida.
Estech is proposing to construct and operate an open pit phosphate
mine, beneficiation plant and rock dryer located on a 10,394-acre
site in northeastern Manatee County. The mine would produce 3
million tons of phosphate rock per year over a period of 21 years.
Since the publication of the Final EIS, the State of Florida has
reclassified the Manatee River at and below the discharge point
from Class 111 to Class 1-A Standards. In order to minimize
discharges from the Duette Mine and meet the more stringent water
quality standards, Estech has made the following changes in its
water management plan: (1) elimination of the planned diversion
and impoundment of a portion of the flow of the East Fork of the
Manatee River; (2) construction of an earthen embankment around
the 210-acre reservoir to provide an additional 3bUU acre-feet of
water storage within the recirculation system; (3) reduction of
groundwater usage by increased use of recycled process water
(possibly after pretreatment in a reverse-osmosis plant); and (4)
the use of active mining areas for water storage when prescribed
levels are reached in the recirculation system storage. Moreover,
as further required by the State of Florida, Estech proposes to
use sano-clay mix (except in an emergency), instead of clay only,
in the 4bU-acre initial settling area. All other aspects of
Estech's proposed operations remain as in the Final EIS.
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In February 1982, the EPA Region IV determined that, because of
the chan9es above described, a Supplement to the Final E1S was
required prior to taking action on Estech's NPDES permit applica-
tion. This Draft Supplement addresses the changes in Estech's
proposed project as well as the change in classification of the
receiving water.
3. Alternatives Considered:
All alternatives evaluated in the Draft ana Final E1S were
re-examined to determine if the project revisions significantly
affected the initial analyses. The alternatives requiring
re-evaluation in this Supplement were: (1) process water source,
(2) waste disposal/reelamation plan, (3) surface water discharge
volume, (4) discharge point, and (b) no-action.
Process Water Source Alternatives:
Process water source alternatives considered in the EIS were: use
of surface and ground water, total requirement from the deep
F1oridan Aquifer, use of surface water in rainfall catchment, and
use of water from the surficial aquifer. Estech's proposed action
in the EIS was for the combined use of surface water (by intake
from the East Fork Manatee River) with deep ground water as the
primary source. Estech's revised proposal calls for significantly
reduced groundwater consumption (from 1U mgd to 2 mga, approximate
annual average), supplemented by surface water from on-site stor-
age. This is to be accomplished by maximizing the use of avail-
able on-site storage such as mine cuts, constructing a reservoir
embankment for additional storage, and modifying the flotation
process to use recycle water. Intake of water from the East Fork
Manatee River is also eliminated.
Waste Disposal/Reelamation Alternatives:
Two alternative waste disposal/reelamation pians--conventional and
sand-clay mix (Estech's proposal )--were evaluated in the EIS.
Estech's proposal called tor a 480-acre initial clay settling area
and b426 acres of sand-clay mix. Estech's revised proposal re-
mains the same except that the 480-acre initial settling area
would be filled with sand-clay mix instead of clays only.
Surface Water Discharge Volume Alternatives:
The EIS considered four alternatives: containment of long-term
accumulation, containment of short-term accumulation, containment
to offset evaporation losses, and n-o containment. Estech's
proposal as evaluated in the EIS was for containment to offset
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evaporation losses, resulting in an average discharge o.t approxi-
mately 200U gpm. Estech's revised proposal, evaluated in this
Supplement, is for containment ot long-term accumulation in order
to eliminate a surface water discharge from the site.
Discharge Point Alternatives:
The EIS evaluated four discharge plans utilizing one or more of
the following discharge points: direct to reservoir pool connec-
ted to the East Fork Manatee River, direct to the East Fork
Manatee River, direct to the North Fork Manatee River, and deep-
well injection. Estech's proposal in the E1S called toe a com-
bination of discharge points including discharge directly into
the North Fork (discharge point 003), into the reservoir when not
full (001K and directly into the East Fork when the reservoir was
full (002). Changes in Estech's discharge point plan are a direct
result of the revised water management plan. Estech's revised
plan includes a change in the reservoir configuration which re-
sults in two discharge points (001 and 002) being in direct flow
alignment. Discharge point 001 (upstream of 002) becomes redun-
dant and can be eliminated. Discharge point 002 would be posi-
tioned to control discharges (if such unexpected discharges were
to occur) at the downstream end of the reservoir. No change in
discharge point 003 is proposed.
No-action Alternative:
The no-action alternative evaluated in the E1S was for Estech to
not construct the Duette Mine and to allow the area to continue
its present day socioeconomic and environmental trends. Onder
Estech's original proposal, this would have occurred had EPA
denied the permit. The additional no-action alternative evaluated
in this Supplement is for EPA to deny the permit application for
the revised project.
4. Summary of Major Environmental Effects:
The Duette Mine project as originally proposed by Estech was eval-
uated in the E1S, and the impacts expected to result from its
implementation were described therein. This Supplement has evalu-
ated the new or revised alternatives proposed by Estech since the
publication of the Final EIS. A summary of the potential impacts
resulting from the revisions to the project is provided in the
following table.
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ELEMENT
IMPACTS OF PROPOSED PROJECT"REVISIONS
Air Quality
Groundwater Hydrology
Groundwater Quality
I
4*
Surface Water
Hydrology
Surface Water Quality
Soi 1 s
Radiological
Envi ronment
Additional source
particulates, S02.
Increase Levels
of emissions due to reverse osmosis facility:
NO?, CO—all less than Specified Significant
Reduction in groundwater withdrawals from 10 mgd to 2 mgo annual
average, causing slight reduction in drawdown of deep aquifer,
small decrease in induced leakance from shallow ground water to
deeper system, and decrease in potentiometric-surface drawdown
at property boundary from 2.b ft. to 0.5 ft. Slight seepage
increase during initial operation of initial settling area (ISA)
as sand-clay mix.
R/0 facility, if
the recirculation system and
used, would introduce several chemicals into
„ redistribute suspended and
dissolved solids ordinarily in recycle water. Contaminant sinks
available to these compounds are expected to minimize the
amounts entering the ground water through seepage.
Eliminating the intake of water from the East Fork Manatee River
(2.8b mgd annual average) would allow that quantity of water to
remain in the stream channel and ba available downstream. Since
intake was limited to high flow periods, hydrological effect of
this decrease is insignificant.
Elimination of proposed surface water discharges has eliminated
potential surface water quality degradation from site effluent.
Conversion of 480-acre initial settling area to sand-clay mix
slightly reduces probability of dam failure with resulting
surface water degradation. In event of dam failure of the
initial settling area, contents would no longer reach Lake
Manatee Reservoir: downstream limit expected to be 3.4 miles
upstream of lake. Probability of failure of embankment of 210-
acre reservoir is 1 in 100,000. Failure would release maximum
of 3,500 acre-feet of stormwater, with sedimentation impact of
2b-year peak flow sediment flush from river system.
Use of sand in the initial settling area would replace 480 acres
of overburden-capped clays with sandy-loam soil, with slightly
improved physical, agronomic, and engineering properties.
Sand-clay mix in the initial settling area would reduce the post
reclamation terrestrial gamma radiation from 13.8 yR/hr for the
clay only to 8.7 uR/hr for the sand-clay mix.
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£>. EPA's Preferred Alternatives and Mitigatiny Measures:
Process Water Source Alternative
by refining the water management plan, Estech's revisea alterna-
tive provides a means to reduce groundwater consumption without
the construction of extensive impoundment areas ana without
diversion of river water. Therefore, the combined use of ground
water and surface water (excluding the diversion of the East Fork
Manatee River) as now proposed by Estech is also tPA's preferred
alternative.
Waste Disposal/Reclamation Alternative
The principal advantage of using sana-clay mix instead of clays
only in the initial settling area (ISA) is a significant reduction
in the extent to which the ISA contents woula flow in the event
of a dam failure. The addition of sana would also improve the
soil characteristics and result in a lower terrestrial gamma
radiation level than with clays alone. Therefore, the revised
proposal for sand-clay mix in the initial settling area is also
EPA's preferred alternative.
Surface Water Discharge Volume Alternative
The revised alternative for containment of long-term accumulation
and elimination of surface water discharge clearly reduces the
potential for surface water degradation ana is EPA's preferred
alternative.
Discharge Point Alternative
Changes in the discharge point plan are attenaant to the revised
water management which is preferred by EPA.
Mitigative Measures
Controlling annual average water levels to 112 ft. MSL in the
recirculation system and to yb ft. MSL in the 210-acre reservoir
would maintain seepage to the surficial aquifer at a minimum. In
addition, observation wells should be installed and a monitoring
program implemented to detect any possible contamination of ttie
surficial aquifer from the sano-clay mix areas, including the
initial settling area and the recirculation ditches. Limiting the
carbon regenerating capacity of the kiln would assure that NU
emissions would not exceed the specified "Significant Increase
Level".
b. EPA's Proposed Action:
Pursuant to provisions of the Clean Water Act of 1 y'/7, EPA pro-
poses to issue a NPUES permit to Estech, Inc. for their proposed
Uuette Mine in Manatee County, Florida. The proposed permit would
impose as permit conditions all mitigating measures incorporated
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within Estech's proposed project, including the revised alterna
tives addressed in this Supplement, ana all mitigating measures
recommended by EPA in the EnvironmentaI Impact Statement and in
this Supplement.
7. Pending and Kelatea issues
Estech's consumptive use permit ^CliPj granted by the Southwest
Florida Water Management District ^SWFWMUj on September b, i^7b,
expires on September b, i9b4. The permit requires the construc-
tion of a recharge-well system to directly recharge i3,Uilt,UUU
gallons per day ^annual averagey trout the uncontined surficial
aquifer and/or secondary artesian aquifer to the Floridan Aquifer,
"lhe project evaluation performed in the EiS included the recharge
program of connector wells as a part of Estech's proposed action.
The CUP and its conditions are still in effect, ano the proposed
project revisions submitted to EPA by Estech do not include
changes to, or elimination of, the recharge program, lhe subject
is, accordingly, not included in the scope of this Supplement.
However, it has been brought to EPA's attention by Manatee County
that a test recharge well on Estech's Duette property has shown
gross alpha radiation levels in water drawn from the surficial
aquifer which exceed drinking water standards. The source of the
elevated gross alpha has apparently not yet been identified;
meanwhile, SWFWMU has ordered the well capped. It seems probable
that SWFWML) will consider eliminating the recharge project
requirement, particularly in view of the currently proposed
reduction in ground water withdrawals. Such action is clearly
within the authority of SWFWMD and would be consistent with the
Central Florida Phosphate Industry Areawide E1S recommendation
which is for connector wells provioea the drained water can meet
drinking water standards.
If the recharge requirement were eliminated, the revised water
balance and water management alternative presented in this
Supplement wo,ulo be unaffected. Ihis is because a conservative
approach was taken in establishing the water storage requirements
in that no credit was given in the water balance calculations tor
removal of water by way of the connector wells. Therefore,
elimination of the recharge program would not increase the
requirement for available water storage.
A second unresolved issue concerns the issuance by the Florida
Department of Environmental Regulation (FDER) of the required
state permits and NPDES permit certification, un May Zb, lbbZ,
the FDEK issued its final order stating that within 3U days the
FDER would issue Estech a dam construction permit, dredge and fill
permit, state discharge permit, and state certification for the
NPDES permit. However, the issuance of these permits has been
stayed pending the outcome of an appeal by Manatee County to the
District Court of Appeal-. The final order also found that Estech
would be required to apply for ano obtain a ground water discharge
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permit from FDER. Regarding any future ground water permit, it
is EPA's intention that the proposed NPDES permit condition
requiring ground water monitoring would be consistent with any
monitoring program developed by the FDER.
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SUPPLEMENT TU FINAL
ENVIRONMENTAL IMPACT STATEMENT
TABLE OF CONTENTS
Page
SUMMARY SHEET FOR SUPPLEMENT TO FINAL
ENVIRONMENTAL IMPACT STATEMENT 1
TABLE OF CONTENTS . i
LIST OF FIGURES iv
LIST OF TABLES v
1.0 PURPUSE AND NEED 1-1
2.0 DESCRIPTION OF THE PROPOSED ACTIVITY 2-1
3.0 ALTERNATIVES EVALUATION 3-1
3.1 PROCESS WATER SOURCE ALTERNATIVES 3-1
3.1.1 Description of the Revised
Alternative 3-1
3.1.2 Environmental Advantages 3-2
3.1.3 Envi ronmental Disadvantages 3-2
3.1.4 Summary Comparison 3-2
3.2 WASTE DISPOSAL/RECLAMATION ALTERNATIVES 3-3
3.2.1 Description of the Revised
Alternative 3-3
3.2.2 Environmental Advantages ............. 3-3
3.2.3 Environmental Disadvantages 3-4
3.2.4 Summary Comparison 3-4
3.3 SURFACE WATER DISCHARGE VOLUME
ALTERNATIVES 3-4
3.3.1 Description of the Revised
Alternative 3-5
3.3.2 Environmental Advantages 3-b
3.3.3 Environmental Disadvantages 3-b
3.3.4 Summary Comparison 3-b
3.4 DISCHARGE POINT ALTERNATIVES 3-b
3.4.1 Description of the Revised
Alternative 3-b
3.4.2 Environmental Advantages/Disadvan-
tages 3-7
3.4.3 Summary Comparison 3-7
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TABLE UF CONTENTS
(CONTINUED )
Page
3.5 NU-ACTION ALTERNATIVE 3-7
3.6 MIT I GAT IVE MEASURES 3-8
3.6.1 Air Quality 3-8
3.6.2 Groundwater Hydrology 3-8
3.6.3 Groundwater Quality 3-8
3.6.4 Surface Water Quality 3-9
3.7 EPA'S PREFERRED ALTERNATIVES, MITIGATIVE
MEASURES, AND RECOMMENDED ACTION 3-f
4.0 THE AFFECTED ENVIRONMENT AND ENVIRONMENTAL
CONSEQUENCES 4-1
4.1 AIR QUALITY 4-1
4.1.1 Description of Air Emission Source ... 4-1
4.1.2 Permitting Requirements 4-2
4.2 GROUNDWATER HYDROLOGY 4-4
4.2.1 Deep Groundwater Withdrawals 4-4
4.2.2 Recirculation System 4-4
4.2.3 Reservoir 4-5
4.2.4 Initial Settling Area 4-5
4.3 GROUNDWATER QUALITY 4-5
4.3.1 Plant Reagents and Scrubber Wastes ... 4-6
4.3.2 Other Wastes 4-6
4.3.3 Deposition of R/O Contaminants 4-7
4.4 SURFACE WATER HYDROLOGY 4-8
4.4.1 Water Balance Development 4-8
4.5 SURFACE WATER QUALITY 4-13
4.5.1 Conversion of Clay Settling Area to
Sand-Clay Mix 4-13
4.5.2 210-Acre Reservoir Embankment 4-14
4.5.3 Reverse Osmosis Water Treatment
Facility 4-15
4.5.4 Proof Testing of Initial Settling
Area 4-15
4. 5SandrClay Mix Runoff 4-16
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TABLE OF CONTENTS
(CONTINUED)
Page
4.6 SOILS 4-18
4.7 RADIOLOGICAL ENVIRONMENT 4-18
5.0 SHORT-TERM USE VERSUS LONG-TERM PRODUCTIVITY b-1
5.1 AIR QUALITY b-1
5.2 GROUNDWATER HYDROLOGY 5-1
5.3 GROUNDWATER QUALITY b-1
5.4 SURFACE WATER QUALITY 5-1
5.5 SURFACE WATER HYDROLOGY ..., b-2
5.6 SOILS 5-2
5.7 RADIATION b-2
6.0 COMPARISON WITH AREAWIDE EIS RECOMMENDATIONS 6-1
7.0 COORDINATION 7-1
7.1 FINAL ENVIRONMENTAL IMPACT STATEMENT
DRAFT SUPPLEMENT COORDINATION 7-1
7.2 CONSULTATION WITH THE U.S. DEPARTMENT OF
INTERIOR, U.S. FISH AND WILDLIFE SERVICE .... 7-3
7.3 CONSULTATION WITH THE STATE HISTORIC
PRESERVATION OFFICER 7-3
7.4 COORDINATION WITH THE U.S. DEPARTMENT OF
INTERIOR, MINERALS MANAGEMENT SERVICE 7-3
8.0 LIST OF PREPARERS 8-1
9.0 REFERENCES * 9-1
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SUPPLEMENT TO FINAL
ENVIRONMENTAL IMPACT STATEMENT
LIST UF FIGURES
Page
Figure 1-1 Lotation of Proposed Duette Mine 1-1
Figure 2-1 Water Distribution Conceptual Flow
Diagram - Original Proposal 2-2
Figure 2-2 Water Distribution Conceptual Flow
Diagram - Revised Proposal 2-3
Figure 2.3-1 Master Development Plan with
Dragline Sequence 2-4
Figure 2-3 Conceptual Flow Schematic - Recycled
Water Preparation Plant 2-9
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SUPPLEMENT TO FINAL
ENVIRONMENTAL IMPACT STATEMEN1
LIST OF TABLES
Page
Table 2-A Summary of Probability of Exceeding
17,000 Acre-Feet of Storage 2-6
Table 4.1-A Emission Estimate vs. Specified
Significant Net Emissions Increase .. 4-3
Table 4.4-A Water Balance - One-month Increments -
Design Storage of 10,000 Acre-Feet Recir-
culation System 4-10
Table 4.4-B Summary of Water Balance Calculations
for Different Combination of Mining and
Rainfall Sequences 4-11
Table 4.4-C Storage Available for Excess Water (in
Acre-Feet) 4-12
Table 4.4-D Water Balance - One-Month Increments -
Design Storage of 17,000 Acre-Feet
Recirculation System 4-13
Table 4.b-A Parameters Affected by Classification
Change 4-17
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SUPPLEMENT TO FINAL
ENVIRONMENTAL IMPACT STATEMtNT
1.0 PURPOSE AND NEED
Estech, Inc., a wholly owned subsidiary of Esmark, is a producer
of agricultural chemicals and phosphate products. Estech proces-
ses phosphate ore in the Central Florida area as part of their
current operations in Southwestern Polk County, Florida. The
Duette Mine phosphate reserve would serve as a replacement for thfi
Watson and Silver City Mines as their reserves are depleted and
their production expires.
Estech's proposed Uuette Mine, encompassing 10,394 acres, would
be located approximately thirty-four miles east of Bradenton in
Northeastern Manatee County, Florida (Figure 1-1). The proposed
project would allow Estech to maintain a supply of phosphate ore
to its customers through an annual production rate of 3 million
tons of phosphate product. The operation would mine a total of
6,600 acres of the 10,394-acre site over the 21-year life of the
mine.
Figure 1-1 Location of Proposed Duette Mine
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As required by the Federal Water Pollution Control Act, and the
amendments of the Clean Water Act of 1977, Estech applied to
the U.S. Environmental Protection Agency (EPA) for a National
Pollution Discharge Elimination System (NPDES) permit for the
proposed Duette Mine. The EPA Regional Administrator deter-
mined in May 197b that the proposed discharge constituted a
"new source" requiring issuance of an NPDES permit. The granting
of the NPDES Permit would be a major Federal action significantly
affecting the quality of the human environment. Therefore, EPA,
as required by the National Environmental Policy Act of 19fa9
(NEPA), prepared an Environmental Impact Statement (E1S) for
Estech's Duette Mine. The EIS was prepared by a third party
contractor under the direction and review of EPA Region IV.
Since the publication of the Final Environmental Impact Statement,
Estech has been engaged in administrative proceedings with the
State of Florida Department of Environmental Regulation and other
parties in an attempt to obtain the necessary state permits
and state certification of the draft NPDES permit required by
Section 401 of the Clean Water Act. In addition, in this interim
period, the Manatee River has been reclassified from Class 111
(Recreation/ Fish and Wildlife Propagation) to Class 1-A (Potable
Water Supply). As a result of requirements placed on Estech by
the Department of Environmental Regulation (FDER, 19b2) and the
reclassification action, Estech now proposes certain revisions to
its water management system that are designed to eliminate dis-
charges from the Duette Mine to the East and North Forks of the
Manatee River. These revisions include:
Elimination of Surface Water Intake - As originally proposed,
Estech would have constructed a stationary weir designed to direct
excess flow from the East Fork of the Manatee River under high
flow conditions into an on-site reservoir (Figure 2-1). Under the
current plan, there would be no diversion and impoundment of
waters of the United States (Figure Z-Z).
Increasing Storage Capacity of Reservoir - Estech proposes to
construct an e~arthen embankment around the 21U-acre reservoir to
provide an additional 3,500 acre-feet of storage in the recircu-
lation system.
Installation of Recycle Water Preparation Facility - As a means
of reducing pumpage of ground water, Estech proposes to use
recycled process water in the flotation circuit. Periodically
during the mine life, it may be necessary to treat the recycle
water to provide the high quality water needed for the flotation
process. Although several water treatment methods are possible,
a reverse osmosis facility is currently being considered.
Maximizing Available On-Site Storage - Estech has modified their
water management plan to incorporate areas not previously used for
water storage, i.e., active mining areas. These areas were always
available but not integrated into the water storage/recirculation
plan. By maximizing the available on-site storage and revising
its water management program, a minimum storage capacity of
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approximately 17,000 acre-feet (after the first five years of
mining) has been developed.
An additional project revision proposed by Estech is the use of
sand-clay mix in the 4b0-acre initial settling area. This
revision was not proposed for water management purposes, but is
required as a result of the State Development of Regional Impact
process (Chapter 380, Florida Statutes).
In accordance with Section 1502.9 of the Regulations for Imple-
menting the Procedural Provisions of the National Environmental
Policy Act (CEQ, 1978), the U.S. EPA Regional Administrator has
determined that these project revisions constitute possible
"significant new circumstances or information relevant to envi-
ronmental concerns". Therefore, the U.S. EPA is required to
prepare a Supplement to the Final EIS to evaluate these revisions.
Since the explicit purpose of the Supplement is to address the
proposed project revisions, the Draft EIS (USEPA, 1979a) and
its attendant Resource Documents (USEPA, 1979b) published in
October 1979, and the Final EIS (USEPA, 1980) published in
September 1980, are essential to full understanding of this
Supplement.
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2.0 DESCRIPTION OF THE PROPOSED ACTIVITY
The following description of the proposed activity incorporates
those changes resulting from: a) requirements placed on Estech,
Inc. by the Department of Environmental Regulation in state
administrative proceedings; b) conditions imposed by the Florida
Governor and Cabinet acting as members of the Land and Water
Adjudicatory Commission; and c) reclassification of the Manatee
River from Class 111 (Recreation/Fish and Wildlife Propogation)
to Class I-A (Potable Water Supply). Figures 2-1 and 2-2 concep-
tually illustrate the activity as originally proposed and as
currently proposed, respectively. In order to clearly show the
changes relative to the entire project, a description of the
proposed activity is presented verbatim from the Final EIS with
the required deletions being struck through ( ) and additions
underlined ( ).
Estech proposes to use equipment and design generally available
and practiced by presently operating mines. The major components
of the operation are large walking draglines; hydraulic ore trans^
portation via pipeline to a central washer; a feed preparation am
flotation plant; rock storage and drying; and shipment via rail.
The draglines strip overburden for deposit in mined-out cuts.
Exposed matrix is excavated and dumped into a slurry pit or
"well" -- an excavated sump within reach of the dragline. A pit
control car directs high pressure water guns at the matrix break-
ing it into a slurry. Pumping systems deliver the slurried matri;
to the plant.
Slurried matrix is passed through a wet screening process. Unac-
ceptable pebble is discarded as waste. Product is stored in
pebble bins for dewatering and quality control analysis prior to
shipment or placement on storage piles.
Underflow fine material from washer screens moves to the feed
preparation area where hydrocylones separate the waste clays from
the sand-sized particles, termed feed. The feea is transported
to the flotation circuit.
Flotation is a two-stage process; "rougher" flotation separates
phosphate particles from silica sand and "cleaner" flotation
by an amine flotation of the sand particles. The sand-sized
product, termed concentrate, is then dewatered.
Rock dewaters to about 13% moisture while in storage with drain-
age directed to the plant water system. The storage system
delivers wet rock to either the dryer feed bins or the wet rock
loadout bins.
The last step in processing is drying. The average 13% moisture
is reduced to 2% in the dryer. Dry product is transferred to
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FIGURE .
2.3-1
U.S. EPA - REGION IV
DRAFT ENVIRONMENTAL
MASTER DEVulOPMENT PLAN
IMPACT STATEMENT FOR
SWIFT AGRICULTURAL CHEMICALS
WITH DRAGLINE SEQUENCE
CORPORATION
PROPOSEO OUETTE 'MINE
SOURCE :
ZELLARS - WILLIAMS , INC.
MANATEE COUNTY , ft ORIDA
<•> A
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concrete silos for storage. Conveyors transfer ary rock from the
silos to rail loadout facilities.
The beneficiation of phosphate ore generates two solid waste
products: 1) clay or "slimes" and 2) sand tailings. Estech has
committed in their mine plan to use a sand-clay mix in lana
reclamation and thereby reduce the need for traditional separate
disposal areas. Estech plans to use a flocculant thickener method
whereby clays are pumped from the beneficiation plant to mechani-
cal thickeners where flocculants are added. Sand tailings from
the plant are added to the thickened clays either directly at the
thickener or at a downstream mixing station. Approximate1y
5,906 acres are planned for use as sand-clay type disposal
areas.
A-4&0-as pe-ceRveRti-ORal--slay-settl-i-ng-a pea -i-s-pVaRRed-fep-fehe
BURev--Tbis-apea-wi-l-l--PeGeive-al-l--cl-ay-wastes-9eneFateei-befepe-tbe
saRfl-6la.y-mix-pP96eabipe-be6emes-epepati9na}T The 4b0-acre initial
settling area will be a sand-clay mix as oTTposea to a conventional
clay-only settling area.* The settling area will remain active
throughout the mine life to receive clay and sand wastes vn-exeess
ef-the-saR€l-e*ay-m4x-FemiipemeRfes and to serve as a secondary
water clarification and storage area. By the end of the mine
life, the area will be filled to about 2b feet above natural
grade.
In the first years of mining, sand tailings will be used to
construct retaining dikes. Thereafter, about 42 acres per year
will be backfilled with tailings for a total of tt4b acres.
The proposed water management plan divides the needed supply
betyreen surface and groundwater resources, minimizes mining
process consumption, and provides for recharge of the Floridan
Aquifer. Water management measures have been incorporated into
the project design in an effort to maximize the use of recycle.
water, minimize withdrawal of ground water, and eliminate
discharge to surface waters (FDAH, 1982; FDER, 19b2).
Estech elected to modify the flotation process to permit the use
oT recycled process water in the acid rinse cycle. This modi-
fication, along with a modification which permits recycled water
in the amine flotation circuit, resulted in a significant reduc-
tion of water input to the water system. With this reduction in
process requirements and by increasing the storage capacity of the
210-acre clear-water reservoir (See Section 4.2.3), itwas possi-_
b'le to balance the system over the long-term and to design a
storage system that would eliminate overflow except during periodj
of long-term, exceptionally heavy rainfall.
*Pursuant to a September 19b0 condition of approval by the
Governor and Cabinet, acting as members of the Land and Water
Adjudicatory Commission.
-------
Since the chance of overflowing the system during
ally heavy ra i n t a I 1 wo'u*] g st i 1 T be 1 in 2b, Estech
+ n n 1 iiTTrr fTTTr n ii u r + I fn .""¦"r-!1 1 ¦ . . ¦! 1 ¦ if -
this exception-
now proposes
to divert this overt low^ nt.p the current mining areas when all but
IbOu acre-feet of the available storage within the recirculation
system becomes filled.
eliminate overflow
The effect of this action would be to
from the system even during periods of long-
term, exceptionally heay'v rainfall.
it the current mininy areas were utilized, the minimum storage
available for excess water during the mine life would be approxi-
mately i/,000 acre-feet patter the first five years), enough to
provioe the required agqjtional storaye. Table 2-A summarizes the
probability of a cumulative rainfall event occurriny which wouTd
exceed the smallest event required to accumulate 17,000 acre-feet
of water ouring the crTtical years of the mine plan.
Table 2-A Summary of Probability of Exceediny 17,000 Acre-Feet
of Storaye.
Probability ot
Exceedance
^percent)
T l ru e Period
(years)
Smallest Event
lo Fill System
(i nches j
1
2
3
4
b
b
11U
1/4
231
294
3b6
422
U.UUUUU1
U. UU1
0.07 0
0. 300
0.220
0.210
As shown, the highest probability of exceeoiny 17,000 acre-feet
of capacity ot the recirculation system and the current mining
areas is 0.3 percent.
lo further document that 17,000 acre-feet ot storaye is sufficient
to contain the excess rainfall from an extreme rainfall eventT
computer analyses were performed using a 24-year rainfall record
created by adding the tour wettest rainfall years obtained at the
Fort Preen rainfall station to the 1921 to 1940 rainfall recoTcf
obtained at the Bartow weather station. The simulated rainfall
record averages bb./ inches per year, a 24-year running average
higher than any in the actual record. The results ot these com-
puter analyses showed the required maximum volume of stored water
would be lb,491 acre-feet when the four rainfall years with the
highest precipitation sequence ji.e., 2b/.b inches during a 40-
month period; were matched with the tour mininy years (1994-199/J
having the lowest water consumption. The probability for exceed-
ance ot the 2 b 7 . b inches ot rainfall during a 40-month period is
less than l in 1000. Therefore, with 17,000 acre-feet of avail-
able storage there would be no discharge from the system for any
combination of the created rainfall record with the mining
sequence.
2-6
-------
based on the above analyses, utilization oft he mine areas, if
necessary, can essentially eliminate a discharge event from trie
Uuette Mine. furthermore, the outlet structures would be con-
structed to allow oischarye at lb percent ot the st reai.it I ow at
the time and point ot oischarye in the remote event that a
discharge shoula occur (fUAH, FUEK, lb6^).
In oraer to monitor the capacity ot the storaye areas, staff yayes
woulu be installed on each spillway ano the water level will be
read at least daily. Duriny normal rainfall periods, the sanu-
clay surface would be plumbeo from a small boat once a month;
ouririy heavy rainfall periods, this would be performed twice a
month or more often it necessary. 1 he volume of sand-clay ano
supernatant water would be calculated arid tabulated in a continual
record.
1 tie minimum available water storage capacity in the initial
settliny area, the disposal areas, ano the reservoir at any time
ouririy the lite ot the mine has been projected to be 1U,UUU acre
feet. iThis ooes not include the first few years ot start-up wTTen
storaye is inaeeo less, but since less yrouno surface area has
been oisturbea, the runoff to be containeo is smaller.) In order
to provioe an extra maryin ot safety ano to allow sufficient time
to act, o,t>UU acre-feet ot stored water has been selected as a
"triyyer" volume.
When the excess water storeo on site reaches b t b U U acre-feet, the
Florida Department of Environmental Keyulatiori ifuEKj would be
notified ano Estech would take all steps necessary to activate the
system by which excess water can be oiverteo to current mininy
areas should such storaye capacity be neeoeo. furthermore, when
the excess water stored on site readies the total available
storaye space within trie recirculation system acre-feet
or yreater; less l,bUU acre-feet, trie FL)tK would be notifieo ano
Estecli would divert the excess water to the mininy areas tor
storaye pursuant to the oesiyn plans ifUAH, fDtK,
The diversion bt water into the current mininy areas would be
accomplished by one ot several procedures. Amony these are:
ia> It trie active disposal area contains water above the yrouno-
surface elevation ot the mininy area, excess water would be~
allowed to flow throuyh the spillway in the disposal area
into a ditch, and thence directly into the mine.
lbj if the active disposal area contains water below the yrouno
surface elevation ot the mininy areas or if a natural stream
separates the active disposal areas ano the mininy areas,
then excess water would be allowed to flow throuyh trie
spillway in the disposal area, routed by ditch to a lift
station, ana thence by pipeline directly into the mininy
area. It the plant water pono is closer to the mininy area
than tlte active oisposal area, then excess water would be
routed directly from the plant water ponoT
2-7
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In the event the water stnrea on site reaches the maximum avail-
able storage (initial settling area, sana-clay disposal areas,
reservoir, ana the mining areas j, Estech woula oischarge excess
water ori an emergency basis trom oischarge points UU£ ana UU3 so
that the discharge ooes not exceea more than lb percent ot stream
11 ow at the time aria at t.he point ot aischarye. Prior to maKiny
any such emergency metered aischaryes, Estech shall notify the
l-~L)EK that it would make such discharges. Estech woula continue
such a aischarye until the water in storaye returns to the maximum
available storaye level, such aischaryes are intended to b¥
emeryericy in nature to~avoio uncontrolled overflow discharged from
the system, bhoulo the maxinium available storaye in combination
with the emergency metered aischaryes not provide adequate storaye
tor excess water accumulating in the system, tstech shall be
required to utilize the active dray line cuts as an additional
storaye area (FUAH, ibbi!: f L) £ K ,
An essential element in the revised water manayement plan is the
siynificant reduction of geep yrounuwater input into the recir-
culation system during periods when sufficient recycle water is
available in the storage areas. To assure a source of water to
the amine flotation process of equivalent quality to deep ground
water, Estech proposes to use a recycle water preparation plant
when necessary to upgrade recycle water to the quality required
for the flotation plant, a reverse osmosis facility is currently
Estech's method of choice for this purposeT"
Reverse osmosis (K/U) permits recovery ot relatively pure water
trom aqueous solutions through high pressure water movement across
a semi-permeable membrane. Dissolved solias are blocked by the
membrane, but water is forced throuyh. An K/U plant produces a
clean water stream relatively tree ot solutes and a reject stream
that contains the concentrated dissolved solias.
Recycled water requires several pre-treatment operations upstream
ot the K/u assembly blocks to prevent membrane fouling. A con-
ceptual flow schematic of Estech's proposea K/U facility design
is proviaeo in figure tL-6. 1 he sequence of operations for the K/U
faci1i ty is:
o raw water pumping trom plant water pond
o addition ot alum and polyectrolyte coagulants
followed by clarification to remove solias
o aadi ti on ot chl ori ne
o pressure filtration to remove remaining turbidity
o removal ot orsanies (ana probably chlorine) by
carbon aGSorption
o adaition ot sulfuric acia to prevent membrane
scaling by calcium carbonate
2-8
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ALUM POLYMER
FIGURE M
tfc*. SPA - RSQION 4
CONCEPTUAL FLOW SCHEMATIC
ENVIRONMENTAL MfACT
RECYCLED WATER
STATEMENT SUPPLEMENT
PREPARATION PLANT
ESTECH. MC*
SOURCE*
DUCTTC MINE
MANATEE OOUHTY. FLOftttA
SVEADRUP * PARCEL
AND ASSOCIATE#, INC.
-------
o cartridge filtration to remove remaining solids
o addition of sodium hexametaphosphate to preven.
membrane scaling by calcium sulfate anu other
scaling compounds
o high pressure feed through K/u assembly blocks
o oegasification of dissolved carbon dioxide
o addition of sodium hydroxide for pH adjustment
o finisheo water pumping to amine flotation process
Operation of a small rotary kiln would be auxiliary to the K/u
plant. I he kiln would be used to regenerate activated carbon
which*removes organic compounds from recycled water as one oT the
pre-treatment steps.
Haste streams from the K/U facility would be combined with the
high flow of clay slurry streams pumped to the sand-clay mix
areas.
1 he Consumptive Use Permit issued by the Southwest Florida Water
Management District allows groundwater withdrawal at a rate of
in go for the first three years. yuF*nt,-fch»&-fe»meT-a-*yu-aePe
SbP*a6e-w«teF-pesePve*P-w*U-be-60RSfcPM6teii-te-ppev*«e-6fc8P«j,e-
*ep-;i-ft^-thepeby-aeepeas*BS-§PeyF'6w*feeF-use-t*-iu-w9<1' Prior
to withdrawal, a Recharge system will be constructed to transmit
water from the surficial aquifer into the deep system.
With the exceotion of a lUU-acre area, all land disturbed by the
operation wU 1 be reconstructed and/or backfilled with waste
ma?e?il?s in conformance with county and state slope requirements,
materials in the exterior levees anu any protruding
In sand-clay m x land jB.tt,e.6iiy-6ettHfi8-<„:ei,-tB,
spo.l mles will be graded d
in sane tailing landfills.
Feta*R*fis-a*ke-w*U-Be P spoils will be distributed over
the overburden in the protru y teet.
the landfill to an average depth of two feet.
,n 1 anu ana la.e areas the .poll, ^ar^r" "U"
'JS'tS'i *'•!>» °ut t0 a depth °f ° ,eet"
nhuciral restoration techniques, several
In addition to primary p y t0 aChieve particular reclamation
special techniques are Pla ment 0f the East Fork Manatee
soals. A three-quarter "HI creation of an adjacent
Kiver is proposed to oe re* channel with the same elevation
hardwood vegetated floodpla n and end ^ £stech ha$ revise(J
and gradient as.the existing mining of the East Fork of the
its proposed activity to ext
Manatee Ri ver.)
2-10
-------
Shallow basins allowed to form around the drainage outlets in
sand-clay landfills will be retained as marsh environments.
Drainage swales will be constructed through adjacent sanu-clay
landfills to interconnect these marshes.
About 6,000 acres of reclaimed land will be planted to forage
grasses and legumes. Forage species will be selected to match the
potential productivity of each reclaimed soil type. Kef orestati ori
in upland areas will include mixed plantings of native species
such as water oak, live oak, longleaf pine and slash pine. The
shallow basins created in sand-clay landfills are expected to
revegetate naturally with marsh-type vegetation. The minimally
reclaimed 100-acre land and lake area will also be allowed to
revegetate naturally.
Contouring ana revegetation of land and lake areas is estimated
to require two years to complete. Backfilling with sano tailings,
capping with overburden and revegetation will require about three
years. lfl sand-clay landfills, two three years have been allotted
to filling, two years to subsidence and consolidation and an
additional year to revegetation, for a total of five six years to
complete reclamation.* ^eeause-ef-the-iengthy-pepieci-FequiFttd-to
fepw-a-SHF^aee-€PbStT-teH-yeaFS-has-been-aUettea-t©-6ewpiete
Fe6laraafcieR-e$-*he-s*n§*e-e}ay-sefcfc}»ng-apea.
*This does not constitute a change in the mine plan. Rather, it
is now recognized that stage filling over a three-year period,
allowing intermediate consolidation, will prevent the necessity
of increased fill ano dike elevations.
2-11
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3.0 ALTERNATIVES EVALUATION
All alternatives evaluated in the Draft ana Final EIS were
re-examined to determine it the project revisions significantly
affected the initial analyses. The following alternatives are not
at feeteo by the changes and are, therefore, not subject to
additional evaluation within the Supplement:
o Plant site location
o Production rate alternatives
o Resource recovery alternatives
o Mining methods
o lire transportation alternatives
o Beneticiation process alternatives
o Rock drying alternatives
o Product transportation
o Energy sources
1 he following alternatives have been re-evaluated in light of the
project changes ano are individually addressed as a part of the
Supp I ement:
o Process water source alternatives
o Waste disposa1/rec1amation alternatives
o Surface water discharge volume alternatives
o Discharge point alternatives
o No action
i.l PROCESS WATER SOURCE ALTERNATIVES
The process water supply objective is to provide to the mining
operation water of sufficient quality and quantity to optimize
operational and mineral recovery efficiency while conserving the
regional water resource (Draft EIS, p. 11) • Process water source
alternatives considered in the EIS were: use of surface and
ground water, total requirement from the deep Floridan Aquifer,
use of surface water in rainfall catchment, and use of water from
the surficial (water table) aquifer.
E stech' nroDosed activity in the EIS was for the combined use of
surfacewater(by intake from the East Fork Manatee River) and
deeD around water as the primary source (Final EIS, p. 12). The
revise £?oposed action continues to utilize both surface ana
prupuseu au rplies primarily on on-site surface
ground water; however, it relies prima, j
water storage of process water and rainfall catchment.
3.1.1 Description of the Revised Alternative
Estech's revised proposed action calls for significantly reduced
cstecn s revised Pr"H Clinniemented by surface water from on-site
groundwater consurnptio recycled water in the acid rinse and
storage. The proposed use of recycieu wau onu
3-1
-------
amine flotation circuit has contributed to the reduction of ground
water withdrawal from an annual average of 1U mgd (Draft EIS, p.
b3) to an annual average of approximately 1 ruga. During the dry
months when make-up water is required, deep ground water, which
is of higher quality than recycled water, would be introduced into
the recirculation system via the flotation process. When suffi-
cient water exists in the recirculation system so that no make-up
water is introduced, recycled water would be used directly in the
flotation process. A water preparation facility would be used,
if and when necessary, to assure the quality of the recycled water
tor the qua 1ity-specific requirements of the flotation process.
A reverse osmosis (R/0) facility is proposed by Estech as the most
probable method to be used it water treatment is needed. (For
additional discussion of the R/U facility, see Sections i:.0, 4.1
and 4.3.)
1 he revised proposed activity excludes the East Fork Manatee River
as a possible water source by eliminating the intake structure.
Additional water storage is attained by constructing an embankment
around the surface water reservoir.
3.1.2 Environmental Advantages
The refined water management plan now proposed by Est* ;h would
significantly reduce the projected deep groundwater withdrawals
and allow for the near-exclusive use of surface water without
excessive impoundment areas. As a result of the reduced deep
groundwater withdrawals, the water levels in the Floridan Aquifer
would not be lowered to the extent anticipated for the original
proposal. The reduced withdrawal would lessen the drawdown at
the property boundary from Z.b feet (Draft EIS, p. t>4) to O.b
feet. Compared to the project as evaluated in the EiS, the re-
vised water source alternative, by lessening the decrease of the
potenti oinetri c head of the Floridan aquifer, also lessens the
induced leakance from the shallow groundwater system to the deeper
system (bee Section 4.<£.l). The proposed project assures a water
balance with an extremely low probability of overflow (discharge)
from the water management system. The use of an internal surface
water supply which excludes the intake of water from the East Fork
Manatee River would allow that quantity of water to be available
for other downstream users.
3.1.3 Environmental Disadvantages
In the event that a reverse (R/U) plant were used to treat recycle
water for the flotation process, selected soluble compounds would
be introduced into the recirculation system (Section 4.3.1) The
use of a kiln in association with the K/0 facility would contri-
bute a source of air emissions not originally present (Section
4.1.1).
3.1.4 Summary Comparison
The revised propdseo activity parallels in some respects the "use
of surface water in rainfall catchment" alternative evaluated in
3-2
-------
the EIS and modifies the selected "use of surface and ground
water" alternative. However, the exclusi ve use of regional and
on-site drainage supply ("rainfall catchment" alternative) re-
quired that no ground water be withdrawn except for potable use.
This alternative, as evaluated in the EIS (Draft EIS, Section
1. y), required further diversion of river water, extensive con-
struction of impoundment areas, increased reduction in downstream
supply, and possibly inundation of environmentally sensitive
areas.' By refinement of the water management plan, the revised
proposed activity provides a process water source alternative
which reduces the adverse impacts of deep groundwater withdrawals
without creating the adverse impacts associated with the "rainfall
catchment" alternative addressed in the EIS. Therefore, the
combined use of ground water and surface water (excluding the
diversion of the East Fork Manatee kiver) is the environmentally
preferred alternative.
3.£ WASTE DISPUSAL/RECLAMAT1UN ALTERNATIVES
The obiecti ve of the waste disposal/reelamation plan is to restore
disturbed land to a productive state, considering both existing
and created environniental systems. lwo alternatives incorporating
all elements of disposaI/reelamation (waste Disposal, physica
restorat i on! and repetition) were .n eva ua ed in
'US Eli iUraff J'nwnoThe' r«i;.«^aHernltWe'remai n'es^en-^
tlaU^'fte'same. Estech's revised proposal replaces the IbU-acre
tlay settling area with a like area ot sand-clay mix.
3.k.l Description of the Revised Alternative
, • , jiiino as the Florida Land and Water
The Florida Cabin®^'i voted to approve the Duette Mine project
Adjudicatory lommissio , ^ sand-clay mixture be discharged
subject to the condi apea piace of clay only. Therefore,
into the initial sett -merqency situations, the initial 4b0-acre
except during temporary receiVe a sand-clay mix in a manner
clay settling area w1i"0Wfor the other sand-clay mix areas
similar to that descrlb the initial sano-clay mix settling
throughout the site, now » whereas other disposal areas are
area would be over unmine settling area woula now employ the
to be in mined-out cuts. f sand-clay disposal/reelamation
reclamation techniques outlined tor
areas.
'i.'i.'L Environmental Advantages
artvantaae of adding sand to the clay
The principal environmental a v tQ which the cUys
settling area is the failure. Should such an entbank-
would flow in the event of a*** sand-clay mixture is not expected
ment failure occur, the re'® . hvDOthetical case, the down-
to reach Lake Manatee. Unde te0 t0 be approximately lii.UUO
stream limit of the spill is exp of the u^e and
feet (3.4 miles) upstream of the begin
3-3
-------
approximately fab.UUU feet upstream of the Lake Manatee dam ana
intake structures.
The addition of sana to the initial clay settling area also
provides an additional 4bU acres of soil classified as a sandy
loam. This type of soil is agronomically superior to the clay in
that the sandy-loam soil can be expected to exhibit the advantages
of clay [i.e., natural fertility with high moisture and nutrient
retention) and the tillage and aeration characteristics inherent
in sandy soil (Uraft EIS, p. b'6). The 4bU-acre sano-clay mix is
expected to consolidate more rapidly ana therefore be available
for post-mining reclamation earlier than a clay-only settling
area.
1 he conversion of the 4bU-acre clay-only settling area to a
sand-clay mix area would provide a net decrease in terrestrial
gamma radioactivity (bee Section 4.7).
3.2.3 Environmental Disadvantages
In comparison with a 4bU-acre clay-only settling area, the sand-
clay area may result in a temporary increase in water lost to
seepage during the initial period of operation. Although the
sand-clay mix area is expected to be more physically stable than
clay-only, it still may not be suitable for construction requiring
a substrate with high compressive strength.
The design-specific analysis of the probability of failure for the
initial sand-clay mix impoundment indicates a probability of
failure of 1 in 140,UUU. The probability of failure tor a clay-
only impoundment is essentially the same.
3.2.4 Summary Comparison
The comparison of the various waste disposal, physical reclama-
tion, and revegetation alternatives evaluated in the EIS remains
generally unchanged. It is recognized that both sano-clay mix and
clay-only waste disposal techniques pose environmental problems.
However, the overall advantage of reducing the probability of Lake
Manatee receiving the contents of the initial settling area in the
event of dike failure makes this the environmentally preferable
alternati ve.
3.3 SURFACE WATER DISCHARGE VuLUME ALTERNATIVES
The objective of the selected wator
is to keep the amount of discharged water vo1ume.alternative
while maintaining the quality of an practical minimum
applicable standards fSr the*rece?J!ngwater 9 3t the
E1S). The four alternatives considerea in thi ' Draft
(1) containment of long-term accumulation i-A W6re:
short-term accumulation, (3) containment ^^conta i nment of
losses, ana (4) no containment t0 0f,set "^oration
3-4
-------
The preferred alternative identified in the E1S was Estech's
proposal for containment to offset evaporation losses only, which
would result in an average discharge over the life of the mine of
approximately 2, ODD gpm. The revised proposal essentially
parallels the "containment of long-term accumulation" alternative
with several notable exceptions which are discussea in Section
3.3.4. The objective of the revised proposal is to eliminate a
surface water discharge from the site.
3.3.1 Description of the Kevised Alternative
The revised alternative is a result of rigorous evaluation of
water sources, water losses, process requirements, and physical
components of the water management system (See Sections 2.0 and
4 4 i) Consequently, the revised alternative reduces the deep
groundwater requirements, utilizes containment within areas not
previously considered feasible for storage (e.g., current mine
areas and active dragline cuts), and allocs use of recycle water
in the amine flotation circuit and the acid rinse cycle. The
revised D^posal would eliminate the intake of surface water from
East Fofk Manatee Kiver and requires the construction of an
earthen embankment around the ""-'ere re er.oir to prov.de an
additional 3,bU(J acre-feet of water storage.
These revisions to the water management system would result in a
muni lital water storage capacity , '^"^f'^^cteo'ole'r
feet (including current mine areas; and no discharge expecteo over
the life of the mine.
3.3.2 Environmental Advantages
onvi ronmental advantage of the revisea
The most ld be the elimination of a discharge to
proposed alternative Manatee River. The inherent benefit of
rierni"hr4eerU Ih^Son of the release of contaminants
to the aquatic environment.
3.3.3 Environmental Disadvantages
. thp earthen embankment around the 210-acre
lhe construction of the _otentjai environmental disadvantage not
reservoir would Present a p The bab11ity of failure of
present in the original prop ^ ^ x _n 10Uj000. lt should
the embankment has been de h ¦ ht ranges from 11' to lb' above
be noted that the embankme water levels below ground
ground level with ofPthe probability of failure assumed
level, lhe determination , j feet ab0ve ground
operational levels at approximately six
surface.
c water within the mine recirculation
The containment of process adverse effect on the surficial
system creates a potential t effect is not expected to
ground water ^See Section aimost all constituents would
be significant due to the and the minimal amounts of
be trapped within *he,c'fly »'u' ! tem WOuld be removed or red-
soluble constituents leaving tne by
3-5
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duced in concentration in the ambient ground water with both time
and distance traveled. Thus, the effect on the ground water would
be expected to be greatest in the vicinity of the recirculation
system and sand-clay mix disposal areas.
3.3.4 Summary Comparison
As indicated in the Final EIS (p. lb;, the selected alternative
did not necessarily define the best possible system. It was
agreed that "improvements or modifications can be implemented by
Estech, during design or operation, to further reduce discharge"
(USEPA, 19bU). The revised alternatives reflect such improvements
ana modifications. 1 he revised proposed alternative is similar
to the "containment of long-term accumulation" alternative which
was originally rejected primarily due to the loss of mineral and
other natural resources as a result of large impoundment areas anu
extensive dike construction (Draft EIS, Section Jd.y). As a result
of the project changes mentioned in Section 3.3.1 above, and an
extensive review of the water management system (See Section 2.0,
pages 2-b through 2-b and Section 4.4.1;, long-term accumulation
has been determined to be possible without construction of
extensive impoundment areas and dike networks.
The significantly reduced potential for surface water degradation
is deemed sufficient to offset the currently identified negative
attributes. Therefore, given all other environmental considera-
tions, elimination of surface water discharges clearly makes this
the most environmentally preferable discharge volume alternative.
3.4 DISCHARGE POINT ALTERNATIVES
The objective ot the discharge point(s) selection is to maximize
the discharge flexibility for purposes ot water conservation and
management while meeting water quality standards for the receiving
waters. The assessment of alternatives in the EIS considered four
discharge plans which utilized one or more of the following
discharge points: (a; direct to reservoir pool connected to the
East Fork Manatee River, (b) direct to the East Fork Manatee
River, (c) direct to North Fork Manatee River, and (a) deepwell
i njection.
Estech's proposed discharge point plan selected in the EIS called
for a combination of discharge points including discharge directly
into the North Fork (discharge point 003;, into the river overflow
pool (reservoir) when not full (discharge point 001;, and directly
into the East Fork when reservoir was full (discharge point 00*;
(See Figure *-1). The revised plan retains discharge point 003,
revises discharge point 002, and eliminates discharge point 001.
(See Figure 2-2 for location ot the proposed discharge points.)
3.4.1 Description of the Revised Alternative
The revised water management plan includes a change in the
configuration of the reservoir and construction of an embankment
3-6
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
349 COURTLANO STREET
ATLANTA. GEORGIA 30365
JAN 7 1983
REF: 4PM-EA/AJT
TO: ALL INTERESTED GOVERNMENTAL AGENCIES, PUBLIC GROUPS,
AND CONCERNED INDIVIDUALS
,uosr.
The Draft Supplement to the Final Environmental Impact
Statement (EIS) for the Estech Duette Mine is enclosed for
your review. This document has been prepared pursuant to
Section 102(2)(c) of the National Environmental Policy Act
(NEPA) (Public Law 91-190) and applicable EPA regulations at
40 CFR Part 6.9.
The Draft Supplement to the Final EIS may be reviewed at the
following locations:
Lakeland Public Library, Lakeland, Florida
Bartow Public Library, Bartow, Florida
Ausley Memorial Library, Wauchula, Florida
DeSoto County Public Library, Arcadia, Florida
Sarasota Public Library, Sarasota, Florida
Manatee County Library System, Bradenton, Florida
Tampa-Hillsborough County Public Library System
Tampa, Florida
A public hearing to discuss this project has been scheduled
for February 15, 1983, at 7:30 p.m. in the Harper-Kendrick
Auditorium, 1303 17th Street, Palmetto, Florida. Persons may
begin to register at 7:00 p.m.
Persons wishing to make comments should attend and speak at
this hearing. A verbatim transcript will be made of the public
hearing. The hearing chairman may request that lengthy or
technically complex statements be summarized and that, to
insure accuracy of the record, such statements be submitted
in writing to:
Ms. A. Jean Tolman
Project Officer
Environmental Protection Agency
Region IV
345 Courtland Street, NE
Atlanta, Georgia 30365
-------
-2-
The hearing record will remain open and additional written
comments may be submitted until March 1, 1983. Such additional
comments will be considered as if they had been presented at
the public hearing.
Please bring this notice to the attention of all persons who
may be interested in this matter.
Sincerely yours.
Enclosure: Draft Supplement to the Final EIS
-------
around the reservoir for additional water storage capacity. These
changes eliminate the capability to divert water from the East
Fork Manatee River and result in two discharge points (U01 and
002; being in direct flow alignment with each other. Discharge
point 001, being upstream of 002, becomes redundant and is
therefore proposed to be eliminated. Discharge point 002 would
be positioned to control discharges (if any; at the downstream ena
of the reservoir. No change in discharge point U03 is proposed.
3.4.2 Environmental Advantages/Disadvantages
No environmental advantages or disadvantages peculiar to the
revision of the discharge points have been identified. The
changes were attendant to the changes in the water management
plan and the elimination of any reasonably expected discharge.
3.4.3 Summary Comparison
Eight discharge point alternatives were evaluated in the E1S ana,
with the exception of deep well injection, were all found to be
acceptable. The preferred alternative in the £15 was selected due
to its operational effectiveness and inherent flexibility. The
revised alternative meets the objectives of operational flexi-
bility and water management without additional environmental
disadvantages. Iherefore, the proposea alternative is environ-
mentally acceptable.
3.b NO-ACTION ALTERNATIVE
iho nn artion alternative evaluated in the E1S was for Estech to
IS? const^c? the Duette Mine and to all., the area to continue
it* oresent dav socioeconomic ana environmental trends. The
rUul« " tSu evaluation, presented in the Els t the NPUES permit application. In the
JhP oriainal project proposal evaluated in the Eli. denial
of the NPttli perilt application would have resulted in tstecti U>
ot the NKUta penni >* vv indefinitely postponing the pro-
terminating thei p J . th(_ Ject t0 achieve zero discharge,
ject, or U) "Strut be require<1. Flnai action has
tor which no NPDES p kpncs permit. However, administrative
rh - C % :^nr^ state agencies have effec-
tively forced ^pursue the third course o actvon, i.e.,
to redesign the water management plan to achieve
di scharge.
An NPUES permit is s 111 " 9 b ^ t ^ f I a ? ^ ' pSSSl bl ^
address the highly imp ^able but / \f EPA were t0
lion permit application for the revised proposal,
arguablytheprojectcould nonetheless go forward. Estech having
3-7
-------
sufficiently demonstrated a no-di^1"" nil, u
although a remote possibility, would be a violation of Sect i onC'}n i
of the Clean Water Act, for which enforcement action could be
taken by EPA against the company.
Un the other hana, any mltigative,measures recommended by EPa m
be imposed as NPDES permit conditions could not be reuuirpa hu fda
if the NPDES permit application were denied. * A
3.6 MIT 1 GAT IVE MEASURES
developed as a result of evalution of the project revisions.
3. b.l Air quality
Estech proposes an additional source of air emissions not previ-
o5sl* in£l£ded in the original project design. The carbon regen-
eration Kiln associated with the proposed reverse osmosis facility
^contribute nitrogen oxioe (N0X) emissions approaching the
significantincreaselevel. (SeexSection 4.1.2). other potential
contaminants are all significantly ower than the significant net
emissions increase" levels that would require a detailed pre-
construction review in accordance with the Prevention of Signifi-
cant Deterioration concept (Table 4.1-A).
Mitigative measures should provide means tor tracking emissions
and assure that cumulative NO emissions do not exceed a speci-
fied limit. Restricting the Kiln operating capacity to £>0>b of
full-time use would limit the total estimated KU emissions to a
rate not expected to exceed the significant increase level".
(See Section 4.1.1 for a description of operating capacity.) a
secondary mitigative measure could be to require tracking of
cumulative NU emissions, which could be accomplished by conduct-
ing EPA Reference Method stack tests in combination with the
total recorded number of kiln operating hours. Should the
cumulative NU emissions approach the significant increase limit,
the company could be required to employ off-site carbon
regenerat i on.
S.b.ii Groundwater Hydrology
Estech proposes to significantly reduce the groundwater with-
drawals to accommodate the revised water balance. Revision of
the Consumptive Use Permit (issued by the Southwest Florida Water
Management District; to reflect the reduced withdrawals would
provide additional regulatory assurance tor control of groundwater
impacts.
3.b.3 Groundwater Quality
As indicated irr the water balance for the revised project ^Table
4.4-D), water loss to seepage from the recirculation system is
3-8
-------
expected to be approximately bOOgpm. lhis seepage could be
maintained at a minimum by limiting water levels in the recircu-
lation system ana in the 210-acre reservoir to 112' MSL (annual
average) and i?b' MSL (annual average), respectively. These levels
are at or near the average water table elevation at the respective
locations.
Estech's Consumptive Use Permit requires extensive flow and
quality monitoring for the connector or "recharge" wells. How-
ever, no provision is maoe to specifically monitor the quality
of the surficial aquifer in the area of the sand-clay mix disposal
areas, including the initial 4bU-acre initial settling area, nor
the recirculation ditches. If observation wells were installed
and a monitoring program implemented in these areas, early
detection of any contamination would be possible and corrective
measures could be undertaken.
3.6.4 Surface Water Quality
The mitigative measures identified for groundwater quality would
be applicable to surface water quality, also. If seepage is
maintained at a minimum, the primary mechanism for transport of
contaminants through the surficial aquifer to surface waters is
significantly reduced. Should the monitoring program suggested
in Section S.fa.S above be implemented, any migration toward
surface waters could be detected and possible corrective measures
implemented.
3.7 CPA'S PREFERRED ALTERNATIVES, MITIGATING MEASURES, AND
RECOMMENDED ACTION
The proposed project changes provide net environmental benefits
not considered at the time the E1S was prepared. In considering
the overall environmental benefits, the project now proposed by
Estech and alternatives preferred by EPA coincide.
In addition to determining the preferred alternatives, EPA has
identified mitigating measures, not already included in the
proposed activity, which should be incorporated into the project.
Specifically, EPA recommends:
0 Controlling annual average water levels to 112 feet MSL
in the recirculation system and to 9b feet MSL in the
2iu-acre reservoir for the purpose of minimizing seepage
to the s-urficial aquifer.
0 installing observation wells and implementing a monitoring
program to detect any possible contamination of the
surficial aquifer from the sana-clay mix areas, including
the initial settling area, and from the recirculation
ditches.
0 Limiting the carbon regenerating capacity ana monitoring
the cumulative NO emissions of the kiln associated with
the reverse osmosis facility.
3-9
-------
EPA's recommended action is to issue the NPUES permit to Estech,
Inc. for their proposed Duette Mine. Ihe proposed permit would
impose as permit conditions all mitigating measures incorporated
within Estech's proposed project, including the revised alterna-
tives addressed in this Supplement, ana all mitigating measures
recommended by EPA in the EIS and in this Supplement.
3-10
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4.0 THE AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES
The Environmental Impact Statement addresses those elements of the
natural and socioeconomic environments which would potentially be
affected by the proposed activity. The various changes since
publication of the Final EIS have required that selected elements
previously investigated be re-evaluated in light of these changes.
No baseline conditions would be affected by the revisions to the
proj ect.
Several elements would not be significantly impacted by the
project changes and are therefore not discussed further in this
Supplement. These include: Meteorological Conditions, Noise,
Topography, Geology, Biology and Ecology, Demography, Community
Services and Facilities, Economics (exclusive of internal cost),
Land Use, Sensitive Manmade Areas, Transportation, Archaeological
and Historical Properties, and Resource Use. The remaining
elements would be either beneficially or negatively affected by
the project changes and have therefore been subject to evaluation
within the context of this Supplement. The elements are: air
quality, groundwater hydrology, groundwater quality, surface water
hydrology, and surface water quality. Two elements, soils and
radiological environment, appear to be only marginally affected
by the project changes.
4.1 AIR QUALITY
Because of changes in the water management plan for the Duette
facility, an additional source of air contaminant emissions may
be included in the overall process design. An evaluation of this
potential additional source is presented in this section.
4.1.1 Description of Air Emission Source
A reverse osmosis (R/0) facility is being considered as a means of
treating recycle water for use in the flotation process. (See
pages 2-8 through 2-10 for a general description of the R/0
facility.) Removal of dissolved organics (primarily the amine
compound used in flotation) by carbon adsorption is one of the
pre-treatment operations upstream of the reverse osmosis mem-
branes. Periodic regeneration of the carbon would be performed
on-site in a rotary kiln.
The planned regeneration kiln would process 11U0 pounds of spent
carbon per hour. An oil-fired rotary kiln would be used to
regenerate spent carbon by thermally desorbiny the organic com-
pounds. Regeneration is best performed with a minimum of excess
air so as to control carbon oxidation losses. Kiln effluent gases
would contain the desorbed organics, carbon monoxide and other
products of incomplete combustion of fuel oil, and some entrained
carbon dust.
4-1
-------
An oil fired afterburner chamber downstream of the kiln would
operate with sufficient excess air to oxidize the combustibles,
including the fixed carbon fraction of the entrained dust.
Afterburner effluent gases would contain traces of the combusti-
bles, the inorganic fraction of the entrained carbon dust, nitro-
gen oxides formed by oxidation of the amines, and by-products of
fuel oil combustion (ash, carbon monoxide, nitrogen oxides, sulfur
oxides).
A wet scrubber downstream of the afterburner would remove most of
the particulate matter and about half of the sulfur dioxide.
Negligible removal of the relatively insoluble carbon monoxide and
nitrogen oxides is assumed. The point source of interest for air
quality analyses would be the scrubber effluent gas containing
particulate and gaseous contaminants that have penetrated the
afterburner and scrubber.
Full-time operation of the kiln would result in estimated NO
emissions exceeding the "significant increase level". (See fol-
lowing section for explanation of "significant increase level".)
However, it is recognized that full capacity of the reverse
osmosis facility (and concomitantly the kiln) would be required
only during those times when deep well water could pot be used or
when the recycle water was not of sufficient quality for use in
flotation. Thus, due to the anticipated limited use of the
reverse osmosis facility (See Section 4.3), the kiln is expected
to operate on an annual basis at a fraction of its operating
capacity. For purposes of the following analysis, this fraction
is conservatively taken to be 50% of the operating capacity.
4.1.2 Permitting Requirements
New facilities planning to emit air contaminants must receive
local, state, and federal regulatory agency approval prior to
initiation of construction. Typically, the applicant must prove
compliance with technology based emission limiting standards.
Also, through use of mathematical dispersion models, the applicant
must prove that the ambient impact of proposed emissions will not
violate ambient air quality standards. Modeling of particulate
and sulfur dioxide emissions has the additional requirement of
compliance with fixed degradation increments in accordance with
the prevention of significant deterioration concept.
Air emission sources for the Duette site were subjected to a com-
prehensive review process during the previous E1S effort. As
explained in the following discussion, such a detailed review does
not appear necessary for the carbon regeneration furnace.
Phosphate rock processing plants are on the EPA list of major
stationary sources subject to a review for the prevention of
significant deterioration of air quality (PSD). The previously
completed PSD analysis of the mine and beneficiation plant site
included approval of best available control technology (BACT) for
4-2
-------
the rock dryers and dry rock storage and transfer operations, and
atmospheric dispersion modeling of site emission sources.
The PSD review process would be required for any additional point
source at the Duette site if its annual emissions were greater
than what is termed the "significant increase level". A compari-
son of carbon kiln emissions with the significant increase levels
is provided in Table 4.1-A, which indicates that none of the
projected pollutant emissions exceeds the significant increase
levels.
Table 4.1-A. Emission Estimate vs. Specified Significant
Net Emissions Increase
SIGNIFICANT INCREASE PROJECTED EMISSIONS^
POLLUTANT
(ton/yr)
(ton/yr)
Particulate
2b
b
Sulfur Dioxide
40
6
Carbon Monoxide
100
11
Nitrogen Oxides (as NO-,)
40
(1) Assumes 50% annual average operating capacity for carbon
regenerati on kiln
(2) Includes oxidation of amines to NUX
The NO emission estimate includes the fuel oil combustion and the
NO formed by oxidation of the amine compound CH3-(CH zhi -nh2.
Ufxthe total 3b tons per year emission estimate above, amine
oxidation accounts for 25 tons per year.
In general, the projected emissions are based on conservative
assumptions, and actual emissions would probably be significantly
lower than those included in Table 4.1-A. Since projected
emissions are all less than the "significant level", a BACT
determination would not be required. A new source performance,
standard has not been adopted for carbon regeneration kilns;
therefore, specific technology-based standards would not be
applicable for these emissions.
Standard permits would be required by the Florida Department of
Environmental Regulation for a new source of particulates and
sulfur dioxide. The applicable process weight code would limit
particulate emissions to approximately 1.6 pounds per hour
(assuming 540 pounds per hour dry carbon feed), and fuel oil
sulfur content would be limited to 1% by wr'nhf
4-3
-------
As the project proceeds, the conceptual information used as a
basis for air emission estimates must be supplemented with more
specific abatement equipment details for state permit application
purposes.
4. 2 GROUNDWATER HYDRULOGY
Estech's revised water management plan directly affects the
groundwater analysis and impacts previously defined in the EIS.
The most significant change affecting ground water is the reduc-
tion of deep groundwater withdrawals. Another change is the
modification of the initial clay settling area to a sand-clay mix
area. It should be understood that the changes in groundwater
impacts have been evaluated given the anticipated operational
water levels. The impacts associated with inordinately elevated
water levels having an extremely low probability of occurrence
(i.e., use of current mining areas) are not discussed.
4.2.1 Deep Groundwater Withdrawals
The re-evaluation of the flotation process water requirements and
the use of recycle water in the flotation process (possibly
treated in a reverse osmosis plant) effectively eliminate the need
for deep groundwater input to the flotation process except during
low rainfall periods. Deep ground water would be utilized in lieu
of recycle water (pretreated, if necessary) when recirculation
system water levels drop below operational levels.
The proposed changes in the operation of the recirculation system
would cause a reduction in the average annual deep groundwater
withdraw s from 1U .ga Draft EIS p. 63) to an average annual
withdrawal of i mgd (Table 4.4-D). This reduction in withdrawal
fiJil ! ^«r""h^%POt"tio«.etr1c-iurface drawdown identi-
fnrfft fi5 » fcdt ti n [ !st. property boundary from 2.6 feet
(Draft EIS p. 64) to 0.5 feet. The natural water level difference
between the shallow groundwater system and the underly n2 ae«
groundwater system (Floridan Aquifer! rannoc fmm "ln?
80 to 110 feet (Draft EIS p. Si). Therefore "!¦
in drawdown resulting from decreased pumping'of thl deep Srou™'""
water system will produce a small reduction in induced leakage
from the shallow groundwater system to the deeper systei?
4.2.2 Recirculation System
mately 112 feet HSL. For «cS ofWT?^ heV 't° e° ecf^cuU^ion
rec?rcul ationUsystem°wou°o be^T" Water !"•! "nhlX thi
The net tosses from the svstem are ?*lmately groundwater level.
BOO gpm over the life of the mine. estlmate0 t0 Oe approximately
4-4
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4.2.3 Reservoir
The configuration of the reservoir (Figure 2-2) is proposed to be
modified ana an earthen embankment is to be constructed around the
reservoir. As a result of engineering refinement, the design size
is increased from 200 acres to 210 acres. The operating levels
of the water within the reservoir would be maintained at 9b feet
MSL, which is approximately the adjacent groundwater level in the
area of the reservoir. Thus, due to the absence of a hydraulic
gradient between the reservoir and the adjacent ground water, no
significant seepage from the reservoir is anticipated.
4.2.4 Initial Settling Area
The introduction of a sand-clay mix to the 480-acre clay settling
area would result in a very slight increase in seepage during the
initial period of operation. The sand particles, at least
initially, allow the material to be more porous and permit water
to seep *As the area fills and the sand-clay mix compacts, the
seeoaqerato will approach that of the conventional clay-only
stofagl area" originally proposed in the EIS.
4.3 GROUNDWATER QUALITY
Implementation of the zero discharge concept requires recycling
of water within the various components of the water management
system (initial settling area, sand-clay disposal areas, c ear
water reservoir etc.). Since surface water discharge would be
eliminated, Jater quality analysis has focused on the Potential
migration of cheuicals from the site system to ground water.
Although Estech p^^o^rm'dLrieuss«p«r-S2S SEJlu.
i t° r^eS o y'r el°a cerU vo?ume may result in a waste-
water discharqp Instead, Estech now proposes to use recycle
water ?lsJJar9-* . nrocess. Since the water requirements of
water in the f1otation pr°cess.tific, it could prove
^celsa^fart?meseto upgrade the quality of the recycled water
n-cessary at times i, ^tion circuit. Estech proposes to
to be used in the ami - plant employing reverse osmosis
utilize a water P^ep ose thereby avoiding the addition oi
technology for this p P t wastewater discharges would be
water to the system. .^ional levels in the recirculation
required to maintain operational icve.s
system.
Because of its high operating costs.m
plant would b®"s^°J^cWfour.month rainy season of June, July,
occur during the hi stori c ^ make_up water from deep ground
August and September, a P® th water budget and therefore
water would not process. Iherefore, the discus-
not available for the f1ot "worst case" operational level
sion provided herein is base
4-5
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of 60% annual operating capacity. As discussed in Section 4.1.1,
a 50% annual operating capacity would result in operation at the
design rate for one-half a year.
4.3.1 Plant Reagents and Scrubber Wastes
The R/0 membranes are susceptible to fouling by physical, chemical
and biological actions. Recycled water requires pre-treatment
upstream of the R/0 plant, and some routine membrane cleaning
operations are necessary for satisfactory operation.
Assuming b0% annual operating capacity for the R/0 plant, the
following chemicals would be added to the existing site wastes:
o filter alum - llu to lbb tons per year.
o polyelectrolyte - l.y to 3.8 tons per year.
o 93% sulfuric acid - 2b4 to 270 tons per year.
o sodium hexametaphosphate - 16 to 32 tons per year.
o chlorine - 23 tons per year.
o sodium hydroxide - 17 to 33 tons per year.
o membrane enzyme cleaner - small quantities of an enzyme
cleaner are used periodically to maintain performance
of the membranes. The exact amount of the organic
enzyme required annually is presently unknown.
o 1% formaldehyde solution - when the R/0 facility is
shut down for extended periods, the membrane assembly
blocks are flushed with a dilute formaldehyde solution
to prevent biological growth on the membrane.
Only small amounts of formaldehyde will be added
to the site waste streams.
(
o regeneration furnace scrubber solids - approximately
7 tons per year of fuel oil and activated carbon ash
compounds.
o regeneration furnace sulfur emissions - 11 tons per
year expressed as sulfur dioxide. Absorbed sulfur
dioxide will be converted to sulfite and sulfate
compounds.
4.3.2 Other Wastes
The typical phosphate clay waste stream from mining and benefici-
ation processes is known to contain phosphorus, trace metals and
radiochemicals. These substances associate with the solids in the
waste stream and are expected to be retained almost entirely in
the settled clays, while the supernatant water is drawn off for
recirculation. The recirculation water would still contain some
4-6
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suspended and dissolved solids. The R/U facility would also re-
move and concentrate these suspended ana dissolved solids typi-
cally present in the recirculation system water supply. These
contaminants do not represent net additions, but instead would
only be redistributed:
o suspended solids - solids present in the pond water supply
are removed during pretreatment upstream of the R/U
assembly blocks. These solids will be contained in back-
wash water wastes from the pressure filters and carbon
adsorbers and in scrubber water waste.
o dissolved solids - the reject stream from the R/U assembly
blocks contains the concentrated dissolved solids, such as
calcium, magnesium, sodium, potassium, and sulfates, that
are blocked by the membranes.
4.3.3 Deposition of R/U Contaminants
All wastes from the R/U facility would be pumped initially to the
reject water holding pond. Water in the pond is projected to
contain the following average composition of dissolved species:
sulfate 285U mg/1; bicarbonate 78 mg/1; calcium 74U mg/1; chloride
t>4 mg/1; magnesium 211 mg/1; aluminum 42 mg/1; sodium 1U3 mg/1;
fluoride 9.U mg/1; and organics 5.3 mg/1 (may include
formaldehyde, enzymes, water treatment polymer).
All waste streams produced in the proposed recycle water prepara-
tion plant, except for sanitary waste, would be discharged into
the reject water holding pond lined with an impermeable material
(Hypalon or equivalent) to prevent seepage. This pond would be
approximately 7 feet deep and 56 feet square at the bottom with
sloping sides. Total storage volume at the maximum normal working
depth of 4 feet would be 16,6U8 cubic feet and would provide
approximately 4.2 hours hydraulic retention time, based upon the
estimated 489 gpm total reject water and waste streams flow rate.
After the R/U facility waste water is pumped from the reject pond
at 489 gpm, it would be mixed with the high volume (68,00U gpm)
clay slurry stream, allowing maximum opportunity for mixing with
the suspended clay particles. The clay particles are expected to
provide sufficient surface area for adsorption of organic
compounds and certain heavy metal species which would remain
attached to the clay particles as they consolidate. Ion exchange
may also contribute to the removal of dissolved metals.
Secondly, as clay particles settle, a substantial quantity of
water is trapped within the interstitial spaces between particles,
capturing dissolved species added in the R/U plant or beneficia-
tion process. The sand-clay settling areas thus would serve as
partial sinks.
A third sink for R/U plant waste chemicals would be provided in
the phosphate rock product. During periods of R/U plant use,
dissolved compounds would be distributed throughout the site water
4-7
-------
inventory ana would be present in process water used for mining
ana beneficiation. These chemicals would leave the site with the
driea product.
K/U plant waste chemicals not removed by the three partial sinks
discussed above would remain in solution. During beneficia-
tion K/U chemicals would come into contact with fluorapatite
[CaF2Ca
-------
The recirculation system includes the 4bt)-acre initial settling
area, the 210-acre reservoir, the sand-clay mix reclamation areas,
the aitch system, and plant water ponds. If the water entering
the system exceeds the water leaving, water must be stored within
the system. If the available storage is exceeded, water will
overflow the system. Conversely, if water leaving the system
exceeds water entering the system, water liiust be removed from
storage. If the available storage is depleted, water must be
aaded. Water input sources include rainfall, matrix water, deep
well water, shallow well water, ana mine cut seepaye. Consumers
of water include evaporation, sand-clay mix, sand tailings,
product and seepage.
Because any water required for make-up i ri the system can be
obtained within the limitations of their consumptive use permit
utilizing deep well water, Estech has elected to modify the ZlU-
acre reservoir, which was previously proposed for collecting ana
storing water skimwea from the East Fork Manatee Kiver, to instead
collect excess rainfall runoff. To maximize the storage capacity
of this reservoir, an embankment would be constructed arounu the
area in accordance with Chapter 17-9, F.A.C. With the maximum
storage level at Elevation Ilk: feet (MSL), and the normal opera-
ting level at Elevation 9b feet (MSL), over 3,bl)0 acre-feet of
additional capacity would be available within this reservoir.
Approximately 4,UUU acre-feet of annual storage would be available
within the sand-clay mix reclamation areas. An additional 2, buu
acre-feet of storage would be available in the initial settling
area. Consequently, the minimum design capacity of the water
recirculation system tor excess water storage would be 10,U0U
acre-feet.
There is a large variation in both the makeup required and the
amount of overflow from the system resulting from the extremes in
rainfall over the mine lite. It should, be noted that the water
balance presented below ^T^b1e 4.4-Aj is for "worst case" condi-
tions in that the rainfall record utilized in the balance contains
a rainfall sequence having a very low probability of exceedance
(less than U.l percent;, and this heavy raintall sequence has been
paired with the mine sequence having the lowest water consumption.
The amount of water consumed in the process during each year of
the mine plan varies from a low of b,32b gpm to a high of 12,46ti
gpm. Similarly, the amount of rainfall collected within the
system will vary from year to year depending on the annual
raintall. Overflow from the system would be at a maximum during
those years when the amount of rainfall collected within the
system is highest and when water consumed within the system is
lowest. The 2!4-year rainfall record used in the calculations
contains a tour-year period during which the average rainfall
exceeded 7U inches per year. lo match this period in the rainfall
4-9
-------
Table 4.4-A Water Balance - One-Month Increments - Uesign Storage ot
1U,00U Acre-Feet Recirculation System*
hater Source (gpm) Water Disposition igpm)
Min.
Ave.
Max.
Mi n.
Ave.
Max.
Rainfall 0
b,S4U
4b4,S0U
Evaporation 1,7 3/
b,9bb
ll,*bU
Matrix i,b/y
2,3bU
2,b41
Sand-Clay Mix i,bb4
4,bSU
b,yiu
Deep Well to
Flotation
U
-
Sand Tailings
-
Seal Water
*bu
-
Product
ilbU
-
Net Mine Cut
Seepage
bb4
-
Uitch Seepage** -
bill)
-
initial Storage
ibb
-
Final Storage
42
-
Ueep Well
Makeup U
l.id'/b
14.S/5#
Overflow U
ibb
iib,b4y
Total
u.uyb
-
T ot a 1
is,uyb
-
*For purposes ot all discussions in this Supplement, the recirculation
system consists ot the initial 4bU-acre settling area, the 2il)-acre
reservoir, the sanu-clay mix reclamation areas, the aitch system, and
the plant water ponds.
**0itch Seepage includes all seepage from the recirculation system.
record with the period in the mine plan with the lowest consump-
tion, the rainfall record was put in a closed loop. Ihe water
balance calculations summarized in lable 4.4-B were made by
cycling this rainfall loop through the mine plan starting each
time with a different rainfall year while keeping the starting
mining year constant. In this way, the four rainfall years with
the highest precipitation were eventually matched with the four
mining years having the lowest water consumption.
As can be seen by the results presented in lable 4.4-B, an addi-
tional storage capacity of about /, Uliu (b,bi?Uj acre-feet would be
required to store all of the excess rainwater contained within the
Fort Ureen rainfall record it the exceptionally heavy events were
to occur during the most critical mining sequence, i.e., during
that period when water consumption within the system was at its
lowest rate. The computer analyses indicate that without addi-
tional storage capacity, the system would overflow during approxi-
mately thirty days of the mine life.
In addition to the minimum 1U,0UU acre-feet of storage provided
in the revised water circulation system, storage could be provided
by diverting excess rainwater into the current mining areas ^min-
ing areas exclusive ot active dragline cuts). This is the water
4-10
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Table 4.4-6 Summary of Water Balance Calculations for Different
Combinations of Mining and Rainfall Sequences
Starti ng Months Total RveTage
Rainfall with Overflow Deep Well
Year PJ scharges (Acre-Feet) Makeup (GPM)
1956
0
0.
1352
195 7
0
0.
1387
1958
0
0.
1419
1959
0
0.
1427
1960
2
1050.
1487
1961
4
6374.
1500
1962
3
4502.
1374
1963
1
3453.
130/
1964
0
0.
1219
1965
0
0.
1122
1966
0
U.
1146
196 7
0
0.
1125
1968
1
2839.
1285
1969
5
6156.
1324
1970
5
6620.
1278
1971
3
6491.
1259
1972
2
4397.
1256
1973
1
2447 .
1143
1974
1
1898.
1153
197 5
1
1525.
1199
1976
2
3826.
1337
1977
2
4203.
1322
1978
1
1949.
1378
1979
1
2260.
1352
Design Storage = 10,000 acre-feet
management alternative now proposed by Estech. Table 4.4-C lists
the storage available for excess water at the beginning and end
of each year of the mine life including utilization of the current
mining areas. Note that this table includes the available storage
only in the two most recently completed sana-clay disposal areas.
Some additional storaye would also be available in the other
active disposal areas. Consequently, Table 4.4-C provides a
conservative estimate of the amount of storage available.
As shown in the table, the minimum storage available for excess
water during the mine life, if the current mining areas are
utilized, is approximately 17,00(J (16,682) acre-feet (after the
first five years), enough to provide the required additional
storage. A water balance (based on one-month increments) was
4-11
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Table 4.4-C Storage Available tor Excess Water (in Acre-Feet)
Mi ne
beginning of
End of Year
Year
Year
kith Mine Areas*
I9b3
1 bb 90
bblb
19b4
20b9b
1307 2
19bb
19479
1 b 9 3 7
1986
22b 12
i bb9b
1987
2267b
1 9 b 2 7
19bb
2 b b 7 b
201 b7
i9b9
27149
lbb/b
1990
2bObO
i b 1 b 9
1991
2371b
lb314
1992
239/4
1 /b42
1993
23b0b
1742b
1994
23610
16682
199b
23104
1 7 9b9
199b
23721
19649
1997
2 b 7 7 0
20b01
199b
2606b
20/92
1999
2bb26
18013
2U00
23 2 7 2
lbOOb
2001
23b lb
lb96b
2002
24432
lbb/9
2003
2429b
1 b412
2004
24349
1 b / / b
200b
2b699
17 b 2 7
200b
24b00
17 809
~Includes available storage in the below-grade reservoir,
the initial settling area, ana the two most" recently
constructed sana-clay disposal areas. Neglects avail-
able storage in other active disposal areas. Assumes
sand-clay disposal areas under construction during
each mining year not completed until last day of year.
computed for a total storage capacity of approximately 17,000
acre-feet which is shown in Table 4.4-U. As shown, increasing
the total storage capacity from 10,000 acre-feet to 17,000 acre
feet (or more) reduces the overflow from 1bb gpm to zero and
decreases the average deep well make-up.
in addition to the removal of input to the river system, the
revised water management plan excludes the intake of water fron
the East Fork Manatee River, lhis would result in restoring 2.
M(iu to the hydrology of the Manatee River. In recognition of 1
4-12
-------
Table 4.4-D Water Balance - One-Month Increments-Design
Storage of 17,000 Acre-Feet Recirculation System
Av Vrage " AVerage"
Water Source
(gpm)
Water Disposition
(gpm)
Rainfall
8340
Evaporati on
6989
Matrix
2360
Sand-clay Mix
4630
Deep Well to
F1otati on
0
Sand Tailings
192
Seal Water
280
P roduct
280
Net Mine Cut
Seepage
6b4
Ditch Seepage
800
Initial Storage
186
Final Storage
42
Deep Well
Make-up
1113
Overf1ow
0
Total
12,933
12,933
fact that the original proposal limited this intake from the river
to the periods of high flow (Draft E1S p. 80), the hydrological
effect of ^his revision is expected to be minimal.
4.5 SURFACE WATER QUALITY
The elimination of discharges to the East and North Fork of the
Manatee River essentially negates the primary concern of water
quality degradation from site effluent. However, as a result of
the proposed project changes, potential impacts not previously
addressed in the EIS deserve consideration. The placement of sand
in the 480-acre initial settling area, the construction of an em-
bankment around the 210-acre reservoir, the possible introduction
of a reverse osmosis water treatment facility, and proof testing
of the initial settling area constitute four changes which have
the potential for affecting surface water quality. In addition,
the reclassification of the North Fork and East Fork of the
Manatee River imposes water quality considerations not applicable
at the time of preparation of the Draft and Final EIS. Specifi-
cally, stormwater runoff from the reclaimed sand-clay mix areas
was not expected to have an impact on the Class III standards of
the receiving waters. This section also addresses the potential
for impact wtien Class I-A standards apply to the receiving
st reams.
4.b.l Conversion of Clay Settling Area to Sand-Clay Mix
As a condition of Estech's Development Order granted by the
Governor and Cabinet serving as the Land and Water Adjudicatory
Commission, Estech is required to employ the sand-clay mix pro-
cedure while filling the initial settling area. This opera-
tional change nullifies the hypothetical dam break scenario
described in the EIS (Draft EIS, Section 4.1U).
4-13
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, u,c h„pn proposed for the dam of the initial
Since a final no«;sibl^ t0 perform a oes i gn-spec i f i c analy-
settling aref?1 ^ f ? :llire (P ^ ). The analysis done for this
v s te-sP-eclfic with no reliance on estimates
Supplement was t „^hor =reas or other dams. "I he purposes of
of performance fr rtpterm-jne the effect on oam safety of storing
the analysis y slurry. The results of the analy-
sand-clay mix r nrobabil1^ ot a shear failure of the ini-
sis indicate that P if1 i4u,UOU. This probability of
tia] sett 1 i the cafpe as that for the clay only. How-
failure is e nofed that operational differences make the
probability°of failures Iiyhtly less ,1,.., than a failure of
- l - w a n 1 w
clay only.
* *ho ria of failure of the
-------
A da in failure could release up to a maximum of 3, b 0 0 acre-feet of
water, which would amount to about 15% of the normal volume of
Lake Manatee. This maximum release assumes loss of all water
above grade (2310 acre-feet) and the release of an additional 1200
acre-feet of water through erosion to approximately six feet below
grade.
The hypothetical dam break of the clear-water reservoir would,
result in the release and deposition of sediment in the form of
sand-size particles and suspended solias. The impact of sedi-
ments would be due to particles entrained from the resrvoir
embankment, eroded uplands and scourea Manatee Kiver bed. Ihe
sand-sized particles from the breach would be expected to be
deposited in close proximity to the Estech property. The safe
yield of the Lake Manatee Reservoir would not be reduced. The
suspended solids impact would be comparable to that of a 2b-year
peak flow sediment flush from the river system.
Projected water management practices dictate that only when all
other available storage is full will the 210-acre reservoir be
allowed to fill to its design capacity. Therefore, the quality
of water within the reservoir, subject to release during a dam
break, would essentially be that of stormwater accumulated over
and above the available storage.
4.b.3 Reverse Osmosis Hater Treatment Facility
A potential concern for surface water quality would be the pos-
sibility of wastewater, which had accumulated during the recycle
of beneficiation and reverse osmosis plant discharges, entering
and migrating through the surficial ground water to enter the
Manatee kiver. As di-scussed in Section 4.3.3, the R/0 contami-
nants present in the recirculation water are expected to be
largely removed by the various available contaminants sinks.
Therefore, the seepage water entering the surficial ground water
is expected to be low in concentrations of these contaminants.
The low hydraulic gradients over the site and plans to keep the
recirculation system water levels near groundwater levels provide
a hydraulic situation which would not promote the rapid movement
of contaminents away from the source via the surficial ground-
water. Furthermore, the contaminant concentrations would be fur-
ther reduced by interaction with the surficial aquifer materials
and the ambient groundwater, resulting in a decrease in concen-
tration with both time and distance from the source. As the com-
bined result of these factors, no adverse impact on the Manatee
River is expected to occur as a result of the R/0 facility.
4.b.4 Proof Testing of Initial Settling Area
As a condition of approval, the Florida Govenor and Cabinet,
sitting as members of the Land and Water Adjudicatory Commission,
requires Estech to proof-test the 4b0-acre initial settling area
with clear water. The concept of proof-testing the clay settling
area is to produce stress conditions less than design maximum but
great enough to measure with installed instrumentation. The
4-15
-------
normal procedure is a si ow-to-moderate f i 11 ">ny rate accompanied
by close observation of instrumentation and physical inspection.
Since filling to the maximum level is not required for adequate
proof-testing, failure by overtopping is not a concern. The majo
concern is uncontrolled excessive seepage that could event-^!!^
lead to piping and possible embankment failure. Under cond1t
of proof-testing, the possibility of rapid dam failure is essen-
tially non-existent.
The source of water for the clear water proof-testi ng would
groundwater withdrawal within the 12.9 MGD limit imposed Dy t
Consumptive Use Permit. Filling to lb feet would require approxi-
mately lbl days at a continuous rate. No flow to the Lake f_
reservoir would be diverted for filling the settling area.
testing of the settling area would pose no additional hazar
tne Lake Manatee dam, even if failure of the settling area du g
proof-testing occurred.
An October 1&79 report by Bromwell Engineering to Manatee County
concluded that the existing dam facilities could be operate
safely pass a lUO-year storm, but recommended installation o
emergency spillway to accommodate the probable maximum fioo
(PMF) (Bromwell, 1979). In the case of the lUU-year storm, the
level inside the reservoir would not exceed elevation ,
leaving lb,UUU acre-feet of storage to the top of the dam, e ug
to accommodate the total capacity of the Estech settling pon
(12,000 acre-feet) without overtopping. The same would app y
during the probable maximum flood, provided the emergency spi w y
had been installed. If the spillway were not in place during the
PMF, overtopping of the Lake Manatee dam would occur with no
contribution from tstech.
4.b.b Sand-Clay Mix Runoff
The mining and beneficiation of the Duette Mine site is projected
to result in the reclamation of 5,90b acres through the use o
sand-clay mix technology. The runoff potential of these soils
should range from (moderately high to high due to a decrease in
surficial permeability (Draft EIS, p. 53). Although runoff poten-
tial would be increased over baseline conditions, increased im-
poundments in lakes and marshes after reclamation would decreas
runoff from the reclaimed property by two to three inches per year
(Draft EIS, p. 81).
Constituents of the sand-clay runoff which might potentially de-
grade the quality of the receiving streams below the C1 ass
criteria were determined by identifying those criteria affe ®
by the reclassification and eliminating from consideration
constituents not expected to be present in the sand-clay mix ">n
sufficient concentrations to potentially cause water qu y -
lations. The availability of these constituents to theece^lng
streams was then investigated by examining the mecharu y
these potential contaminants might be introducted
st reams.
4-16
-------
Table 4.b-A summarizes those parameters affected by the classi-
fication change from Class 111 to Class i-A. In the case of
aluminum, a criterion exists for Class 111 waters but not for
Class I-A.
Table 4.b-A Parameters Aftectea by Classification Cnange
' F.A.C. 17-3
General F.A.C. 17-b F.A.C. 17-a
Parameter Criteria Class 1 -A Class 111
A1 umi nurn l.b
Barium l.U
Chloride 2bU
F1uoride 1U. 0 l.b
1 ron U. 3 l.U
Nitrogen, Nitrate-N 10
Z, 4 - D U. 1
Z, 4, b IP, jiy/1 --- 1U
Selenium 0.U1 O.U2b
TUi> bUU monthly avy.
1UOO maximum
NOTE: o In milligrams/liter unless otherwise noted,
o yg/1 = micrograms per liter
The following constituents are not known to be present in sana-
clay mix disposal areas in sufficient concentrations to poten-
tially cause a violation of Class 1-A standards: selenium;
Z, 4 - D; Z, 4, b TP; chloride; and nitrate. The remaining
parameters of fluoride, iron, total dissolved solids, and barium
have been investigated relative to their availability to the re-
ceiving streams. To identify this avaiTabi1ity , the mechanisms
by which these contaminants would reach (or be prevented from
reaching) the surface waters were evaluated.
In order of their relative potential for being introduced into
the receiving streams, fluoride presents the most significant
potential for approaching the Class 1-A criterion followed by lUi>,
iron, ano barium. However, several physical characteristics of
the mining ano reclamation plan reduce potential for impact from
these constituents.
4-17
-------
As mentioned earlier, the overall runoff from the site is expected
to decrease slightly due to the increase in impoundment areas of
the reclaimed land. Approximately b3b acres of shallow aquatic
environments would be created within the sand-clay reclamation
areas. These naturally vegetated systems provide for long-term
uptake, degradation, and precipitation of selected elements. In
addition, the reclamation of sano-clay areas requires that ex-
terior dikes be graded to approved slopes. It is inherent in
this procedure that the exterior dikes be graaed over portions of
the sand-clay soils. Approximately 21 to 37 percent of the sano-
clay soils would be capped with the dike material resulting in
reduced exposure of these areas to surface runoff. The reclama-
tion plan also provides tor the revegetation of all reclaimed
soils as soon as physical stability permits and grading to
approved slopes is complete. Ihis revegetation serves to
stabilize the surface soils and prevent erosion.
A final feature of the mine plan which would serve to buffer the
impact of the constituents on the North and East Forks of the
Manatee River is the preservation of a 200-foot wide zone adjacent
to the streams. This zone, in addition to its ecological signifi-
cance, will provide an area of established vegetative cover, humic
soils, and microbial communities available for assimilation and
b i odegradat i on.
in conclusion, the surface runoff from the reclaimed sand-clay mix
areas is not expected to have an adverse affect on the Class I-A
waters of the East and North forks of the Mane ".ee River.
4.b SOILS
The Uuette Mine as originally proposed proviaed tor the disposal
of clay wastes within a 4b0-acre settling area which would ulti-
mately be reclaimed by encouraging dewatering and grading the re-
taining dike inward over the area. The use of sand in the initial
settling area will eliminate this type of soil profile and replace
it with an additional 4b0 acres of a soil classified as a sandy
loam. Its physical, agronomic, and engineering properties would
not be unlike those expected from the b,42b acres of sand-clay
reclamation proposed for other areas of the mine site.
4.7 RADIOLOGICAL ENVIR0NMEN1
The waste disposal/reelamation plan for the Uuette Mine originally
provided for a 4b0-acre clay waste settling area. 1 he clay waste
from pilot plant studies of Uuette Mine matrix is reported to
exhibit a concentration of radi urn-22& of between 3.2 to b.b pCi/g.
This area was predicted to have a total external gamma radiation
level of 13.b yR/hr. The addition of sand tailings (radium-22o
concentration between .b ano 1.4 pCi/g) to the initial settling
4-18
-------
area in approximately the Z.b to 1 ratio as proposed tor the
sand-clay mix reclamation areas, is predicted to yield a gamma
radiation level for the area of tt. / yR/hr. Therefore, it appears
the conversion of the 4bU-acre clay-only settling area to a sand-
clay mix will provide a net decrease of b.1 yR/hr in terrestrial
gainma radioactivity (from 13.b yR/hr to b.7 yK/hr}.
4-19
-------
5.0 SHORT-TERM USE VERSUS LONG-TERM PRODUCTIVITY
The following discussion of short-term use versus long-term produc-
tivity includes, where applicable, an identification of the
irreversible or irretrievable commitments of selected resources
resulting from the proposed project revisions. Irreversible or
irretrievable resource commitments are defined as those resources
which would be consumed, depleted, permanently removed, or de-
stroyed. Only those disciplines subject to evaluation within this
Supplement are discussed.
5.1 AIR QUALITY
The proposed project revisions will periodically contribute an
additional source of air contaminants over the life of the mine.
In addition to those sources identified in the E1S, the reverse
osmosis facility would primarily contribute NO emissions which
may impact the air quality over the short term? No long-term
impact has been identified.
5.2 GROUNDWATER HYDROLOGY
The withdrawal of ground water would be significantly reduced over
those quantities identified in the EIS. There would still be a
depression of the potentiometric surface of the Floridan Aquifer
and a capturing of surficial ground water from pit seepage over
the mine life. At a pumping rate of approximately Z MGD, more
than 15 billion gallons of water would be committed from the Flo-
ridan Aquifer over the life of the mine.
5.3 GROUNDWATER QUALITY
The revised project introduces additional contaminants not
originally present in the recirculation system. Although most of
these constituents are expected to be deposited in several iden-
tified contaminant sinks, the possibility exists for some migra-
tion with seepage to the adjacent surficial groundwater. The
contaminant sinks would result in a possible long-term deposition
of various process constituents.
5.4 SURFACE WATER QUALITY
The proposed project essentially eliminates all discharges to
surface waters over the life of the mine thereby reducing both the
short-term and long-term surface water quality impacts relative
to the originally proposed projects. Changing the intial settling
area from clay-only to sand-clay mix reduces the potential
throughout the mine life for a clay waste spill to impact Lake
Manatee.
5-1
-------
b.b SURFACE WATER HYDROLOGY
The short-term use of the river for process water (by off-stream
diversion) and as a recipient of discharge water has been elimi-
nated by the proposed project changes. The short-term impoundment
of water within the active project areas would prohibit run-off
from entering adjacent water courses. The short-term diversion
of run-off is not expected to adversely affect the long-term
productivity of the riverine systems.
b.6 SOILS
The revised project requires that an area previously designated
for 480 acres of clay wastes be utilized for sand-clay mix. This
short-term use directly affects the long-term productivity of this
limited area. The agronomic and structural attributes of the
sand-clay mix would provide long-term benefits not available with
clay only.
5.7 RADIATION
The conversion of the clay-only settling area to a sana-clay mix
area provides a net decrease in terrestrial gamma radioactivity.
In view of the inherent persistency of radioactivity, this
revision must be considered to result in a long-term beneficial
impact relative to the originally proposed project.
5-2
-------
6.0 COMPARISON WITH AREAWIDE EIS RECOMMENDATIONS
A comparison of the project (as originally proposed) with the
Areawide EIS Recommendations was presented in the Draft and Final
EIS for the Duette Mine. Subsequently, changes in the project
have required that the Areawide Recommendations be revisited to
determine to what degree these changes may affect the
Recommenaati ons.
The following EIS recommendation are affected by the project
rev i s i ons :
The Areawide EIS recommended that State of Florida and local
effluent limitations for any discharges be met. Estech, in an
effort to provide "reasonable assurance" that its discharges will
meet State of Florida effluent limitations, has revised its water
management plan to eliminate all surface water discharge from
mine. The extremely low probability of discharge has been deter-
mined by recent administrative hearings to qualify as a "zero
discharge" facility. The Florida Department of Environmental
Regulation has indicated it will provide the required certifi-
cation for the federal NPDES permit (FDER, 19b2).
The Areawide EIS recommended the elimination of conventional
above-ground slime disposal areas through development of a min-
ing and reclamation plan whereby the clay wastes and sand-clay
mixture would be used for reclamation or some other purpose.
Although Estech's original plan was consistent with the areawide
recommendations, the use of the initial clay settling area has
been further modified to accommodate sand along with the clays.
The initial settling area will now provide for the use of the clay
as a component of a sand-clay mix.
The Areawide EIS recommended that the requirements of the South-
west Florida Water Management District consumptive use permit
requirements be met. Although Estech was bound to the conditions
of their Consumptive Use Permit, the project changes provide a
further reduction of groundwater withdrawals. This reduced with-
drawal is the result of increased utilization of the recycle water
through the use of a reverse asmosis treatment facility and in-
creased storage capacity.
Although Estech's original water management plan provided for
"capture of 100% of water recovered from slimes", the revised
water management plan provides for recovery and recirculation of
al1 process water.
6-1
-------
7.0 COORDINATION
7.1 FINAL ENVIRONMENTAL IMPACT STATEMENT DRAFT SUPPLEMENT
COORDINATION
The Final Environmental Impact Statement (Final EIS) was published
in September 1980 and made available to the public and the Council
on Environmental Quality. The Federal Register (Vol. 45, No. 179)
dated September 12, 1980, announced the availability of the Final
EIS, and a corresponding public notice appeared in local
newspapers.
On February 17, 1982, EPA distributed to all citizens, public
groups, and governmental agencies a Notice of Intent to prepare
a Supplement to the Final EIS to address changes in the proposed
project. The Notice of Intent also appeared in the Federal Regis-
ter (Vol. 47, No. 39) dated February 2b, 1982.
The following federal, state, and local agencies, public offi-
cials, organizations, and interest groups have been requested
to comment on this Draft Supplement.
Federal Agencies
Bureau of Mines
Coast Guard
Corps of Engineers
Council on Environmental Quality
Department of Agriculture
Department of Commerce
Department of Education
Department of Interior
Department of Transportation
Department of Health and Human
Federal Highway
Admi n i strati on
Fish and Wildlife Service
Food and Drug
Admi ni strati on
Forest Service
Geological Survey
National Park Service
Department of Housing and
Serv ices
Soil Conservation Service
Urban Development
Department of Energy
Members of Congress
Honorable Lawjon Chiles
United States Senate
Honorable Andy P. Ireland
U.S. House of Representa
ti ves
Honorable Paula Hawkins
United States Senate
Honorable Connie Mack III
U.S. House of Representa-
Honorable Sam Gibbons
U.S. House of Representatives
7-1
-------
State of
Honorable D. Robert Graham
Governor
Patrick K. Neal
State Senator
Warren S. Henderson
State Senator
Lawrence F. Shackleford
State Representative
Peggy Simone
State Representative
Thomas E. Danson, Or.
State Representative
Robert M. Johnson
State Representative
Fred Burrall
State Representative
Local and
Manatee County Commission
Polk County Commission
Hillsborough County Commission
Desoto County Commission
Hardee County Commission
Sarasota County Commission
Tampa Bay Regional
Planning Council
Interest
The Fertilizer Institute
Florida Phosphate Council
Florida Audubon Society
Florida Sierra Club
Manasota 88
League of Women Voters
Conservation Council of
Manatee County
Florida
Department of
Admi nistrati on
Environmental Regulation
Commi ss i on
Game and Freshwater Fish
Commi ss i on
Department -of Commerce
Department of Health and
Rehabilitative Services
Department of Environmental
Regulati on
Department of Community
Affairs
Department of Natural
Resources
Department of Transportation
Department of Agriculture
and Consumer Services
Regional
Manatee County Department
of Pollution Control
Sarasota County Health
Depa rtment
Sarasota County Environ-
mental Control Department
Southwest Florida Water
Management District
Groups
Manatee Audubon Society
Florida Defenders of
the Environment
Izaak Walton League of
America, Florida Division
Florida Wildlife
Federati on
7-2
-------
7.2 CUNSULTAT1 UN WITH THE U.S. DEPARTMENT UF INTERIOR, U.S. FiSH
AND WILDLIFE SERVICE
EPA has performed all consultation procedures in accordance with
requirements of Section 7 of the Endangered Species Act of 1973,
as amended. Un February 14, 1980, EPA provided the U.S. Depart-
ment of the Interior, Fish and Wildlife Service (USF&WS) with a
description of the proposed Duette Mine and requested confirma-
tion of the accuracy of the information contained in the Draft EIS
provided by the consultant preparing the EIS on behalf of EPA.
Subsequently, EPA received a letter from USF&WS issuing a Bio-
logical Opinion indicating satisfaction with the information
provided in the Draft EIS. The proposed changes to the project
would not affect the potential impact on threatened and endangered
species on the site and, therefore, would not require additional
consultati on.
7.3 CONSULTATION WITH THE STATE HISTORIC PRESERVATION OFFICER
EPA has complied with all consultation requirements established
by Section 10b of the National Historic Preservation Act of 1966.
In an April 29, 1980 letter, EPA provided the Director of the
Florida Department of State, Division of Archives, History and
Records Management and State Historic Preservation Officer with
pertinent sections of the Draft EIS Summary Document and a copy
of the Archaeological and Historical Properties Resource Document.
This information was provided pursuant to the procedures for con-
sultation and comment promulgated by the Advisory Council on His-
toric Preservation in 3b CFR Part 800 and 3bb CFR Part b3. The
State Historic Preservation Officer concurred by signature a find-
ing of "no adverse effect" given the imposition of conditions
described in a letter from EPA dated July 12, 1980.
The proposed changes to the project would not affect the condi-
tions required and agreed upon in the letter. Therefore, addi-
tional consultation with the State Historic Preservation Officer
and provision of further information for compliance with 36 CFR
Part 800 and 3b CFR Part 63 would not be necessary.
7.4 COORDINATION WITH THE U.S. DEPARTMENT OF INTERIOR, MINERALS
MANAGEMENT SERVICE AND BUREAU OF LAND MANAGEMENT
In response to EPA's February 1982 Notice of Intent to prepare
this Supplement, the Department of interior, Minerals Management
Service (MMS) notified EPA in a letter dated May 12, 1982, of the
existence of a 40-acre tract of Federally reserved phosphate
located within the boundaries of the proposed mine site. The
exact location is the NE 1/4 of the NW 1/4 of Section 18, Range
22E, Township 33S. At the time of EIS publication, neither Estech
nor EPA was aware of the Federal minerals ownership, and the
proposed mine plan described in the EIS indicated that the tract
would be mined by Estech. MMS indicated that Estfech and the
Bureau of Land Management (BLM) should be made aware of*the
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Federal phosphate ownership of the tract and the need for Estech
to meet Competitive Lease Application requirements before mining
the subject tract.
EPA advised Estech of the existence of the 40-acre tract, and in
a letter dated June 1, 19b2, Estech acknowledged the Federal
minerals ownership, which was found to be recorded in the 1927
Manatee County lands records. Estech indicated that they would
want to mine in the area in question in approximately Year 18 of
the mine life and that they would comply with all necessary prior
approvals before mining.
The 4U-acre tract represents U.t>% of the area to be mined and
contains about 10,000 tons of phosphate per acre. Although the
value of phosphate is a function of many variables, Estech has
estimated the value of the Federally reserved phosphate to be
$1.00 to $4.00 per ton.
Bypassing the 40-acre tract would mean the non-recovery by Estech
of approximately 400,000 tons of phosphate. This amount 1s so
small relative to the mine reserve that its disposition would have
no significant effect on the Duette Mine. If Estech did not
obtain the necessary approvals from BLM and the tract were
bypassed in the course of Estech's proposed mining operation, 1t
is unlikely that the economics of recovery would allow its later
recovery by Estech or any other mining entity.
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8.0 LIST OF PREPARERS
The Supplement to the Final Environmental Impact Statement for
Estech, Inc., Duette Mine, was prepared for EPA by Conservation
Consultants, Inc. (CC1) of Palmetto, Florida using the third party
EIS preparation method. The following EPA officials, CCI staff,
and subconsultants to CCI participated in preparing this
Supplement.
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
NAME RESPONSIBILITY
Robert B. Howard Chief, NEPA Compliance
Section
A. Jean Tolman EIS Project Officer
J. H. Bricker Air Quality
Richard DuBose Air Quality
Gail D. Mitchell Ground Water
Thomas R. Cavinder Surface Water
Marshall Hyatt Surface Water
H. Richard Payne Radiation
Craig Bromby Office of Regional Council
CONSERVATION CONSULTANTS, INC.
William W. Hamilton President
H. Clayton Robertson Project Manager
A. Lee Genoble Air Quality
Reverse Osmosis Process
Water Quality
George A. Weinman, P.E. Surface Water Hydrology
Water Balance
ARMAC ENGINEERS, INCORPORATED
Ross T. McGillivray, P.E. Dam Failure Probability
LEGGETTE, BRASHEARS, AND GRAHAM, INC,
Frank H. Crum
Harry Oleson
Michael E. Zellars
Mickey Lee
Groundwater Hydrogeology
Groundwater Quality
Groundwater Hydrology
ZELLARS-WILLIAMS, INC.
Water Balance
Water Balance
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9.0 REFERENCES
Andaman and Associates, Inc. 1901. Water Balance and Discharge
Calculations, Proposed Duette Mine. Prepared for Estech
General Chemicals Corporation, Manatee County, Florida.
July 3, 1981.
Ardaman and Associates, Inc. 1982. Analysis of Effects on the
Manatee River from a Dam Failure of the Estech 210-Acre
Clear Hater Reservoir. February ID, 1982.
Armac Engineers, Inc. 1982. Geotechnical Supplement to the Final
E1S, Proposed Estech Duette Mine. July 7, 1982.
Bromwell Engineering, Inc. 1979. Lake Manatee Dam Phase II
Inspection. October, 1979.
Council on Environmental Quality, Executive Office of the
President. 1978. Regulations for Implementing the
Procedural Provisions of the National Environmental
Quality Act. November 29, 1978.
Development of Regional Impact. 1980. Public Hearing Proceedings.
Transcript - State of Florida, Department of Administra-
tion, Division of Administrative Hearings. Case #79-
1«94. March, May, 1980.
Florida Department of Environmental Regulation. 1982. Final Order
Entered by Victoria J. Tschinkel, Secretary, State of
Florida Department of Environmental Regulation. May 28,
1982.
Florida Division of Administrative Hearings. 1982. Recommended
Order. March lb, 1982.
Miller, R. L., and Sutcliffe, Horace, Jr. 1982. Water-quality
and Hydrogeology Data for Three Phosphate Industry Waste-
disposal Sites in Central Florida, 19/9-80. U.S.
Geological Survey Water-Resources Investigations 81-84.
Apri 1 , 1982.
Miller, R. L. , and Sutcliffe, H. Jr., (unpublished abstract),
Effects of the Central Florida Phosphate Industry on the
Quality of Ground Water.
Seaber, P. R., Miller, R. L., and Sutcliffe, Horace, Jr. 1982.
Seepage of Contaminants into Ground Water from Two
Phosphogypsum Disposal Sites in Central Florida (Abs.).
Environmental Symposium '82. San Antonio, Texas.
March 10, 1982.
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Seaber, P. R., Miller, R. L., and Sutcliffe, Horace, Jr. 1982.
Movement and Chemical Modification of Phosphogypsum
Process Water in Ground Water, Central Florida (Abs.).
Geological Society of America, Abstracts with Annual
Meeting Proceedings. New Urleans, Louisiana.
October 18-21, 1982.
Sverdrup, Parcel and Associates, Inc. 1982. Duette Mine and
Beneficiation Complex Recycled Water Preparation Facility,
Proposed Carbon Regeneration Furnace Air Pollution
Emissions. March 15, 1982.
U.S. Environmental Protection Agency. 1979a. Draft Environmental
Impact Statement. Estech General Chemicals Corporation,
Duette Mine, Manatee County, Florida. October, 1979.
U.S. Environmental Protection Agency. 1979b. Draft Environmental
Impact Statement Resource Documents (Volumes A through M).
Estech General Chemicals Corporation, Duette Mine, Manatee
County, Florida. October, 1979.
U.S. Environmental Protection Agency. 1980. Final Environmental
Impact Statement. Estech General Chemicals Corporation,
Duette Mine, Manatee County, Florida. September, 1980.
Water and Air Research, Inc. 1981. Fate of Chemicals Associated
with a Reverse Osmosis Process for Preparation of Recycled
Water at the Proposed Duette Mine and Beneficiation Plant
of Estech, Inc. December 8, 1981.
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