United States Region 4 EPA 904/9-83-106
Environmental Protection 345 Courtland Street, NE March 1983
Agency Atlanta, GA 30365
<&EPA Environmental Final
Impact Statement
Tallahassee-Leon County
Wastewater Management
Tallahassee, Leon County
Florida
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Cr sr
72 ? UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
proi^ REGION IV
345 COURTLAND STREET
ATLANTA, GEORGIA 3O30S
^ 1 S 1983
TO ALL INTERESTED AGENCIES, PUBLIC GROUPS, AND CITIZENS:
Enclosed for your review and comment is the Final Environmental
Impact Statement (EIS) for wastewater management in the
Tallahassee-Leon County, Florida area.
This EIS was prepared in compliance with the National
Environmental Policy Act and implementing Agency regulations
(40 CFR Part 6, November 6, 1979). In accordance with
these regulations, the Final EIS will be filed with EPA's
Office of Federal Activities. Availability of the EIS will
then be announced in the Federal Register, beginning a 30-day
comment period. (The Federal Register date is the same as
the date of this notice). This Agency will take no administrative
action on this project until the close of the comment period.
We will appreciate your review of this document and any
comments you may have. Please send all comments to E.T. Heinen,
Chief, Environmental Assessment Branch at the above address.
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Environmental Impact Statement
Final
Uhrary Region IV
OS Eaviroruneotal Protection Agency
•y'lS Courtland Street
Abasia, Georgia 30365
Tallahassee-Leon County Wastewater Management
Tallahassee, Leon County, Florida
U.S. Environmental Protection Agency
Region IV
Atlanta, Georgia 30365
This Final EIS has addressed the Federal Action of the
provision of Federal Funds for Phase II wastewater facilities
as proposed by the Draft 201 Facilities Plan for Tallahassee-
Leon County. The Phase II wastewater facilities were proposed
for growth areas which will not be served by 201 facilities
already approved for Federal funding. Alternatives for
wastewater management in the study area were developed and
evaluated with emphasis on protection of the groundwater
resources and sensitive natural systems such as floodplains
and wetlands.
The selected action for the Final EIS is that no further
Federal grants be made for expansion of the wastewater system
beyond that already approved under Phase I of the 201 Plan.
The basis of this decision is the determination that the
Phase I facilities already approved by EPA will serve all
existing and some future needs, and that new growth in
wastewater generation can be handled in an environmentally
sound and cost effective manner by on-site and small community
systems.
Comments or inquiries should be forwarded to:
E.T. Heinen, Chief
Environmental Assessment Branch
Environmental Protection Agency
34 5 Courtland Street, N.E.
Atlanta, Georgia 3036 5
404/881-3776
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EXECUTIVE SUMMARY FOR ENVIRONMENTAL IMPACT STATEMENT
TALLAHASSEE-LEON COUNTY WASTEWATER MANAGEMENT
TALLAHASSEE-LEON COUNTY, FLORIDA
Draft ( )
Final (X)
Environmental Protection Agency
Region IV
345 Courtland Street
Atlanta, Georgia 30365
Type of Action: Administrative Action (X)
Legislative Action ( )
EXECUTIVE SUMMARY
PART A. DESCRIPTION OF RECOMMENDED ACTION
This EIS has addressed the Federal Action of the provision
of Federal funds for Phase II wastewater facilities as proposed
by the Draft 201 Facilities Plan for Tallahassee-Leon County.
The selected action for the Final EIS is that no further Federal
grants be made for expansion of the wastewater system beyond that
already approved under Phase I of the 201 Plan. The basis of
this decision is the determination that the Phase I facilities
already approved by EPA will serve all existing and some future
needs, and that new growth in wastewater generation can be han-
dled in an environmentally sound and cost effective manner by
on-site and small community systems.
The EIS projected that by the year 2000, the wastewater flow
from within that area now served by the City, without flow
reduction measures, will approximate the available 17.5-mgd
capacity at the T. P. Smith/Southwest treatment facility.
Data on soils in the growth area support the use of on-site
systems. The Leon County Health Department indicates that
on-site systems operate properly when their construction follows
the basic rules governing their placement. The few failures of
on-site systems that have occurred in the northeast growth area
are a result of poor siting and poor construction.
The importance of groundwater quality in an area where
groundwater is the sole potable water supply is a most critical
consideration. The EIS shows no significant adverse impact to
i
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groundwater quality from the use of on-site systems and small
community systems in the growth areas. The potential impacts on
down-gradient city water supply wells were fully considered in
the selection of Alternative 4. The geological formations in
northern Leon County, including the projected growth areas,
should provide adequate protection for the drinking water (Flori-
dan) aquifer.
Another issue investigated by the EIS was the potential det-
rimental impacts to wetlands resulting from development in north-
east Leon County. Properly implemented, the recommended
alternative decreases the potential for development of marginal
lands and environmentally sensitive lands such as wetlands, flo-
odplains, and high groundwater areas.
For the implementation of Alternative 4, the importance of
proper siting, construction, and operation and maintenance of
on-site and small community systems cannot be overemphasized. If
these systems are used extensively and are poorly maintained, the
potential for adverse environmental impacts increases. These
impacts include the potential for human contact with wastewater
surfacing from poorly located or designed drainfields and result-
ing health effects. Managed competently, however, on-site
systems and small community systems are effective and environ-
mentally sound. It is recommended that the implementation of
Alternative 4 include several measures at the local level which
will serve to mitigate potential impacts. The primary recommen-
dations are the following:
1. Revision of basic rules governing septic tank use
to allow for systems more suited to current and
future demands. These revisions should address
siting criteria, basic system design, and the use
of alternative systems.
2. The implementation of a management district or oth-
er means of on-site systems management to promote
efficient operation.
3. Monitoring of groundwater quality in developing
areas of Leon County to ensure early detection and
correction of contamination of groundwater
resources. The focus of this program would be to
identify cumulative areawide impacts on
groundwater.
PART B> SUMMARY OF ALTERNATIVES COMfiTngppn
lahas^Lerpc^:ntfi^?er^^? sn/sw.*"
rates complete wastewater management systems f^th^a
available collection, treatment and diLno,! f the area. The
water management were screened under the ElS^ain^v/0!^ wa?£?"
options for the study were determined feasible
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In developing and evaluating the alternative systems, the
following were considered:
1. The EIS wastewater flow projection for the planning
period (through the year 2000) is 22.3 mgd without
conservation measures. The 201 Plan-projected flow
for the year 2000 is 30.4 mgd.
2. The EIS identifies three major wastewater - gener-
ation areas: the southwest, the northeast, and the
southeast. The alternatives have been developed
for serving these three areas.
3. The evaluation of conservation measures for the EIS
study showed that a flow reduction of 2.4 mgd by
the year 2000 is feasible. The costs and struc-
tural configurations of each alternative are
described with and without conservation.
4. The only wastewater disposal options evaluated in
detail were land application options. Surface
water discharges and other options were eliminated
as inappropriate, for cost, environmental or tech-
nical reasons.
5. Florida DER rules require secondary treatment prior
to application of effluent to the land. EPA deci-
sions regarding funding of pre-application levels
of treatment prior to land application are deter-
mined on a case by case basis.
6. The Dale Mabry treatment plant will be closed.
The alternative wastewater management systems developed and
evaluated for the study area are described as follows:
1. Alternative System 1A
A new treatment plant would be constructed in the
northeast, and the T. P. Smith/Southwest treatment
facility would be expanded beyond the Phase I
capacity of 17.5 mgd. A northeast treatment plant
would provide service in the northeastern growth
areas of Leon County. In addition, sewers would be
extended to developed portions of the northeast
presently served by on-site and small community
systems. The expanded T. P. Smith/Southwest Plant
would serve the Southwest and Southeast service
areas. Effluent from the T. P. Smith/Southwest
plant would be disposed of at the expanded South-
east Sprayfield. The Northeast plant effluent
would be disposed of by rapid infiltration at a
northeast disposal site.
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2. Alternative System IB
This alternative is the same as 1A except that the
treated effluent from the Northeast plant would be
conveyed to the expanded Southeast Sprayfield for
disposal.
3. Alternative System 2
For this alternative, existing facilities serve as
a regional treatment system. The structural con-
figuration depends on the decision whether or not
to implement conservation measures. Without con-
servation measures, the most cost-effective system
is continued operation of the Lake Bradford plant
at 4.5 mgd and expansion of the T. P.
Smith/Southwest plant by 0.3 mgd. With conserva-
tion measures, an expanded T. P. Smith/Southwest
treatment facility would serve the entire sewered
area as a regional treatment plant with a 19.9-mgd
capacity. This alternative includes extensive con-
struction of interceptors to serve the Northeastern
and eastern portions of the 201 planning area.
4. Alternative System 3
Under this alternative, a Southeast treatment plant
would be constructed to supplement the treatment
capacity of the expanded T. P. Smith/Southwest
facility. The Southeast plant would serve growth
.areas in the Southeast and Northeast. The T. P.
Smith/Southwest plant would serve projected growth
areas in the Southwest and the existing service
area. For both plants, wastewater would be dis-
posed of at the Southeast Sprayfield.
5. Alternative System 4 (No-Federal-Action
Alternative)
The No-Federal-Action Alternative is described by
considering the present situation in the Tallahas-
see-Leon County area and projecting future condi-
tions with no changes in public policy or private
practices. Expansion of the present wastewater
system would continue only until the limits of
Phase I expansion are reached. New growth in
wastewater generation would be handled by on-site
and small community systems. Population infilling
would take place in the City1s service area and
some additional collectors would be necessary.
Each alternative was evaluated with respect to cost, envi-
ronmental impacts, technical feasibility, and implementability.
A summary of the evaluation of alternatives is presented in Table
1.
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TABLE I
SUMMARY OP ALTERNATIVES EVALUATION
Alttrnatlves Pescrlptlon of Alternatlvea
1A T.P. Smlth/SW plants Co serve
SV A SE with disposal at SE
spray flald. NE plant to
serve NE with disposal In NE
Total Present
Worth ($x!0 )
$36.4
(29.4)*
Impacts
1. Development flexibility In density and location
2. 24.3 million greather than lowest cost alternative
3. Cost to homeowners from tap-on fees and sewer use
fees.
4. Construction impacts on surface waters and plant and
animal resources
Same as 1 above except NE plant $52.7
effluent disposal at SE spray- (46.0)*
field
5. NE plant considered incompatible with existing land
usss by area residents
6. City's drinking water wells down gradient of
proposed rapid infiltration site
7. Increased potential for nonpolnt source pollution due
to Increased impervious surfaces from higher density
development and opportunity to develop flood plains,
wetlands and high groundwater areas.
1. Development flexibility In density and location
2. Highest cost structural alternative
3. Less Impact on groundwater than 1A
4. Cost to homeowner from tap-on fees and sever uss fees
5. Alternative most desired by the City
6. Construction impacts on surfsce water, and plant and
animal resources
T.P. Smlth/SW plants A Lake
Bradford plant, if needed, serve
as regional plants with dis-
posal at SE sprayfleld
T.P. 8mlth/SV plants eo serve
8V and 8E. NE served by 8E
plant. All disposal at 8E
sprayfleld.
T.P. Smith/SV plants to sarve
existing city service eras.
Growth areas outside service
area served by on-site of small
community systems
$31.5
(27.6)*
$40.0
(34.3)*
(5.98)*
7. Increased potentlsl for non-point source pollution
due to increased Impervious surfaces from higher
density development and opportunity to develop flood-
plains, wetlsnds and high groundwater areas
8. Added construction Impacts from transmission line to
SE sprayfleld
1. Development flexibility In density snd location
2. Coat to homsovner from tap-on fees and aever use fe«s
3. 21.1 million greater than lowest cost alternative
4. Construction impacts on surface water and plant and
animal resources
5. Maximum use of existing facilities
6. Increaaed potential for nonpolnt source pollution
due to Increased impervious surfaces from higher
density development snd opportunity to develop flood-
plains, wetlands and high groundwater areas.
7. Makes full use of already constructed force main to
8E sprayfleld
8. Long Interceptors potentially causing anaerobic
conditions and treatment problems
Development flexibility In density and location
29.6 million greater than lowest cost alternative
Avoids public acceptance problems of NB plant
Coat to homeowner from tap-on feea and sever use fees
Conetruetlon Impacts on surface water, and plant and
animal resources
6. Increased potential for nonpolnt source pollution due
to increased Impervious surfaces from higher density
development and opportunity to develop floodplalna,
wetlands, snd high groundwater areas
7. Long lnterceptora causing anaerobic conditions and
treatment problems
1. Does not promote development of marginal lands (flood-
plains, wetlands, high groundwater areas)
2. Lowest Cost
3. Most lmplementable
4. Decentralised systems potsntlally more difficult to
operate and maintain
5. Least concentrated Impact on groundwater
6. Higher potential for human contact and health effects
vlth on-lot systems under malfunction conditions
7. Laast Impact on streets and yards In araas now served
by on-lot systems and on plant and animal co—unities
due to reduced pipeline conetruetlon
8. Small co—unity syatema vlth a vapor.-perk ponds
present potential Impact to groundwater
9. Reduced energy uaa.
* Cost If flow reduction measures are Implemented.
** Includes costs for on-lot systems.
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PART C. DRAFT EIS COMMENTS
Comments on the Draft Statement were received from the fol-
lowing:
Federal Agencies
U.S. Army Corps of Engineers, Environment and Resources Branch
U.S. Department of Agriculture, Soil Conservation Service
U.S. Department of Health and Human Services, Environmental
Health Services Division
U.S. Department of Housing and Urban Development
U.S. Department of the Air Force, Environmental Planning Division
U.S. Department of the Interior, Fish and Wildlife Service
State Government
Florida Department of Environmental Regulation, Bureau of
Wastewater Management and Grants, and Drinking Water Program
Local Government
City of Tallahassee
- Mayor (Hurley W. Rudd)
- 201 Program
- Tallahassee Water Quality Lab
Leon County Board of County Commissioners
Leon County Health Department
Interested Groups
Munson Area Preservation, Inc.
Tallahassee Board of Architects and Engineers
William M. Baldwin, P.E.
Tallahassee-Builders
Other
Falls Chase Special Taxing District
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FINAL ENVIRONMENTAL IMPACT STATEMENT
TALLAHASSEE - LEON COUNTY
TABLE OF CONTENTS
Page
EXECUTIVE SUMMARY i
PART A. DESCRIPTION OF RECOMMENDED ACTION i
PART B. SUMMARY OF ALTERNATIVES CONSIDERED ii
PART C. DRAFT EIS COMMENTS vi
I. INTRODUCTION 1-1
II. RECOMMENDED ACTION II-l
PART A. INTRODUCTION II-l
PART B. SELECTION OF THE RECOMMENDED ACTION II-l
PART C. MITIGATIVE MEASURES II-4
III. SUMMARY OF DRAFT EIS III-l
PART A. BACKGROUND OF STUDY III-1
PART B. ALTERNATIVES DEVELOPMENT AND EVALUATION III-2
PART C. DESCRIPTION OF THE RECOMMENDED ALTERNATIVE 111-13
PART D. DESCRIPTION OF THE STUDY AREA 111-17
PART E. ENVIRONMENTAL IMPACTS OF ALTERNATIVES 111-22
PART F. EIS COORDINATION 111-25
IV. REVISIONS TO THE DRAFT EIS AND ADDITIONAL
INFORMATION IV-1
V. COMMENTS ON THE DRAFT EIS AND EPA RESPONSES V-l
PART A. WRITTEN COMMENTS V-2
PART B. ORAL COMMENTS V-98
VI. COORDINATION WITH FEDERAL, STATE, REGIONAL, AND
LOCAL AGENCIES VI-1
VII. LIST OF PREPARERS VII-1
vii
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LIST OF TABLES
No. Title Page
I Summary of Alternatives Evaluation v
11.1 Failures and Mitigative Measures,
Septic Tank—Soil Absorption
Field Systems II-6
11.2 Failures and Mitigative Measures,
Extended Aeration—Evaporation -
Percolation Pond System II-7
111.1 Summary of Feasible System Combinations III-5
111.2 Summary of Alternatives Evaluation 111-15
111.3 Tallahassee-Leon County EIS Review
Committee 111-26
V.1 Recommended Rates of Wastewater
Application for Trench and Bed
Bottom Areas V-83
viii
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LIST OF FIGURES
No. Title
Page
II.1 Phase I Facilities II-2
111.1 Alternative System 1A III-8
111.2 Alternative System IB III-9
111.3 Alternative System 2 111-10
111.4 Alternative System 3 III-ll
111.5 Alternative System 4 111-14
V.1 On-Site System Layout V-82
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I. INTRODUCTION
This Final Environmental Impact Statement (FEIS) for Waste-
water Management in the City of Tallahassee and Leon County, Flo-
rida supplements the Draft EIS issued in September 1981. The EIS
has been prepared in accordance with the Council on Environmental
Quality (CEQ) Guidelines and EPA Guidelines for the preparation
of Environmental Impact Statements. This EIS is also in response
to the requirements of Public Law 91-190, the National Environ-
mental Policy Act of 1969, which requires the preparation of an
EIS for any major Federal action that will significantly affect
the quality of the environment. While this summary document is
intended to be comprehensive, the supporting information fur-
nished with the Draft EIS should be reviewed and is incorporated
here by reference. It is to be noted that this Final EIS super-
cedes the Draft EIS wherever conflicts between the two exist.
The Final EIS contains eight major sections. Section II,
Recommended Action, describes in detail the recommended action
and evaluation process that led to its selection. Section III
presents a summary of the Draft EIS, including a review of each
Chapter in the Draft EIS and major findings and recommendations.
Section IV presents any revisions and additional information
gathered after issuance of the Draft EIS in September 1981.
EPA's responses to comments received on the Draft EIS are tabu-
lated in Section V. The written comments, and the oral comments
received at the Public Hearing are indexed in this section. Sec-
tion V also contains the transcript of the Draft EIS Public
Hearing held on November 5, 1981. A coordination list is pre-
sented in Section VI and a list of preparers is presented in
Section VII.
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II. RECOMMENDED ACTION
PART A. INTRODUCTION
This EIS has addressed the Federal Action of the provision
of Federal funds for Phase II wastewater facilities as proposed
by the Draft 201 Facilities Plan for Tallahassee-Leon County.
The selected action for the Final EIS is that no further Federal
grants be made for expansion of the wastewater system beyond that
already approved under Phase I of the 201 Plan. The basis for
this decision is the determination that the Phase I facilities
already approved by EPA will serve all existing and some future
needs, and that new growth in wastewater generation can be han-
dled in an environmentally sound and cost effective manner by
on-site and small community systems.
PART B. SELECTION OF THE RECOMMENDED ACTION
No additional centralized treatment capacity is recommended
for construction. Areas within the existing City service area
can be served by 201 Plan Phase I construction: expansion of
T.P. Smith/Southwest facility to 17.5 mgd, expansion of South-
east sprayfield to 17.5 mgd, and construction of new 17.5 mgd
sludge handling facilities. It is projected by the year 2000 the
wastewater flow within the area presently served by the City will
approximate 17.5 mgd, without considering flow reduction
measures. It is expected that infilling will occur within the
existing City service area and that some additional collectors
are likely to be constructed by the City in order to serve this
infilling population. No additional interceptor sewers are
recommended. Facilities already approved by EPA, known as Phase
I of the 201 Plan Facilities are eligible for funding and most
them have already been funded. Phase I includes several lines in
the southwest which will connect the Municipal Airport treatment
plant to the T.P. Smith plant. Phase I facilities are shown in
Figure II.1.
Phase I also included interceptor sewers (J-Series) for the
Miginnis Arm area of Lake Jackson. However, these lines were
later added to the proposed facilities to be studied by the EIS.
This area is not recommended for conventional sewers as proposed
in the 201 plan. Alternative wastewater facilities such as
improved on-lot or small community systems, have been found to be
cost effective and environmentally sound.
One of the issues which resulted in the preparation of the
EIS is that wastewater flow projections in the 201 plan were
found to be excessive. The 201 Plan projects a wastewater flow
of 30.4 mgd by the year 2000. The EIS projects a wastewater flow
of 22.3 mgd by the year 2000 for the study area, a difference of
8.1 mgd. Further, should flow reduction measures be utilized,
the year 2000 flow would be 19.9 mgd, a difference of 10.5 mgd.
II-1
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LA&E
ijbtow*
TP SMITH AND SOUTHWEST
SEWAGE TREATMENT PLANT
APALACHICOLA
LEGEND
- EXISTING TRUNK LINES
- J-SERIES INTERCEPTORS
GRADY
COUNTY
¦ PHASE I EXCLUDING J-SERIES
— PROPOSED TRUNK LINES
EXISTING SEWAGE TREATMENT PLANT
EXISTING SPRAYFIELD SITE
F EXISTING EFFLUENT FORCE MAIN
J THOMAS COUNTY
LIBERTY
COUNTY
V, -4"
SOUTHEAST
SPRAYFIELD
WAKULLA
COUNTY
CITY OF TALLAHASSEE
LEON COUNTY, FLORIDA
PHASE I
201 FACILITIES
300 0 12,000 2^000
SCALE IN FEET
SOURCE OF BASE MAP: LEON COUNTY HIGHWAY MAP
FIGURE n.l
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The 4.8 mgd of flow (without flow reduction measures) above
the 17.5 mgd capacity of the T.P. Smith/Southwest facility is
projected to be generated mainly in the northeast and eastern
portions of the study area. The EIS has shown these areas to be
mostly suitable for the use of on-site and small community sys-
tems. This determination of suitability is based on soil types
and groundwater conditions.
Data on soils in the growth area support the use of on-site
systems. The Leon County Health Department indicates that
on-site systems operate properly when their construction follows
the basic rules governing their placement. The few failures of
on-site systems have occurred in the northeast growth area are a
result of poor siting and poor construction. This is confirmed
by personal communication with septic tank installers in the
area. In addition, a recent study conducted in Leon County, Flo-
rida, to develop soil potential ratings for septic tank
absorption fields rated most of the soils in the growth areas as
having medium to very high potential for septic tank
installation.
Future use of on-site systems in the eastern and northeast-
ern areas of Tallahassee should be fully acceptable. The few
future problems with on-site systems will predominantly be insti-
tutional problems in that pressure will be placed by developers
for less stringent rules governing on-site placement and siting,
and existing rules may not be followed. Most of those contacted
concerning potential septic tank problems said that one of the
most important future needs with respect to septic tank use is a
modification of the rules to address problems associated with the
increased use of garbage disposals and washing machines.
The EIS assessed the needs of the Meginnis Arm area near
Lake Jackson in detail. It was found that the area included some
malfunctioning on-lot systems. The soils in the area are gener-
ally suitable for on-lot systems. On-lot and small community
systems were found to be the most cost-effective wastewater sys-
tems for this and other areas of low density development. Also,
it should be noted that only a small percentage of this area
would be eligible for Federal funding of conventional sewers.
Another issue of the EIS is that the potential for future
development in Leon County is in the Northeast part of the
County. Concern was expressed that this development would have
adverse impacts on wetlands and streams in this area. The recom-
mended alternative will result in decreasing the potential for
nonpoint source pollution. In addition, the recent implementa-
tion of the Leon County Stormwater Management Ordinance will help
to mitigate the impacts on surface water quality. Also, the
impacts on wetlands and streams from the construction of inter-
ceptors, which would require ten stream crossings, would be
avoided.
The importance of groundwater quality in an area where
groundwater is the sole potable water supply is a most critical
consideration. The EIS shows no significant potential adverse
II-3
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impact to groundwater quality from the use of on-site systems and
small community sewers in the growth areas.
The use of septic tanks and community systems for the growth
areas and their impact on the down-gradient City water supply
wells are fully considered in making this recommendation. The
geological formations in northern Leon County, including the pro-
jected growth areas, provide adequate protection for the drinking
water (Floridan) aquifer. The Floridan Aquifer in this area is
covered by several hundred feet of soil and the Hawthorne Forma-
tion, which is a confining layer. The City's wells range in
depth from 294 to over 400 feet.
Operation and maintenance problems as well as siting and
construction inadequacies have been the cause of the few failures
of on-site systems in the growth areas. These are considered to
be institutional problems that can be overcome. In addition, the
use of small evaporation/percolation ponds, is considered to have
minimal potential for adverse impacts to groundwater when oper-
ated properly and in conjunction with groundwater monitoring.
Some aspects of the recommended plan may be eligible for
federal funding. They include the following:
1. The construction of on-site and small community
systems as innovative and alternative technologies
incumbent on the implementation of a public manage-
ment agency, such as is described in this document.
2. The facilities for the treatment and disposal of
the septage and sludge from on-site and small com-
munity systems incumbent on the implementation of a"
public management agency, such as described in this
document.
PART C. MITIGATIVE MEASURES
The success of the recommended action is chiefly dependent
on obtaining effective treatment from a large number of small
systems. In the development of specific mitigative measures it
is important to consider the potential causes of and the appro-
priate corrective actions in response to on-site and small commu-
nity system failures.
For this purpose two commonly used systems, one on-site and
one small community, were investigated. A septic tank followed
by a soil absorption field is a typical on-site treatment dis-
posal system. The septic tank removes nearly all settleable sol-
ids and floatable grease and scum. This partially treated
wastewater is applied to the soil absorption field where it is
absorbed and treated by the soil as it percolates. Travel
through two to four feet of unsaturated soil will provide ade-
quate removals of pathogenic organisms and other pollutants from
the wastewater. A commonly used small community system, espe-
II-4
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cially in areas where surface water discharge is not likely to be
permitted, is an extended aeration treatment system with disposal
to an evaporation-percolation pond. Extended aeration is a
biological treatment process which removes substantial amounts of
BOD and suspended solids that are not removed by simple sedimen-
tation. Evaporation-percolation ponds utilize the natural energy
of the sun and the natural purification capabilities of soil to
dispose of the treated effluent.
Both of these systems can be effective and environmentally
sound with proper siting, design, installation, operation and
maintenance. When failures do occur they usually fall into a few
general categories. Tables II.1 and II.2 contain, for each sys-
tem, an identification of the types of failures which may occur,
the environmental impacts of these failures, the possible causes
for these failures, and the corrective actions which would be
necessary to rehabilitate the system. In addition, measures are
identified which would mitigate the impacts of these failures.
The primary goals of the mitigative measures identified in
Tables II.1 and II.2 are to prevent, or lessen the chances of,
the occurrence of a failure and to increase the chances of early
detection and correction of any failures that do occur. The mit-
igative measures listed can be summarized by three principal rec-
ommendations :
1. Revision of basic rules governing septic tank use
to allow for systems more suited to current and
future demands. These revisions should include
siting criteria, basic system design, and the use
of alternative systems.
2. Monitoring of groundwater quality in the developing
areas of Leon County.
3. The implementation of a management district or oth-
er means of on-site and small community systems
management.
1. Regulations
Current regulations controlling the siting and design of
septic systems make it difficult to implement sufficient site or
design modification to compensate for less than optimum condi-
tions. State regulations do not allow installation of an on-site
system where percolation rates exceed 15 minutes per inch. Per-
colation rates as slow as 60 minutes per inch have been shown to
be effective because such percolation rates can be compensated
for with lower loading rates. In addition, allowances for a
slower percolation rate are recommended to help protect ground-
water from contamination and allow for site and design
modifications that are more flexible. Soils with high percola-
tion rates may not properly renovate the wastewater in standard
septic systems.
II-5
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TABLE II. 1
FAILURES AND MITIGATIVE MEASURES
SEPTIC TANK — SOIL ABSORPTION FIELD SYSTEM
Type of Failure
Overloaded absorption field;
septic tank effluent breaks
through ground surface
Environmental Impacts
. Potential for surface
water degradation from
runoff
. Odors
. Potential for human
contact and health
effects
Possible Causes
Field initially designed
too small
Substantial increase in
water usage
. Clogging by bacterial
mats and sludge; insuffi-
cient solids removal by
septic tank or septic tank
not being pumped as needed
Improper method of drain-
field installation
. Unsuitable soil conditions
or site characteristics
. Water table higher than anti-
cipated due to ungradient
development
Mitigative Measures
Implementation of a
management agency which
would be responsible
for:
-Proper siting, design
and installation of
systems
-An inspection and pre-
ventive maintenance
program
-Providing prompt at-
tention to problems
. Revision of regulations
to allow greater site
and design flexibility
Corrective Actions
Increase absorbtion
. Flow reduction measures
Eliminate clear water
discharges
. Oxidize clogging mat;
pump out and repair or
replace septic tank
. More frequent maintenance
. Dosing
. Modification of site or
system: regrading/
filling/alternate system
Insufficient renovation by
soil absorption field
I
C\
Transmission of minerals,
nutrients, bacteria
or viruses to ground-
water
Unsuitable soil conditions
or characteristics; poorly
structured, too rapidly
permeable soils provide in-
sufficient renovation
Unsuitable site; high ground-
water, or geological charac-
teristics provide direct
path to groundwater
Implementation of manage-
ment agency as described
above
Groundwater monitoring
to increase chances of
early detection
Revision of regulations
to allow greater site
and design flexibility
Modification of site or
system: filling/alter-
nate system
Intercept flow to ground-
water by subsurface
drainage
-------
TABLE II.2
FAILURES AND MITIGATIVE MEASURES
EXTENDED AERATION — EVAPORATION-PERCOLATION POND SYSTEM
Type of Failure
Mechanical failure; re-
duction of treatment
efficiency
Environmental Impacts
Odor
Potential for human con-
tact and health effects
from effluent in ponds
Possible Causes
Blower or mechanical aerator
failure
Pump and pipe clogging
Electrical motor failure
Corrosion and/or failure of
controls
Electical malfunctions
Mitigative Measures
Installation of alarm
system
Implementation of manage-
ment agency which would
be responsible for:
-Proper siting, design
and installation of
systems
-An inspection and pre-
ventive maintenance
program
-Stockpiling parts
-Providing prompt atten-
tion to problems
Corrective Actions
Repair or replace-
ment of malfunction-
ing parts
Hydraulic overload of
treatment system; re-
duction of treatment
efficiency
Odor
Potential for human
contact and health ef-
fects from effluent
in ponds
Heavy rainfall; problem could
be magnified by infiltration
problems
Treatment system undersized
Sludge not removed regularly
Conservative design
Installation of alarm
system
Implementation of manage-
ment agency as described
above
Correct infiltration
problems
Expansion or modifi-
cation of treatment
system
More frequent mainte-
nance
Hydraulic overload of
disposal system
Potential for surface
water degradation from
runoff
Clogging of percolation surface
Heavy rainfall
Pond undersized
Conservative design;
storage volume for wet
periods
System designed with dual
ponds or chambered single
pond; periodic resting
included in maintenance
program
Pond designed with well-
vegetated, steep walls to
prevent channels from
developing through the
walls
Implementation of manage-
ment agency as described
above
Rejuvenation of per-
colation surface
Expansion or modifi-
cation of disposal
system
Insufficient percolation
time from ponds
Potential for a build-
up of minerals and
nutrients in groundwater
Unsuitable soils or site
characteristics
Implementation of manage-
ment agency as described
above
Modify site or soils to
ensure sufficient perco-
lation prior to installa-
tion
Drain pond and modi-
fy infiltrative sur-
face to ensure suf-
ficient percolation
Groundwater monitoring to
ensure early detection
-------
Design flexibility to fit the septic system to site condi-
tions would allow creative solutions to specific problems. Pres-
ently, soil absorption beds are sized on the number of bedrooms
in the residential home instead of the ability of the soil to
absorb septic tank effluent. With siting and design flexibility,
installation that would not have worked on a particular site can
be avoided. Design flexibility would also allow the use of
alternative systems such as pressure dousing and split bed appli-
cation.
Additional flexibility for site selection can be obtained by
the U.S.D.A. Soil Texture Classification instead of the United
Classification system in regulations. The United Classification
system arranges soil types in large groups which tend to include
soils that can be useful for wastewater renovation with those
that are of limited use. In contrast, the U.S.D.A. Soil Texture
Classification System identifies the soils in more detail and
allows better use of soil types.
2. Groundwater Monitoring
Groundwater quality monitoring in developing areas of Leon
County, where on-site or small community systems will be used,
should begin before each subdivision is started. This will allow
background information to be developed as well as the identifica-
tion of the effects on groundwater from construction activity.
Continual monitoring throughout the construction and life of the
development will ensure that changes in groundwater quality are
quickly detected. With the location of monitoring wells .up and
down gradient of the groundwater movement and within the develop-
ment area, the impact to groundwater resources can be detected.
Should adverse conditions appear to be developing, corrective
actions, such as those shown in Tables II.1 and II.2 can be
taken.
3. Management District
Poor operation and maintenance of on-site and small communi-
ty systems is one cause leading to their failure. Public manage-
ment of these systems is a possible means of ensuring that
improper operation and maintenance does not contribute to system
failure. Although poor operation and maintenance is recognized
as one cause of septic system failure, regulatory agencies gener-
ally do not set standards or specific requirements to ensure
proper operation and maintenance. In general, the regulations
are applicable to the design and construction of septic systems
but leave the operation and maintenance responsibility to home-
owners.
Enforcement officials as well as researchers have identified
enforcement problems as the weak link that leads to ineffective
II-8
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management and malfunctioning systems,
following:
Such problems include the
1. Many agencies lack time and resources to control
on-site and small systems adequately.
2. Local authorities usually depend on the integrity
and ability of soil testers and contractors to
evaluate site and to design and install systems.
3. Local authorities are sometimes pressured into
approving the construction of septic systems on
poor or marginal soils.
To overcome these problems, a number of communities have
opted for public management of on-site and small community sys-
tems. Public entities must have the authority to control these
systems. Essential controls and the authority to enforce them
are:
Control Element
Authority Needed
Siting and Design
Installation
Operation and Maintenance
Problem Correction
To enter property and do in-
depth site evaluations.
To set design standards,
design systems, and review
designs.
To enter property to inspect
and ensure proper operation
and maintenance.
To require and enforce repair
or replacement of failing
systems.
A public management agency can also be responsible for
implementing certain measures which would further reduce the
chance of failure of on-site systems:
1. Initiate a project to analyze the causes of failure
based on historical data and analyze each new fail-
ure reported. Identify trends in local as well as
area-wide causes for failure. Use this information
to anticipate future problems and respond with pre-
ventive maintenance activities in high risk
neighborhoods.
2. Establish a public education program. Develop a
brochure for all homeowners using on-site systems
describing the proper use of their systems and
include it in their property tax bill or water
bill, etc.
II-9
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3. Establish a liaison with Tallahassee-Leon County
Planning Department. Ensure that zoning officials
are furnished maps of areas of known failure and
areas of high risk so that development densities in
these areas can be held to the level that physical
systems can sustain.
The types of entities capable of managing a decentralized
wastewater treatment system such as that which could develop
under the recommended action would depend on Florida rules and
regulations. Entities capable of managing decentralized waste-
water treatment systems include municipalities, counties, town-
ships, electric cooperatives, and special districts. With proper
authority, a public management entity can ensure the use of
on-site and small community systems as effective wastewater man-
agement tools in preventing water pollution and public health
problems.
11-10
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III. SUMMARY OF DRAFT EIS
PART A. BACKGROUND OF STUDY
In response to rapid growth in Leon County, wastewater
facilities planning studies were conducted in 1972 and 1973 to
determine how service could be expanded in a cost-effective and
environmentally sound manner. These studies identified a need
for additional facilities, the costs of which were believed too
high for the residents of the County and the City of Tallahassee
to bear alone. As a result, it was decided to apply for federal
grants to fund a majority of the facilities costs, and a 201
Facilities Plan was prepared by William M. Bishop Consulting
Engineers, Inc.
The draft Tallahassee-Leon County 201 Plan was approved in
April, 1977, by the City and County Commissions and received ini-
tial approval from the Florida DER and the EPA. EPA subsequently
decided to release Step II grants for only those facilities which
would relieve existing water quality problems. This decision was
made in part as a result of opposition from citizens and private
organizations to portions of the 201 Plan. It was further
decided that an EIS would be prepared on those portions of the
201 Plan which support future growth that may result in signif-
icant environmental impacts.
EPA has funded only those facilities which relieve existing
water quality problems under the first phase of 201 planning.
These facilities are:
PHASE 1
Completed and Operational
1. Upgrading of 2.5 mgd Southwest Treatment Plant
2. New Southwest Holding Pond and Pumping Station
3. New 22.5 mgd Southwest to Southeast Force Main
4. New 10.0 mgd Southeast Sprayfield, Holding Pond and
Pump Station
5. Expansion of Southeast Sprayfield to 17.5 mgd
Under Construction or Awaiting Construction
1. Expansion of T. P. Smith Plant to 15.0 mgd
2. Abandonment of the Dale Mabry Plant
III-l
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3. New 17.5 mgd Sludge Handling Facility
Those proposed facilities under the Phase 2 portion of the
201 Plan which are covered by this EIS are:
PHASE 2 (Subject to EIS Study)
1. New 5.0 mgd Northeast Plant
2. New 60,000-Linear-Foot Force Main to Southeast
Sprayfield from Northeast Plant
3. Expansion of 2,000-Acre Southwest Sprayfield
4. Expansion of T. P. Smith Plant Beyond 15.0 mgd
5. Additional Interceptors to Growth Areas
The EIS was initiated because of the following issues raised
by organizations and individual citizens:
1. Public health risks may be associated with land
application of wastewater.
2. Wastewater flow projections may be too high.
3. Potential detrimental impacts to wetlands may
result from development in northeast Leon County.
4. Northeast treatment plant may be incompatible with'
residential use of the area.
5. The construction, operation, and maintenance of the
Northeast plant force main to the Southeast spray-
field may have detrimental impacts on wetlands and
the dam at Lake Lafayette.
6. The renovation of the Lake Bradford plant may' be
more cost- effective than closing it.
7. Any of the alternatives may have potential impacts
on the habitats of threatened and endangered flora
and fauna.
PART B. ALTERNATIVES DEVELOPMENT AND EVALUATION
Alternatives development and evaluation must be based on a
ronsideration of the existing wastewater management system in
Leon County. There are five municipal wastewater treatment
nlants in the study area, all of which are owned by the City of
Tallahassee. Besides these public facilities, there are eighteen
nrivately-owned wastewater treatment plants scattered through the
study area. In addition, subsurface on-lot treatment and dis-
III-2
-------
posal is used extensively by individuals and commercial
establishments in all areas not served by municipal wastewater
facilities.
The City of Tallahassee wastewater collection and treatment
system serves approximately a 60-square mile area with a popu-
lation approaching 90,000. Wastewater is conveyed by approxi-
mately 430 miles of sewer lines, both gravity and force mains, to
the various treatment plants.
The results of a flow monitoring program undertaken by the
EIS consultants revealed that, for the most part, the existing
wastewater collection system has sufficient capacity to serve its
immediate and some future needs. Construction programs are
already underway to relieve constraints in the area just south of
Meginnis Arm and neighborhoods north of Centerville Road and east
of Meridian Road.
Infiltration/inflow (I/I) is not considered excessive in the
study area and, therefore, it is more economical for the City to
treat I/I than to rehabilitate the the sewer system.
The Thomas P. Smith plant is a 7.5 mgd activated sludge
facility which, because of its size and location, receives waste-
water from much of the study area. This plant operates in paral-
lel with the 2.5 mgd high-rate trickling filter Southwest Plant
located on the same site. Since the recent start-up of the 201
Plan Phase-1 Southeast sprayfield facility, treated effluent from
both plants is either sprayed onto this site or sprayed onto 120
acres of land surrounding the treatment facility. Sludge dis-
posal is by landspreading on City-owned lands adjacent to the
airport. Plant performance data from 1978 indicated good treat-
ment efficiency and a high quality effluent. Expansion of the
Thomas P. Smith plant to a capacity of 15.0 mgd is under way.
Planned under the EPA approved 201 Plan, Phase I is a new 17.5
mgd sludge handling facility. This facility calls for a sludge
dewatering and land filling system.
The Lake Bradford plant, a 4.5 mgd activated sludge
facility, treats wastewater generated from the central core of
Tallahassee including institutional flow from both the Florida
State University and Florida A & M as well as from the state gov-
ernment complex. Any flow in excess of 4.5 mgd is diverted to
the Thomas P. Smith/Southwest treatment facility. Sludge dis-
posal is by landspreading on City-owned lands adjacent to the
airport. 1978 plant performance data indicate that the plant is
well operated and maintained and produces a high quality
effluent.
The 0.9 mgd Dale Mabry plant is a trickling filter-activated
sludge facility built in 1940. The City of Tallahassee will
abandon the Dale Mabry plant when the expansion of the Thomas P.
Smith plant is completed.
Ill-3
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The Municipal Airport facility is a small package plant with
a design capacity of 60,000 gpd serving the needs of the Talla-
hassee Municipal Airport.
There are 18 private wastewater systems located in the study
area. Most of these treatment plants discharge to surface water
while the remainder employ discharge to the atmosphere or ground-
water via evaporation — percolation ponds and spray irrigation
systems.
In areas not served by municipal sewer facilities, individ-
ual homes and businesses rely on some method of subsurface
on-site treatment and disposal. Major areas utilizing on-site
systems include the more recently developing areas in northeast-
ern Leon County. Septic tank system failures have been docu-
mented by the Leon County Health Department in the area
surrounding Meginnis Arm of Lake Jackson.
The development of alternatives for wastewater treatment in
Leon County was accomplished in two phases. The first consisted
of developing alternative wastewater service area configurations.
A service area configuration is a distinct plan for providing
wastewater treatment and disposal services to each designated
service area either by local treatment/disposal or by regional
treatment/disposal of two or more service areas. It does not
include options for actual treatment and disposal methods but
rather delineates locations and flows.
The second phase of alternatives development involved
screening available wastewater treatment/disposal techniques for
applicability within Leon County. This generated a list of
options for wastewater treatment, effluent disposal, and sludge
disposal for each of the service area configurations.
The result of the alternatives development process, as
illustrated in Table III.l, was a few wastewater management
alternatives, each with several treatment/disposal combinations.
In order to quantify costs, environmental impacts and other eval-
uation factors for comparison of alternatives, it was necessary
to go one step further. The first step of the evaluation
process, therefore, was to select preferred treatment/disposal
options for each wastewater management alternative.
Preferred treatment options were selected primarily so costs
for each federal action alternative could be specified. Pre-
ferred options are the same for each proposed treatment"plant.
While these decisions are basically engineering judgments, they
are not meant to dictate to the study area which options would be
federally funded and which would not. The options were selected
which reflect the least environmentally sensitive and most eco-
nomically and technically sound implementation schemes.
Secondary treatment of wastewater is the minimum level of treat-
ment allowable for land application by the Florida DER within the
study area. Advanced wastewater treatment is not considered nec-
essary for the study area. A final selection of a preferred
secondary treatment option would need to include bench-scale
III-4
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TABLE III. 1
SUM4ARY OF FEASIBLE SYSTEM COMBINATIONS
Alternative
System
Service
Areas
Capacity Effluent Effluent Sludge Sludge
Plant (mgd) Treatment Disposal Disposal Disposal Disposal
Location w/o FRM w/ FRM Technique Options Sites Options Sites
SN/SE
TPS/SW
AS
RBC
SK
RI
SE
SW
NE(A)
SE(B)
LF
LS
C
I
LF
LS
C
I
Adj. to
Plant, Air-
port
Adj. to
Plant, Air-
port
SW/SE/NE
TPS/SW
and
LBP
SE
SN
LF
LS
C
1
Adj. to
Plant. Air-
port
TPS/SW
SE/NE
1.0 AS
RBC
SE
SW
LF
LS
C
I
LF
LS
C
I
Adj. to
Plant, Air-
port
Adj. to
Plant, Air-
port
4 or
No Federal
Action Al-
ternative
Growth Portions
of
Study Area
TPS/ Si*
17.5 17.5 AS
NA ST/SC
Adj. to
Plant
Abreviation: SW ¦ Southwest
NE ¦ Northeast
SE ¦ Southeast
FRM
Plow Reduction
Measures
TPS/SW ¦ T.P. Smith/Southwest Treatment Facility
LBP ¦ Lake Bradford Treatment Plant
NA ¦ Not Applicable
AS • Activated sludge
RBC - Rotating Biological Contactor
ST/SC ¦ Septic Tank/Small Comunity Systems
SA • Soil Absorption
tended for use under this alternative system
SR ¦ Slow Rate
RI • Rapid Infiltration
LF ¦ Landfllling
LS • Landspreading
C ¦ Composting
I ¦ Incineration
* La)ie Bradford Plant is reca
*" Infilling population that is expected to take place within the existing service aroa boundaries is expected to generate 17.5 mgd of wastewater.
ui-5
-------
tests of all secondary treatment options with local wastes. Sim-
ilar bench-scale tests would be needed before selection of
preferred sludge treatment processes can be finalized. Activated
sludge is the preferred treatment option; anaerobic digestion
followed by lime treatment is the preferred sludge stabilization
option; and chemical conditioning followed by vacuum filtration
is the preferred sludge conditioning and dewatering option.
Disposal options are subject to more qualitative judgment
and debate than treatment options primarily because their envi-
ronmental impacts are not readily quantifiable. The only waste-
water disposal options which were evaluated in detail were land
application options. Surface water discharges and other disposal
options were eliminated from consideration during the Alterna-
tives Development stage of this EIS as inappropriate for use in
the study area due to cost, environmental or technical reasons.
Slow-rate land application is the selected option for all areas
except the Northeast where the availability of suitable sites and
higher land costs favor rapid infiltration.
The favored option for sludge disposal at any suitable
location in the study area after preliminary evaluation is land-
spreading. The option would supplement the planned 17.5-mgd
sludge dewatering and landfilling system already approved for
funding by the EPA. Preliminary evaluations including costs for
incineration and composting operations favor the options of land-
spreading or landfilling. Somewhat lower costs for landspreading
combined with the fact that metals and nutrients would be spread
over a larger area and recycled by using disposal areas for crop
production favor the landspreading option.
For sludge transport, pipelines do not allow the flexibility
needed if sludge disposal sites are relocated. Costs are also
higher than for other transporting methods. The choice between
hauling sludge by tank or by truck is inconsequential to this
EIS.
Incorporated into each of the alternative systems are the
actions under Phase 1 of the 201 Plan facility expansions which
include: expanded capacity of 17.5 mgd at the T.P.
Smith/Southwest Treatment Facility; expansion of the Southeast
Spray Facility to a capacity of 17.5 mgd; and construction of a
new 17.5 mgd sludge handling and disposal system.
The alternative wastewater management systems developed and
evaluated for the study area are described as follows:
1. Alternative System 1
Under this alternative a new treatment plant would be con-
structed in the Northeast, and the T.P. Smith/Southwest treat-
ment facility would be expanded beyond its Phase I capacity of
17.5 mgd. A Northeast treatment plant would provide wastewater
service in the northeastern growth areas of Leon County. Inter-
III-6
-------
ceptor sewers would also be extended to developed portions of the
Northeast presently served by on-site and small community
systems. The expanded T.P. Smith/Southwest plant would serve the
Southwest and Southeast service areas. In Alternative 1A, eff-
luent from the T.P. Smith/Southwest plant would be disposed of at
the expanded Southeast Sprayfield, with the Northeast Plant eff-
luent disposed by means of rapid infiltration at a Northeast dis-
posal site. Alternative 1A is shown in Figure III.l.
Alternative IB, shown in Figure III.2, is the same as 1A except
the Northeast plant effluent is disposed of by conveying the
treated wastewater to the expanded Southeast Sprayfield. Sludge
disposal beyond the capacity of the 201 Plan Phase I landfill
facility would be by landspreading on sites adjacent to the
treatment plant in the Southwest and Northeast or by continuing
to landspread at the Airport site.
2. Alternative System 2
The structural configuration of this alternative hinges on
the decision whether or not to implement flow reduction measures.
The importance of flow reduction measures is based on the judg-
ment to continue operating the Lake Bradford plant if a flow
capacity greater than 4.2 mgd was needed in the service area.
This occurs when flow reduction measures are not implemented.
From the cost analysis described previously it has been deter-
mined that continuing to operate the Lake Bradford plant at
4.5-mgd, and expanding T. P. Smith/Southwest 0.3 mgd is more cost
effective than expanding the T. P. Smith/Southwest by 4.8 mgd.
With flow reduction measures, an expanded T.P. Smith/Southwest
Treatment Facility would serve the entire sewered area as a
regional treatment plant with a 19.9 mgd capacity. This alterna-
tive is illustrated in Figure III.3. Wastewater and sludge
disposal would be carried out as in Alternative 1, with treated
wastewater disposed at an expanded Southeast Sprayfield, and
sludge disposal from T.P. Smith/Southwest plant beyond Phase I
capacity of 17.5 mgd occurring either by landspreading adjacent
to the T.P. Smith Plant or landspreading at the Airport.
3. Alternative System 3
Under this alternative a Southeast treatment plant would be
constructed to supplement the treatment capacity of the expanded
T. P. Smith/Southwest facility. The Southeast plant would serve
the growth areas of the Southeast and Northeast. The T.P.
Smith/Southwest plant would provide wastewater service to pro-
jected growth areas in the Southwest and to the existing service
area. Figure III.4 illustrates this alternative. For the T. P.
Smith/Southwest facility, the Phase I expansion to 17.5 mgd would
provide 0.4 mgd additional capacity beyond year 2000 requirements
if flow reduction measures are implemented. Without such meas-
ures, the T.P. Smith/Southwest plant would require an increase of
1.4 mgd capacity in addition to the Phase I expansion. Waste-
III-7
-------
LEGEND
- EXISTING TRUNK LINES
• PROPOSED TRUNK LINES
GRADY
COUNTY
COUNTY
— SERVICE AREA BOUNDARY
¦ EXISTING SEWAGE TREATMENT PLANT
A PROPOSED SEWAGE TREATMENT PLANT
j 1 EXISTING SPRAYFIELD SITE
"WMh POTENTIAL SPRAYFIELD SITE
F EXISTING EFFLUENT FORCE MAIN
LIBERTY
COUNTY
WAKULLA
COUNTY
SOURCE OF BASE MAP LEON COUNTY HIGHWAY MAP
CITY OF TALLAHASSEE
LEON COUNTY, FLORIDA
ALTERNATIVE
SYSTEM IA
12,000 0 12,000 24000
SCALE IN FEET
GANNETT FLEMING CORDDRY AND CARPENTER, INC
HARRIS BURG , PENNSYLVANIA
FIGURE JR
-------
~
EO
LEGEND
- EXISTING TRUNK LINES
- PROPOSED TRUNK LINES
• SERVICE AREA BOUNDARY
EXISTING SEWAGE TREATMENT PLANT
PROPOSED SEWAGE TREATMENT PLANT
EXISTING SPRAYFIELD SITE
POTENTIAL SPRAYFIELD SITE
- EXISTING EFFLUENT FORCE MAIN
- PROPOSED EFFLUENT FORCE MAIN
THOMAS COUNTY
WAKULLA
COUNTY
SOURCE OF BASE MAP LEON COUNTY HIGHWAY MAP
CITY OF TALLAHASSEE
LEON COUNTY, FLORIDA
ALTERNATIVE
SYSTEM IB
SCALE IN FEET
GANNETT FLEMING CORDDRY AND CARPENTER, INC
HARRISBURG, PENNSYLVANIA
FIGUREHI . 2
-------
LEGEND
——- EXISTING TRUNK LINES
PROPOSED TRUNK LINES
¦ EXISTING SEWAGE TREATMENT PLANT
I 1 EXISTING SPRAYFIELD SITE
POTENTIAL SPRAYFIELD SITE
F EXISTING EFFLUENT FORCE MAIN
COUNTY
LIBERTY
COUNTY
WAKULLA
COUNTY
CITY OF TALLAHASSEE
LEON COUNTY, FLORIDA
ALTERNATIVE
SYSTEM 2
12,000 24,000
SOURCE OF BASE MAP- LEON COUNTY HIGHWAY MAP
SCALE IN FEET
GANNETT FLEMING CORDDRY AND CARPENTER, INC
HARRISBURG , PENNSYLVANIA
FIGURE HI. 3
-------
¦
~
LEGEND
— EXISTING TRUNK LINES
— PROPOSED TRUNK LINES
— SERVICE AREA BOUNDARY
EXISTING SEWAGE TREATMENT PLANT
PROPOSED SEWAGE TREATMENT PLANT
EXISTING SPRAYFIELD SITE
POTENTIAL SPRAYFIELD SITE
— EXISTING EFFLUENT FORCE MAIN
LIBERTY
COUNTY
WAKULLA
SOURCE OF BASE MAP LEON COUNTY HIGHWAY MAP
GRADY
COUNTY
J THOMAS COUNTY
COUNTY
CITY OF TALLAHASSEE
LEON COUNTY, FLORIDA
ALTERNATIVE
SYSTEM 3
12,000 24,000
SCALE IN FEET
GANNETT FLEMING CORDDRY AND CARPENTER, INC
HARRISBURG, PENNSYLVANIA
FIGURE HI.4
-------
water effluent would be disposed at the expanded Southeast
Sprayfield. Sludge disposal beyond the capacity of the 201 Plan
Phase I landfill facility is anticipated to take place either by
landspreading adjacent to the proposed treatment plants in the
Southwest and Southeast or by landspreading at the Airport site.
4. Alternative System 4 (No-Federal Action Alternative)
The No-Federal-Action Alternative represents how existing
conditions would be altered in the future by local development
pressures in the absence of federal investment. Analysis of the
No-Federal-Action Alternative shows continued growth in the area
if publicly-owned and funded sewage treatment facilities are not
constructed. This growth would take place in response to previ-
ously committed investments and continuing pressures for new
residential construction that would be accommodated in large part
either by hook up to existing system, individual on-site treat-
ment systems, or by privately-owned package plants. Thus,
"no-federal-action" does not imply "no growth". The major dif-
ferences between the no-federal-action alternative and any of the
structural alternatives will be the density of development, the
viability of some of the private real estate developments in the
area, and the total and individual costs of wastewater
management. Differences in impacts on the natural environment
can also be expected under the funding and no-federal-funding
alternatives.
It is difficult to predict the changes in development pat-
terns that might occur if no federal grants are used to support
wastewater facilities construction. The following assumptions
will, however, help define the development framework sufficiently
to permit an analysis of costs and impacts associated with the
No-Federal-Action Alternative:
1. The City will not independently finance treatment or
disposal capacity beyond the 17.5-mgd capacity of the
201 Plan Phase I facilities currently authorized for
Federal participation.
2. The Dale Mabry facility will be closed.
3. The City would construct interceptors in selected unsew-
ered areas until they reach the capacity limitation of
the T.P. Smith/Southwest facility.
4. Areas not served by the City would remain or be devel-
oped with on-site or small community disposal systems
depending upon the suitability of the area. Development
densities will be limited to three units per acre.
Under these assumptions, development pressure is expected to
be greatest inside the City's existing service area. Therefore,
infilling or redevelopment of depressed areas ^ in the City can be
expected to take place during the planning period. Based on pop-
III-12
-------
ulation forecasts developed by the Tallahassee - Leon County
Planning Department, growth in the existing service area will add
approximately 45,000 residents and 35,000 employees to the City's
collection system resulting in an additional 5 mgd of wastewater
reaching the T.P. Smith/Southwest facility.
An analysis was undertaken to determine currently undevel-
oped and developed lands and to delineate those areas which could
be served by:
1. On-lot disposal systems
2. Tap-ons to the existing centralized sewer system
The analysis used a series of maps and overlays incorporating
information about land use classes, flood hazard areas, soils
suitable for on-lot systems, depth to water table, sewer system
area boundaries, and trunk line service area boundaries.
The results of this analysis indicate that the excess capac-
ity in the existing sewer system appears to be adequate to serve
future infilling population. Constraints in areas just south of
Meginnis Arm and neighborhoods north of Centerville Road and east
of Meridian Road will be relieved by a construction program cur-
rently underway. This construction is being funded totally at
the expense of the City. Alternative 4 is illustrated on Figure
III.5.
Each of the alternatives described in this section was eval-
uated with respect to cost, environmental impacts, technical fea-
sibility, and implementability. Table III.2 contains a summary
of the evaluation of alternatives.
PART C. DESCRIPTION OF THE RECOMMENDED ALTERNATIVE
EPA selected Alternative 4 (No-Federal Action) to be the
recommended alternative as the proposed action for the draft EIS.
The EIS failed to demonstrate a justified need for the 201 Plan's
Phase II facilities represented by the structural alternatives.
The remainder of the Phase I facilities which have been approved
by EPA will serve all existing and some future needs.
As discussed in Section B, no additional centralized treat-
ment capacity is proposed for construction in Alternative 4.
Areas within the existing City service area will be served by
201's Plan's Phase I construction: expansion of T.P. Smith
/Southwest facility to 17.5 mgd, expansion of Southeast* spray-
field to 17.5 mgd, and construction of new 17.5 mgd sludge
handling facilities. It is projected by the year 2000 the waste-
water flow within the area presently served by the City will
approximate 17.5 mgd, without considering flow reduction
measures. Some construction of additional collectors is expected
in order to connect the infilling population within the City's
existing system.
Ill-13
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LEGEND
—EXISTING TRUNK LINES
PROPOSED TRUNK LINES
¦ EXISTING SEWAGE TREATMENT PLANT
m'SMl EXISTING SPRAY FIELD SITE
F EXISTING EFFLUENT FORCE MAIN
COUNTY
WAKULLA
COUNTY
CITY OF TALLAHASSEE
LEON COUNTY, FLORIDA
ALTERNATIVE
SYSTEM 4
12,000 24,000
SCALE IN FEET
SOURCE OF BASE MAP: LEON COUNTY HIGHWAY MAP
FIGURE m.5
-------
TABLE III. 2
SUMMARY OF ALTERNATIVES EVALUATION
Alternatives Description of Alternative*
1A T.P. Snlth/SW plants to serve
SW A SE with disposal at SE
spray field. NE plant to
serve NE with disposal In NE
Sane as 1 above except NE plant
effluent dlapoaal at SE spray-
f laid
T.P. Smith/SW plant* 4 Lake
Bradford plant, If nssded, sarve
as regional plants with dis-
posal at SE sprayfiald
T.P. Smith/SW plants to aerve
SW and SE. NE served by SE
plant. All disposal at SE
•prayf1*14.
T.P. S»lth/8V plane* to mw
existing city service area.
Growth irui outs Ids ssrvice
area airvid by on~eite of saall
rolty systems
Total Present
Worth ($x!0 )
$38.4
(29.4)*
$52.7
(46.0)*
931.5
(27.6)*
940.0
(34.3)*
910.4**
(5.98)*
Impacts
1. Development flexibility In density and location
2. 24.3 million greather than lowest cost alternative
3. Coat to homeowners from tap-on fees and sewer use
fees.
4. Construction lmpacta on aurface waters and plant and
animal resources
5. NE plant considered incompatible with existing land
uaes by area realdents
6. City's drinking water wella down gradient of
proposed rapid infiltration site
7. Increased potential for nonpolnt source pollution due
to increaaed Impervious surfacea from higher density
development and opportunity to develop flood plains,
wetlanda and high groundwater areas.
1. Development flexibility in denalty and location
2. Highest cost structural alternative
3. Less Impact on groundwater than 1A
4. Cost to homeowner from tap-on fees and sewer use fees
5. Alternative most desired by the City
6. Construction Impacts on surface water, and plant and
animal resources
7. Increased potential for non-point source pollution
due to lncrsaaed impervious surfaces from higher
density development and opportunity to develop flood-
plains, wetlands and high groundwater areas
8. Added construction lmpacta from transmission line to
SE sprayfield
1. Development flexibility in denalty and location
2. Cost to homeowner from tap-on fees and aewer use fees
3. 21.1 million greater than lowest coat alternative
4. Construction Impacts on surface water and plant and
animal resources
5. Maximum uae of existing facilities
6. Increaaed potential for nonpolnt aource pollution
due to lncrsaaed impervious surfacea from higher
dsnslty development and opportunity to develop flood-
plains. wetlands and high groundwater areaa.
7. Makes full uae of already constructed force main to
SE eprayfield
8. Long Interceptors potentially causing anaerobic
conditions and treatment problems
1. Development flexibility in denalty and location
2. 29.6 Billion greater than lowest coat alternative
3. Avoids public acceptance probleaa of ME plant
4. Coat to homeowner from tap-on fees and aewer uae faea
5. Construction lmpacta on surface water, and plant and
animal resourcee
6. Increaaed potential for nonpolnt source pollution due
to increaaed impervious surfaces from higher denelty
development and opportunity to develop floodplalna,
wetlanda* and high groundwater areaa
7. Long interceptors causing anaerobic condltlona and
treatment probleaa
1. Does not proaote development of marginal lands (flood-
plains, wetlands, high groundwater areaa)
2. Lowest Cost
3. Most lapleaentabls
4. Decentralised syateas potentially more difficult to
operate and maintain
5. Least concentrated impact on groundwater
6. Hither potential for human contact and health effects
with on-lot ayateaa under malfunction conditions
7. Least iapact on streets and yards in areaa now served
by on-lot systeas and on plane and an las1 csaaunltlea
due to reduced pipeline construction
6. Small community systems with svapor*-p«rk ponds
present potential iapact to groundwater
9. Reduced enargy uae.
* Co.t if flow reduction '¦fl***""'1'
** Includee coeta for on-lot ejreteas.
HI-IS
-------
The following measures are recommended to minimize the
chance of the occurrence of a failure and to promote correction
of any failures that may occur:
1. Revision of basic rules governing septic tank use to
allow for systems more suited to current and future
demands. These revisions should include siting
criteria, basic system design, and the use of alterna-
tive systems.
2. Monitoring of groundwater quality in the developing
areas of Leon County.
3. The implementation of a management district or other
means of on-site and small community systems management.
1. Regulations
Current regulations controlling the siting and design of
septic systems make it difficult to implement sufficient site or
design modification to compensate for less than optimum condi-
tions. State regulations do not allow installation of an on-site
system where percolation rates exceed 15 minutes per inch. Per-
colation rates as slow as 60 minutes per inch have been shown to
be effective because such percolation rates can be compensated
for with lower loading rates. In addition, allowances for a
slower percolation rate are recommended to help protect ground-
water from contamination and allow for site and design
modifications that are more flexible. Soils with high percola-
tion rates may not properly renovate the wastewater in standard
septic systems.
Design flexibility to fit the septic system to site condi-
tions would allow creative solutions to specific problems.
Design flexibility would also allow the use of alternative sys-
tems such as pressure dousing and split bed application.
2. Groundwater Monitoring
Groundwater quality monitoring in developing areas of Leon
County, where on-site or small community systems would be used,
could begin before each subdivision is started. This would allow
background information to be developed as well as the identifica-
tion of the effects on groundwater from construction activity.
Continual monitoring throughout the construction and life of the
development would ensure that groundwater quality is fully known.
With the location of monitoring wells up and down gradient of the
groundwater movement and within the development area, the impact
to groundwater resources can be detected. Should adverse condi-
tions appear to be developing, corrective actions such as those
described in Chapter III, Part C of the Draft EIS can be taken.
Ill-16
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3. Management Districts
Poor operation and maintenance (O&M) of on-site and small
community systems can be one cause of failure. Public management
of these systems is a possible means of ensuring that improper
operation and maintenance does not contribute to system failure.
Although poor operation and maintenance is recognized as one
cause of septic system failure, regulatory agencies generally do
not set standards or specific requirements to ensure proper oper-
ation and maintenance. In general, the regulations are
applicable to the design and construction of septic systems but
leave the operation and maintenance responsibility to homeowners.
To minimize O&M causing problems, a number of communities
have opted for public management of on-site and small community
systems. These public entities accepted the authority to control
these systems. These on-site management agencies exercise con-
trol and enforcement authority in the areas of siting and design,
installation, operation and maintenance and problem correction.
The types of entities capable of managing decentralized
wastewater treatment systems such as that which could develop
.mder the No-Federal-Action Alternative would depend on Florida
rules and regulations. Entities capable of managing decentral-
ized wastewater treatment systems include municipalities, coun-
ties, townships, electric cooperatives, and special taxing
iistricts. With proper authority, a public management entity can
snsure the use of on-site and small community systems as effec-
tive wastewater management tools in preventing water pollution
and public health problems.
PART D. DESCRIPTION OF THE STUDY AREA
Leon County is located in northwestern Florida. The only
Incorporated city within the study area, Tallahassee, serves as
50th state capital and county seat. The majority of the County's
>opulation is concentrated within Tallahassee and its immediate
jnvirons. Most new urbanization has occurred north and east of
:he City. The remaining land area is comprised of natural and
>lanted woodlands and swamps and contains scattered residential
levelopment.
This Environmental Impact Statement has been prepared to
iddress the provision of wastewater management facilities for
jeon County. It is necessary to document the existing natural
md man-made environments so that an assessment of the primary
ind secondary impacts of alternative actions can be made and mit-
.gative measures for each alternative can be recommended.
Ill-17
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1. Existing Natural Environment
Leon County is located 20 miles from the Gulf of Mexico and
has a mild and moist climate that is characteristic of the Gulf
States. The average year-round temperature in Tallahassee is
68° F (20° C) and has varied between 65° F (18.3° C) and 71° F
(21.6° C). The average yearly rainfall is about 61 inches
(154.9 cm) with variations from as low as 30.98 inches (78.7 cm)
to 104.18 inches (264.6 cm). Prevailing winds average 7.7 miles
per hour. They are from a southerly direction in the spring and
summer and shift toward a more northerly direction near the end
of the year.
No major odor producers are identified within the boundaries
of the EIS study area. A few potential sources of odor, such as
sewage treatment plants and light industry exist, but these are
apparently under control. According to the Florida Department of
Environmental Regulation (FDER), no major violations of ambient
air quality standards have been reported recently, and air quali-
ty in the study area has been good. The primary noise generators
in the study area are the Tallahassee Municipal Airport, railroad
corridors, and Interstate 10, U.S. 319, U.S. 90, and U.S. 27.
Three major physiographic divisions are recognized in Leon
County: 1) the Northern Highlands, 2) the Gulf Coastal Lowlands,
and 3) The River Valley Lowlands. Development in the study area
has taken place mainly in the Northern Highlands, which is pro-
jected as the major future growth area, and to a lesser degree in
the Gulf Coastal Lowlands. Subsurface geological formations in
the study area include the Miccosukee and the Hawthorn Formations
in northern Leon County, the St. Marks Formation and Sewanee
Limestone in southeast Leon County, and the Jackson Bluff Forma-
tion in southwest Leon County.
About 25 percent of the land in the study area has slopes
between one and four percent. The remainder of the County has
slopes exceeding four percent in areas characterized by gently
rolling topography. Slopes may exceed 10 to 15 percent in some
areas along drainage ways.
The soils in the Tallahassee area and northeastern Leon
County are generally well-drained, loamy sand to sandy loams. In
southern and southeastern Leon County, the soils are well to
excessively drained. In southwestern Leon County, the soils are
nearly level, somewhat poorly drained sands overlying thick beds
of elastics.
Five bodies of water in the study area can be considered
large lakes: Iamonia, Jackson, Lafayette, Miccosukee and
Talquin. Each lake occupies an ancient stream valley in the Tal-
lahassee Red Hills and has a direct flow connection with the
limestone aquifer via one or more sinkholes. This allows the
water level of the lakes to fluctuate greatly even to the point
III-18
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in varying diversity and density of plants and animals in the
area surrounding the lakes.
There are two major rivers associated with Leon County, the
Ochlocknee which forms the western border of the County and the
St. Marks found in the southeastern portion of the County. Leon
County has many relatively permanent lakes and ponds that are
smaller than the five large lakes. Some of these are Moon Lake,
Silver Lake, Eagle Lake, Lake Munson, Orchard Pond, Lake
Bradford, the Cascades, Dog Pond, Dog Lake, Lake Hall, and Lake
Ella. In the Woodville Karst Plain there exist a number of open
sink ponds, some examples being Gopher Sink and Dismal Sink. As
a result of isolation from one another, these ponds formed their
own unique ecosystems. Many small bodies of water in Leon County
are called ephemeral ponds because they tend to dry up.
Leon County has only a few marshes confined to the edges of
the larger lakes. Branch or creek swamps in this region occur
along fourth or fifth order tributaries. River swamps occur
along the St. Marks and Ochlokonee Rivers in rich broadleaf
woodlands that periodically become inundated by high river
waters.
The groundwater reservoir in Leon County consists of a
sequence of limestones and dolomites. The saturated portion of
the overlying sands, clays, and silts is also utilized in some
localities. The limestone and dolomite section is named the Flo-
ridan Aquifer and is the principle source of groundwater in Leon
County. The overlying sands, silts, and clays comprise the Flor-
idan Aquiclude and confine the water in the Floridan Aquifer
under artesian pressure. Some beds in the Floridan Aquiclude
yield small supplies of groundwater and are called water table
aquifers.
The majority of the water obtained from wells in the Talla-
hassee area is of good quality without color, odor, or objection-
able taste and relatively low in dissolved solids and hardness.
The only parameter which shows a few high readings is iron.
Chlorination is the only treatment process required prior to dis-
tribution.
Aquatic systems in the Tallahassee area can be categorized
as two types: lentic (standing water systems) which include
ponds, lakes and swamps, and loxic (flowing water systems) and
pond systems are the predominant aquatic type within the Talla-
hassee area.
In the Environmental Monitoring Program (EMP) of the Talla-
hassee-Leon County EIS, aquatic faunal and floral components were
studied with the purpose of defining existing water quality con-
ditions within the study area. These studies indicate that the
aquatic systems of the study area are currently suffering from
degraded water quality. While the problems are widespread, there
are indications that there is a direct relationship to nqn-point
and point pollution sources. The Lake Munson system seems to be
in the worst condition. Major contributing factors to these
III-19
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problems are most likely urban runoff and effluent discharges
from wastewater treatment plants.
The classification of the terrestrial vegetation has devel-
oped through a series of studies to a detailed mapping effort.
The 201 Study (1), 208 Study (City of Tallahassee, 1977) (1), 208
Study (Tallahassee-Leon County Planning Department 1978) (2), and
the EIS Environmental Monitoring Program-Segment II (EPA 1980)
activities have all addressed vegetation.
The EIS field investigations of potential sprayfield areas
were under taken with several goals in mind: 1) to provide
detailed descriptions of vegetation communities by quantitative
sampling; 2) to field truth vegetation maps and aerial photos; 3)
to make observations concerning the presence of protected species
or their potential habitats; and 4) to compare ecological fea-
tures of potential sprayfield sites. The field investigations
concluded that nine vegetation types were present in the poten-
tial sprayfield sites: longleaf pine-scrub oak; longleaf
pine-scrub oak-wiregrass; longleaf pine-pasture; pine plantation;
pine forest; oak-hickory forest; mixed hardwoods; wetlands; and
open land.
The definition and description of the wildlife in Leon Coun-
ty have been much less sophisticated than that of the vegetation.
The level of effort involved has generally been restricted to
species lists. This effort has been extended to habitat/wildlife
associations only for protected or sensitive species.
EIS field investigations showed that several protected ani-
mals are likely to occur within some of the potential sprayfield
areas, although none of these species were seen during field
investigations. In the southern sprayfield sites, proper habitat
conditions were present for the occurrence of the gopher frog,
indigo snake, gopher tortoise, red-cockaded woodpecker, and
southeastern kestrel.
A number of ecosystems have been identified as being vulner-
able to impacts of wastewater management systems or development,
or as providing habitat for threatened and endangered species.
The ecosystems may be grouped in the following categories:
lakes, wetlands, aquatic-subterranean ecosystems, habitats for
protected species, steepheads and other ravines, and floodplains.
Nonpoint source pollution refers to nondiscrete and diffuse
inputs or loadings which are usually associated with rainfall
events and are associated with both natural processes and human
activities. Non-point sources which affect the study area
include atmosphere, vegetation, urban areas, construction activ-
ities, agriculture-silviculture activities and solid waste
disposal sites.
Ill-20
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2. Existing Man-Made Environment
The populations of Tallahassee and Leon County have experi-
enced steady growth over the past 50 years. The primary factor
in population growth has been in-migration. The sunbelt states
and Florida in particular have experienced significant population
increases over the last two decades. In addition, Tallahassee is
the State's capital and the site of Florida State University and
Florida A&M University. Increased opportunities in government
employment and increased enrollments have both contributed to
in-migration.
The Tallahassee-Leon County Planning Department (TLCPD) 1977
population projections were employed in the EIS. These projec-
tions show 20,000 fewer persons than were planned for in the 201
Plan. The 1977 TLCPD projections call for a population of
192,113 in 1990 and 239,034 in 2000. The 1980 final census fig-
ure of 148,655 for Leon County tends to confirm the accuracy of
the TLCPD 1977 estimate of 149,480.
Residential land use is the predominant land use in the stu-
dy area. Other land uses in Leon County include commercial,
industrial, institutional, open space, agriculture, transporta-
tion/utilities, and the Appalachicola National Forest. Developed
land accounts for 35,644 acres or only 8.3 percent of total land
area in the County.
TLCPD land use projections show a requirement for 63,105
acres of developed land by the year 2000. Given the areas of
available land in Leon County and the location of major highways
serving the County, most of the future growth is expected to
occur on vacant land available within the urban area, and north
and east of the present urban area.
Leon County is primarily a government, trade and service
center. 50.8 percent of nonagricultural employment is in govern-
ment, reflecting Tallahassee's status as the state capital.
Approximately 20.3 percent of the nonagricultural employment is
in wholesale and retail trade. The third largest employment sec-
tor is services, which records 12.9 percent of total nonfarm
employment, and is attributable to the presence of Florida A&M
University, Florida State University, and the Tallahassee Commu-
nity College in the study area.
A wide variety of recreational opportunities are available
in Leon County. Apalachicola National Forest is the largest rec-
reational resource in this area covering 103,471 acres. Silver
Lake, located within the Forest offers a complete range of out-
door activities. Numerous State, County, City, and privately
owned parks and recreational facilities are available for public
use.
Of the major components of the transportation system, (high-
way, air, rail, and water), only highway and air systems have
significant importance to the study area. Four major Federal
111-21
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highways, U.S. 90, U.S. 27, U.S. 319, and 1-10, intersect the
Tallahassee area. The Tallahassee Municipal Airport is owned and
operated by the City of Tallahassee and is served by several com-
mercial airlines. There are no important navigable waters or
significant rail centers in the study area, although there is
rail freight service to Leon County.
Various natural resources are found and utilized within the
Tallahassee-Leon County study area. The major natural resources
are minerals, timber, agriculture, freshwater fish and wildlife.
One sanitary landfill is found in the study area, located on
U.S. 27 South. It is owned and operated by Leon County. The
existing site comprises 620 acres with only 82 acres permitted at
this time and has a life of 30 years. The sanitary landfill
operates the trench method and uses the cell concept for compact-
ing the refuse. The landfill currently disposes of about 400
tons of waste daily.
The existing wastewater management system in the study area
is described in Part B.
Land development controls are an important aspect of water
quality management planning. Land use regulations can be used to
direct development away from sensitive environmental areas,
including water quality-sensitive areas. Land use controls can
also serve to mitigate any short or long-term negative impacts
that may result from the provision of wastewater treatment and
disposal facilities. Leon County and the City of Tallahassee at
present administer many environmentally oriented regulatory meas-
ures. However, most ordinances now in effect are only for the
purpose of regulating development. Few ordinances take a compre-
hensive approach toward resources and their use.
PART E. ENVIRONMENTAL IMPACTS OF ALTERNATIVES
The most significant environmental impacts that would be
caused by each alternative are described below:
1. Alternative 4: No Further Federal Action
The major difference between this alternative and the other
alternatives is the wastewater management system envisioned for
the developing areas of Leon County. Environmental impacts
potentially associated with the widespread use of on-site and
small community systems are as follows:
1. The use of on-site systems limits development den-
sities. Lower density of development can have ben-
eficial water quality effects. Because there will
be less impervious surface per developed acre, pol-
lution from urban runoff will be less per acre than
111-22
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under the other alternatives. Water quality prob-
lems should be reduced due to less overland flow of
stormwater runoff.
2. The use of on-site systems eliminates the need for
construction of sewer lines and the adverse impacts
that result.
3. This alternative promotes the infilling of areas
which are already sewered resulting in higher den-
sity development in these areas.
Under Alternative 4 effluent disposal would be handled by a
variety of on-site and small community systems relying largely on
subsurface drainfields, evaporation/perc ponds and/or sandmounds.
Rather than concentrating the pollutant load at one or two spray-
fields, this alternative, in effect, spreads the load throughout
the area. Therefore, on an areawide basis adverse environmental
impacts may be less severe than they would be under Alternatives
1 through 3. On a localized basis, however, malfunctioning
on-site disposal systems can have the following adverse impacts.
1. On-site systems are more difficult to operate and
maintain.
2. The malfunctioning of an on-site system presents a
higher potential for human contact.
2. Alternatives 1-3: Centralized Wastewater Management Alterna-
tives
Alternatives 1 through 3 propose a centralized wastewater
management system in developing areas of Leon County. A central-
ized wastewater management system can support higher development
densities than on-site and small community systems would allow.
In addition, Alternatives 1-3 propose an extensive collection
system which extends lines into the Lake Lafayette wetlands and
Northeast service area. Impacts common to Alternatives 1-3
include the following:
1. An increased potential for nonpoint source pollu-
tion due to increased impervious surfaces from
higher density development. This could adversely
affect surface water quality and aquatic
ecosystems.
2. Construction of collection lines could have a tem-
porary adverse impact on surface water quality and
terrestrial ecosystems. Areas of concern include
Gum Swamp in the Southwest and the Lake Lafayette
wetlands area, Piney-Z Lake, and Alford Arm in the
Northeast.
111-23
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3. Allows for development flexibility in density and
location.
The preferred effluent disposal option for Alternative 1A is
rapid infiltration at a Northeast effluent disposal site. The
site was chosen as the least environmentally sensitive of nine
possible sites. It is a 440-acre tract containing 348 acres of
open land and no permanent streams or wetlands whose water quali-
ty could be adversely impacted. There is a low potential for
disturbing the habitat of threatened or endangered species. The
most significant impact associated with this disposal method and
site is the potential for groundwater contamination if pollutant
removal capabilities are not adequate. Solution channels could
develop in areas underlain by limestone. Groundwater levels
could rise over time; the decrease in the depth to water table
could allow effluent to enter the groundwater before being fully
renovated.
The preferred effluent disposal option for Alternatives IB,
2, and 3 is the use of slow rate land application at the South-
east Sprayfield expansion site. At the sprayfield, potential
exists for the following impacts:
1. Runoff of pollutants not taken up by crops or bound
by the soil could adversely affect nearby surface
waters. Inadequate agricultural management could
result in sediment, herbicide, and pesticide
runoff. Aquatic ecosystems could be adversely
impacted.
2. Groundwater contamination is possible due to karst
areas which underlie much of the southern portion
of Leon County.
Preferred options for sludge disposal beyond the capacity
provided by the 201 Phase I landfilling facilities consist of
landspreading at sites adjacent to the Northeast plant, the
Southeast plant and the T.P. Smith/Southwest plant or the
Airport. Potential significant impacts are as follows:
1. Odor problems can arise if the sludge is not prop-
erly stabilized and incorporated into the soil.
Problems with odors from stored sludge are also
possible.
2. Low pH in soils throughout the study area could
result in uptake of heavy metals (especially cadmi-
um) by plants. At the Southwest site, excess seep-
age rates will require lining of the liquid sludge
holding ponds. The same problem is found at the
Southeast site to a greater degree.
3. Possible impacts can occur from runoff of 1) pollu-
tants not taken up by crops or bound by the soil,
or 2) agricultural chemicals or sediment.
111-24
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4. Runoff from disposal sites could adversely impact
aquatic ecosystems either through heavy metal tox-
icity or nutrient enrichment.
A management group or agency could be developed to oversee
the siting, design, installation, and operation of on-site and
small community systems. With proper authority, a public manage-
ment entity can ensure the proper use of on-site and small commu-
nity systems as effective wastewater management tools in
preventing water pollution and public health problems. Mitiga-
tive measures and recommendations for the recommended action are
discussed in more detail in Chapter II (page II-3).
PART F. EIS COORDINATION
Public participation programs are mandated by federal regu-
lations governing the preparation of Environmental Impact State-
ments. Public participation is an important and valuable part of
the EIS process in that it provides for active public involvement
in developing and evaluating wastewater management alternatives.
At the beginning of the Tallahassee-Leon County EIS, a pub-
lic participation program was established to provide opportu-
nities for interested groups, individuals and governmental
agencies to participate in the development of the EIS. The focal
point of this program was the establishment of a Review
Committee. This group served in an advisory capacity to EPA and
its consultants. Specific functions and duties of the group
included:
1. Identifying local planning and environmental objectives
2. Identifying study area issues and conflicts regarding
wastewater disposal and environmental conditions
3. Reviewing all task report submissions
4. Assisting in the development and evaluation of waste-
water alternatives
The public participation program included one public scoping
meeting and four Review Committee meetings. The Review Committee
was composed of 23 persons representing 10 public agencies and 13
private groups. A broad range of community interests was
included: business persons' groups and trade associations, envi-
ronmental groups, homeowners associations, and developers. Table
III.3 lists the committee membership.
On November 29, 1978, a public hearing (scoping meeting) was
held at the R.D. Gray Building in Tallahassee to describe the
procedures EPA would use in preparing the EIS. The meeting
included presentations on the purpose and background of the EIS,
the 201 Study, the scope of the EIS and issues to be addressed,
the EiS schedule, and a description of the public participation
111-25
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TABLE III. 3
TALLAHASSEE-LEON COUNTY EIS
Review Committee
Organization
Representative
Board of County Commissioners
Leon County
Apalachee Audobon Society
Clean Water, Inc.
Florida Department of
Environmental Regulation
Florida Wildlife Federation
Killearn Homes Association
Lakeshore Homeowners
Association
League of Women Voters of
Tallahassee
Falls Chase Special
Tax District
George Flatt
Leon County Dept. of Public Works
Division of Utilities Services
Leon County Courthouse
Tallahassee, Florida 32304
Mr. R. Marvin Cook, Jr.
Chapter President
P.O. Box 1237
Tallahassee, Florida 32302
Ms. Terri Saltiel
President
7769 Deep Wood Trail
Tallahassee, Florida 32301
Mr. Gerald Neubauer
Manager
N.W. District Tallahassee
Branch Office
Twin Towers Office Building
2600 Blair Stone Road
Tallahassee, Florida 32301
Mr. C. Richard Tillis
Director
Office of Environmental Education
Knott Building
Tallahassee, Florida 32301
Mr. Philip Anthony
2620 Bantry Bay Drive
Tallahassee, Florida 32308
Mr. Estus Whitfield
3515 Sharer Road
Tallahassee, Florida 32312
Miss Martha Chapman
129 North Franklin Boulevard
Tallahassee, Florida 32304
Mr. J. D. Boone Kuersteiner
Attorney-at-Law
115 South Adams
Tallahassee, Florida 32302
111-26
-------
TABLE III.3 (CONT'D.)
TALLAHASSEE-LEON COUNTY EIS
Leon County Health
Department
Munson Area Preservation, Inc.
Mr. Rhett White
P.O. Box 2745
Tallahassee, Florida 32301
Mr. Glen Carter
President
1808 Old Briar Trail
Tallahassee, Florida 32304
Office of the City
Attorney
National Wild Turkey
Federation
Sierra Club
Florida Chapter, Big Bend
Group
City of Tallahassee
Tallahassee Area Chamber
of Commerce
Tallahassee Department
of Underground Utilities
Tallahassee-Leon County
Planning Department
Tallahassee Water Quality
Laboratory
U.S. Department of Agriculture
Forest Service
Mr. Jim English
Henry, Buchanan, Mick & English,
118 South Monroe Street
Tallahassee, Florida 32301
Mr. Charles J. Allen
Route 5, Box 3150
Tallahassee, Florida 32301
Mr. David Allender
1532 Brook Street
Tallahassee, Florida
Mr. Michael Schneider
City of Tallahassee
201 Program
Route 12, Box 9999
Tallahassee, Florida 32301
Mr. Terry Lewis
P.O. Box 1876
Tallahassee, Florida 32302
Thomas P. Smith, P.E.
2602 Jackson Bluff Road
Tallahassee, Florida 32304
Mr. Thomas Pierce
Lewis State Bank Building
Suite 201
215 South Monroe Street
Tallahassee, Florida 32301
Mr. William G. Leseman
Laboratory Supervisor
2602 Jackson Bluff Road
Tallahassee, Florida 32304
Mr. Donald C. Hughes
Forest Service
P.O. Box 13549
Tallahassee, Florida 32308
111-27
-------
TABLE III.3 (CONT'D.)
TALLAHASSEE-LEON COUNTY EIS
U.S. Department of the
Interior Geological Survey
Windwood Hills Homeowner's
Association
Glen Faulkner
Water Resources Division
325 John Knox Road
Suite L-103
Tallahassee, Florida 32303
Ms. Elizabeth A. Steenblik
1121 East Windwood Way
Tallahassee, Florida 32301
111-28
-------
program. Afterwards, several citizens and officials made com-
ments.
The first Review Committee meeting was held on May 16, 1979
at the Myers Park Community Center to review the EIS Plan of Stu-
dy. Gaps in the existing data base for terrestrial and aquatic
systems were discussed, and the design of a sampling program was
presented. The Committee was asked to confirm if all major
issues of the EIS had been identified and incorporated into the
work effort.
The format of the first Review Committee meeting and all
subsequent ones consisted of a presentation by the EIS consult-
ants followed by the Committee dividing into two round table dis-
cussion groups. At the end of the evening, a representative from
each table summarized the discussion for the benefit of the other
table and observers.
The second Review Committee was held on January 9, 1980, at
the Myers Park Community Center to review the Environmental
Inventory task report and the Alternatives Development task
report. The program started with the showing of a 30-minute vid-
eotape prepared by the EIS consultants highlighting the issues of
local concern and certain aspects of aquatic and terrestrial eco-
systems. During the discussion group sessions, Review Committee
concerns centered on spray irrigation impacts, wastewater flow
projections, the development potential of the northeast portions
of the Tallahassee urban area, the desirability of a Northeast
wastewater treatment plant, impacts to vegetation and wildlife,
and the implementability of widescale use of on-site disposal
systems or small community systems.
The third Review Committee meeting was held on January 15,
1981, at the Lafayette Community Center to review the Alternative
Evaluation task report. Each of the four alternatives was dis-
cussed in turn. Concern focused mainly on Alternative 1 (T.P.
Smith/Southwest and Northeast Plants) and Alternative 4
(No-Federal-Action). The widespread use of on-site systems and
their maintenance continued to be a matter of concern. Institu-
tional management aspects of on-site systems were perceived to be
a serious problem. Other questions addressed cost analyses and
wastewater flow projections.
The fourth Review Committee meeting was held on July 9,
1981, at the Myers Park Community Center to present a briefing
paper describing the No-Federal-Action Alternative that was
selected by the EPA Region IV Regional Administrator. Discussion
focused on the need for and responsibilities of a management
agency for on-site and small community systems. In addition,
committee members requested an expanded discussion in the EIS of
causes of system failure, corrective actions, and mitigative mea-
sures.
111-29
-------
IV. REVISIONS TO THE DRAFT EIS AND ADDITIONAL INFORMATION
Comments received concerning the Draft EIS revealed some
corrections which were needed to rectify errors in the report.
Below the correction, location in text, and comment in which the
correction is noted are given.
Page II-2, end
of last paragraph
before Section 2.
Page 11-20,
last paragraph
Page 11-22,
first paragraph,
sixth line
Page 11-51, last
column, sub-total
row
Page 11-54, top
of page
Page 11-54,
between last
two paragraphs
Add paragraph, "The service area w-9
designated on Figure II-l as T.E.C.
Lakewood Village (3) is actually
Talquin's Lake Jackson Water Service
Area. The Lakewood Village Sewer
Service area is a smaller area
located within the Lake Jackson
area. The area designated as T.E.C.-
Killearn Lakes (5) is a water service
district which has been approved for
the use of septic tanks. All other
service areas designated on Figure
II-l are sewer service areas."
Change first sentence to read, "In W-35
the predominantly unsewered southern
portion of Leon County there are
many small drainage areas due to
karst sinks."
Change phrase from "four to eight" w-5
to, "three to five"
Change "17." to "17.7". w-75
Add paragraph, "Population: In W-45
the Tallahassee Urban area, popu-
lation growth and economic growth
will, for the most part, be induced
by the presence of state government
employment opportunities and the
expansion of the two major universi-
ties. However, population infilling
within the urban area will be en-
couraged by the lack of a centralized
system outside of the City's service
area."
Add paragraph, "Soils: Soils may w-48
clog due to suspended solids in
effluent and treatment and disposal
efficiencies may be impaired."
TV—1
-------
Page 11-54, add
to Wastewater
Disposal Section
Page 11-71, end
of second para-
graph
Page 11-71,
third paragraph,
second sentence
Add paragraph, "Natural Resources W-49
Use: Any potential recycling of
nutrients or benefits of growing
crops are lost."
Add sentence, "The Leon County Health W-6
Department currently holds the respon-
sibility of permitting wastewater
treatment/disposal systems which have
daily flow less than or equal to
2000 gallons."
Change "will" to "may". W-10
Page 11-71,
third paragraph,
fourth sentence
Page III-4,
second to last
paragraph, last
sentence
Delete sentences, "This agency
is now trying to obtain respon-
sibility for managing and operating
several water supply systems owned
by Talquin Electric Cooporative
(T.E.C.). Similarly, it may
eventually take over the responsi-
bility of operating T.E.C. and
other privately-owned wastewater
systems."
Change, "fifteen" to "ten". Delete,
"primary".
W-10
Page III-4,
end of second
to last para-
graph
Page III-5,
second to last
line
Page III-6,
end of second
paragraph
Page III-9,
last entry under
"Authority Needed"
Add sentences, "field data provided
by the City of Tallahassee show
little or no flow in these stream
crossings. This data was collected
at a time when Leon County was
experiencing an extended dry period.
Add "suitable," between "of" and
"unsaturated".
Add, "The recent EPA publication,
Design Manual, Onsite Wastewater
Treatment and Disposal Systems,
October 1980, presents a detailed
coverage of design, siting, instal-
lation, and operation for a variety
of on-site systems."
Add sentence, "It will be necessary
to carefully and specifically define
system 'malfunctions' in order to
efficiently realize this authority.
W-114
IV-2
-------
Page 111-10, Revise sentence to read, "Presently, W-40
third paragraph, soil absorption fields are sized
second sentence on the basis of the proposed or
anticipated number of bedrooms and
the results of the site evaluation
and percolation tests."
Page IV-33,
paragraph IV.a.,
last sentence
Page IV-51,
last paragraph,
second sentence
Page IV-55,
second to last
item in
bulleted list
Page IV-57,
second paragraph,
second sentence
Page IV-57,
end of third
paragraph
Page IV-71,
Noise
Replace phrase, "a threatened W-56
species" with, "a species of spe-
cial concern".
Replace term, "citrus groves" with W-57
"orchard groves".
Add sentence, "(The City Utilities W-58
Sewer Division claims this situa-
tion has improved since the com-
pletion of the 201 Plan.)"
Sentence should read, "In the past W-59
effluent was either discharged to
Munson Slough, where it eventually
entered Lake Munson or was sprayed
onto 120 acres of land surrounding
the treatment facility." Add sen-
tences, "Recently, effluent disposal
has begun at the 201 Phase I Southeast
Sprayfield and surface water dis-
charges from the TP Smith/Southwest
Plants have ceased. The small spray-
field adjacent to the plant is still
in use."
Add sentence, "The centrifuge has W-59
not been used recently because a)
landfilling is not being used for
ultimate sludge disposal and b)
the centrifuge has been a mainte-
nance problem and its production
has not been sufficient to justify
its use."
Under "Description of Impact", W-60
sentence should read, "Operation
of farm machinery and trucks
hauling/spreading sludge or
septage." Under Alt. 4 for this
impact add direct, "D" negative,
long term, "L", and minimum,
"Min".
IV-3
-------
Page IV-71, Label impacts under Alts 1-3 W-121
Surface Water for, "Sedimentation from...
Quality collection system," "Sig" rather
than "Maj".
Page IV-72, Label impacts under Alts. 1-3 W-121
Aquatic for, "Sedimentation from...
Ecosystems disrupt aquatic communities",
"Sig" rather than "Maj".
IV-4
-------
V. COMMENTS ON THE DRAFT EIS AND EPA RESPONSES
The Draft Environmental Impact Statement (DEIS) was pub-
lished and made available to the public on September 17, 1981.
The DEIS was provided to various Federal, State, and local Agen-
cies, as well as concerned individuals, interest groups, and, pub-
lic officials. The public hearing was held in Tallahassee,
Florida on November 5, 1981. In addition to the public input
afforded by the hearing (a transcript provided herein), many let-
ters were received and are included in this Final EIS.
The designations in the margins of the letters identify spe-
cif ic comments for which responses have been developed. These
responses follow the letters. In a similar manner, the desig-
nations in the margins of the hearing transcript identify com-
ments which have received responses. Many of the transcript
comments were similar or identical to the written; consequently,
some transcript responses refer to responses to written comments
already presented.
V-l
-------
PART A. WRITTEN COMMENTS
Index to Written Comments
Comment
Name
Agency
W-l
W-2 thru W-7
W-8
W-9 thru W-ll
W-l 2
W-l3, W-l4
John M. Giarnese
Van R. Hoofnagle
Jesse B. Livingston
James W. Parrish
William M. Baldwin
William M. Baldwin
W-l5 thru W-96 Hurley W. Rudd
W-97 Willis E. Ruland
W-98 thru W-104 Frank S. Lisella
W-105 thru W-107 James H. Lee
W-108
W-l 09
W-110
Clifton G. Brown
Glen Carter and
Jessie Brown
Jesse B. Livingston
W-l11 thru W-l15 Walter 0. Kolb
Department of the Air
Force
Florida Department of
Environmental Regulation*
Bureau of Wastewater
Management and Grants
U.S. Department of
Agriculture,
Soil Conservation Service
Leon County, Board of
County Commissioners
Consulting Engineer
Tallahassee Board of
Architects and Engineers
City of Tallahassee
Department of the Army
Department of Health and
Human Services, Center
for Environmental
Health
U.S. Department of the
Interior
Department of Housing
and Urban Development
Munson Area Preservation
Inc.
U.S. Department of
Agriculture,
Soil Conservation Servic
State of Florida, Office
of the Governor
V-2
-------
W-116 thru W-120 Richard W. Smith Florida Department of
Environmental Regulation,
Bureau of Wastewater
Management and Grants
W-121, w-122 T. Michael Schneider City of Tallahassee,
201 Program
W-123 thru W-127 William G. Leseman City of Tallahassee,
Water Quality Lab
V-3
-------
DEPARTMENT OF THE AIR FORCE
REGIONAL CIVIL ENGINEER. EASTERN REGION (HQ AFESC)
526 TITLE BUILDING. 30 PRYOR STREET. S.W.
ATLANTA, GEORGIA 30303
REPLY TO
attn of: R0V2 22 September 1981
sl'bject: Draft Environmental Impact Statement (DEIS), Tallahassee - Leon County,
Florida
U. S. Environmental Protection Agency-
Region IV
Attn: Mr. John E. Hagan, III, PE
Chief, EIS Branch
3^5 Courtland Street, N. E.
Atlanta, Georgia 30365
1. We have reviewed subject DEIS and find that development of the proposed
program will have no impact on Air Force operations in Florida.
2. Thank you for the opportunity to review this DEIS. Our point of contact
is Mr. Winfred G. Dodson, commercial telephone number 221-6821/6776.
Cy to: USAF/LEEV
Captain, USAF, Deputy Chief
Environmental Planning Division
V-4
-------
STATE OF FLORIDA
DEPARTMENT OF ENVIRONMENTAL REGULATION
TWIN towers office building
2600 BLAIR STONE ROAD
Tallahassee. Florida 32301
BOB GRAHAM
GOVERNOR
VICTORIA J. T3CHINKEL
SECRETARY
September 30, 1981
Mr. John E. Hagan, III, P.E.
Chief, EIS Branch
U. S. Environmental Protection Agency
345 Court!and Street, N.E.
Atlanta, Georgia 30365
Re: C120581010 (Step 1) - City of Tallahassee
Environmental Impact Statement - Draft Report
Dear Mr. Hagan:
The Florida Department of Environmental Regulation (DER) has reviewed
the above referenced draft report and offers the following comments/
questions for your consideration:
11 Page 11-35 and 11-39 indicated that the sludge disposal option
for Alternative 4— "No Federal Action" is landfilling. However,
the text on Page 11-34 and in Section 6 of the report indicate the
selected alternative is landspreading. Are you using these terms
interchangable or can the reviewer assume that landfilling was
later rejected? Was a cost-effectiveness analysis done in comparing
these two options?
2) In comparing Alternative 4 with the other three alternatives, did
you include the Operation and Maintenance (0 & M 1 costs for the
Thomas P. Smith and Southwest Treatment Plants in Alternative 4
although these facilities are not heing expanded? All 0 & M costs
for both centralized and on-lot facilities should be considered.
3) Page 11-66 discusses establishment of a centralized management agency
with various responsibilities, the most critical being notification
of homeowners. Does the City of Tallahassee have any intention of
establishing such an agency? Where is septage presently being
disposed of? Will the Thomas P. Smith sewage treatment plant have
facilities for accepting septage? Such facilities are grant eligible.
Will the City of Tallahassee build only such facilities "incumbent on
the implementation of a public management agency" (Page III-5)?
4) For Alternative 4, you have recommended 4-to 8-year intervals between
septic tank pumpouts. Often septic tank systems will become y c
overloaded and their solids flow into the drainfield, thus causing W""-J
clogging, in only three to five years.
v-5
Protecting Florida and Your Quality of Life
-------
Page 2
Mr. J. E. Hagan
9/30/81
5) On Pages 11-70 to 11-72 in your discussion of Public Agency Actions,
you have not identified the agency responsible for approval and
permitting of individual on-lot septic systems, which is a critical
element of Alternative 4, The DER believes that a discussion of the
responsibilities, criteria and concerns of the Leon County Public
Health Department is in order.
6) Upon final EPA approval of the Tallahassee EIS, it is our understanding
that the grantee will submit either a revised 201 Facility Plan
incorporating the recommendations of the EIS or the grantee will adopt
the EIS into the 201 Facility Plan by a letter amendment. Upon
completion of the grantee's adoption/incorporation or revision to the
201 Plan, the DER will be in a position to offer final review comments
and certify the Facility Plan. It is our further understanding that at
that time EPA may approve the Facilities Plan and issue a "Finding of
No Significant Impact" (F0NSI) on the selected alternative. Please
inform the DER if this procedure is inappropriate or incorrect.
If you have any questions please contact me at 904/488-258''
Sincerely,
Van R. Hoofnagle, P.E.
Sewage Technology and Planning Section
Bureau of Wastewater Management and Grants
VRH/wc
cc: David Peacock - EPA/Atlanta
Mike Schneider - City of Tallahassee
Richard Sublette - DER/Pensacola
A1 Bain - Gannet, Fleming, Cordry and Carpenter
-------
ijn:| u iici n
-?SSfy Agriculture
Soil
Conservation
Service
P. 0. Box 1208
Gainesville, FL 32602
subject: EVT - Draft Environmental Impact Statements Date-. October 8, 1981
To: John E. Hagan III, P.E.
Chief, EIS Branch
EPA, Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
We have no comments on the Draft Environmental Impact Statement for Leon
County Wastewater Management, Tallahassee, Leon County, Florida.
cc: Norman Berg, Chief, NO, SCS, Washington, D.C
The Soil Con$ervation Service
i* an agency of me
Department ol Agriculture
V-7
-------
Board of County Commissioners
BOARO OF COUNTY COMMISSIONERS
LEON COUNTY COURTHOUSE
TALLAHASSEE. FLORIDA 32301
904-488-4710
CommiMionars:
DOUG NICHOLS
O^sirtci i
GAYLE NELSON
Otttnei 2
JIM CREWS
0<«ir*CI 3
ROBERT HENOERSON
J. LEE VAUSE
District 5
JAMES W. PARRISH
County Aomm»traio'
FE. STEINMEYER. HI
County Anof«#v
October 30, 1981
Mr. John E. Hagan, III, P.E.
Chief, E.I.S. Branch
EPA, Region IV
345 Courtland Street, N. E.
Atlanta, Georgia 30365
Dear Mr. Hagan:
I have completed a review of the draft Tallahassee/Leon County
Environmental Impact Statement, and I have found the document
to be essentially complete. However, I would like to take this
opportunity to identify what I consider to be two inaccuracies
within the document and will provide amendments which would
correct these errors.
1. Two of Talquin Electric Cooperative's water
service areas were inadvertently identified
as sewer service areas in Figure II.1. The
Killearn Lakes area is a water service dis-
trict which has been approved for the use of
septic tanks. This area should be deleted
from the figure.
The area identified as the Lakewood Sewer
Area is actually Talquin's Lake Jackson
Water Service Area. The Lakewood Sewer
Service Area is a much smaller area located
within the Lake Jackson area. Attached for
your use is a Lakewood Village Sewer Boun-
ary Map in order that you might amend Figure
II.1. accordingly.
2. The other area of concern is the section en-
titled Leon County Public Works Department.
on page 11-71. Two statements in the section
are inaccurate and do not reflect current
County ordinances and policies. The first
statement of concern indicated that the Public
Works Department will be the operating agency
for all wastewater facilities other than the
City's. The second statement of concern indi-
cated that Leon County has been actively en-
gaging in the negotiation to take control of
Talquin Systems.
V-8
-------
Mr. John E. Hagan, III
Page 2
October 30, 1981
Leon County Ordinance 80-20 provides for the
regulation of facilities and Board authoriza-
tion of future facility placements. In addi-
tion, Ordinance 80-29 provides a legal
mechanism for the County to own and operate
such systems when the Board of County Com-
missioners deems it appropriate. However,
as yet there has been no active contemplation
by Leon County to get into the water or sewer
business. In the event that neither the City,
Talquin, or other suitable entity is identified
nor willing to operate a system, then the County
would be forced to consider the operation of
the system for the benefit of the Leon County
Community. In essence, Board policy has been
to consider operation as a last resort.
As to the negotiations to take control of
Talquin Systems, County staff initiated an in-
vestigation earlier this year to determine the
necessary additional staffing and other re-
lated needs to effectively operate a system.
This investigation was#initiated for planning
purposes only and was intended to prepare the
County should the Board of County Commissioner!
ever elect or desire to enter into the systems
operation business.
In closing, the County's position with regard to the use of
septic tanks and community systems has not deviated from the
Board's position as it was previously described in the April
28, 1981 reply to Mr. Robert Howard. The County believes that u 11
this alternative, in addition to the alternative to expand the
City Central System, when economically practical, will prove
to be environmentally sound, financially realistic and the
most flexible approach.
If my staff can be of assistance in this matter, please do not
hesitate to contact me.
W-10
Sincerely,
environmental impact statement
BRANCH
V-9
JWP/ka
REGION IV • EPA
-------
-%ypM
LEON COUNTY SEVER
SERVICE AREA =4 2
*
-------
WilliamM. Baldwin, P.E., p. a .
Consulting Engineer
CEDARS EXECUTIVE CENTER _ SUITE 2S0-B
2639 NORTH MONROE STREET
TALLAHASSEE, FLORIDA 32303
TELEPHONE 904/386-3208
HOME 904/389-3198
November 4, 1981
TO: Mr. John E. Hagen IIT, P. E.
Chief , EIS Branch
Environmental Protection Agency
345 Court land Street, N.E.
Atlanta, Georgia 30365
RE: Tallahassee - Leon County
Environmental Impact Study
I have reviewed the document submitted and have serious concerns
relative to the conclusions reached.
Leon County soils in developing areas in general, are not suit-
able for septic tanks or other similar on site disposal schemes.
This is shown on the Fig. IV. 10. of the EIS and documented by
the Soils Conservation Soils Map of the County.
My professional and personal observations verify the high proba-
bility of on site disposal system failures. For the past 15
years I have designed building foundations. In the North and
Northeast parts of Tallahassee about 75% of the houses I have
checked in the past 5 years have been on soils which will not
percolate. The soils, highly plastic clays, randomly occur North
of U.S. 90. For this reason, septic tanks for most homes and
small businesses will not work. On the street where my home is
located, nearly all septic tanks and drain fields (mine is a lone
exception) have been rebuilt one or more times.
I like the concept of small STP's and septic tanks but with the
odds about 3:1 failure, I think the health risks are not acceptable.
This community must accept the need for sewers into the North and
Northeast as development occurs. Sewage or treated effluent must
be transported to the South where soils will accept water.
Sincerely,
w-
WILLIAM M. BALDWIN, P.E
WMB/bb
»
V-ll
-------
WilliamM. Baldwin, RE. > pa.
Consulting Engineer
:EDARS EXECUTIVE CENTER _ SUITE 2S0-S
2639 NORTH MONROE STREET
TALLAHASSEE, FLORIDA 32303
TELEPHONE 904/386-3206
HOME 904/389-31 98
November 5, 1981
TO: Mr. John E. Hagen III, P. E.
Chief, EIS Branch
Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
RE: Tallahassee - Leon County
Environmental Impact Study
I have been requested by the Tallahassee Board of Architects
and Engineers to express this organizations concerns regarding
the captioned study.
Several serious problems related to wastewater treatment and
disposal are not addressed in this study.
The conclusion that package sewage treatment plants and septic
tanks will be usable is not borne out by the soils maps within
the body of the report. Fig. IV. - 10.
W-13
About 3/4 of northern Leon County is underlain by plastic or
highly plastic clays which are virtually impermeable. This
drastically limits underground disposal sites.
New Department of Environmental Regulation rules virtually
eliminate surface disposal due to unreasonable limitations and
large buffer zones. Small commercial plants cannot be used in
most cases because of the large site requirements. In addition,
stormwater must be kept on site compounding water problems and
the two cannot be mixed per proposed DER stormwater rules.
Unless sewers are available in North and Northeast Leon County
only large 1/2 A.+ lots can be developed for residences and no W-l^i
commercial development requiring 2,000 GPD or more can be built. !
The design professional in private practice questions the possi-
bility of future growth of the community if the recommended
Alternative #4 is selected.
ENVIRONMENTAL '
Sincerely,
WILLIAM M. BALDWIN, P. E.
. i
11
WMB/bb
V-12
-------
OFFICE OF .. . ^
THE MAYOR CITY HALL • TAULAH A » ¦ 11, FLORIDA 3830<
November 5, 1981
Mr. Charles R. Jeter
Regional Administrator
Environmental Protection Agency
Region IV
34 5 Courtland Street
Atlanta, Georgia 30365
Dear Mr. Jeter:
On Wednesday, September 16, 1981, Joe Dykes,
Mike Schneider and I met with you and requested that
you not release the Draft Environmental Impact Statement
(DEIS) for the Tallahassee-Leon County area. It was known
from information in the Preliminary Decision Paper that the
recommended action of the DEIS would not be an acceptable
solution for the residents of this area.
While our professional staff had reason to
believe the DEIS would not be acceptable, we had no idea
that it would be as unacceptable as it has proven to be
following a close examination. There are many instances
of information in one section not being in agreement with
information in another section. In fact, there are instances
where information in one section is completely reversed in
another section. There are instances where the same situation
shows favor to one alternative and is not mentioned in evaluating
another alternative.
The above contradictions, examples of which are given
in an attachment, are enough to question the entire report.
However, the unacceptability does not end with numerous problems
of this category. There are errors of fact throughout the
publication. Examples of these errors are listed in an attachment.
V-13
FLORIDA'S CAPITAL CITY
-------
Mr. Charles R. Jeter
November 5, 1981
Page two
Mr. Jeter, it is my understanding you are one of
the few Regional Administrators who has a sound technological
background. If you would personally review the DEIS and the
attachment to this letter, I believe you would have ample
reason to rescind the DEIS and I am requesting you do so in
the best interest of the citizens of this entire area.
It is our further understanding that EPA will
comment on each question and statement found in the attachment
to this letter, and the attachment with EPA's comments will be
bound in the final EIS. Please let me know if this is not
the case.
Thank you.
Mayor
HWR/cg
Attachment
cc: Mr. John E. Hagan III, P.E., EPA
Mr. Richard W. Smith, P.E., FDER
V-14
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COMMENTS FROM THE CITY OF TALLAHASSEE'S STAFF
CONCERNING THE DRAFT ENVIRONMENTAL IMPACT STATEMENT
1. Centralized sewer systems are unaffected by various water
level uses or monthly rainfall. The large family with a good
deal of laundry or the family who likes to take long showers
must pay more for their high consumption, but they are able to
make the choice. If they live on a h acre lot with clay soil and
a 20 minute perk they probably will be forced to cut back on W~16
consumption, especially during the summer months when rainfall
is the heaviest, showers taken more frequently and clothes
washed more often. The wastewater problems which had been
removed will now be back in the yard. An on-site wastewater
system does initially cost less, but you also get less.
2. When addressing past problems with on-site systems and their
causes, the EIS consistently states that "these are considered
to be institutional problems that can be overcome". Attitudes W~17
such as this demonstrate a lack of understanding of the political
situation in this area and the effect political decisions have on
engineering design. On-site system designs are extremely susceptible
to political influence. One recent example is the rule allowing
on-site systems on h acre lots.
3. The EIS recommends expansion of the City wastewater system
to "pickup" the area by Meginnis Arm which was discussed in
the "J" Series Study. However, the soil types found in the "J"
area are common in N.E. Leon County. Do the EIS consultants
feel the problem found in the "J" Series Study was a unique
situation?
4. The EPA Manual "On-site Wastewater Treatment and Disposal
Systems" does not mention the design life of a drainfield.
V-15
-------
Septic tank drainfields are designed to fail. If they didn't
filter the water leaving the septic tank, they wouldn't be doing
one of their primary jobs. Therefore, after a period of time,
the filter surface is sealed with filterable material and the
drainfield fails. At this time it must be replaced.
What is the design life of drainfields constructed in the clay 19
soil found in N.E. Leon County?
5. Homeowner association and/or developer management of package
plants will be plagued with problems unless the plant owner is held
responsible for its performance. Otherwise, the homeowners will
be stuck with cheap, unworkable systems after the plant owner W-20
has "left the picture". Should a package plant be abondoned,
who would be responsible for its operation?
6. Current rules of the Department of Health and Rehabilitative
Services Programs Chapter 10D-6 Standards for Individual Sewage
Disposal Facilities states that "A percolation rate over fifteen
(15) minutes is unsuitable for absorption beds or drainfields." W~21
Since many of the soils in Northeast Leon County will have perk
tests exceeding the 15 minute maximum, how does the EIS recommend
we circumvent a state rule?
7. Neither the Leon County Health Department, which permits
septic tanks in this area, nor the State of Florida,
Department of Health & Rehabilitative Services, which issues
the septic tank rules for the State, has provided an effective
control to insure acceptable septic tank performance by requiring
management and control techniques which would govern the design
construction and operation of septic tanks.
Public management of septic tank systems in Florida and this
local area lacks established standards.
V-16
-------
In the State of Florida septic tank maintenance is an owner
responsibility. The great majority of owners do not have
any idea of how the system works or how to properly operate
and maintain it. Neglect usually comes from the owner not
being aware of maintenance needs.
Therefore, what reason is there to believe that the local
area will establish a septic tank management system with rules
more stringent than the "minimum standards" set forth in the W—22
State rules for septic tanks (Chapter 10D-6)?
We submit that there are County Health Departments in Florida
ready to enforce rules more stringent than State rules, but
they cannot obtain the authority to act. We further submit y_23
that no local area in Florida will be able to establish rules
more strict than the State rule. Do you feel otherwise? If so,
Why?
8. Can a single area comparable to Leon County in climate, soils,
area and population, in the United States, be named that incorporates
a management agency as the EIS suggests and has rules more strict ^
than its State standard? We suggest not, one hasn't been presented
to date. Should an example be found, please give the name and
phone number of the person in charge of the management agency.
9. how many water quality monitoring wells will be required
by the year 2000 to provide an acceptable assurance of safe
drinking water? How many of these wells would fall into
the following depth categories?
0 - 50'
50' - 100'
100' - 150' W-25
200' & deeper
Should monitoring wells show contamination of the drinking
water acquifer, what is the remedy? Please explain the sewer
and water solutions in detail.
-------
10. The EIS clearly stated in eight of its formal publications
that an investigation of the proposed 2000 acre Southwest spray
irrigation field would be a major output of the study.
A. Preliminary Plan of Study
Item "B" under "Major Issues of the EIS" concerns
"alternative spray irrigation sites."
B. Preliminary Study Background Task Report
Item "1" under "Issues of Local Concern" is
"Spray Irrigation Impacts"
C. Second Segment-Plan of Study (Preliminary)
1. Item "1" under "Background" is
"Spray Irrigation Impacts".
2. Item "3" under "Those actions which will be covered
by the EIS include" is "Proposed 2000 - acre Southwest
spray irrigation field".
D. Environmental Inventory Task Report Item "1" under a
paragraph which heads a list of the EIS issues is
"Spray Irrigation Impacts".
E. Environmental Monitoring Program - Segment II
Item "(2)" under "Conclusions" is "Potential
sprayfield sites... S.W. Sprayfield..."
F. Environmental Monitoring Program - Segment II Item
"(2)" under "Conclusions" is "Potential sprayfield
sites .... S.W. Sprayfield...".
G. Alternatives Development - Pages 89 - 90
"... land adjacent to the T.P. Smith/Southwest
treatment facility ... a viable alternative ..."
4 V-18
-------
H. Draft - Alternatives Evaluation - Volume II
pages 1-7 and 1-8
"...summary of issues follows:
1. Land Application Impacts - "
Considering the eight specific references above, why wasn't
anything significant done to show the environmental impact, yj.
if any, of the proposed 2000 acre S.W. sprayfield?
We submit that the S.W. sprayfield was not in line with the
predetermined outcome of the EIS and was, therefore, shelved.
Can it be shown that environmental and economic studies of the
proposed 2000 acre S.W. sprayfield were made?
Was consideration given to construction of the S.W. sprayfield
using equipment now in service in the S.E.? What was the cost
differential and breakdown between the two sites (S.E. & S.W.)?
What was the cost per gallon per year? Was energy conservation
considered in the evaluation of the S.W. sprayfield? If not,
why not?
11. With references to a N.E. treatment plant and disposal in
the N.E., what are the increased impervious surfaces listed in
the "Cons" column of the "Preliminary Decision Paper"? is it
suggested that a higher density development will occur in the yj_
N.E. than available under the State septic tank rule (h acre
lots)? If so, we suggest no one investigated the type development
presently occuring in the N.E. and will continue no matter which
type of wastewater treatment is used.
12. How many homes are within a half mile circle of the proposed
site of the N.E. treatment plant (±10%)? From within 100 yards
of any of these homes could anyone see any structure of the
proposed N.E. treatment plant? If so, how many? (+10%)? With
these facts, how can the EIS state the facility is incompatable ^
with existing land uses (p. vi, 1-3)? We do not feel that odors
or vehicle traffic would be a problem, do you? if so, please explain.
V-19
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13. With reference to alternative 1A, what logic can De given
that supports the EIS statement in the "Con" column
"Construction impacts on surface waters and plant and animal
resources" (P.vi)? With 500± square feet in each septic tank
drainfield, how can central wastewater facilities amount to a
greater number of square feet? A large mimber of new homes in 0Q
Tallahassee are leaving their lots "natural" (no clearing of the
yard). To clear 500± square feet of this natural environment
for the initial drainfield will impact "waters and plant and
animal resources". Please compare the construction of individual
systems and central systems and define which will give the
greater impact.
Please note that once a permanent central system is installed
that the construction is complete for 50+ years while septic
tank drainfields are reconstructed considerably more often.
14. The Florida State rule for septic tanks (Chapter 10D-6)
clearly states under the title "Prohibitions" that
"Whenever an approved sanitary sewer is made
available (Section 10D-6.25), any individual
sewage disposal system device or equipment
shall be abandoned and the sewage wastes from
the residence or building shall be discharged
to the sanitary sewer through a properly
constructed house sewer within three-hundred
and sixty-five (365) days after notification
that such a system is available."
Considering this rule which was developed by the State's
highest health agency, it can be seen what action they deem
necessary to protect the health of the citizens of Florida.
It can also be seen that they consider their "minimum standards" W~30
only an interim measure until a sewer is available. Why do
you think otherwise?
6
V-20
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15. The State of Florida requires that effluent not contain
more than 10 mg/1 nitrate by the time it reaches the groundwater.
>7e have no reason to believe the nitrate will drop to 10 mg/1
from the time it leaves a community system's percolation pond
until it reaches the groundwater. Do you feel there is a
dependable way in which this will happen? EPA publication
(J 71
"Process Design Manual, EPA 625/1-77-008,"... concluded that
the only feasible mechanism for removing large quantities of
nitrogen in high-rate applications is denitrification". Why
do you think this is not the case in the Leon County area?
16. Who, by name, in EPA's Region IV Water Supply Branch
is stating that septic tanks and package treatment plants
in N.E. Leon County will not degrade Tallahassee's drinking
water wells? If there is no such career EPA person who will W~32
take the responsibility of taking this stand, why is the EIS
advocating it?
17. With reference to Table 11.18, why isn't a cost listed
for sludge disposal for septic tanks? How many sludge trucks
of what size will be needed by the year 1990? The year 2000? W~33
How many miles per year will these trucks travel and how many
septic tanks will they serve per day?
18. Oxidation ponds are listed on page 11-11. They are not
allowed by the Florida Department of Environmental Regulation.
Do you feel otherwise?
19. Items 2 & 4 toward the bottom of page 11-19 report the
need of "sufficient depth to bedrock... and relatively flat
land" for septic tank drainfields. At the bottom of the
next pacre. it is reported that "in the unsewered portions...
w-^t;
the terrain is irregular... many of these areas have shallow n
bedrock?" Isn't this inconsistent with the EIS advice to use
septic tanks? If not, why not?
7
V-21
-------
20. Page 11-24 lists sand filters and aerated lagoons. The
Florida Department of Environmental Regulation doesn't permit W-36
these. Do you feel otherwise?
21. At the bottom of page 11-28, a disadvantage of a pressure
system is listed as a higher concentrated wastewater. Please ^ -j-j
explain how under Florida rules that this is a problem.
22. Who with the St. Joe Paper Company has approved the revised
routing the EIS shows on figure II.7 for the proposed force main? y|_3g
We suggest they will not allow the routing you suggest. An
answer which is not implementable is not an answer.
23. On Page 11-46 an assumption is made in Item 1 that the City
will not independently finance beyond 17.5 MGD... On what do
you base this assumption? On that same page in Item 4 an W-39
assumption is made that development densities will be limited
to three units per acre. What is this assumption based on?
24. On Page 11-50, please explain "cost-effective (... W 40
environmentally) " .
25. On Page 11-53, the words "with Federal funds" should be
added to the first sentence.
Paragraph number two reports "urban runoff could increase"
while paragraph number five reports "runoff will be less". W-41
Which is correct? What evidence is there of the EIS considering
runoff from over saturated drainfields?
26. Under "Alternative IV" which begins on Page 11-53,
several headings are missing which were listed under other
alternatives. Why weren't the following headings listed?
A. Surface water quantity - Will there be no runoff
due to saturated drainfields? If not, why not? What W~42
is the source of your information?
V-22
-------
B. Aquatic ecosystems - Will septic tank runoff not
get into these systems? If not, why not? What is the W~43
source of your information?
C. Terrestrial ecosystems - Will the cumulative area of
drainfields not require "permanent dedication of additional I(1-44
acreage"? If not, why not?
D. Population - Is the answer not the same as on
Page 11-55? If not, why not?
E. Recreation - Was yard recreation considered? A big
recreation form in Tallahassee is gardening. In a \ acre
lot, half the back yard is taken up with the initial
drainfield. What is the minimum separation needed between
drainfields and vegetable gardens?
W-45
W-46
F. Transportation - If the presumption of less dense
population is true, longer roads will be needed to get out W~*47
to the less dense areas. Why wasn't this considered. If
it was, where is it?
G. Soils - "Soils may clog due to suspended solids in the
effluent . .. and disposal efficiencies may be impaired" VM8
(pII-57). Would this not also be the case for septic tanks?
If not, why not?
H. Natural resources use - "Any potential recycling of
nutrients or benefits from growing crops are lost". (PII-57)
Wouldn't this also be the case for septic tanks? If not, VM9
why not? Alternative "1A - modified", proposed by the City
of Tallahassee proposed sprayfields.
9
V-23
-------
27. "Microbiology" by Pelczar & Reid states: "They (Septic
tanks) cannot, however, be relied upon to eliminate pathogenic
microorganisms carried in sewage. Consequently, it is imperative
that the drainage from the tank be prevented from seeping into
the drinking — water supply". Do you have reason to believe
the pathogenic microorganisms are eliminated? If so, how?
28. On Page 11-54, under "Public Health" there is no mention
of possible contaimination of drinking water wells. Why not?
W-50
W-51
On Page viii a "Pros" claim is "least impact on groundwater"
and a "Cons" claim is "potential impact to groundwater". Which W-52
is it? Please explain.
29. Reference Page 11-55, under "Acquatic Ecosystems". What
makes you believe the "existing degradation" is only applicable
to Alternatives 1A & B?
W-53
30. Reference Page 11-55, under "Historic and Archeological VI-54
Resources". Why reference anything listed as "not well documented"?
31. Which State or Federal agency has established "species
of special concern" for the gopher tortoise? Are you aware W~55
that the gopher tortoise is legal game under the State game
agency?
32. The gopher tortoise is listed as "species of special
concern" on Page IV-31 and "threatened species" on Page IV-33
Which is it? What State or Federal agency has established
that status?
33. Where are the citrus groves listed on Page IV-51?
Specific locations are requested.
W-56
W-57
10
V-24
-------
34. What is the source of your information that "the City's
sewer collection system maps ... are neither accurate nor
comprehensive enough for sufficient management of sewer
system requirements"? Are you aware that the City has
extensively documented these collection lines with in-line W~58
television tapes, lamping, written logs and controlled
plan & profile maps? Please correct the DEIS to show the
actual situation. These records will be made available in
our offices.
35. On Page IV-57, a statement is made that "Effluent
(from the T.P. Smith Treatment Plant) is either discharged
to Munson Slough, where it eventually enters Lake Munson or
it is sprayed onto 120 acres of land surrounding the treatment
facility". There are some basic things, such as effluent
disposal points, that a technical report has no excuse of
reporting in error. The EIS also implies that the Southwest
Treatment Plant has the same disposal. This is a textbook
example of the problems of reporting a situation from hundreds
of miles away. Please investigate the disposal methods of
these two plants and report them correctly. Along the same
line, anyone visiting these plants would know the centrifuge
was taken out of operation years ago.
36. With reference to Table IV.19:
A. Under the paramenter "Noise", why isn't the sound
of a septic tank pump out truck traveling all over
town (and even up on lawns next to homes) equal or
greater than the trucks listed which only cross the
road between the sewage treatment plant and the
airport? If not, why wouldn't it be? What farm
machinery is being used for sludge?
11
V-25
-------
B. Under the parameter "Topography", why isn't
earth moving to install numerous septic tanks, W-61
drainfields and absorption beds considered?
C. Under the parameter "Soils", why wasn't the
"soils clogging" under alternative #1 listed under
alternative #4? Do you feel the drainfields will
not clog? If so, why?
D. Under the parameter "Surface Water Quality", when
and where in Leon County was the "overland runoff or
lateral seepage to nearby surface water bodies from
sprayfields and sludge disposal sites"? There is ample
experience of both sprayfield and sludge disposal operations
in Tallahassee to forecast that the past record is an in-
dication of what can be expected in the future. If this
experience was not considered, why wasn't it?
E. Under the parameter "Surface Water Quality", why
do you feel the N.E. population will change its density
to match the wastewater treatment method? If so, explain
why.
W-62
W-63
W-64
F. Under the parameter "Groundwater Quality", what is
your source of information that alternative #4 will have W-65
a minimum impact?
G. Under the parameter "Acquatic ecosystems", what is the
source of contamination impacting protected species? What
are the specific species? What Federal or State agency has Vl~66
labeled them "protected"? Who, by name, of the EIS team
can vouch for the local existence of these species?
12
V-26
-------
H. Under the parameter "Terrestrial ecosystems", why
aren't "habitat losses" due to clearing "natural vegetation"
lots for septic tanks and drainfields considered? Why won't W-67
there be sludge disposal sites for septic tanks? If you
feel there will not be sludge from septic tanks, please
explain why.
I. Under the parameter "Land use", why will there be no
sludge disposal sites for septic tanks which will "convert
W*"* RR
several hundred acres from agricultural/forestry to cropland"?
What is the difference between agricultural land and cropland?
J. Under the paramenter "Public Health", why do you list
as an impact "transmission of pathogens from sprayfields
by wind or vectors" when on page 11-59 you state "public
health impacts are negligible from spray irrigation..."?
What is spray irrigation as it is now being practiced on
over 1000 acres by the City of Tallahassee, a public health
impact or a negligible factor?
W-69
K. Under the parameter "Archeological and historical
resources" why do you feel there will be more destruction
under alternatives #1, 2 & 3 as compared to alternate #4?
In your answer, consider the Federal requirements for
archeological and historical surveys before construction W~7C
of EPA wastewater facilities and no requirement for such
surveys under a "No Federal Action" plan. Also consider
the greater surface area disturbed by the numerous septic
tanks and drainfields compared to a central facility.
L. Under the paramenter "Recreation", where is the public
hunting areas which will be lost to land conversion? We
hope you are not considering protecting private land and
its interest instead of the public's welfare. What other W—71
county in Florida has over 100,000 acreas of publicly owned
hunting area?
13
V-27
-------
M. Under the parameter "Natural resource use", where is
the forestry activity in the N.E. which would have a W-72
significant impact by alternative #1?
37. Please give the number of working hours (±15%) that the
following personnel spent on this project while in Leon County:
U.S. Environmental Protection Agency
Robert B. Howard, Chief, EIS Preparation Section
W. Bowman Crum, Current Project Officer
Richard D. Green, Prior Project Officer
Virginia W. Buff, 201 Project Engineer
Gannett Fleming Corddry & Carpenter, Inc.
Thomas M. Rachford, Senior Project Manager
Albert T. Bain, Project Manager
Mark Flaherty, Environmental Engineer W-73
Jim Fuller, Environmental Engineer
Sara Frailey, Environmental Engineer
John W. Jacobs, Environmental Scientist
Richard C. Callahan, Environmental Scientist
Claude Terry & Associates, Inc.
Claude E. Terry, Project Executive
Louise B. Franklin, Project Manager, Environmental Planned
Robert J. Hunter, Environmental Scientist
Thomas C. Mather, Environmental Scientist
James C. Hodges, Environmental Scientist
A. Anita Patterson, Environmental Scientist
38. Please give a drawing showing the layout of an on-site
disposal system for a 1/4 acre lot including any areas required
for drainfield expansion following the rules of the Department ^-7*1
of Health and Rehabilitative Services Health Programs Chapter
10D-6 Standards for Individual Sewage Disposal Facilities.
14
V-28
-------
The on-site disposal system should be sized based on the
following criteria which is common for northeast Leon County:
1400 sq. ft. home, 3-bedroom, washer, garbage disposal,
15 minute percolation rate, and yard elevations falling
3 feet from front to back. Also consider Leon County
setback rules and the following from septic tank rule
10D-6.24(6): "Suitable, unobstructed land shall be
available for the installation of drainfields and/or
absorption beds. The minimum absorption area shall be
no less than three (3) times the drainfield absorption
area required by Section 10D-6.26 and shall be in additicfn
to that required in subsection three (3) above." Also,
please show where a small vegetable garden would go
(keeping good health practices in mind). If a vegetable
garden is not feasible in a situation of this sort, please
explain why.
39. Alternative IV cost estimates shown in Table 1.3.3. of
the Draft Alternatives Evaluation Volume I- Summary and Table
11.18 (11-51) of Environmental Impact Statement - Draft do W-75
not agree. There is a $700,000 differential in the "No -
Federal - Action" column and neither upper column is added
correctly. Please explain.
40. Page 111-10 of the EIS Draft states in the section on
regulations that "percolation rates as slow as 60 minutes
per inch have been shown to be effective because such
percolation rates can be compensated for with lower loading
rates" ... and later, "Presently, soil absorption beds are
sized on the number of bedrooms in the residential home
instead of the ability of the soil to absorb septic tank
effluent."
First a 60 minute perk would be compensated for by a larger
drainfield, not telling the family they have to use less
water.
-------
Secondly, soil absorption areas are sized on the number of
bedrooms and the percolation rate. Please explain why the W-76
EIS says otherwise?
41. The EIS assumes that development densities for on-site
systems will be three units per acre. This is wrong as
on-site systems are allowed and are being constructed on
k acre lots. Please explain why the EIS states three units
per acre.
3
<£ 44. What is the source of the information shown on
it-"- figure IV. 10?
46. In light of high energy costs & the high cost of urban
services, why are you promoting urban sprawl. In your answer,
please give consideration to transportation, fire protection,
garbage and similar services.
VI-77
42. It is common knowledge to Florida wastewater engineers
that Duval & Orange Counties have very serious problems
which have developed due to on-site & community systems. VI-78
What makes you feel that a similar situation would not
develop in Leon County?
43. The State requires that local governments cooperate and
publish a policy document entitled the "Local Government
Comprehensive Plan" (LGCP). The LGCP calls for higher
population densities in and near the central d.ity to cut
^ down on the length of utility runs and roads. The DEIS calls W~79
2 for less dense population thru spreading out of communities.
v Since the EIS branch has a copy of the LGCP, why is the EIS
suggesting a direction counter-current to local & State
government planning?
W-80
45. Why wasn't the alternative "Modified la" as described
in recent City correspondence evaluated in the DEIS? W~8l
N-82
16 v-30
-------
47. Were the costs of wells & sampling included in the cost
effectiveness analysis of alternative IV? If not, why not?
48. Should contamination be found in the drinking water wells,
will EPA fund a study to determine how it can be remedied?
V-31
17
-------
On-Site Wastewater Mangement
District Responsibilities
The EIS recommends the use of on-site wastewater disposal
systems for most future developments in Leon County. This has
the effect of shifting some of the responsibility for wastewater
disposal from the City to other agencies.
Concerning on-site systems the EIS states the following:
"Operation and maintenance problems as well as siting and
construction inadequacies are cited as reasons for doubting
the effectiveness of on-site systems in growth areas. These
are considered to be institutional problems that can be
overcome."
Institutional problems are not easily overcome. They
usually prove more difficult to solve than engineering problems.
If a management district fails to overcome the institutional
problems, it will be individual homeowners who suffer, not the
district. Following are some of the institutional problems each
district will have to face:
1. Any measures implemented by a district which would
increase the cost of septic tanks and drainfields will be met
by strong opposition from developers.
Each district will be the homeowners sole line of
defense against developers who want to "get in and get out"
at the lowest cost. A new septic tank and drainfield, even if
poorly designed, will probably work fine for a year or so; or
at least beyond normal warranty periods.
Developers will place tremendous pressure on each
district to allow development of marginal areas for septic tanks.
18
V-32
-------
2. The EIS recommends that management districts regulate
the design, construction, operation and maintenance of on-site
disposal systems, and lists the services which need to be W~86
provided. Where will the money come from to regulate on—site
disposal systems? Certainly, developers will strongly resist
any increase in permit fees.
3. Districts must change their attitude from viewing
drainfields as temporary systems to viewing them as permanent
systems. See the attached memorandum from the Leon County
Health Department.
4. Drainfields which must last 40 years will require
reworking of existing design rules. Flexibility in design VI-88
from lot to lot will be needed; and this goes directly against
regulators who try to make everything "fit in one slot".
5. Can a district be sued when a district approved septic
tank and drainfield design fails?
6. Possible, districts have little or no experience with
package plant designs, operation and maintenance, or the design
of sewer lines, pumping stations, and force mains which feed VI-90
the package plants. They will have to train or hire new
personnel to adequately regulate these facilities.
Do you feel the responsibilities are valid? If not, why not?
19
V-33
-------
t: u'j
Fi
H £-3
si a
0. J. X.lUf. Jr.. Stc/«bi7
DIVISION OF HEALTH -
ftjvkiA 0*0 C«
• £. CHAAL70/J PRATHER, M.O.. M.P.H. Oi*cct0«
II
Leon County Health Department
2965 MUNICIPAL WAY
P. O. BOX 27^5
TALLAHASSEE. FLORIDA 32204
TELEPHONE (9QA) SV6-121S
201 Prog:
io/23/e:
B. E. BENNISON. M.O.. W.P.H.
&l«C«TO«
Hay 8, 1975
MEMORANDUM
TO: 3. S. 3ENNIS0NM.D. DIRECTOR
RRCtt: GEORGE M. BOYD, R. S. , DIRECTOR jsj/l/.
DIVISION OF ENVIRONMENTAL HEALTH
-------
Reasons Why the EIS Cost estimates
for Alternative IV are too low
1. Cost estimates were based on current septic tank
designs which have proven to be inadequate as permanent
facilities. Can you show that costs were considered for W~91
facilities more adequate than the State's "minimum standards"?
2. The EIS lists many functions to be performed by the
management district responsible for the on-site systems. W~92
Can you show where costs for these services were included
in the estimates?
3. The design life of houses is 50± years, therefore the
drainfields should last this long. No drainfield constructed
in clay soil can function for 50 years unless grossly overdesigned W~93
initially. Can you show where the EIS included costs for
periodically rebuilding the drainfield?
4. We consider a drainfield as "lost land" which has a
value. The loss would be to natural vegetation, animal ^ ^
habitat if left alone or to recreation such as gardening
if cleared. Do you agree? If not, why?
5. Small community systems (package plants) are described
as the most expensive wastewater treatment system per gallon
of water treated, and they play an integral part of
Alternative IV. However, the costs of these systems are VI—9-5
left out of the 17.7 million dollar figure. Can you show
this is not the case and give a cost break down with a
source reference? How many package treatment plants does
this allow for?
21 V-35
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Reasons for Reopening the EIS
For Alternative IV to prove to be the most cost effective
and environmentally sound wastewater disposal method, will
depend on many factors. The most important being the ability
of the managment districts to adequately regulate the design,
construction, and maintenance of on-lot disposal systems.
Unfortunately, it will be several years before any judgments
can be made as to how well the districts are doing the job.
This being the case, we feel the EIS should be reopened in
3 years should some of the following occur:
1. Homeowners make numerous complaints about failing
drainfield systems.
2. Evidence is found of developers using their political
influence to construct drainfields in marginal areas
which are doomed to failure.
3. Districts fail to perform the tasks recommended by
the EIS for the management district. These tasks are:
a. Revision of basic rules governing septic
tank use to allow for systems more suited to
current and future demands. These revisions
should include siting criteria, basic system
design, and the use of alternative systems.
b. The implementation of on-site systems
management to promote the efficient operation
of on-site systems.
c. Monitoring of groundwater quality in the
developing areas of Leon County to ensure early
detection of groundwater contamination.
22
V-36
-------
4. EIS cost estimates for on-lot disposal systems
prove to be substantially low due to the expense of
permanent on-lot disposal systems constructed in
clay soils.
5. Districts are unable to adequately regulate small
community systems.
6. Local wastewater treatment plants fail to meet
Florida Department of Environmental Regulation rules.
7. Florida Department of Environmental Regulation
allowing the use of trickle filter plants without
filtration for spray irrigation. This would substantially
lower the EIS cost estimates for Alternatives I, II, and III.
Do you feel the EIS should be reopened if any of these
seven
items
items occur? If not, which items or combinations of W-96
would warrant a reopening of the EIS?
23
V-37
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DEPARTMENT OF THE ARMY
M08ILE DISTRICT, CORPS OF EN6INEERS Hildreth/rwr/FTS 537-4141
P. 0. BOX 2288
MOBILE. ALABAMA 36628
REPLY TO
ATTENTION O Ft
SAMPD-EE
13 November 1981
Mr. John E. Hagan III, P.E.
Chief, EIS Branch
EPA, Region IV
345 Courtland Street, NE
Atlanta, GA 30365
Dear Mr. Hagan:
We have reviewed the Draft Environmental Impact Statement for Tallahassee-Leon
County Wastewater Management, Tallahassee, Leon County, Florida. The statement
appears adequate concerning matters related to the responsibility of this
office. We have no specific comments to offer.
Thank you for the opportunity to review the statement.
Sincerely,
WILLIS E. RULAND
Chief, Environment and Resources Branch
V-38
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(404) 262-6649
November 13, 1981
Mr. John E. Hagan, III, P.E.
Chief, EIS Branch
U.S. Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Mr. Hagan:
We have reviewed the Draft Environmental Impact Statement (EIS) for the
Tallahassee-Leon County Wastewater Management 201 Facilities Plan (Phase 2),
Tallahassee, Florida. We are responding on behalf of the Public Health
Service and are offering the following comments for your consideration in
preparing the final document.
We understand- that Alternative 4 (No-Federal Action or Limited-Federal Action)
has been selected to be the preferred alternative because it is considered by
EPA to be the most effective and environmentally sound alternative. Since _
this alternative for disposal of sewage effluent would be handled by a variety W~98
of on-site treatment systems, we believe the local zoning and building inspec-
tion agencies must have satisfactory regulatory authority to prohibit the
construction of on-site systems on lands which would be unsuitable.
A determination of suitability would depend upon many factors including: land
use, density of on-site systems, slope, soil type, permeable soil depth above
water table, soil clogging, minimum lot size, proximity to water bodies and
watercourses, springs and karstic features, and location of other on-site y An
systems, water supply lines, and/or wells. Are all these factors considered "
by the Leon County Health Department in approving new on-site systems? What
authority does the Leon County Health Department and other county agencies
have in regulating and monitoring the construction and management of on-site
sewage treatment systems? Do any regulations exist for installing private
wells or other on-site drinking water supplies? What local standards exist for W-Tflfl
satisfactory casement and monitoring of private and public wells for drinking
water?
Several control methods and installation procedures for on-site systems are
recommended in EPA's Polluted Groundwater: Some Causes. Effects. Controls
and Monitoring, EPA-6001 4-73-0016, July 1973. These should be discussed in
the EIS and, where applicable, recommended for implementation by the local
health department to prevent long-term failure of on-site systems and degradation
of groundwater. Where local regulations for regulating on-site treatment systems
V-39
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Page 2 - Mr. John E. Hagan, III, P.E.
are unsatisfactory, we believe local authorities should be required to adopt
appropriate regulations for approving on-site systems before funds are released
for other eligible elements under Alternative 4 of the Phase 2 Facilities Plan. W" 101
While we fully support the "primary recommendations" listed on page IX of the
EIS to mitigate potential impacts associated with Alternative 4, we believe
these measures should be subject to EPA1s review and approval.
It is indicated on page III-5 that "travel through two to four feet of
unsaturated soil will provide adequate removals of pathogenic organisms and
other pollutants from the wastewater." Please provide references of research y -i/y)
that document this viewpoint. It should be recognized that "adequate removals" ""lUt
depend primarily upon the soil's physical and hydrologic characteristics. We
believe the statement quoted above should be revised with qualifiers such as
"suitable" and "may." Our experience, as well as an examination of the
literature, reveals many cases where pathogens and/or pollutants have migrated
considerable distances through subsurface soils and strata to contaminate
potable groundwater sources. The four-foot limitation associated with "unsatu-
rated soil" (see above) usually refers to satisfactory retainment of sewage
effluent in the drain field below the ground surface. According to the Report •
to Congress, Waste Disposal Practices and Their Effects on Groundwater. January W~].03
1977, two criteria have been successful in keeping septic tank effluent below
the ground. These criteria require: a minimum 4-foot separation between the
bottom of the seepage system and the maximum seasonal elevation of groundwater
and a reasonable thickness, usually 4 feet, of relatively permeable soil '
between the seepage system and the top of an impervious soil or rock formation
The types of septic tank system failures that have been documented by the L
County Health Department should be described. Have any of these fail h60n W"10^
associated with: standing pools of sewage or effluent where direct hu"1^68
is likely, sewage in basements, or contamination of private wells d/^ Contact
waters used for water supply purposes? an r surface
We appreciate the opportunity to review the Draft EIS. Plea
of the final document when it becomes available. Should vo Sh S6n US °ne C0^
about our comments, please call Robert Kay of my staff at FTS 236-6649qUeStl°nS
Sincerely yours,
Frank S. Lisella, Ph.D.
Chief, Environmental Affairs Gm.m
' SMr&rr.
I •
70=;
';3J »
V-40
•epa
-------
United States Department of the Interior
OFFICE OF ENVIRONMENTAL PROJECT REVIEW
Southeast Region / Suite 1384
Richard B. Russell Federal Building
75 Spring Street, S.W. / Atlanta, Ga. 30303
ER-81/1983
November 16, 1981
Mr. John E. Hagan, III
Environmental Protection Agency
345 Courtland Street, NE
Atlanta, Georgia 30365
Dear Sir:
We have reviewed the Draft Environmental Statement, Tallahassee-Leon
County Wastewater Management, Leon County, Florida, and have the follow-
ing comments.
General Comments
In general the draft statement is well written and recognizes fish and
wildlife resources and their habitats. Adequate consideration has also y qnc-
been given to mineral activity within the study area. The statement W-IUd
does a good job discussing alternatives and impacts of the proposed
work.
Specific Comments
Page IV-25. Daraqraph 3. The fish fauna found within the project area
should be listed in the draft document. Although such a list is found N-10$
in the 201 Plan, many reviewers may not have access to the document.
Summary Comments
The Fish and Wildlife Service is in agreement with the selection of
alternative 4 (No-Federal-Action) as the preferred alternative. W-107
Thank you for the opportunity to comment on this document.
Sincerely
V-41
-------
0.
>v fill ta °* DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT
~ I OP iS ATLANTA REGIONAL OFFICE
llllll ; RICHARD 8. RUSSELL FEDERAL BUILDING
\ l| llll 75 SPRING STREET, S.W
jA30 W*
ATLANTA, GEORGIA 30303
REGION IV IN REPLY REFER TO-
November 23, 1981 40
John E. Hagan III, P.E.
Chief, EIS Branch
EPA, Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Mr. Hagan:
Reference: Tallahassee-Leon County, Florida
201 Area Draft EIS
We have completed our review of the referenced Draft EIS, and wish to
offer the following comment.
HUD's concern in this matter relates to the selection of the preferred
alternative. For many years HUD has discouraged new growth development
in areas using "on-site" sewerage disposal systems. Requests for
mortgage insurance have been denied because the sewerage disposal
methods were "on-site" systems. "On-site" systems can only be considered
for FHA mortgage insurance in residential development proposals if ¦
establishment of a central collection and treatment system, or connection
to an existing system has been found economically and/or phvsicallv
infeasible. As a result, applicants for FHA mortgage insurance for
new growth developments are encouraged to develop in those areas wh^rp
central systems are available, or if their development is larae enouah
to construct a central collection and treatment system for their orniprt
The preferred alternative selected by EPA may therefore limit the
availability of FHA mortgage insurance in the Tallahassee-Leon County
afford1"9 US w1th the °PP°rtunity to review and comment
Sincerely,
toiVllfft::" ¦ : .-EMLNT
rown
Regional Administrator
II!
i ¦
liG 7 2 5 |
Li jsEMind.
REGION IV • EPA
V-42
AREA OFFICES
BIRMINGHAM. ALABAMA' COLUMBIA, SOUTH CAROLINA • GRttNlBOKO, NORTH CAROLINA .JACK»ON. Ml»tl«*
ATLANTA, SEORO JACKSONVILLE. FLORIDA- KNOXVILLE, TENNESSEE « LOUISVILLE. KENTUCKY
-------
1808 Old Briar Trail
Tallahassee, Florida 32304
November 25, 1981
Mr. John E. Hagan III, P.E.
Chief, EIS Branch
EPA, Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Mr. Hagan:
We are writing to reiterate our support for the alternative
selected regarding the recommended spray irrigation site in the
Tallahassee Environmental Impact Statement. As we stated at the
public hearing on November 5, 1981, we believe the consultants
recommendation that the spray field be placed in an isolated
area is far more sound than putting a spray field in close
proximity to populated neighborhoods. Leon County has an
abundance of nondeveloped land which is suitable for spray
irrigation. There is no need to subject the citizenry to the
possibility of ground water and odor pollution, transmittal of
virus, bacteria, parasites, etc., not to mention the depreciation
of property values. We have heard far too many horror stories of W~109
the after effects of pollution to feel secure with allowing the
placement of such a facility near our homes a.id simply do not
see the necessity for taking such a chance if there is an
alternative solution.
We would also like to take this opportunity to thank the
officials conducting the Tallahassee EIS. While we have always
argued that the Review Committee was too heavily stacked with
officials of the City of Tallahassee, the various EIS authorities
have continually been willing to meet with us and listen to our
concerns. We will be eternally grateful for their attention to
those concerns.
Sincerely,
/Glenn Carter, President Jessie Brown, Secretary/Treas.
Munson Area Preservation, Inc. Munson Area Preservation, Inc.
cc; Claude Terry & Associates, Inc.
Gannett Fleming Corddry & Carpenter, Inc.
V-43
EWV!P',NVi;.: iiV:T/ic)' STATEMENT,
i,11;
! V
ft cec 03 mi •(,'!
ill '!1
7 -TA
-------
jrweu otdtc
Department
Agriculture
' Jnited States
*4 A i .< Hanar+mont r\
5 Department of
Soil
Conservation
Service
P. 0. Box 1208
Gainesville, FL 32602
subject: EVT - Draft Environmental Impact
Statements
Date: November 30, 1981
ro: John E. Hagan III, P.E.
Chief, EIS Branch
EPA, Region IV
345 Courtland Street, K.E.
Atlanta, Georgia 30365
We have no comments on the DEIS for Tallahassee-Leon County
Wastewater Management Plan.
'James w. MitcSJsll
State Conservationist
H-llfl
cc: Norm Berg, National Office, Washington, D.C
ENVIRON"' * oifTtMrNf
i. r • . !
1 ««*-• w
REGION IV • D *
The Soil Conservation Service
is an agency of the
Oepartment of Agriculture
V-44
SC8-AS-2
i0-79
-------
STATE OF FLORIDA
xtt of tht (Unfcrmtur
THE CAPITOL
TALLAHASSEE 32301
Bob Graham
GOVERNOR
December 2, 1981
Mr. John E. Hagan III, P.E.
Chief, EIS Branch
EPA, Region IV
34 5 Courtland Street, NE
Atlanta, Georgia 30365
Dear Mr. Hagan:
In reference to your Draft Environmental Impact
Statement for Tallahassee-Leon County Wastewater Management,
Tallahassee, Leon County, Florida, please be advised that
we have circulated these documents to the concerned state
agencies for their review and comment.
Attached for your consideration are comments submitted
by the Department of Veteran and Community Affairs and the
Department of Natural Resources. No other substantive comments
have been received to date regarding this document. However,
the Department of Environmental Regulation may submit comments W_111
at a later date. The Department of Veteran and Community Affairs
does raise several valid concerns regarding the project,
specifically potential impact on the local government's
financial capabilities. We strongly suggest that this issue
and others raised by the Department be given serious
consideration in developing your final document.
Thank you very much.
Sincerely,
WOK/jkc
Mr. John Outland
Mr. Art Wilde
Mr. Brad Hartman
Walter 0. Kolb
Sr. Governmental Analyst
cc: Mr. John Burke V *
V-45
An Affirmative Action/Equal Opportunity Employer
I;.: -•
h\ ;sWl ijlj
"-'-CM IV . f 0A W
jun
-------
STATE OF FLORIDA
DEPARTMENT OF VETERAN
AND COMMUNITY AFFAIRS
OFFICE OF THE SECRETARY
BOB GRAHAM
Governor
JOAN M. HEGGEN
Secretary
November 6, 1981
Mr. Walter B. Kolb
Senior Governmental Analyst
Executive Office of the Governor
The Capitol
Tallahassee, Florida 32301
Dear Walt:
SUBJECT: Draft Environmental Impact Statement for
Tallahassee-Leon County Wastewater Management
SAI-FL8109230442E
A Department of Veteran and Community Affairs' staff review of the
referenced project was based on the agency's advocacy of the viability of
Florida's local governments and on our awareness and knowledge of their
operations. In that context, this Department wishes to bring several matters
to the attention of the Environmental Protection Agency.
One basic concern overrides all otters in our review and analysis of
the Environmental Impact Statement Preferred Alternative: namely, inadequate
discussion of the implications of No-Federal-Action in regard to Leon
County's wastewater treatment system. On pages ix, 11-22 et. seq. and
111-10, statements alluding to the methods for coping with weaknesses of
small community systems or septic tank wastewater disposal seem to overlook a
number of implications.
For example, the pressures for keeping costs of local government'" as low
as possible are leading to reductions of service levels, not increases.
Little in the way of resources are available in Leon or other counties or
municipalities for the level of staffing required to do groundwater monitoring,
not to mention enforcement of the nature and extent required here. Evidence
of this lack of resource is implicit in numerous Leon County public works
procrams, including road maintenance, storm drainage, tree ordinance
enforcement, and so on. Consultants for the Draft Environmental Impact
Statement show little understanding of local government capability in today's
budget-squeezed world.
V-46
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Mr. Walter B. Kolb
November 6, 1981
Page Two
Furthermore, there is apparent lack of appreciation for the strict
administrative procedures under which Florida agencies operate. The Draft
Environmental Impact Statement states that the employees of a proposed special
district government could go on private property (a small sewer system
treatment plant) and put the system in working order when it malfunctions. W-113
Only the most exacting definitions of malfunctions specifically directed
toward each case would allow such activity without the delays of an
administrative hearing. Who is to pay for the entire process?
Finally, staff members of this Department have witnessed the coming of
the wastewater disposal day of reckoning in several urban counties in Florida,
specifically Escambia and Duval Counties, where package plants deteriorated
and eventually were purchased by the local government at the insistence of the
residents. That situation could be repeated in Leon County if the
Environmental Protection Agency's recommendation is adopted.
The Department of Veteran and Community Affairs wishes to see more
attention paid to the disadvantages attendant to the implementation of
proposed alternative (4) in management terms.
¥-114
JGB/DP/sg
-------
State of Florida
epartment of Natural Resources^
Interoffice Mer.\
November 19, 1981
TO:
FROM:
Art Wilde
Contracts and Fixed Capital Outlay Coordinator
Ted Forsgren, Chief
Bureau of State Lands ^Tartiagement
Division of State Land's
SUBJECT: SAI #FL8109230442E, DEIS for Tallahassete - Leon
County Wastewater Management
The material provided is too general for us to do a detailed
review of state-owned lands involvement in this proposal.
If state-owned lands are involved, approval must be obtained W-ll5
from the Board of Trustees of the Internal Improvement Trust
Fund for their use.
The material provided us is returned herewith.
TF:hhc
Attachment
V-48
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STATE OF FLORIDA
DEPARTMENT OF ENVIRONMENTAL REGULA TION
"WIN TOWERS OFFICE BUILDING
300 BLAIR STONE ROAD
CALLAHASSEE, FLORIDA 32301
December 3, 1981
BOB GRAHAM
GOVERNOR
VICTORIA J. TSCHINKEL
SECRETARY
Mr. John E. Hagan III, P.E., Chief
EIS Branch, EPA Region IV
U.S. Environmental Protection Agency
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Re: CI20581010 (Step 1) - City of Tallahassee
Tallahassee-Leon County EIS
Dear Mr. Hagan:
The Florida Department of Environmental Regulation has completed its review of the
above referenced Environmental Impact Statement (EIS) and adds the following comments
to those previously submitted September 30, 1981:
1) The recommended on-site disposal alternative has potential for contami-
nation of potable groundwater supplies, since in many areas the over-
burden may not be adequate to protect the resource. Also, some surface U-llg
water areas may discharge directly into the Floridan Aquifer through
sinkholes.
2) The planned use of septic tanks may be satisfactory for a rural setting
but these systems are inappropriate for high density developments. The
soils suitability map for the 201 project areas, which shows all of the W-117
northern area of the county acceptable for septic tank use, is question-
able. In view of the variation in soils, suitability would have to be
confirmed by individual percolation tests.
3) Small package wastewater plants can create problems in the long run.
Operation and maintenance of these small facilities is generally not
of the same quality as for regional systems. In many instances, this
inadequately and/or inconsistently treated waste will be disposed of in yiio
percolation ponds which have the potential for rapid transmission into "~-L-Lo
the ground water resource. In the regional systems adequate monitoring
usually demonstrates the effectiveness of treatment and disposal by land
application.
4) It may not be economically feasible to provide interceptor sewers for
collection of the waste due to the population density at this time; how-u 11Q
ever, planning should certainly continue to provide this service in the Vr-lla
future.
V-49
Protecting Florida and Your Quality of Ufa
-------
Mr. John E. Hagan
December 3, 1981
Page Two
Unless planning is carried out and guidance given to future development,
Leon County may experience the same problems with growth that other
counties have experienced.
In summary, the plan as outlined will take some rigid controls if the small
systems are collectively going to function as efficie-tly as one or two large
spray irrigation sites with centralized treatment. The selected alternative
leaves some doubt as to whether adequate protection of the groundwater will be
provided.
If you have any questions/comments please contact me at 904/488-2582.
Si ncerely,
Richard W. Smith, P.E., Chief
Bureau of Wastewater Management and Grants
RWS/vhj
cc: Michael Schneider - City of Tallahassee
David Peacock - EPA
Richard Sublette - DER/Pensacola
A1 Bain - Gannett Fleming
.• wr.'.-j sta.s
i r:
!v-
V-50
lilte'iS'L-.. -
REGION I«
-------
HURLEY W. RUDO
^•VtOR.COMMISSIONER
JAMES P. FORD
m \ • o p -S R q - £ M . c O x* M I S 5 : O t* ER
: " ^ isi JNiiR
g:.s
5AS<'JEL E. "EhGUE
- •_• <4 si : s s, -• ER
T-L «l-^1
• -v
DANIEL A. KLEMAN
CITY MANAGER
HERBERT J. SECKEL
: TV AIIOITOH.CLERK
BRYAN W HENRY
. ;~v vrTo/'NO
I ELeiPHONE
004i 599-8100
CITY HALL
•-i • } o 1
December 4, 1981
Mr. John E. Hagan III, P.E.
Chief, EIS Branch
EPA, Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
Attention: Mr. Bo Crum
Dear Mr. Hagan:
Please add the following comments to our earlier
submittal.
A. On page III-4 of the Draft Environmental Impact
Statement a primary impact of fifteen stream crossings is
reported in the sixth paragraph. A primary impact implies
a big problem, therefore I asked for a map showing the
crossing points. The contractor sent a map and a letter
which reduced the fifteen crossing to ten.
On November 13, 1981, Mr. Bob Ballard and I made a
field check of the area depicted by the Gannett-Fleming map.
On that map, I have labeled their ten crossings "A"
thru "J". The sites where photographs were taken are
labeled with Roman numberals "I" thru "IX". In three
"locations (VI, VII & IX) photographs were made at road
crossings as the lack of any flow under the road indicated
there wouldn't be any flow found up or down the dry bed.
Please be advised that it is no problem to write into
a construction contract the provision that cuts made for
laying pipe be dug in dry weather only. This is specifically
what we would do in this situation.
V-51
¦lc-iudxs capital cur — s/.m/.vc; all Florida
-------
Mr. John E, Hagan
EIS
Page 2
The following conditions were found at sites "I" thru
"IX" as labeled on the enclosed map and documented by the
enclosed photographs which are similarly keyed.
I. 0" the south side of the road a one quarter inch
trickle of water was coming out of the metal conduit. On
the north side of the road dirt blocked the bottom one inch
of the box culvert preventing any flcv whatsoever. The
conclusion is that a non-moving puddle was found on the
south side of the road and no flow under the road. The
puddle was approximately 5' x 8'.
II. On the south side of the road was a non-moving
puddle with no water inlets or outlets. On the north side
of the road was dry land where Bob is shown. The box culvert
had less than one inch of water in the south end and no water
in the north end. The conclusion is that there is no flow
at this point.
III. In the photographs it can be seen that there is no
flow on either side of the railroad trestle. A stagnet puddle
can be seen on the south side. The conclusion is that there
is no flow at this point.
IV. In the photographs tire tracks can be seen crossing
under the trestle. There was a very slow northerly flow in
the tire tracks. Please note the flow direction. The
conclusion is a very small flow.
V. In the photographs one can see Weems Pond which is
not a good crossing point. If the line crossed on the other
side of the road, a very small flow would be encountered.
There is less than one inch of water in the three 48" conduits.
The conclusion is a very small flow.
VI. These photographs show the dry box culvert which
indicates no flow. Also shown is a puddle on the south side
which stops at the fence. The conclusion is no flow at the
road and little chance of flow at "F" or "G".
VII. These photographs show no flow whatsoever under
Miccosukee Road. The conclusion is that there is little
chance of flow at "H" as none passes under the road.
V-52
-------
Mr. John E. Hagan
EI S
Page 3
VIII. These photographs show a two inch flow in the 48"
pipe nearest Bob. There was no flow in the other two pipes.
The conclusion is that, while this is the largest flow found,
it would not be difficult to protect while laying a pipe line.
IX. These photographs show dry ground on either end
of the culvert which passes under Thomasville Road. The
conclusion is that there is no flow under the road and little
chance of flow at "J".
The situation might be summarized by stating that there
is only a very small flow at three of what was reported in
the DEIS to be fifteen streams. The cumulative flow of the
three "streams" is estimated to be one gpm. I do not feel
this situation is significant enough to be reported in an EIS
as a primary impact, do you? If you do feel it is significant
please explain why you feel that way. Please keep in mind
we would only construct the lines during dry weather. Had we
not field checked this situation, most readers would have had
no trouble "picturing" the never to be doubted EIS description
of fifteen streams.
B. The EIS, on several occassions when discussing the
suitability of on-site wastewater disposal systems for Leon
County, referred to a publication by Richard L. Guthrie and
Gerald J. Latshaw entitled "Soil-potential ratings for septic
tank absorption fields in Leon County, Florida". This
publication gives a "High" rating for septic tank absorption W~122
fields to the most common soils found in northeast Leon
County (e.g. Lucy, Norfolk,and Orangeburg soils, see general
soil map).
I feel that this report gives a false sense of
security to persons unfamiliar with the soils in this County
and is inaccurate. Our comments on the soil conditions in
northeast Leoft County and the soil potential ratings publication
follow:
I. The source for our information is the Soil Survey of
Leon County by the United States Department of Agriculture
Soil Conservation Service and Forest Service, 1979.
A review of soil maps contained in the survey reveals that
the Orangeburg, Lucy and Norfolk soils are the most common soils
found in northeast Leon County. A description of these soils,
follows:
V-53
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Mr. John E Hagan
EIS
Page 4
Orangeburg-Lucy-Norfolk, Page 9
These are nearly level to strongly sloping, well drained
soils; some are loamy throughout; some are sandy to a depth
less than 20 inches and loamy below; some are.sandy from 20
to 40 inches and loamy below.
The map unit which includes these soils is the largest
unit in the county and occupies most of the northern sector.
The City of Tallahassee and the Lake Jackson area are in
this unit.
This unit consists of nearly level to gently sloping soils
on uplands in most areas but consists of sloping to strongly
sloping soils in drainageways. There is a fairly well developed
drainage system of creeks and branches. Many ponds and small
lakes are scattered throughout the unit. The native trees
include slash, longleaf, shortleaf, and loblolly pines, live
oak, red oak, white oak, hickory, magnolia, sweetgum, dogwood,
and an understory of woody shrubs and grasses.
This unit makes up about 112,800 acres or 26 percent of
the county land area. It is about 60 percent Orangeburg soils,
13 percent Lucy soils, 5 percent Norfolk soils, and 22 percent'
soils of minor extent.
Orangeburg soils are well drained. Typically, the surface
and subsurface layers are fine sandy loam. The upper 5 inches
is brown, and the lower 5 inches is yellowish red. The subsoil,
extending to 80 inches or more, is yellowish red and red sandy
clay loam.
Lucy soils are well drained. Typically, the surface layer
is dark grayish brown fine sand about 5 inches thick. The
subsurface layer is dark yellowish brown, dark brown, 'and strong
brown fine sand about 19 inches thick. The subsoil is yellowish
red sandy clay loam to a depth of 80 inches or more.
Norfolk soils are well drained. Typically, the surface
layer is yellowish brown loamy fine sand about 4 inches thick.
The subsoil is brownish yellow and yellowish brown fine sandy
loam and sandy clay loam to a depth of about 58 inches where it
changes to strong brown and reddish yellow sandy clay. The
substratum is mottled brownish yellow, strong brown, and gray
sandy clay that extends to 80 inches or more.
V-54
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Mr. John E. Hagan
EIS
Page 5
Of minor extent in this unit are Blanton, Faceville,
Wagram, Yonges, and Lynchburg soils and Urban land.
Many areas of this unit are in native trees. Some
areas have been cleared for improved pasture, hay, and
cultivated crops such as corn, peanuts, and soybeans.
Some areas are in urban use.
II. Following are additional excerpts from the soil
survey:
1. Sanitary Facilities, page 48.
Table 11 shows the degree and the kind of soil
limitations that affect septic tank absorption
fields, sewage lagoons, and sanitary landfills.
The limitations are considered slight if soil
properties and site features are generally
favorable for the indicated use and limitations
are minor and easily overcome; moderate if soil
properties or site features are not favorable
for the indicated use and special planning,
design, or maintenance is needed to overcome
or minimize the limitations; and severe if
soil properties or site features are so
unfavorable or so difficult to overcome that
special design, significant increases in
construction costs, and possibly increased
maintenance are required.
Septic tank absorption fields are areas in
which effluent from a septic tank is distributed
into the soil through subsurface tiles or perforated
pipe. Only that part of the soil between depths of
24 and 72 inches is evaluated. The ratings are
based on soil properties, site features, and
observed performance of the soils. Permeability,
a high water table, depth to bedrock, and flooding
affect absorption of the effluent. Large stones
and bedrock interfere with installation.
Unsatisfactory performance of septic tank
absorption fields, including excessively slow
absorption of effluent, surfacing of effluent,
and hillside seepage, can affect public health.
V-55
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Mr. John E. Hagan
EIS
Page 6
Ground water can be polluted 11 nigua.y perraeauie
sand and gravel or fractured bedrock is less than
4 feet below the base of the absorption field, if
slope is excessive, or if the water table is near
the surface. There must be unsaturated soil
material beneath the absorption field to effectively
filter the effluent. Many local ordainances require
that this material be of a certain thickness.
Table II. Sanitary Facilities, Page 115.
Soil Name
Lucy
0-8 percent slopes
Norfolk
2-8 percent slopes
Norfolk
Clayey Substratum
2-8 percent slopes
Orangeburg
2-8 percent slopes
Orangeburg
8-12 percent slopes
Absorption Field Limitations
Moderate:
Perks Slowly
Moderate:
Wetness
Moderate:
Perks Slowly
Moderate:
Perks Slowly
Moderate:
Perks Slowly, slope
2. Physical and Chemical Properties, pa%e 52.
Table 15 shows estimates of some characteristics and
features that affect soil behavior. These estimates
are given for the major layers of each soli ?n ?he
survey area. The estimates are based on field
observations and on test data for these and similar
soils.
Permeability refers to the ability of a soil to
transmit water or air. The estimates indicate the
rate of downward movement of water when the soil is
saturated. They are based on soil characteristics
observed in the field, particularly structure DS?ositv
and texture Permeability is considered in the design
saturated conditions afiects behavio? ® '"OVement Under
V-56
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Mr. John E. Hagan
EIS
Page 7
Table 15 -
Soil Name
Lucy
- PHYSICAL AND CHEMICAL PROPERTIES OF SOILS-Page 1an
Depth
In
Q-30
3Qrv36
36-80
Permeability
In/hr
6,0-20
2.0^6.0
0.6^2,0
Norfolk
2-8 percent slopes
0-8
8-58
58-80
6.0-20
0.6-2,0
Q.6-2.0
Norfolk
clayey substratum,
2-8 percent slopes
0-7
7-14
14-64
64-80
2,0-6.0
2,0-6.0
0.6-2.0
0.06
Orangeburg
2-12 percent slopes
0-10
10^80
2,0-6.0
0,6-2.0
III The EIS included in their Preliminary Decision Paper
an article by Richard L. Guthrie and Gerald J. Latshaw entitled
"Soil-potential ratings for septic tank absorption
Leon County, Florida." In this article the authors rated the
Lucy, Norfolk, and Orangeburg soils as having a "High" potential
forseptic tank absorption fields. We strongly question these
ratings because of information shown in Table 2 of this article
and its treatment of one of the most important factors in the
reliability of drainfields *¦ Permeability.
Following is Table 2 in its entirety:
,or Pf*P*rta9 potwitUi ratings for'aapMe tank ttttarltafcft'dKIMroffc fMmy ftna sand, 2 to S |
t «op*«, Laon
£*ptor$
!^,na Nona
* ,abl« dapth 4-6 ft
Sort
and SJta Mono of Efforts
Condition* Limitation on Uao
Kind
Comcthm maaaurma
Indoit Kind
Continuing I imit*,,—
Indax
P*fmnbi
ility
Sllyttt Nona
Modarata Posaibki contamlna- Additional labor ba-
llon of cauaa of difficulty
groundwatar in Inattllfng tank
0.8-2.0 In/hr Modarata FaJlura of ayatam Enlaraa flaW to
570 «q
Fsquara fact
PoMlWaeontamtoia- 3
Won of groundwatar
Nona
9a
10-15 mlnfln
2-5 parcant
^ ^•snsr1 5 1
ftuant In dram ffalcf
Total
11
jofmanca ittndard indax) - 11 (maaaura coat Indax) - 4 (continuing limitation coat Indax) » 85 (toll potential Indaxi
V-57
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Tabla 2. Worksheet lor preparing toil potential ratings^o?"septlc^fanT
County. Florida.
•Ids on^Afrfblk loamy tin* sand, 2 to 5 percent slopes, Laon
Evaluation
Factors
Soil
and Site
Conditions
Degree of
Limitation
Effects
on Use
Corrective measures
Continuing Limitatic
Kind
Index Kind
Index
Flooding
later table depth
Permeability
Slope
None
4-6 ft
Slight
Moderate
0.6-2.0 in/hr Moderate
10-15 min/in
2-5 percent
Slight
None
Possible contamina-
tion of
groundwater
Failure of system
Surfacing of effluent
on lower slopes
Additional labor be-
cause of difficulty
in installing tank
Enlarge field to
570 square feet
Design and install sys-
tem to distribute ef-
ffuent in drain field
Total
Possible contamina-
tion of groundwater
None
Surfacing of effluent 1
on lower slopes
11
100 (performance standard index) - 11 (measure cost index) - 4 (continuing limitation cost index) = 85 (soil potential index)
number of soils, and costs are variable.
However, the advantages afforded by soil-
potential ratings in applying local knowl-
edge and technology easily outweigh their
disadvantages and justify their prepara-
tion.
The ratings apply only to the local area
in which they are developed; and although
costs and corrective measures may change
with time, the relative rating of each soil
should remain the same.
The first step in developing soil-poten-
tial ratings is to identify the specific need
for them. The next step is to identify the
kinds of technical assistance needed in their
preparation. An interdisciplinary team is
!*nportant to ensure use of the latest infor-
ition in determining corrective mea-
sures, continuing limitations, and relative
costs. In the pilot project this team con-
sisted of a septic tank installation contrac-
tor, planners, engineers, sanitarians, and
soil scientists.
The land use for which the soil-potential
is rated must be specific enough to guide
preparation of the soil-potential index. Us-
ing local data modified from national
guidelines (i), the Florida team prepared
the following definition:
"A septic tank absorpton field is a single-
family home sewage-disposal system that
consists of a subsurface system of tile or
perforated pipe that distributes effluent
from a septic tank into soil. The system is
expected to function year-round at the
designated capacity without surfacing of
effluent or pollution of ground water. A
three-bedroom residence on a one-third-
acre lot with public water supply or one-
half-acre lot with private water supply, a
900-gallon septic tank with distribution
box, 400 square feet of absorption field,
and an installed cost of $800 are assumed."
Calculating the index
The index of performance or yield (P)
numerically represents the performance of
November-December 1900
a benchmark soil. A standard such as 100
or, if appropriate, specific yield values can
be used. All soils are measured against the
same standards. In the pilot project, 100
was chosen as the value of P; therefore, SPI
-100- (CM + CL).
Soil scientists and planners identified the
soil factors affecting the proper function-
Table 3. Potential of soils In Leon County, Florida, for septic tank absorption fields.
Soil
Potential
Index Bating Soil
Alpin sand, 0 to 5 percent slopes
Kershaw sand, 0 to 5 percent slopes
Lakeland sand, 0 to 5 percent slopes
Troup fine sand, 0 to 5 percent slopes
Foxwood sand, 0 to 5 percent slopes
Ortega sand, 0 to 5 percent slopes
Kersnaw sand, 5 to 8 percent slopes
Lucy fine sand, 0 to 5 percent slopes
Blanton fine sand, 0 to 5 percent slopes
Bonifay fine sand, 0 to 5 percent slopes
Faceville sandy loam, 2 to 5 percent slopes
Lucy fine sand, 5 to 8 percent slopes
Orangeburg fine sandy loam, 2 to 5 percent slopes
Wagram loamy fine sand, 0 to 5 percent slopes
Faceville loamy fine sand, 5 to 8 percent slopes
Orangeburg fine sandy loam, 5 to 8 percent slopes
Wagram loamy fine sand, 5 to 8 percent slopes
Faceville sandy loam, 8 to 12 percent slopes
Norfolk loamy fine sand, 2 to 5 percent slopes
Orangeburg fine sandy loam, 8 to 12 percent slopes
Norfolk loamy fine sand, 5 to 8 percent slopes
Chipiey fine sand
Arents, 0 to 5 percent slopes
Leefield loamy sand
Lutterloh fine sand, 0 to 5 percent slopes
Ocilla fine sand
Norfolk loamy fine sand, clayey substratum, 5 to 8 percent slopes
Dothan loamy fine sand, 2 to 5 percent slopes
Fuquay fine sand, 0 to 5 percent slopes
Albany loamy sand
Fuquay fine sand, 5 to 8 percent slopes
Lynchburg fine sandy loam
Chaires fine sand
Dothan loamy fine sand, 5 to 8 percent slopes
Leon fine sand
Sapelo fine sand
Talquin fine sand
Plummer fine sand
Ptummer mucky fine sand, depressional
Surrency fine sand
Pelham fine sand
Rutledge loamy fine sand
Rutledge soils, occasionally flooded
Meggett soils, frequently flooded
Yonges fine sandy loam
Dorovan mucky peat
Pamlico-Dorovan complex
100
Very high
100
Very high
100
Very high
100
Very high
96
Very high
96
Vary high
95
Very high
92
High
91
Hign
91
High
90
High
90
H-gh
90
High
90
High
88
High
88
High
88
High
85
High
85
High
85
High
84
High
82
Medium
79
Medium
77
Medium
77
Medium
77
Medium
72
Medium
71
Medium
65
Medium
64
Medium
64
Medium
63
Low
61
Low
61
Low
61
Low
61
Low
61
Low
59
Low
44
Very low
38
Very low
33
Very low
23
Very low
23
Very low
19
Very low
19
Very low
0
Very low
0
Very low
279
V-58
B-2
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Mr. John E. Hagan
EIS
Page 8
I feel the description for soil and site conditions,
degree of limitation, and effects on use as related to
permeability are depicted accurately, but the descriptions
of corrective measures and continuing limitations are very
contrary to local knowledge of soils in this area.
To say that a homeowner with a 0.6 in/hr permeability
rate merely has to enlarge his drainfield to 570 square feet
and will then have no continuing limitations is wrong. In
fact, a 570 square foot drainfield is the same size obtained
when following the roles of the Department of Health and
Rehabilitative Services Health Programs. 10D-6 Standards for
Individual Sewage Disposal Facilities for a 3-bedroom home
constructed on soil with a 15 minute percolation rate; and
the 10D-6 standards were not intended for permanent drainfield
facilities. Drainfields which are to last 40 years must bo
periodically enlarged. The enormity of these two errors is
enough to render the report's entire soil potential index
ratings meaningless.
In conclusion, once again we have a case where authors
from hundreds of miles away make determinations about conditions
in Leon County which are contrary to local history and knowledge.
Please refrain from using the soil potential ratings given by
Guthrie and Latshaw as a basis for any EIS recommendations.
I would like to emphasize again that the Soil Conservation
Service (SCS) rates the Lucy, Norfolk and Orangeburg soil as
having moderate limitations for absorption fields and defines
this as "soil properties or site features which are not
favorable for the indicated use and special planning, design,
or maintenance is needed to overcome or minimize the limitations."
We feel the SCS best describes the soils in northeast Leon
County.
Do you agree with this assessment of the Soil Potential
Ratings article? Do you feel the soil potential rating given
to the Norfolk soil shown in table 2 is correct? If not, why
not? Do you feel the Lucy, Norfolk, and Orangeburg soils are
common for northeast Leon County and do you feel they deserve
a "High" soil potential rating when used as septic tank absorption
fields? If you do, what is the basis for your opinion?
Thank you for the opportunity to comment on the DEIS.
Should there be any questions, please give me a call.
Sincerely,
T. Michael SchneiderP.E
201 Program Manager
TMS/bjs y_59
Attachments
-------
December 4, 1981
Mr. John E. Hagan III, P.E.
Chief EIS Branch
U.S. Environmental Protection Agency Region IV
345 Courtland St., N.E.
Atlanta, Georgia 30365
Re: Tallahassee-Leon County Wastewater Management
Environmental Impact Statement
Dear Mr. Hagan:
This letter is a followup to the verbal comments I made
at the November 5, 1981 draft EIS public hearing. At that
meeting, I pointed out the misleading conclusions and false
assumptions as well as the blatent misrepresentation of facts
by the consultants. My purpose in doing this was to emphasize
the shaky data upon which the consultants based their con-
clusions. In so doing, I wanted to prevent an ultimate EPA
decision based on wrong information.
The current EIS study did not evaluate impacts of the
201 study but attempted to rewrite another 201. Major issues
that were defined as the prime focus of study were not studied
at all. They were defined as not feasible and the need for
gathering information thus eliminated.
The executive nummary read by Mr. Crum at the public
hearing stated, "The EIS was initiated because of the following
issues raised by organizations and individual citizens:
1. "Public health risks may be associated with land
application of wastewater . . ."
V-60
I'LOR!DA'S CA/Tf.W. CITY' — SLRYISC; A/./. FLORIDA
-------
Mr. John E. Hagan III, P.E.
EIS
Page 2
The enclosed highlighted documentation addresses only
this critical element of the EIS. I wish to emphasize the
following details.
1. The major reason for instituting the EIS was to
evaluate spray irrigation impacts of an expanded W-123
SW sprayfield on residents living near Lake Munson.
2. Public health risks of spray irrigation were stated
as being a major issue.
3. The environmental monitoring segment of the EIS
collected no data concerning health risks and
recommended no additional monitoring. Data
presented by the city to the consultants referenced
several studies by EPA which concluded little or
no health risk associated with properly operated
land application systems. This information was not
present in the EIS.
W-124
W-I25
The Alternatives Development Task Report stated that
the SW site was "a viable alternative" (Pg 89-90) and
that "sands exist up to 45 ft. below this surface."
This report also stated (pg. 92) "As described earlier, W—126
the soils (in the SW) are capable of accommodating
large hydraulic loadings making the area amenable to
this method of treatment disposal."
As if written by someone who had never read the above
mentioned report the Draft Alternatives Evaluation
eliminated the SW field from further consideration
by stating "The potential southwest site with its
predominant Albany and Leon fine soils has excellent
bacterial and viral removing characteristics, but the
site is marked by a shallow water table during the W-127
wet months of the year." In addition "... However,
the site (referring the SW site) is characterized by
soils with a depth to high water table that could
result in severe ponding at the site during several
wet months of the year."
These two statements are genuine fabrications born
in the imagination of the consultants. I only ask
that you look at the enclosed highlighted US Department
of Agriculture Soil Survey of Leon County, Florida
(sample period 1975-78) of the proposed SW site for
which this EIS was begun, and see if you can find the
Albany and Leon soils. I sir, cannot.
V-61
-------
Mr. John E. Hagan III, P.E.
EIS
Page 3
The predominant soil is the same as on the existing
sprayfield, which is Kershaw sand, (see specifications
of soils on SW site). We have never had a ponding
problem at the existing site. We have irrigated
under experimental conditions at fates exceeding
10"/day and did not experience any ponding. Contrary
to all available information, the consultant
eliminated the SW site from consideration based on
a ponding problem that does not exist.
In conclusion I ask that you review the highlighted documents
and ask the same questions we have asked in the City - "How did
the consultants reach these conclusions" and "Where did this
information come from?"
Sincerely,
WGL/bjs
cc:
William G. Leseman
Laboratory Supervisor
Tallahassee Water Quality Lab
7.P. Smith
T. M. Schneider
V-62
-------
Specification of Soils on SW Site
Kershaw Sand
Ortega Sand
Alpin Sand
Blanton Fine Sand
0-5 % slopes
0-5 % slopes
0-5 % slopes
0-5 % slopes
Hydraulic Conductivity
Ave. 54.8 cm/Hr
Ave. 32.2 cm/Hr
Ave. 31.2 cm/Hr
Ave. 11.8 cm/Hr
V-63
-------
RESPONSES TO WRITTEN COMMENTS
W-l. No response necessary.
W-2. The first phase of the Tallahassee-Leon Co. 201 Plan was
approved by the EPA in 1978. Work has begun on the Phase I
facilities, and these facilities are not an issue of this EIS
(see Chapter I of the DEIS for further details). Included in the
first phase of the 201 Plan is a new 17.5 mgd sludge handling
facility. This facility calls for a sludge dewatering and land-
filling system.
Because Alternative 4 does not propose further expansion or con-
struction of centralized wastewater treatment and disposal facil-
ities, the 201 Plan Phase I sludge handling facility would be
adequate. For this reason landfilling was noted as the only
option for sludge disposal in Alternative 4 on p. 11-35 of the
DEIS.
Alternatives 1 through 3, on the other hand, would require an
expansion of sludge disposal facilities beyond 17.5 mgd. A
cost-effectiveness analysis was done on the extra capacity needed
and landspreading was chosen as the preferred option. The evalu-
ation of sludge treatment and disposal options is described in
Chapter 7 of the Draft Alternatives Evaluation Report, Volume II.
W-3. Cost estimates for the alternatives were developed for com-
parative purposes and do not include the costs of existing facil-
ities. The O&M costs for wastewater collection, treatment, and
disposal for Alternatives 1 through 3 include only the costs of
the expanded capacity of existing facilities or new facilities.
Therefore, it would not be appropriate to include O&M costs for
the T. P. Smith and Southwest treatment plants in Alternative 4.
W-4. (1) The City of Tallahassee has not expressed any inten-
tion of establishing a centralized management agency and the area
slated for on-site and small community systems is outside of
their service area. A Leon County agency, such as the Health
Department or a community group, such as a homeowner's associ-
ation seem to be the most likely seats for a centralized
management agency in this area.
(2) Presently septage is delivered to the S. W. Treatment Plant
and deposited into the septage digester. Future plans call for
septage to be processed thru the treatment plant by way of the
old head works to the trickling filter. It is estimated that
12,000 additional gallons per day of septage would be produced by
the increase in septic tank usage. This volume of septage would
not be an operational problem.
V-64
-------
(3) The Federal funding eligibility for these facilities is
incumbent on the implementation of a public management agency.
If further sludge and septage disposal facilities are found to be
needed in the future, however, their construction would certainly
be encouraged by an eligibility for Federal funding.
W-5. The text should read 3 to 5 years Four to eight years was
somewhat optimistic and reflects ideal conditions. Cost esti-
mates would not be affected by this change as an average figure
o? 4 year intervals between pumpouts was used for costing pur-
poses. The revision will be noted in Chapter IV of the FEIS.
W-6. The DEIS contains a delineation of the functions and
responsibilities of a management district in Chapter III, pages
III-6 through 111-10. It would not be appropriate for the DEIS
to identify a specific agency to take over these responsibilities
as this should be a local decision.
A description of the Leon County Public Health Department should
be added to page 11-71. The revision will be noted in the FEIS
in Chapter IV, "Revisions to DEIS and Additional Information".
W-7. It is necessary to amend 201 plans once a final EIS is
issued so that the 201 plan is consistent with the final EIS.
The final EIS is EPA's decision on the action of the provision of
Federal funds for proposed facilities, therefore, future requests
by the 201 grantee for Federal funding of wastewater facilities
must be consistent with the Final EIS.
The EIS process eliminates the need for the preparation of a FON-
SI since the EIS satisfies NEPA requirements.
W-8. No response necessary.
w-9 Revisions to the DEIS will be noted in Chapter IV of the
FEIS, "Revisions to the Draft EIS and Additional Information."
W-10. The necessary revisions will be noted in Chapter tv »r0
visions to the DEIS and Additional Information". -LV' Ke_
W-ll. Comment noted.
W-12. Figure IV.10 shows the majority of developing areas in
Leon County to be suitable for on-site systems such as septic
tanks. Figure IV.10 was developed using a series of overlays
incorporating information about land use classes, flood hazard
areas, depth to water table, and soils suitable for on-site sys-
V-65
-------
terns. The source of the soils data was the U.S. Department of
Agriculture (USDA), Soil Conservation Service (SCS).
Slowly permeable soils are quite acceptable for treating septic
tank effluents. Many consist of somewhat slowly permeable loams
and silty clay loams. These fine textured soils with high cation
exchange capacities help to remove nutrients chemically and
therefore are frequently imported into areas that have limiting
horizons at or near the surface. These same soils are also used
in coarse textured sandy areas to overcome problems with rapid
permeability (perc rates of less than 1 minute/inch).
W-13. Figure IV.10 in the DEIS shows at least 3/4 of northern
Leon County to be suitable for conventional on-site systems (see
the response to Comment W-12). Alternative on-lot systems, such
as sand mounds, are available for use on less than suitable
sites.
W-14. (1) Comment noted. The designs and costs developed in
the EIS were based on the Draft Rule of the Department of Envi-
ronmental Regulation - Chapter 17-6 - "Wastewater Facilities".
(2) To optimize both system performance and land use, 1/3 acre
lots are recommended. Lots as small as 1/4 acre are allowed and
with careful system and subdivision design, can be adequate.
(3) Comment noted.
W-15. The National Environmental Policy Act (NEPA) requires that
an EIS be prepared when a proposed Federal Action may have sig-
nificant adverse impacts to the quality of the human environment.
This EIS has been prepared according to EPA's regulations imple-
menting the requirement of NEPA. The conclusions reached in this
EIS are based on sound technical information. There is no reason
to rescind this EIS.
Concerns of the City of Tallahassee, detailed in written comments
W-15 thru W-96 and W-115 thru W-121, have been responded to by
EPA in this Final EIS. The comments received on the Draft EIS
have been carefully considered in the final decision in this
Final EIS.
W-16. The EIS did not use the "exceptional family" to determine
the most applicable wastewater management alternative. There are
families that probably use much more water than an average sized
family with typical habits, however, this family could not be
used as a basis for planning in the EIS. With the growing water
shortage problems, any reduction in excess water use would proba-
bly be considered a benefit and therefore, would be a positive
impact for this alternative.
V-66
-------
W-17. Comment noted. If regulations are properly designed and
enforced, then on-site systems should not be any more susceptible
to political influence than central systems.
W-18. The Meginnis Arm (J-Series) area has some documented cases
of malfunctioning on-lot systems, but not all of the area is in
need of new or upgraded wastewater systems. As pointed out in
the comment, the soils in this area are common in N.E. Leon Coun-
ty, and they were found to be generally suitable for on-lot sys-
tems. The Final EIS is not recommending this area for
conventional sewers as proposed by the 201 plan, instead, it
recommends improved on-lot or small community systems to elimi-
nate the existing malfunctioning systems.
W-19. A septic tank drainfield is not designed to fail, it is
designed to renovate and dispose of wastewater. Theoretically,
inert filterable material will eventually clog the filter
surface; in practice it is the build-up of biological material
that prematurely clogs a soil absorption field. With proper
loading, this biological material will not build up due to
natural decomposition. The life-span of a drainfield based on
the accumulation of inert filterable material is dependent on
many factors such as type of wastewater, the alkalinity and hard-
ness of the water as well as the type of the sand used in
construction. The EIS assumed a twenty year life-span.
W-20. The Florida DER issues operating permits to package treat-
ment plants and takes enforcement action when necessary to assure
that permit conditions are met. Should a package plant be aban-
doned, responsibility for its operation is usually settled by the
courts. In some cases, homeowners may take over operation of a
plant through the formation of an association or special taxing
district.
W-21. The EIS realizes that some current rules and regulations
may need to be modified to address various situations that will
arise. Technical means, such as low application rates or site
modification techniques, may be used to satisfy existing regula-
tory needs. The widespread use of on-site systems may require
regulatory changes.
W-22 & W-23. Public management of septic systems is a new con-
cept to optimize the operation and life span of on-site systems.
Among the primary objectives of a management district is to sup-
ply information and controls that State and local agencies can
not enforce due to manpower limitations. Information such as the
maintenance needs of septic systems, as well as siting, design,
and construction requirements for specific conditions are ?prime
examples of the type of information supplied by management dis-
tricts.
V-67
-------
The current decrease in Federal funding of wastewater projects
will make the cost of centralized systems prohibitive to many
local communities. State and local rules and regulations may
need to be modified to provide wastewater management with tech-
nology that can be funded locally. Without Federal funding and
with a need to provide wastewater management, there could be con-
siderable interest in establishing septic tank management systems
with rules more stringent than State standards if it would pro-
vide a viable alternative to conventional centralized systems.
W—24. The E1S has not located a management district with charac-
teristics exactly matching those found in Leon County. It ^
doubtful that there exists an area that matches all or most of
Leon County s characteristics for two reasons First/ the man-
agement district concept is relatively new and*second/most man-
agement districts differ in function and concept due to physical/
environmental/ social/ and political circumstances. it is the
flexibility of the management district that makes the concept
useful.
W-25. It is difficult to quantify the number of monitoring wells
which would be needed by the year 2000 to provide an acceptable
assurance of safe drinking water. This is because the number and
location of wells will be directly related to the location and
size of development.
A general monitoring strategy can be recommended, however.
Groundwater monitoring in developing areas should ideally be
implemented before building begins. This will allow background
information to be developed as well as the identification of the
effects on groundwater from construction activity. Monitoring
should continue through construction and the life of the develop-
ment. At a minimum, wells should be located down gradient of
groundwater movement as well as within the development area. The
use of existing private and public water supply wells should be
considered for monitoring. Because municipal water supply wells
in this area are normally 250 to 450 feet deep, most sampling
locations should include a well with a depth greater than 200
feet. Private water supply wells are generally less than 300
feet in depth. The actual depths of private wells in the vicini-
ty of the sampling location should be taken into account when
determining if a second, shallower well is necessary at that
location.
The purpose of a groundwater quality monitoring program would be
to detect trends in its quality. This would allow corrective
action to be taken before the quality became so degraded as to
require renovation or additional treatment before use as potable
water.
Should adverse conditions appear to be developing, corrective
actions, such as those described in Part C of Chapter III in the
DEIS, should be taken.
V-68
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W-26. Firstly, the EPA's position is and has been that if a
southwest sprayfield had been part of the selected alternative,
then a microbiological study of health effects of this sprayfield
would have been conducted.
Secondlv the expansion of the southeast sprayfield to 17.5 mgd
was an 'EPA approved part of the 201 Facilities Plan. The deci-
sion to route 17 5 mgd to this site had already been made and was
not an issue of this EIS. The task of the EIS was to evaluate
what to do with any flow greater than 17.5 mgd which would need
to be disposed of in southern Leon County.
Finally, the decision to utilize the southeast site for flows
greater than 17.5 mgd (Alternatives 1-3) considered the
following:
l Effluent conveyance capacity from T.P.
Smith/Southwest plant to Southeast sprayfield site
is adequate for all alternatives.
2. There is sufficient land at the existing southeast
site to expand its capacity to 20.0 mgd.
3. The southeast sprayfield site is much more isolated
from human habitation than the proposed southwest
site.
4. Available soils data at the time of the Alterna-
tives Evaluation Task showed a seasonal high water
table at the southwest site.
W-27. Impervious surfaces include roads, parking lots, and roof
tops! The conclusion that increased impervious surfaces would
result is based on two premises, the first being increased densi-
ty and the second being ability to develop in marginal areas
which would not be possible with on-site systems.
Between now and the year 2000, the Tallahasee-Leon County Plan-
ning Department anticipates that areas containing an average den-
sity of greater than four units/acre will be developed in the
Northeast These areas will contain both residential and commer-
cial land uses. The I-10/Mahan Drive interchange area has
already started* to undergo commercial development and it is
expected that this node will expand during the next 20 years.
Potential also exists for development of apartment and townhouse
complexes along arterials in the Northeast.
Higher density development is possible with a centralized system.
The type of development that may occur depends on many factors.
It is safe to say a developer who can obtain a higher return on
his investment with high density housing will do so whenever pos-
sible* a centralized system would make this option possible.
Marginal land would also become more valuable to a developer and
therefore would be developed whenever possible thus increasing
impervious surfaces.
V-69
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W-28. The EIS does not make this conclusion. Rather, the state-
ment that a treatment plant in the northeast would be incompat-
ible with existing land use is the opinion of local homeowners in
response to the 201 Plan, and is noted as such.
W-29. Impacts from septic tank and drainfield construction are
limited to the installation site, where they are considered mini-
mal in relation to the total impact associated with home con-
struction. In the past, septic tank drainfield sites have been
completely cleared, however, the now recognized need to limit
heavy equipment operation over the area where the drainfield
would be installed to prevent soil compaction may reduce overall
home construction impacts in the future.
Wastewater disposal from a centralized system effectively pre-
vents the disposal area from being utilized for other purposes.
This impact would last the life of the centralized system. An
on-site drainage field, on the other hand, while imposing some
limitations, does not prevent the area from being used as a nor-
mal yard.
Finally, interceptors to a centralized system are normally placed
in low-lying areas to take advantage of gravity collection.
These areas may be environmentally sensitive. They could be more
susceptible to erosion due to slope and therefore more difficult
to stabilize. Construction of a home with an on-site
treatment/disposal system would probably not be allowed in these
low-lying areas.
W-30. On-site systems are now considered to be viable options to
conventional sewers when suitable conditions exist. EPA requires
that on-site and other innovative and alternative systems be ful-
ly considered in 201 facility planning, especially when their
systems are likely to be more cost-effective than collection and
interceptor networks.
With the escalating cost of wastewater collection, treatment and
disposal and the advances in alternative technology, the emphasis
on large centralized systems has changed. Many rules and regu-
lations have yet to reflect this reality.
W-31. The rapid infiltration method of wastewater treatment and
disposal normally provides a poor means for nitrogen removal as
indicated in the publication referred to. However, Bonwer (1)
obtained up to 80% nitrogen removal as a combined result of ammo-
nia absorption and denitrification by managing hydraulic loading
cycles to create alternately anaerobic and aerobic conditions.
In addition, by controlling hydraulic loading, vegetation may be
employed to remove some nitrogen as long as the vegetation can
withstand the high hydraulic loading rates and is harvested.
Nitrogen removal may require additional process attention and
will be strongly influenced by wastewater characteristics. Cost
for nitrogen removal by denitrification may typically range from
V-70
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47 cents per 1000 gallons at 1 mgd to 22 cents per 1000 gallons
at 10 mgd. (2)
(1) Bonwer, H. J. C. Lance, and M. S. Riggs: High-Rate Land
Treatment II: Water Quality and Economic Aspects of
the Flushing Meadows Project, J. WPCF. Vol. 46, pp.
884-859. May 1974.
(2) U.S. EPA. Environmental Pollution Control Alternatives:
Municipal Wastewater. Technology Transfer, EPA-
625/5-79-612, November 1979.
W-32. The evaluation of the impacts of alternative wastewater
management systems on the quality of groundwater in the study
area was carried out by a number of professionals at EPA, Region
IV and by EPA's consultants for this EIS. The conclusion reached
was the concensus of those involved in the preparation of this
EIS and is based on the best available information.
W-33. Sludge disposal cost for septic tanks is part of the oper-
ation and maintenance cost which is in the present worth values
in Table 11-18. It was not listed separately because pumping of
sludge from septic tanks represents the major operation and main-
tenance cost for septic tanks. This cost includes the expense of
sludge disposal by the person pumping the septic tank as well as
labor costs.
An additional 12,000 gallons per day of septage sludge was esti-
mated to be produced by the year 2000. Assuming a septic tank
pumping truck could clean 4 tanks per day with 1000 gallon capac-
ity, three additional trucks would be required in 2000. If these
trucks could haul more or serve more homes in one day, the number
of trucks would be less. Half as many trucks would be required
by the year 1990. The actual number of miles traveled and tanks
served per day depends on the location of the various septic
tanks in relation to each other and the disposal site.
W-34. Oxidation ponds were included as a means of achieving sec-
ondary quality effluent. Its selection was not based upon wheth-
er or not the process was permitted by the Florida Department of
Environmental Regulation, rather it was included on its technical
characteristics.
W-35. The physiography of Leon County is described in Chapter IV
of the DEIS. The most irregular terrain in the unsewered portion
of Leon County is found in the Northeast, the area expecting the
most future population growth. This area is known as the North-
ern Highlands and is described as having "...mature topography
that is gentle and moderate." (Hendry, C. and C. Sproul; Geology
and Ground-Water Resources of Leon County, Florida; Florida? Geo-
logical Survey, Bulletin #47, 1966; p. 24.) The USGS Topographic
Maps of the area show that slopes in this area rarely exceed 10%
V-71
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and cannot be considered excessive for on-site systems. In addi-
tion, neither depth to water table nor depth to bedrock would
limit the use of on-site systems in the Northern Highlands. More
restrictive to the use of on-site systems in Leon County are the
high groundwater conditions found in the Apalachicola Coastal
Lowlands and the sinkhole-sand dune topography and high bedrock
(limestone) conditions found in the Woodville Karst Plain. Both
areas are found in southern Leon County and are not expected to
experience large future population growth. A revision to page
11-20 of the DEIS will be noted in Chapter IV of the FEIS.
The Design Manual, Onsite Wastewater and Disposal Systems,
(EPA 1980, p. 212) states that a soil absorption bed can function
effectively with slopes up to 5%, while trenches can be effective
with slopes up to 25%. Therefore, slopes would not limit the use
of conventional on-site systems in unsewered portions of Leon
County.
High groundwater and water table conditions could limit the
use of conventional on-site systems in southern Leon County and
the use of alternative on-site systems or small community systems
should be considered for any development in this area.
W-36. Sand filters and aerated lagoons were included in Table
11-10 as small community treatment systems that have been used
successfully in the treatment of small wastewater flows. Inclu-
sion in this Table was not based upon whether or not they were
permitted by the Florida Department of Environmental Regulation,
rather they were included on their technical characteristics.
W-37. The disadvantages associated with higher waste concen-
tration were not based on Florida rules, rather, it was based
upon possible treatment difficulties. These treatment difficul-
ties stem from high organic loadings which may require greater
aeration and sludge handling capabilities at a particular treat-
ment facility.
W-38. Due to the number of alternatives developed by the EIS and
the planning nature of the study, specific approval by affected
organizations and agencies was not sought. Proposed locations
for wastewater management facilities were based on the most
cost-effective options under existing conditions. Actual facili-
ty locations will vary depending upon the situation at the time
of design. The primary function of developing tentative
locations for wastewater management facilities was to estimate
cost for the different alternatives.
W-39. This assumption was made for the purpose of projecting a
development framework for analyzing the costs and impacts of the
No-Federal-Action Alternative. The EIS recognizes the City's
right and ability to independently finance treatment capacity
beyond 17.5 mgd.
V-72
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The assumption that development density of three units per acre
would take place with no federal grants is based on the need to
optimize the feasibility of on-site wastewater systems.
One-third acre lots will permit large absorption areas where nec-
essary and limit difficulties such as isolation distances, sur-
face runoff and personal land use created by higher density
development.
w-40. Cost-effectiveness in an environmental sense means that
the money expended for Alternative 4 will create the least amount
of or most acceptable environment impacts while achieving the
desired goal.
W-41 The environmental impacts of Alternative 4 discussed on
a eg n-53 and 11-54 are based on the assumptions of no expan-
sion or construction of centralized wastewater treatment/disposal
facilities (see pages 11-43 through 11-47 of the DEIS and the
response to comment W-39). Therefore it would be incorrect to
imply in this sentence that these facilities might be built and
the environmental impacts listed below apply to both situations.
The environmental impacts of the expansion or construction of
centralized wastewater facilities, with or without Federal fund-
ina are listed under Alternatives 1 through 3 on pages 11-55 to
11-62 of the DEIS.
Pacre 11-53, paragraph 2: Erosion could occur where areas are
denuded of' vegetation during the laying of those few collection
lines proposed under Alternative 4. Stormwaters could carry silt
to nearby surface water bodies or other low lying areas.
Page 11-53, paragraph 5: The smaller amount of impervious sur-
face per developed acre, the greater amount of stormwater which
is absorbed by the soil and the smaller the amount of stormwater
which runs off. The EIS concluded that Alternative 4 will result
in a smaller percent of impervious surface per developed acre in
the Northeast area of the city than will Alternatives 1, 2 and 3.
The EIS concluded that when on-site soil absorption systems are
properly installed and maintained, oversaturated drainfields do
not occur except after rare climatological conditions.
W-42. The EIS concluded that properly installed and maintained
drainfields will not lead to saturated drainfields except after
extremely unusual climatological conditions.
W-43. The possibility of runoff from malfunctioning systems is
mentioned in this section (p. 11-54). Experience in the use of
septic tanks in the N.E. area does not indicate a high level of
failure. In addition, these few malfunctions could be virtually
eliminated by proper installation and maintenance.
V-73
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W-44. On-site systems obviously require acreage. However,
drainfields can be situated on comparatively small parcels, and a
large number of lots will have suitable areas which are already
cleared. While regional sprayfield sites can be designed to min-
imize major habitat disruptions, they cannot be designed to uti-
lize the smaller sites available for on-site systems.
W-45. In the Tallahassee urban area, population growth and eco-
nomic growth will, for the most part, be induced by the presence
of State government employment opportunities and the expansion of
the two major universities, rather than by the provision of
wastewater management systems. However, population infilling
within the Tallahassee urban area will be encouraged by the lack
of a centralized system outside of the City's service area. This
will be noted in Chapter IV of the FEIS, "Revisions to DEIS and
Additional Information". Further, the trend for single family
detached housing in the N.E. area can be fully maintained under
this alternative
W-46. One foot separation should exist between the gravel filter
(envelope) and the bottom of deeper root plants such as carrots
and potatoes.
Most drainfields have from 1 - 1 1/2 feet of soil cover over
trench laterals principally for protection of the soil absorption
system. Therefore, even deep rooted plants can, in many places,
be grown directly over soil absorption systems.
In the case of shallow placement system, often railroad ties are
used to define the garden and 1/2 foot of topsoil and/or compost
are imported.
Chapter 10D-6, Florida Administrative Code, Standards for Indi-
vidual Sewage Disposal Systems, states: "a minimum area of two
(2) times the required absorption area shall be available for the
absorption system". This reserve area would be an excellent
place for a garden.
W-47. This point is addressed on page 11-54 of the DEIS under
Community Services and Facilities but is expected to be mitigated
by the increased infilling in the existing sewered areas.
W-48. Yes, soils may clog due to suspended solids in the eff-
luent. A revision to page 11-54 of the DEIS will be noted in
Chapter IV of the FEIS.
W-49. Yes, any potential recycling of nutrients or benefits from
growing crops are lost with the use of septic tanks. A revision
to page 11-54 of the DEIS will be noted in Chapter IV of the
FEIS.
V-74
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W-50. Septic tanks reduce the total number of microorganisms but
the removal of pathogens by the septic tank has not been demon-
strated. However, the septic tank is only half of the on-site
system; the soil absorption field has demonstrated the ability to
significantly reduce the microbial population of wastewater. The
mechanisms of bacteria and virus removal by soil are very complex
and include absorption to soil partials, filtering, and attrition
due to toxic chemicals and antibiotics produced from molds,
bacilla, and actinomycetes. For example, Ziebell (1) concluded
that in properly constructed and maintained systems, there will
be a 3 log reduction of bacteria within 1 foot into the soil sur-
rounding the soil absorption system. In addition, Ziebell showed
that within the second foot, bacterial counts are in the compara-
ble range for some treated wastewater effluent.
(1) Ziebell, W. A., D. H. Nero, J. F. Deininger and E. McCoy.
1975a. "Use of Bacteria in Assessing Waste Treatment and Soil
Disposal Systems." Ground Water Pollution. Editorial Board,
Underwater Research Institute, St. Louis, Missouri, pp. 58-64.
W-51. The statement on page 11-54 is general. Malfunctioning
septic tanks could constitute a public health risk by direct
human contact in instances of ponding "breakouts" where improper-
ly maintained or improperly placed septic systems occur (i.e. on
seasonally high water tables). The EIS has concluded that due to
the confining layers between drainfields and well intakes and the
great depth of soil (over 200 ft.) through which the effluent
would travel that risk of detectable contamination is very
remote.
These specifics will be noted in Chapter IV of the FEIS, "Re-
visions to DEIS and Additional Information".
W-52. All of the alternatives have potential for adverse impacts
on groundwater, hence the "Cons" statements on page viii. Of all
the alternatives, 4 is felt to have the least impact, hence the
"Pros" claim on the same page. The groundwater impacts from sep-
tic tanks are expected to be localized to the upper level of the
surficial aquifer.
W-53. The sentence merely states that "existing degradation" is
documented in the Environmental Monitoring Program Segment I -
Task Report. The citation is also incorporated into other alter-
natives by reference to the environmental impacts described under
Alternative 1A and B. The discussion of increased impervious
surface under Comment W-27 explains the probable increase of
urban runoff under various alternatives.
W-54. During an interview on May 17, 1979, Louis Tesar, Florida
Department of State, Division of Archives, History and Record
Management, stated that the area above the Cody Escarpment is
thought to be rich in archaeological resources, although only
V-75
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certain areas have been investigated to date in detail. His
expectations are based on statistical models of the area.
W-55. Three groups have designated protected species for the
study area. The Florida Committee on Rare and Endangered Plants
and Animals (FCREPA) has prepared a series of reports on the rare
and endangered biota of Florida. FCREPA has completed five vol-
umes dealing with mammals, birds, amphibians and reptiles, fishes
and plants. Volumes on invertebrates and recommendations and
liaison are expected to be released by Fall of 1981. FCREPA uses
five categories to classify the current status of these species:
endangered, threatened, rare, species of special concern, and
status undetermined.
Based on their inventory and review, FCREPA recommends that spe-
cies be formally included and protected under the wildlife code.
The Florida Game and Fresh Water Fish Commission (FGFWFC) makes
the decision at the State level as to which species are listed
and under which category they are listed. In addition, the U.S.
Fish and Wildlife Service (USFWS) lists species to be protected
under the Federal Endangered Species Act of 1973.
Species are not legally protected unless they are included on
either the State or Federal Lists. However, EPA is required to
review impacts to species proposed on the Federal list. Protec-
tion generally varies according to the status designation. For
example, the Gopher tortoise (Gopherus polyphemus) is not listed
by the USFWS, was recommended for threatened status by FCREPA,
and downgraded to a species of special concern by FGFWFC. Even
though it is legal game, as a species of special concern the
Gopher tortoise has a closed season during breeding periods and
is protected by a possession limit.
FCREPA has recommended protected status under the species of spe-
cial concern category for several aquatic invertebrates known to
exist in Leon County. These species include the Leon-Wakulla
County Cave crayfish (Procambarus orcinus) and the Hobb's Cave
isopod (Asellus holobsi maloney). These species occupy sinkhole,
aquatic cave, and other subterranean habitats. Due to the rela-
tive inaccessibility of these habitats, the full extent of these
species' distribution cannot be determined. The FCREPA recommen-
dation has not yet been accepted by FGFWFC. No invertebrate
species are listed for Leon County by the USFWS. Due to the
unknown distribution pattern of the species, impacts were
assessed as negative, long term, and minor for alternatives with
spray fields in areas with karstic geology.
W-56. See the response to comment W-55. The gopher tortoise is
listed as a "species of special concern" by the Florida Committee
on Rare and Endangered Plants and Animals. A correction to the
term on page IV-33 of the DEIS will be noted in Chapter IV of the
FEIS, "Revisions to DEIS and Additional Information".
V-76
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W-57. Citrus groves is not an accurate term. The term which
should be used is orchard groves and a revision of the text to
reflect that fact will be noted in Chapter IV of the FEIS. The
source of this information is the Tallahassee-Leon County 208
Plan.
W-58. As noted on page IV-55 of the DEIS, this statement was a
conclusion of the 201 Facilities Plan. When contacted, Mr. John
Dean of the City Utilities, Sewer Division expressed the opinion
that the documentation is more than adequate for sewer system
management at this time, and has been in good shape for about 10
years. He said that improvements to the documentation are con-
stantly implemented, and that the sewer maps have been revised
twice in the past three years. Given this information, it will
be noted in Chapter IV of the FEIS, "Revisions to the DEIS and
Additional Information" that the situation appears to have
improved since the completion of the 201 Plan.
w c q At the time the data for the EIS Environmental Inventory
!""• collected, the effluent disposal points reported were cor-
Since that time, effluent disposal has begun at the 201
Ihtse 1 Southeast Sprayfield and surface water discharges from
the TP Smith/Southwest Plants have closed. The small SW spray-
ed advent to the plant is still in use. The centrifuge has
nS hPM used recently because a) most sludge is disposed of by
not been. the airport, for which the centrifuge is not
reauire^and b) the centrifuge has been a maintenance problem and
required an ' . been sufficient to ;justify its use. These
facts^will be noted in Chapter XV of_the FEIS, "Revisions to the
Draft EIS and Additional Information.
w-60 A aiven septic tank will probably be pumped out once every
Therefore, the noise impact of pumping and pump out
tracks is very infrequent in a given locale. Pump out trucks
. yopntace disposal site on a daily basis will
converging on Such noise may be equal to or greater than
create noise impacts. Such nol y A revision will be noted
in^Chapter IV of the FEIS? Revisions to the Draft EIS and Addi-
tional Information".
^ used with sludge disposal include plowing
Fa5mJ®qU^pme" ?™nts to incorporate sludge into the soil. This
and discing imP^em® ,,ced bv the farmer to which the land is
equipment would be usea Dy
leased, however, not to the Y«
W-61. The earth moving necessary to install on-site soil aba
tion systems is temporary. After construction, the sit^?"
returned approximately to its original contours. No signifirLi?
impact results from this temporary earth moving. Moreover ?h
earth moving necessary to install an on-site soil absorDtinn
field will be incidental to the larger scale construction act-i
ities related to landscaping and home construction.
V-77
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W-62. Soil absorption systems are affected by two forms of soil
clogging. The most prevalent is that associated with improper
maintenance of the septic tank which allows solids from the sep-
tic tank to overflow into the soil absorption system. This form
of clogging can be prevented with proper operation and mainte-
nance. The second form of soil clogging is associated with
system failure due to soil surface blinding by inert material
build-up. This form of soil clogging is the natural aging proc-
ess of the soil absorption field and can not be prevented.
However, specific design and operation such as the following can
be utilized to ensure that soil clogging is not premature:
1. Pressure distribution
2. Alternating drain fields
3. Additional treatment, e.g. septic solids retainer
4. Septic system rehabilitation
5. Water conservation
6. Prohibit garbage disposals
The time it takes to render the soil absorption field inoperable
is the design life of the septic tank/soil absorption system.
W-63. The reference to overland runoff and lateral seepage to
nearby surface waters from sprayfields and sludge disposal sites
is included to address possible impacts from system malfunction-
ing or periods of extreme precipitation. A similar impact is
included in the same table for on-site system malfunctions under
Alternative 4. A more detailed discussion of the impacts and
mitigative measures can be found in Chapters VI and VII of the
Alternatives Evaluation Task Report.
W-64. Surface water quality may be adversely impacted by urban
runoff from increases in impervious surfaces. Population densi-
ties in the Northeast quadrant of the city will reflect whatever
technologies future developers consider cost-effective for their
projects at the time of construction. The response to comment
W-27 contains a discussion of these items.
W-65. The impact assessment is based on the data base developed
and referenced in the Environmental Inventory Task Report, the
proper installation and maintenance of proposed systems, and the
institution of a monitoring program. It should be pointed out
that this impact is from malfunctioning systems in the overall
study area.
W-66. See the response to comment W-55.
V-78
-------
W-67. This point is addressed in the response to comment W-44.
The clearing for septic tanks and drainfields can be considered a
direct, negative, long-term impact and is nominal in degree. A
revision to page IV-72 of the DEIS will be noted in Chapter IV of
the FEIS.
Septage disposal is discussed in the response to comment W-4.
K-68. The decision about the technology for sludge disposal from
septic tanks remains to be made. The decision will be made even-
tual!? by the management agency responsible for operation and
maintenance of small community systems and individual on-site
systems ^see p. III-5). " is premature to speculate whether
"sjverll hundred acres" will be converted fro*
agricultural/forestry land uses to cropland.
As discussed in the response to comment W-4, the Southwest
nlantcurrently accomodating septage and should have suffi-
cient capacity to continue. Therefore, this practice was assumed
?nContinue and the costs were assumed to be passed on to the
user in the O&M costs (estimated from local pump-out charges).
•should the City decide not to continue this service, it would be
necessary to construct a separate septage treatment and disposal
farilitv This would, of course, increase the costs to the
users Sludge treatment practices which would be applicable to
septage trealment include sludge lagoons, lime stabilization
composting, chemical treatment, and dewatering. Land disposal
nractices applicable to septage disposal include land application
and sludge lagoons. Given the proper management agency, these
facilities would probably be grant-eligible.
CroDland is a type of agricultural land on which typically row
crops are planted. Pastures and pine plantations are not typi-
cally referred to as cropland.
W-69 impacts from transmission of pathogens from sprayfields by
wind* or vectors are assessed as insignificant in Table IV.19 and
as negligible on Page 11-59. The EIS intends no contradiction in
these statements. Public Health concerns are discussed in more
detail in the Alternatives Evaluation Task Report (Pages VI-53 to
VI-57).
W-70. Destruction of archaeological and historical resources
could come from home construction including septic tank drain
fields and from wastewater management facility construction if
not surveyed before construction. "^ruction it
W-71. Hunting in the Apalachicola National Forest will not be
directly impacted by conversion of land to urban uses.
V-79
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Other areas of the County presently used by hunters may be urban-
ized by the year 2000, especially portions of the St. Joseph
Paper Company lands. In addition, should Southwood Plantation
ever be sold for development, the game supply on nearby St.
Joseph Paper Company lands could be decreased. Game in excess of
the carrying capacity of Southwood Plantation tends to migrate to
St. Joseph Paper Company lands which are open to public hunting
(pers. comm., Charles Allen, National Wild Turkey Federation,
December 1981).
W-7 2. It is not claimed that there are forestry uses in the Nor-
theast which will be converted to other land uses. The EIS con-
cluded that an influx of 90,000 additional persons by the year
2000 will reduce forestry uses in Leon County by causing the
urbanization of those areas closest to Tallahassee. The St.
Joseph Paper Company lands may come under development pressures.
W-73. As requested, the estimated number of working hours the
following personnel spent on this project while in Leon County
are listed below:
Hours
U.S. Environmental Protection Agency
Robert B. Howard, Chief, EIS Preparation Section 32
W. Bowman Crum, Current Project Officer 52
Richard D. Green, Prior Project Officer 45
Virginia W. Buff, 201 Project Engineer 0
Gannett Fleming Corddry and Carpenter, Inc.
Thomas M. Rachford, Senior Project Manager 20
Albert T. Bain, Project Manager 112
Mark Flaherty, Environmental Engineer 184
James Fuller, Environmental Engineer 0
Sara Frailey, Environmental Engineer 16
John W. Jacobs, Environmental Scientist 40
Richard C. Callahan, Environmental Scientist 0
Claude Terry and Associates, Inc.
Claude E. Terry, Project Executive 60
Louise B. Franklin, Project Manager, Environmental
Planner 111
Robert J. Hunter, Environmental Scientist 162
Thomas C. Mather, Environmental Scientist 121
James C. Hodges, Environmental Scientist 48
V-80
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A. Anita Patterson, Environmental Scientist
(Laboratory Scientist)
0
W-74. The layout requested is presented in Figure v-1. The
drainfield absorption area required for a three bedroom house on
a site with a percolation rate of 15 minutes per inch is 190
square feet per bedroom X 3 bedrooms = 570 square feet. This
fiqure was increased by 50 percent to compensate for a loss of
sidewall absorption area resulting from the bed configuration.
W-75. The collection system costs for Alternative 4 in the Draft
Alternatives Evaluation Report include costs for the expansion of
an existing interceptor that extends northeast towards Killearn
Estates (referring to Figure II.4.2, this interceptor extends
north from monitoring point 1). The EIS flow monitoring study
indicated no excess capacity in this interceptor. An improve-
ments program has been undertaken by the City, however, which
will give this interceptor adequate capacity to handle projected
year 2000 flows without further expansion. Therefore, costs for
expanding this line, approximately $700,000, were not included in
the Draft EIS cost estimates. Totals for the No-Federal Action
Alternative should read 5.98 (w/ FRM) and 10.4 (w/o FRM) which
includes only the cost of on-lot systems. Alternative 4 does not
include any interceptor sewers.
W-76. (1) Slowly permeable soils are quite acceptable for treat-
ing septic tank effluent. Many of the preferred soils for proper
wastewater renovation consist of somewhat slowly permeable loams
and silty clay loams. These finer textured soils with high cat-
ion exchange capacities help to remove nutrients chemically and
therefore are frequently imported into areas that have limiting
horizons at or near the surface. These same soils are also used
in coarse textured sandy areas to overcome problems with rapid
permeability, perc rates of less than 1 minute/inch.
Many states have an abundance of slowly permeable fine textured
soils with permeabilities, as slow as 120 min./inch. Table V-1
shows acceptable application rates for wastewater effluent with
respect to various soil textures and associated percolation
rates. It can be readily seen that as permeability decreases so
does the application rate. A soil absorption system installed in
a silt loam with a percolation rate of 60 minute/inch would
require approximately 1000 square feet of soil absorption area
which can be constructed in a 32 foot square bed configuration.
At no point in the DEIS was it stated that these lower loading
rates would be obtained only by reduced water use. Water conser-
vation measures are not necessarily required when absorption sys-
tems are considered for slowly to very slowly permeable soils.
Though not specifically stated in many regulatory publications, a
net reduction in wastewater flow generation could indeed warrant
V-81
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100* X 109' LOT
SLOPE
I 3%
-X
DRIVEWAY
62'
1,736 FT2
oo
CM
HOUSE
li'
36
12
12
812 FT2
GARDEN
PARCEL
20'
30' X 30' =
900 FT2
PRIMARY SOIL
ABSORPTION
BED
30' X 30' =
900 FT2
RESERVE SOIL
ABSORPTION
BED
I ,
52'
11
4,590 FT2 "SUITABLE, UNOBSTRUCTED LAND"
CITY OF TALLAHASSEE
LEON COUNTY, FLORIDA
ON-SITE SYSTEM
LAYOUT
to
to
20
SCALE IN FEET
BANNETT FLEMING CORODRY AND CARPENTER, INC.
HARRISBURO, PENNSYLVANIA
FIGURES. I
-------
TABLE V-l
RECOMMENDED RATES OF WASTEWATER APPLICATION
FOR TRENCH AND BED BOTTOM AREAS (a)
Soil Texture
Percolation
Rate
(min/in.)
Application
Rate(b)
(gpd/sq. ft.)
Gravel, coarse sand less than 1 Not suitable(c)
Coarse to medium sand 1-5 1^2
Fine sand, loamy sand 6-15 q!s
Sandy loam, loam 16-30 q16
Loam, porous silt loam 31-60 0^45
Silty clay loam, clay loam(d) 61-120 0.2(e)
(a) May be suitable estimates for sidewall infiltration rates.
(b) Rates based on septic tank effluent from a domestic waste
source. A factor of safety may be desirable for wastes of
significantly different character.
(c) Soils with percolation rates §1 min/in. can be used if the
soil is replaced with a suitably thick (52 ft.) layer of
loamy sand or sand.
Id) Soils without expandable clays.
(e) These soils may be easily damaged during construction.
Source: U.S. EPA. "Design Manual, Onsite Wastewater Treatment
and Disposal Systems." October 1980.
V-83
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a proportional reduction in the required absorption area require-
ment.
(2) This statement should be corrected to reflect the fact that
soil absorption area requirements are sized on the proposed or
anticipated number of bedrooms and the results of the site evalu-
ation and percolation tests. This revision will be noted in
Chapter IV of the DEIS.
W-77. The EIS looked at three units per acre as the ideal lot
size to ensure proper operation of on-lot systems. This density
allows for additional disposal area where needed and limits the
adverse conditions that can be created by higher densities.
Examples of problems caused by higher densities would be minimal
isolation distances, high percentage of impermeable surfaces and
runoff from adjacent lots and driveways. The EIS concluded that
3 lots per acre is the ideal density for on-site septic systems
and, therefore, based Alternative 4 on this assumption.
W-78. Given the soil types and depths found in the
Tallahassee-Leon County area, the EIS concluded that on'-lot and
small community systems are the most cost-effective and environ-
mentally sound wastewater management alternative. Because most
of the projected development has yet to begin there is good
potential to ensure that developing wastewater needs can be met
with on-lot and small community systems and management districts.
Basically, problems can be prevented with proper planning design,
construction, operation and maintenance.
Soils in the Leon County area are taxonomically quite different
from other soils that have developed recently from coarse sand
deposits such as Duval and Orange Counties. These Entisols are
relatively young and lack true diagnostic soil horizons. These
soils simply consist of fine to coarse sandy textures which rely
on the sand particles to physically remove wastewater contam-
inants. These soils are generally found in low-lying moist to
wet topographic settings. Periodic wetness and rapid permeabil-
ity in deeper columns reduces the overall potential these soils
have for wastewater renovation.
Leon County soils are for the most part older and have distinct
horizons, many of which are chemically active loams and clay
loams. Except for the low-lying setting adjacent to the numerous
lakes and ponds, there are vast areas of deep and well drained
moderately permeable Orangeburg and Norfolk soils which have a
generally high potential for accepting and treating septic eff-
luent.
It is recognized that one of the reasons for the problems that
have occurred with these systems in Orange and Duval Counties is
the lack of proper operation and maintenance. The EIS recommends
a public management district or other means of on-site and small
community systems management so as to avoid this problem.
V-84
-------
W-7 9. The Draft EIS selected plan does not suggest a development
direction counter to that of the Comprehensive Plan. The land
use plan map for the Tallahassee area (dated July 1981) developed
by the Tallahassee-Leon County Planning Department (TLCPD) and
adopted by the Tallahassee City Commission and the Leon County
Board of Commissioners shows high density development to be con-
centrated within the City's service area boundaries. Lower
development densities are indicated for the outlying areas. By
not providing centralized collection and treatment facilities to
the lower density outlying areas, higher density development is
encouraged within the City's service area boundaries, and the
intentions of the TLCPD are upheld.
W-80. This map was developed using a series of maps and overlays
incorporating information about land use, flood hazard areas, and
soils with minor restrictions regarding the use of on-site sys-
tems based on permeability and depths to restrictive horizons.
Areas determined to be suitable for on-site systems have soils
with a medium or higher potential for the use of septic tank
absorption fields, have little present development, are not in a
flood hazard area, and have at least a two foot deep soil profile
free of groundwater and other restrictive horizons. Information
on the physical characteristics of these soils was obtained from
the interpretation record of the U.S. Department of Agriculture
Soil Conservation Service Established Series Listings. Other
sources of information include the Tallahassee-Leon County Plan-
ning Department; the U.S. Geological Survey topographic maps; and
the U.S. Department of Housing and Urban Development, Federal
Insurance Study for Leon County.
W-81. Alternative System la, as developed in the EIS (see p.
11-38 of the DEIS) includes the construction of a centralized
treatment/disposal facility in the Northeast. Because of high
land costs in the Northeast and the availability of suitable
sites, the EIS determined that effluent disposal by rapid infil-
tration is, the most cost-effective option. The City's modified
Alternative System la is the same as the system described above,
except that effluent disposal would be by slow rate land applica-
tion. The City was concerned about potential negative effects of
a rapid infiltration system on the potable water supply.
The modified Alternative la was not introduced until the end of
the Alternatives Evaluation Task and does not represent a major
change in concept or configuration from the original. While the
use of slow rate land application has the advantage of increased
protection from groundwater contamination, it has the disadvan-
tages of greater land requirements in an area where land is
relatively expensive and where the local citizens have already
voiced their objections to a treatment plant in their neighbor-
hood. It was not felt that this modification altered the
alternative sufficiently to justify further evaluation effort.
V-85
-------
W-82. The impacts on public services due to lower development
densities were considered in the evaluation of alternatives (p.
11-54, DEIS). Furnishing community services and facilities to a
given population may require more miles of roads, longer utility
runs, more police, more fire stations and personnel, and higher
energy consumption and transportation costs. These increased
costs cannot be quantified; however, neither can the benefits
which some people feel arise from larger lots and greater dis-
tances from urban centers. Moreover, as discussed in response to
comment W-79, it is felt that the DEIS selected plan will encour-
age population infilling within the City's service area boundary.
W-83. Costs for wells and sampling were not included in the cost
of Alternative 4. As explained in the response to comment W-25,
this figure would be difficult to quantify at this time. It is
not felt that this cost would change the fact that Alternative 4
is significantly less costly than any of the other alternatives.
If implemented by an appropriate management agency, the costs of
a monitoring system would most likely be eligible for Federal
funding.
W-84. The EIS proposes a groundwater monitoring program that
would detect trends in groundwater quality so that contamination
requiring renovation can be avoided (see response to W-25). It
cannot be assured at this time that EPA would fund a study to
determine remedial action should drinking water supplies become
affected. A significant effect from the proposed alternative on
finished water supplies is considered a very remote possibility.
W-85. First, the failure rate in Leon County has been low. Even
without a management system this very low rate would be expected
to continue. Should the EIS recommendations be implemented the
low rate could be further minimized.
(1) Comment noted.
(2) If a management district is implemented and invested with
the proper authority, they will not permit the installation of a
poorly designed system.
(3) This may be true, but if the management district enforces
the proper siting of systems, development of marginal lands with
on-site systems will not be allowed. If a centralized sewer sys-
tem was available, it would be more difficult to control the
development of marginal lands.
W-86. The users would probably bear most of the costs of a man-
agement district. These costs are difficult to quantify, but the
O&M costs would cover many of the services.
W-87. EPA agrees with this statement.
V-86
-------
W-8 8. The importance of flexibility in the regulations is
stressed in the DEIS (see page 111-10). As shown on Table 1.3.2
of the Draft Alternatives Evaluation Report, a design life of 20
years was assumed for soil absorption fields.
W-89. Yes, provided it can be shown that the failure resulted
from improper management rather than homeowner actions. It is
conceivable that the management agency may institute some form of
homeowner's insurance program that would cover the cost of
repairing or replacing the tank or drainfield under any circum-
stances .
W-90. Comment noted.
W-91. The cost estimates used were obtained from local on-site
system installers and represent costs for a conventional on-site
system. Properly designed and installed, a septic tank/soil
absorption field system should be adequate as a permanent facili-
ty.
W-92. Costs for the operation of a management district are dif
ficult to quantify. Much of these costs would be covered bv th*
O&M costs for the system. verea Dy the
W-93. The costs presented in the EIS are for a planning period
from 1982 to 2000. Therefore, when present worth costs for cen-
tralized collection, treatment, and disposal systems were com-
puted, the salvage values of land, equipment, and structures at
the year 2000 were incorporated. The design life of a soil
absorption field is assumed to be approximately 20 years (see
Table 1.3.2, Draft Alternatives Evaluation Report, Volume I) and
no salvage values were included in the present worth costs for
these systems. By using a present worth analysis the EIS was
able to develop comparable costs for systems with different
design lives.
W-94. The EIS did not consider a drainfield as "lost land".
While wastewater disposal from a centralized system effectively
prevents the area from being utilized for other, purposes, an
on-site drainage field imposes some limitations, but does not
prevent the area from being used as a normal yard. Refer to the
response in comment W-46 for a discussion of the potential for
gardening on a lot with a drainfield.
W-95. Costs for small community systems were not included in the
costs for Alternative 4. It would be difficult to quantify the
number of small community systems which would be constructed as
it depends on future decisions by developers as to the cost
effectiveness of a high density development with a small communi-
V-87
-------
ty system compared to a lower density development with individual
on-site systems. Moreover, package plants are not the only type
of small community system available. For example, costs of a
system incorporating individual septic tanks and a community
absorption field would be lower than the costs of an extended
aeration package plant with a percolation pond.
W-96. It is impossible to determine at this time just exactly
what event or combination of events would have to occur to justi-
fy re-opening the decisions made in this EIS. A decision to reo-
pen the EIS decision in the future would be made by the Regional
Administrator.
W-97. No response necessary.
W-98. EPA agrees with this statement. This is the intention of
the management district concept.
W-99. Chapter 10D-6 of the Florida Administrative Code currently
regulates individual sewage disposal systems in Florida. County
health departments are responsible for permitting all systems
which have a daily flow less than or equal to 2000 gallons. The
following factors are required by Chapter 10D-6 to be taken into
consideration when determining the suitability of an individual
on-site system:
1. Lot size
2. Slope and natural drainage features of the lot (in-
cluding filled area)
3. Proposed lay-out of lot: location, of buildings,
water supply well if proposed, proposed
treatment/disposal system
4. Proximity to surface waters
5. Percolation test
6. Soil profile
7. Water table elevation at time of site evaluation
and estimated water table elevation during the wet-
test season of the year.
When an entire subdivision is being evaluated for the use of
on-site systems, the following additional information is
required:
1. Plan of the subdivision
2. Topographic map
V-88
-------
3. General site reference map identifying the area
4. Any proposed drainage plans
5. Size and number of units
W-100. Chapter 10D-6 of the Florida Administrative Code (see the
response to comment W-99) regulates the installation of wells on
lots with on-site systems. Private wells can not be located on
lots less than one-half acre if a septic system is used for
wastewater disposal. Where a septic system is used, the well
must be located a minimum of seventy-five feet from the drain
field. Local standards call for wells to be grouted and a con-
crete apron provided. Wells must be cased for proper operation
but the type of casing is not specified. Monitoring of private
wells is the responsibility of the homeowner. Public water sup-
plies are the responsibility of the public health department.
W-101. Table III.2 (page III-7 of the DEIS) addresses many of
the recommendations discussed in EPA's report under the Mitiga-
tive Measures and Corrective Actions columns. The EPA report did
go into more detail than the DEIS in the proper installation and
operation of septic systems. Their recommendations for proper
installation included the following:
1. No heavy equipment on infiltrative surfaces
2. Trenching, boring, or excavating for percolation
systems only when soil moisture is below smearing
level
3. Use of trenching equipment which does not compact
trench sidewalks
4. Use of classified stone sizes in backfills
5. Utilize level bottom trenches and observation well
risers at end of each tile line
In addition, the following recommendations for effective opera-
tion were given in the EPA report:
1. Alternating loading and resting one-half the perco-
lation system; the cycle to be determined by the
onset of ponding in the system at the observation
well.
2. Where size of system makes it practicable, loading
the entire infiltrative surface of the system at
each cycle as uniformly and simultaneously as pos-
sible by the use of a dosing siphon.
3. Inspecting and removing scum and grease from septic
tanks annually.
V-89
-------
4. Drawing off half the sludge rather than pumping out
the entire contents.
A more recent EPA publication, Design Manual, Onsite Wastewater
Treatment and Disposal Systems, October 1980, contains an even
more detailed coverage of the design, siting, installation, and
operation of a variety of on-site systems. Rather than try to
reproduce this volume of information in the DEIS or FEIS, a ref-
erence to this document will be included in the FEIS and will be
noted as a revision to the DEIS in Chapter IV of the FEIS, "Re-
visions to the Draft EIS and Additional Information".
W-102. See the response to comment W-50.
W-103. The following references apply to this statement:
Small-Scale Waste Management Project. University of Wisconsin,
Madison. Management of Small Waste Flows. EPA-600/2-89-173,
NTIS Report No. PB 286 560, September 1978. 804 pp.
Tyler, E. J., R. Laak, E. McCou, and S. S. Sanhu. The Soil as a
Treatment System. In Proceedings of the Second National Home
Sewage Treatment Symposium, Chicago, Illinois, December 1977.
American Society of Agricultural Engineers, St. Joseph, Michigan,
1978. pp. 22-37.
Harkin, John M., Charles J. Fitzgerald, Colin P. Duffy, David G.
Kroll. Evaluation of Mound Systems for purification of Septic
Tank Effluent. Wisconsin University, Madison. NTIS- Report No.
PB80-122807. 1979. pp. 34-52.
The addition of the word "suitable" to the statement in question
will be noted in Chapter IV of the FEIS, "Revisions to the Draft
EIS and Additional Information".
W-104. The only problem area of septic tank system failures
brought to the EIS study team's attention by the Health Depart-
ment was the area near Meginnis Arm known in this study as the
"J-Series". For a discussion of the causes of these failures see
pages IV-61 through IV-64 of the DEIS.
W-105. Comment noted.
W-106. Because the DEIS serves to summarize all the work done in
the EIS study, it is not the appropriate place for such a
detailed list. The Environmental Inventory Task Report also
included a reference to this list, but did not reproduce it. For
your information, the list is included below.
V-90
-------
Fishes of the Ochlockonee River in Leon County, Florida
Common Name Scientific Name
Southern Brook Lamprey
Atlantic Sturgeon
Longnose Gar
Florida Gar
Bowfin
American Eel
Threadfin Shad
Gizzard Shad
Alabama Shad
Redfin Pickerel
Chain Pickeral
Carp
Creek Chub
Dusky Shiner
Taillight Shiner
Weed Shiner
Ironcolor Shiner
Coastal Shiner
Ohoopee Shiner
Blacktail Shiner
Pugnose Minnow
Golden Shiner
Spotted Sucker
Lake Chubsucker
Channel Catfish
Yellow Bullhead
Brown Bullhead
Spotted Bullhead
Tadpole Madtom
Speckled Madtom
Pirate Perch
Golden Topminnow
Banded Topminnow
Starhead Topminnow
Lined Topminnow
Pygmy Killifish
Bluefin Killifish
Misquitofish
Least Killifish
Brook Silverside
Mud Sunfish
Flier
Largemouth Bass
Suwanee Bass
Warmouth
Bluegill
Redear Sunfish
Redbreast Sunfish
Spotted Sunfish
Ichthyomyzon gagei
Acipenser oxyrhynchus
Sepisosteus osseus
Lepisosteus platyrhyncus
Amia calva
Anguilla rostrata
Dorosoma petenense
Dorosoma cepedianum
Alosa alabamae
Esox americanus
Esox niger
Cyprinus carpio
Semotilus atromaculatus
Notropis commingsae
Notropis maculatus
Notropis texanus
Notropis chalybaeus
Notropis petersoni
Notropis leedsi
Notropis venustus
Notropis emiliae
Notemigonus crysoleucas
Minytrema melanops
Ermyzon sucetta
Ictalurus punctatus
Ictalurus natalis
Ictalurus nebulosus
Ictalurus serracanthus
Noturus gyrinus
Noturus leptacanthus
Aphredoderus sayanus
Fundulus chrysotus
Fundulus cingulatus
Fundulus notti
Fundulus lineolatus
Leptolucania ommata
Lucania goodel
Gambusia affinis
Heterandria formosa
Labidesthes sicculus
Acantharchus pomotus
Centrarchus macropterus
Micropterus salmoides
Micropterus notius
Chaenobryttus gulosus
Lepomis macrochirus
Lepomis auritus
Lepomis auritus
Lepomis punctatus
V-91
-------
Common Name
Scientific Name
Dollar Sunfish
Black Crappie
Bluespotted Sunfish
Banded Sunfish
Banded Pygmy Sunfish
Okefenokee Pygmy Sunfish
Everglades Pygmy Sunfish
Blackbanded Darter
Swamp Darter
Brown Darter
Gulf Darter
Hogchoker
Lepomis marginatus
Pomoxis nigromaculatus
Enneacanthus gloriosus
Enneacanthus obesus
Elassoma zonatum
Elassoma okefenokee
Elassoma everglade1
Percina nigrofasciata
Etheostoma fusiforme
Etheostoma edwini
Etheostoma swaini
Trinectes maculatus
Source: City of Tallahassee. Tallahassee - Leon County, Florida
201 Facilities Plan. Appendix A, Environmental Inventory. Wil-
liam M. Bishop Consulting Engineers, Inc. 1977.
W-107. Comment noted.
W-108. Comment noted.
W-109. Comment noted.
W-110. No response required.
W-lll. Comment noted.
W-112. The use of federal funds is also being carefully scruti-
nized. Costs of local government are eventually passed on to the
community in the form of taxes or user charges. The centralized
wastewater management systems proposed by Alternatives 1-3 in the
DEIS would also require increases in staffing and services. Fur-
thermore, the debt from financing the capital costs of a
centralized system would also be passed on to the community. The
EIS evaluation showed Alternative 4, No-Federal-Action to be the
most cost-effective wastewater management system for the study
area.
W-113. As discussed in the response to comment W-112, the costs
of local government are eventually passed on to the community.
The Draft EIS states that, in order to be effective, a public
management agency must have the authority to enter property to 1)
perform site evaluations and 2) inspect operation and maintenance
(see page III-9 of the DEIS). It is reasonable to expect that
this authority could be obtained by a local governmental agency.
The DEIS also states that this agency must have the authority "To
V-92
-------
require and enforce repair and replacement of failing systems."
It will be necessary to carefully and specifically define system
"malfunctions" in order to effectively administer this authority.
A revision to the Draft EIS will be noted in Chapter IV of the
FEIS, "Revisions to the DEIS and Additional Information."
W-114. The events recounted in this comment show the local gov-
ernment gaining control over the package plants after they have
deteriorated. It is the intent of the public management agency
concept to impose this control at the planning stage of a small
community system and by this control encourage proper design,
installation, operation, and maintenance.
W-115. Comment noted.
W-116 The EIS concluded that the overburden is adequate to pro-
tect the aquifer. As shown in Figure IV.1 of the DEIS, the two
aeoloqical formations underlying northeastern Leon County, the
area slated for most of the future development, are the Miccosuk-
ee and Hawthorn Formations. The St. Marks Formation underlies
southeastern Leon County. Further, these water supply wells are
located over 200 feet deep providing appreciable protection from
significant effect. These formations are described on pp. IV-7
and IV-9 of the DEIS. It is recognized that on-site systems
using suitable soils provide renovation of wastewater within
several feet of discharge (see response to W-49).
The EIS is concerned with the potential for nonpoint source pol-
lution due to high density development. This pollution of sur-
face waters which discharge directly to the Floridan Aquifer
through sinkholes presents a potential adverse impact which may
be difficult to control.
W-117. (1) True, small community systems would be more suitable
for high density developments. However, the existing and pro-
jected development patterns are not high density and are mostly
suitable for on-site systems.
(2) The response to comment W-80 discusses the methodology and
sources utilized in the development of Figure IV.10.
(3) Percolation tests are currently required by Chapter 10D-6 of
the Florida Administrative Code before the approval of an indi-
vidual on-site system.
W-118. These possibilities were taken into account in the evalu-
ation of the selected alternative. Both the use of a management
district and the implementation of a monitoring program are
recommended to mitigate the potential adverse impacts due to
these possibilities. These mitigative measures are discussed in
Part C, Chapter III of the DEIS. Further, the State regulatory
V-93
-------
programs provide considerable mechanisms to avoid these adverse
effects.
W-119. Comment noted.
W-120. Comment noted.
W-121. The interceptor system configuration proposed by the EIS
represents a preliminary design effort based on the most
cost-effective options under existing conditions. The source of
data on stream crossings in the EIS is U.S. Geological Survey
(USGS) topographic maps of the area. Detailed field surveys of
interceptor routes are not commonly done until the final design
of the system.
In order to provide the most economical system configuration, the
proposed interceptors were designed to follow natural drainage
patterns where land use patterns did not interfere. This permit-
ted the use of gravity lines rather than force mains, thus mini-
mizing the amount of pumping required. Therefore, many of the
proposed interceptors in the northeast run parallel to streams,
ponds, and wetland systems, and there is a potential for con-
struction impacts on these systems. In addition, there are ten
(10) actual stream crossings which are indicated on USGS maps for
the interceptors that would not be required under Alternative 4.
The figure of fifteen (15) is incorrect in the statement on page
III-4. This figure represents the total number of stream cross-
ings for the entire interceptor system (as was proposed, for
example, under Alternatives 1 and 2), and should not have been
used in this context. A correction will be noted in Chapter IV
of the FEIS, "Revisions to the Draft EIS and Additional Informa-
tion" .
Because the field data provided by the City show little flow in
the streams shown on the USGS maps, the following revisions to
the DEIS will be noted in Chapter IV of the FEIS.
1. The term "primary" will be removed from the last
sentence of the second-to-last paragraph on page
III-4. In addition, the City's findings will be
noted.
2. Under the parameter "Surface Water Quality" on page
IV-71 and "Aquatic Ecosystems" on page IV-72, all
impacts from sedimentation due to construction
activities will be changed from "major" to "signif-
icant" .
It should be noted, however, that the field data presented by the
City was collected at a time when Leon County had been experienc-
ing an extended dry period. EPA agrees that the potential
impacts addressed in this comment can be mitigated to a great
degree through good construction practices.
V-94
-------
W-122 The description or interpretation of a moderate limita-
tion for sanitary facilities given in this comment is not com-
plete The U.S.D.A. National Soils Handbook, Rating Soils for
Selected Uses, provides the following definition for a moderate
limitation rating :
Moderate is the rating given soils that have properties
moderately favorable for the use. This degree of limi-
tation can be overcome or modified by special planning,
desiqn, or maintenance. During some part of the year,
the expected performance of the structure or other
planned use is somewhat less desirable than for soils
rated slight. Some soils rated moderate require treat-
ment such as artificial drainage, control to runoff to
reduce erosion, extended septic tank absorption fields,
gxtra excavation, or some modification of certain fea-
tures through manipulation of the soil. For these
soils, modification is needed for those construction
plans' generally used for soils of slight limitation.
Modification may include specially designed
foundations, extra reinforcement of structures, sump
pumps, and the like.
The referred publication by Richard Guthrie and Gerald J. Latshaw
USDA SCS, entitled "Soil-Potential Ratings for Septic Tank
Absorption'Fields in Leon County, Florida" is an article describ-
ing a local effort whose task was to develop soil potential rat-
ings in order to better supplement the SCS uniform or national
rating scheme for soils and selected uses.
The USDA SCS was instrumental in getting this pilot project to
test soil-potential rating procedures for septic tank absorption
fields started in Leon County. Close coordination between the
SCS State Soil Scientist's Office and local offices was necessary
to assemble a multi-disciplinary team of soil scientists, plan-
ners, engineers, sanitarians, and local septic tank contractors
for local input during the planning process.
The USDA SCS provided technical assistance regarding soil survey
procedures and interpretations but did not provide input regard-
ing the development of corrective measures. Local contractors
who install septic tanks identified corrective measures that they
use to overcome soil limitations.
Corrective measures and the continuing limitations associated
with the use of soil absorption systems in various soils are the
results of the local planning process. Therefore the corrective
measures listed on the worksheets, Table 2, represent the tech-
niques presently considered feasible for overcoming various phys-
ical constraints encountered by local sanitarians and septic tank
contractors. The corrective measures identified on the worksheet
should by no means be taken as an absolute, for in many instances
an expansion of the soil absorption field should be designed with
respect to the soil permeability for saturated conditions.
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W-123. Concern over public health risks associated with land
disposal of treated wastewater on the proposed SW land applica-
tion was one of the issues which led to the EIS. For a dis-
cussion of the issues which led to the initiation of the EIS
refer to pages 1-1 through 1-3 of the DEIS. Based on the results
of this EIS, EPA sees no reason to expand the SW sprayfield. If
the City elected to expand the capacity of the T.P.
Smith/Southwest plant using local funds they could still consider
the SW site as an effluent disposal alternative. It would be
their responsibility to address potential health risks associated
with further development of this site.
W-124. See the response to comment W-123. The EIS concluded
that the potential health risks associated with the Southeast
sprayfield, even if expanded, were minimal.
W-125. EPA determined that health risk data would be collected
at the SW spray field if its expansion was part of an alternative
being considered.
Without knowing which studies the City is referring "to it is
impossible to respond specifically to this comment. Several stu-
dies on the health effects of land application were considered ir
the Alternatives Evaluation Task. These studies are listed 01
page R-5 of the Draft Alternatives Evaluation Report. The con-
clusions of these studies were not consistent and it cannot b<
inferred from a review of the documents that there is little o]
no health risk associated with properly operated land applicatioi
systems. A discussion of public health concerns related to lan<
application systems can be found in the Draft Alternatives Evalu-
ation Task Report, Volume II, pp. VI-53 through VI-66.
W-126. These statements were based on a preliminary screening o:
land application sites which was part of the Alternatives Devel
opment Task. Further scrutiny of the needs and available site
in the Alternatives Evaluation Report led to the decision to uti
lize the Southeast site for flows greater than 17.5 mgd. See th
response to comment W-26.
W-127. As the U.S. Department of Agriculture (USDA), Soil Con
servation Service (SCS) Soil Survey of Leon County, Florida wa
not published at the time the EIS evaluation of land applicatio
sites was being done, the consultants utilized interim SCS dat
that had been transferred to U.S. Geological Survey (USGS) topo
graphic maps by the Tallahassee - Leon County Plannin
Department. Copies of these maps reveal that the predominan
soil series at the proposed SW land application site were show
to be Leon fine sand and Albany variant fine sand. These soi
series are characterized by moderate to moderately rapid perme
abilities, however, the depth to the season high water table i
indicated as 1.0 foot or less and 1.0 - 2.5 feet respectively
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Furthermore, the USGS topographic maps of the area show a gener-
ally low-lying area with depressions and some actual ponding.
Wetlands are shown approximately 2,000 feet southwest of the
site. The conclusions in the EIS were based on this information.
The recently published soil survey indeed reflects several
soil series name changes with respect to the tenatively assigned
names as referenced in the Interim Soil Surveys. Significant
areas in Leon County previously mapped as Albany loamy sands more
appropriate fall into the range of characteristics of the recent-
ly established (1977) Ortego series. A similar situation exists
with the range of characteristics of the Plummer series in the
interim survey better fitting the diagnostic description of the
Blanton Series.
In the SW sprayfield area the more gently rolling sectors
consist of deep well drained sands. The Kershaw series was dif-
ferientated in the advanced soil survey to a more limited extent
than in the final survey mapping. The Kershaw series was ori-
ginally delineated only on the higher topographic settings. Sub-
sequent checks of the interim SCS mapping effort reveals a more
extensive coverage of the Kershaw series. Some error is encount-
ered in the interim data in the interpretation of soil mapping
units when the basic SCS data at a scale of 1 inch equals 1,760
ft. was transferred to a 1 inch equals 2,000 ft. scale by the
Tallahassee - Leon County Planning Department. Problems with
incomplete soil mapping boundaries resulted in more extensive
areas of the Leon soil in regions where the Kershaw series would
normally occur.
Based on the recently published soil survey, expansion of the SW
sprayfield does not appear to be limited by soil and water table
conditions.
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PART B. ORAL COMMENTS
Index to Oral Comments
Comment
Name
Agency
T-l, T-2
T-3 through T-8
T-9
T-10, T-ll
T-12
William G. Leseman
Glenn Dykes
T. Michael Schneider
Rhett White
Jessie Brown
T-l3 through T-l7 John Koelemij
T-l8 through T-27 J.D. Boone Kuersteiner
City of Tallahassee,
Water Quality Lab
Florida Department
of Environmental
Regulation, Drink-
ing Water Program
City of Tallahassee,
201 Program
Leon County Health
Department
Munson Area Preser-
vation, Inc.
Tallahassee-Builders
Falls Chase Special
Taxing District
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Before the
ENVIRONMENTAL PROTECTION AGENCY
WATER MANAGEMENT DIVISION
REGION IV
ATLANTA, GEORGIA
In the matter of:
ENVIRONMENTAL IMPACT STATEMENT
ON PROPOSED WASTEWATER MANAGE-
MENT FOR THE CITY OP TALLAHASSEE,
LEON COUNTY, FLORIDA
DER Courtroom
Fourth Floor
Department of Energy
Twin Towers Office Bldg.
Tallahassee, Florida
Thursday, November 5, 1981
The above-entitled matter came on for hearing, pursuant
to notice at 7:30 p.m.
BEFORE: PAUL TRAINA,
Director Water Management
Environmental Protection Agency
Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30308
1(404)881-4450
MR. VAN HOOFNAGLE,
Suite 500F^°r^a De^artlnent Environmental Regulation
2 600 Blair Stone Road
Twin Towers Office Building
Tallahassee, Florida 32301
1(904)488-2582
MR. BOWMAN CRUM
EPA Project Officer
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INDEX
SPEAKERS:
MR. PAUL J. TRAINA, Director Reg.IV EPA,
Water Management Division
MR. BOWMAN CRUM, EPA Project Officer
MR. VAN HOOFNAGLE, Bureau of Wastewater Management
and Grants
MR. WILLIAM LESEMAN, City of Tallahassee Water
Quality Laboratory
MR. GLENN DYKES, Florida Department Environmental
Regulations
MR. MIKE SCHNEIDER, Program Manager
City of Tallahassee 35,
MR. RHETT WHITE, Leon County Health Department
MS. JESSIE BROWN, Munson Area Preservation, Inc.
MR. JOHN KOELEMIJ, Member Advisory Committee
Leon County
MR. J. D. BOONE KUERSTEINER, Falls Chase Special
Special Taxing District
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proceedings
7:30 p.m.
MR. TRAINA: I'd like to call this hearing together
tonight. I want to welcome you all to this public hearing on
the draft Environmental Impact Statement on the proposed
wastewater management for the city of Tallahassee and
surrounding areas of Leon County, Florida.
I would like to begin by introducing the hearing
panel. First, my name is Paul Traina. I am Director of the
Water Management Division of the Environmental Protection
Agency of Region IV in Atlanta, Georgia. To my immediate
left is Mr. Bowman Crum, who is the EPA Project Officer on
this project. And on his left is Mr. Van Hoofnagle with the
Florida Department of Environmental Regulation.
The purpose of this evenings hearing is to receive
public and other agencies1 comments on the wastewater
management proposal contained in the draft Environmental
Impact Statement for Tallahassee and Leon County, Florida.
This environmental Impact Statement is being prepared on
wastewater facilities proposed in the 201 Facilities Plan
prepared for the City of Tallahassee by William M. Bishop,
Consulting Engineers, Inc., Tallahassee, Florida.
The preparation of this EIS is authorized by the
Federal Clean Water_Act and the Natiqnal_Envirqnmental_PqlicY.
Act. The Federal_C1ean_Water_Act enables the EPA to fund up
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to 75% of the eligible costs for the planning, design and
construction of wastewater facilities. The planning phase of
this process results in the preparation of a facilities plan.
In this instance, the City of Tallahassee has been designated
as the local agency responsible for facilities planning in
this area. The National Environmental Policy Act, NEPA, re-
quires Federal agencies to prepare and Environmental Impact
Statement on major Federal actions significantly effecting
the quality of the human environment. Because of the envi-
ronmental complexities and water quality issues involved in
this project EPA made the decision to prepare an EIS on the
completed 201 Facilities Plan. Accordingly, in November of
1978 the Notice of Intent to prepare an EIS was issued.
Pursuant to the guidelines of the President^s_Council_on
?!2Yi£°!l®®l2tal_QualitY and the rules and Regulations of EPA,
with regard to the preparation of EIS's, this Public Hearing
is being held to receive comments on the draft EIS.
The draft EIS and Facilities Plan are being discus-
sed in a public forum to encourage public participation in
the Federal decision-making process and to develop improved
public understanding of federally funded projects. In this
regard, the draft EIS was made available to the public and
EPA's office of Federal Activities in Washington, D.C. on
September 17, 1981. And was listed in the Federal Register
on September 25, 1981. The draft, EIS, comment period will
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extend until November 20, 1981. The comments received during
this evening and during the comment period will become part
of the record.
I'd like to let you know now that the proceedings
tonight are being recorded. We have a private consultant
here who is recording the proceedings, Mary Lou Stokes.
These proceedings will be available in our offices in Atlan-
ta. And for those of you who would care, I'm sure you can
make arrangements with Ms. Stokes if you'd like to receive
directly a copy of these proceedings.
At this point, I would like to introduce and have
Mr. Crum, who's the EPA Project Officer, provide us with a
brief summary of this project.
Mr. Crum.
MR. CRUM: Good evening. This draft, Environmental
Impact Statement or EIS, has been prepared in response to is-
sues raised in opposition to portions of the Tallahassee,
Leon County 201 Facilities Plan. The draft EIS addresses
wastewater management needs for growth areas which will not
be served by 201 facilities already approved by EPA. Through
the EIS process alternatives for wastewater management in the
study area were developed and evaluated and a perferred
alternative was selected.
The draft, Tallahassee-Leon County 201 Plan, was
approved in April of 1977 by the City and County Commission-
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ers and received initial approval from the Florida DER and
the EPA. The EPA subsequently made a decision to initiate
grants for the design of only those facilities which would
recieve or relieve existing water quality problems. This de-
cision was made in part due to the opposition of citizens and
private organizations to portions of the 201 Plan. It was
further decided that an EIS would be prepared on those por-
tions of the 201 plan that may result in significant environ-
mental impacts.
The wastewater facilities which EPA has already ap-
proved and many of which have already been constructed pro-
vide for a total capacity of 17.5 million gallons a day or
MGD at the Southwest and TP Smith Plants and the Southeast
sprayfield. Also a new seventeen and a half MGD sludge
handling facility and additional interceptors and pump
stations have been approved for construction. Those
facilites proposed by the 201 plan, which are covered by this
EIS, are a new 5 MGD Northeast Treatment plant, a sixty
thousnd linear foot forcemain from the Northeast plant to the
Southeast Sprayfield; expansion of the TP Smith Plant beyond
15 million gallons a day; additional interceptors to growth
areas, mostly in the northeast.
This EIS was prepared because of issues raised by
several organizations and individual citizens. These issues
are summarized as follows: Number one, Public health risks
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may be associated with land application of wastewater; Num-
ber two, wastewater flow projections in the 201 plan may be
too high; Number three, adverse impacts to wetlands may re-
sult from development in northeast Leon County; Number four,
a wastewater treatment plant in the northeast may be incom-
patible with the residential use of the area; five, the con-
struction, operation and maintenance of a forcemain from the
projected Northeast Plant to the Southeast Sprayfield may
have adverse impacts on the wetlands and the dam at Lake
Lafayette; Number six, renovation of the Lake Bradford Plant
may be more cost effective than closing it; and issue Number
seven, concern that any of the alternatives may have adverse
impacts on the habitats of threatened and endangered plants
and animals. With these issues as a basis for the EIS an in-
ventory of existing environmental conditions was conducted.
The EIS then screened the available collection treatment and
disposal options for wastewater management and determined the
most feasible options appropriate for the study area. Flow
and waste reduction measures were considered for the study
area by the EIS and was evaluated with and without and each
alternative, excuse me, was evaluated with and without flow
reduction. These wastewater management alternatives were
then evaluated and a preferred alternative was selected. The
alternative management systems developed and evaluated by the
EIS are Alternative System 1(a), this alternative would
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include a new treatment plant in the northeast with disposal
by rapid infiltration. Expansion of the TP Smith and
Southwest facility with disposal at the Southeast Sprayfield
and additional interceptors to growth areas. Alternative
System 1(b) is the same as 1(a) except that the Northeast
plant affluent would be disposed of at the Southeast
Sprayfield.
Alternative System 2 uses existing facilities as a
regional treatment system without the implementation of flow
reduction measures, continued operation of the Lake Bradford
Plant and an expanded TP Smith, Southwest Plant would serve
the entire sewered area. With the implementation of flow re-
duction measures, an expanded TP SMith-Southwest Plant alone
would serve the sewered area as the regional facility. All
disposal would be at the Southeast Sprayfield and this
alternative also includes additional interceptors to be
constructed.
Alternative System 3 would consist of a Southeast
treatment plant to supplement the TP Smith-Southwest facility
with disposal at the Southeast Sprayfield, also additional
interceptors will be constructed.
Alternative System 4 is the no-federal action al-
ternative. Under this alternative expansion of the present
wastewater system will continue until all of the facilities
already approved for construction by EPA are completed. New
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growth in wastewater generation would be handled by on-site
and small community systems. Population in-filling will take
place in the city service area and seme additional sewering
will be necessary. To be constructed under this alternative
is most of the proposed southeast system of interceptor sew-
ers including the "J" series interceptors and the McGinnis
Arm area of Lack Jackson.
Alternative number four has been selected by EPA to
be the preferred alternative for the draft, EIS. This alter-
native was determined to be the most cost effective and envi-
ronmentally sound wastewater management alternative.
The remainder of the phase 1 facilities, which have
been approved by EPA, will serve all existing and some future
needs. The EIS projected at by the year 2000 the wastewater
flow from within that area now served by the city, without
flow reduction measures will approximate the available seven-
teen and a half MG cap — MGD capactiy at the TP Smith-
Southwest — Southwest treatment facility. The projected
growth areas are suited to the use of on-site and small com-
munity systems. Data on soils in the growth area support the
use of on-site systems. The Leon County Health Department
indicates that on-site systems operate properly when their
construction follows the basic rules governing their place-
ment. The few failures of on-site systems that have occurrec
in the northeast growth area are a result of poor siting and
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pure construction.
The importance of ground water quality in an area
where ground water is the sole, potable water supply is the
most critical consideration. The EIS shows no significant
adverse impact to ground water quality from the use of
on-site and small community systems in the growth areas. The
impacts on downgrading at city water supply wells were fully
considered in the selection of alternative number four. The
geological formations in northern Leon County, including the
projected growth areas, should provide adequate protection
for the drinking water aquifer for Florida inaquifer.
Another issue of the EIS is that potential detri-
mental impacts to wetlands may result from development in
northeast Leon County. Properly implemented, the recommended
alternative decreases the potential for development in margi-
nal lands and environmentally sensitive lands, such as the
wetlands, floodplains and high ground water areas. For the
implementation of alternative four, the importance of proper
siting, construction and operation and maintenance of on-site
and small community systems cannot be overemphasized. When
managed competently, on-site systems and small community sy-
stems are cost effective and environmentally sound.
It is recommended that the implementation of alter-
native four include several measures at the local level which
will serve to mitigate potential impacts. The primary recom-
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mendations are as follows: revisions of the basic rules gov-
erning septic tank use to allow for systems more suited to
current and future demands. These revisions should include
siting criteria, basic system design and the use of alterna-
tive systems. The implementation of a management district or
other means of on-site systems management to promote effi-
cient operation is also recommended. The third recommenda-
tion is that monitoring of ground water quality in developing
areas of Leon County to assure early detection should ground
water quality problems occur. The focus of this program
would be to identify cumulative area-wide impacts on ground
water.
In conclusion, it should be emphasized this EIS ad-
dresses a federal action only. And that action is the provi-
sion of federal funds for the construction of the proposed
facilities. This decision affects only the use of federal
funds. The City and County are free to proceed with addi-
tional wastewater management programs that are locally fundec
provided they meet state and EPA Permit requirements.
Thank you, Mr. Chairman.
CHAIRMAN TRAINA: Thank you, Mr. Crum.
I'd like now to ask Mr. Van Hoofnagle to make a
statement on behalf of the Florida Department of DER.
MR. HOOFNAGLE: Thank you, Paul.
Good evening. My name is Van Hoofnagle, I work in
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the bureau of Wastewater Management and Grants, specifically
in the 201 program. I have been involved in the TAC group
for the last several months and have had the opportunity to
review this document. However, we have had several other
bureaus within the Department that have not had the opportun-
ity to completely review so I would like to ask Mr. Traina
and Bo if they would extend the comment period beyond Novemb-
er 20th.
CHAIRMAN TRAINA: Yes, that'll be granted.
MR. HOOFNAGLE: I don't have any other requests or
statements at this time.
CHAIRMAN TRAINA: Thank you.
Okay. You've heard from the federal and state
bureaucrats now it's your meeting. That's what this is all
about, it's a public hearing, public meeting, to hear your
comments. I would ask that those of you who haven't yet fil-
led out a yellow card please do that. That'll do two things
for us. First, it will tell us when -- or tell our bosses
when we get back to Atlanta, and in the case of Van in Talla-
hassee, that people really showed up at this meeting and it
was worth their while to pay for our trip here. Secondly, i
will put you on a mailing list to receive the results of thi;
hearing and any other information that you might want. And
the other thing is that I'm going to proceed new and call
people who've indicated on this card that they would like to
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make a statement. And that's in the order that I will fol-
low, that is the order in which you've registered. When I do
call your name, I would appreciate your caning up to the po-
dium. If you will, identify who you are. If you do repre-
sent someone let us know that and if you have a written copy
of your statement we would appreciate getting a copy so that
we can follow along with you. Before I get to that let me
ask, are there any elected officials here at the local level?
We'd certainly like to recognize those if they'd like to get
up and be recognized and make a statement. Is the Mayor
here, any of the Councilmen or women here or anyone else?
Okay.
Let me then proceed and call on Mr. William G.
Leseman.
MR LESEMAN: My name is William Leseman with the
City of Tallahassee Water Quality Lab. Okay, one of the
major issues, major items subject to EIS study was the
expansion of the two acre southwest Sprayfield. In Mr.
Crum's summary he stated that the EIS was initiated because
of the following issues raised by organizations and
individual citizens. Number one was that public health risk
may be associated with the land application of wastewater.
Now, what I wish to do is to go through the several differen
volumes or preliminary plans of studies and plans of studies
and the various assundry plans that came out in somewhat of
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chronological order using the words of the consultant and not
my words to carry you through this evaluation, or proposed
evaluation.
To start off with, the preliminary plan of study,
which was in April, 1979, and the facilities associated with
the second phase of the proposed 201 plan which have not been
permitted to proceed and are being investigated by the EIS
are as follows: Construction of a 2,000 acre southwest spray
irrigation field . . .
CHAIRMAN TRAINA: Excuse me, Mr. Leseman. Can
everyone hear him in the back?
(No audible answer.)
CHAIRMAN TRAINA: Okay. Thank you. Go ahead, Mr.
Leseman.
MR. LESEMAN: Construction of two thousand acre
southwest spray irrigation field adjacent to the TP Smith
plant, okay.
I'll give you page numbers on these so -- just for
the record.
I'm on page 4 of the preliminary plan of study.
CHAIRMAN TRAINA: What --do you have a prepared
copy of your statement?
MR. LESEMAN: No, I've just got xeroxed copies of
this.
CHAIRMAN TRAINA: Okay, fine.
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MR. LESEMAN: (Quoting)
"Impacts of construction on operation
of alternative spray irrigation sites:
Potential impacts to be evaluated in-
clude public health hazards due to ae-
rosol or ground water transport of vi-
ruses, bacteria or hazardous pollutants.
Impacts to property values and impacts
to endangered species and buffered zone
vegetation. Furthermore, changes
expected to occur to the ecosystem
of the spray site through it's de-
sign life, the ultimate use of the
site and the ultimate fade of any
nutrients, bacteria or viruses
discharged at the site will be thor-
oughly discussed for the reasonable
alternatives."
Okay, we go over here to page 23.
"Initiate Monitoring Program and Col-
lect Data: The intent of the moni
toring program is to supplement back-
ground information, permit quantifi
cation of existing conditions and aid
in identifying and assessing potential
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impacts for proposed alternatives.
This task will require field trips to
the study area by project personnel.
As specifically described in Appendix
(b) the monitoring program will focus
on two main areas; monitoring of sur
face waters and sediments and monitor-
ing the current sprayfield to allow
projections of impacts of expanded
spraying".
Basically what I'm trying to do here is to outline/
as I have read it in here, what the original plan was and to
carry it through as to what was the ultimate output.
CHAIRMAN TRAINA: Mr. Leseman, is it fair to ask
you at this point as to whether or not you're agreeing or
disagreeing with the tentative federal decision on this
project?
MR. LESEMAN: I'm disagreeing with the decision
based on the fact that the decision was made on data which i:
false.
CHAIRMAN TRAINA: Okay, thank you.
MR. LESEMAN: Which I plan on showing.
"Potential land application sites will
be identified based on proximity to ex-
isting and future wastewater generators.
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This is on page 3 6.
Okay. Now we come over here to preliminary study
background task report, page 3 5. Again,
"Issues of local concern:
Number one is,
"How spray irrigation impacts:
Come down here to.
"Spray irrigation impacts:
on page 3 5;
"several health or risk assessment asso-
ciated aspects of land disposal merit
consideration in evaluating impacts on
potential southwest sprayfield sites.
First, residents near the small existing
site have voiced concern that aerosols
generated during spraying could transmit
bacterial or viral diseases. Second, gi-
ven the sand overlaying caustic limestone
nature of this geological subunit, Wood-
ville Carts Plane, there may be a poten-
tial for ground water contamination with
bacteria or viruses due to rapid passage,
absorption, ellution, channelling or other
perhaps poorly understood mechanisms."
Finally,
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"Concerns exist that animal vectors could
spread disease from the site.
Again, pointing out what the study is to look at,
go over here to the second segment plan of study, preliminary
May 1980. Again, in the introduction it states;
"Number one, the spray irrigation
impacts, concern has been raised
for public health risk associated
with transmittal of bacteria and
viral diseases from spraying oper-
ation and subsequent ground water
contamination, as well as disease
transmittal from the site by animal
vectors."
Also number eight states, on page 2,
"General concern has been express-
ed about long-range impacts from
the sprayfield and buffer zone vege-
tation as well possible devaluation
of local residential property."
Page number 3,
"Those actions which will be covered
by the EIS include number 3, propos-
ed two thousand acreas southwest
spray irrigation field. Okay, so
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three separate documents we have stat-
ed that the southwest field is going
to be one of the main focuses of con-
cern. "
Okay, I'm ncm speaking from the environmental in-
ventory task report, page number 5,
"The EIS was initiated as a response
to a number of issues raised by organ-
izations and individual citizens dur-
ing the 201 study and during the re-
view period after the negative declar-
ation issued by EPA in February 1978.
A summary of these issues follows:
Number one, spray irrigations impacts:"
Again, the same paragraph,
"concern has been raised for public
health risk associated with land dis
posal of treated wastewater on the
proposed southwest sprayfield sites,"
et cetera, et cetera. The environmental monitoring program,
segment 1, draft report, April 1980. Page number
3,
"In the Tallahassee EIS one of the
major concerns of spraying sewage
effluent on land is the potential con-
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tamination of ground water resources
which are heavily utilized in Talla-
hassee and the State of Florida. The
comprehensive monitoring program at
the TP Smith wastewater rennovation
plant spray site was established to
quantify the hydrogeologic and the
chemical effects of sewage effluent
disposal on ground water in the vi-
cinity of the plant. This program
was undertaken by the USGS in 197 5
which owns and operates thirty wells
and the surrounding spray field area
for monitoring purposes. In addition
to the USGS has a sampled and tested
ground water from privately owned wells
near the spray site. However, this com-
prehensive program, which includes test-
ing of a variety of chemical and biological
parameters does not test for the tran-
sport of virus in the ground water."
On the same page it says.
" Since the USGS monitoring program for
the chemical bacteriological data seems
adequate no additional work was recom-
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mended as part of the first segment of
EMP."
So on the same page they said they don't monitor for viruses
in the ground water but that's okay, although the first, I
think, four different volumes that I stated said that one of
the major areas of concern was to look at the effects of
viruses and bacterial contamination.
Okay. On page number 4, the bottom of the page;
"A microbiological study of land dis-
posal effluents was not included in
the first segment EMP. Such a study
would be site specific and would be
contengent upon the inclusion of
land disposal in the list of rea-
sonable alternatives. As such, a
microbiological study is being con-
sidered in the second segment, EMP,
plan of study."
Okay. Well, so far we've had that the main goal is
to study this because that's the whole reason that people do
not wish to have the southwest sprayfield utilized and it's
kind of been a "we'll do a end-run and we won't have to look
at it". So, now we come over here to the environmental moni-
toring program, segment 2, terrestrial survey. Back here we
stated that based on the alternatives we'd determine whether
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a microbiological study was really necessary. So we go on
here and we look and see if the spray field is really a via-
ble alternative.
"Potential sprayfield sites . . .
again this is the environmental monitoring program segment 2,
terrestrial survey, page 3 6.
"Potential sprayfield sites with
adequate disposal capacity were
present at five locations."
number one.
"Southwest sprayfield expansion"
Okay, so it's got enough capacity according to the consul-
tant.
"Alternatives development task report."
Page 89.
"Slow rate land appllication is- present-
ly utilized in Southwest Leon County.
The city of Tallahassee disposes of ap-
proximately 1.5 million gallons per day
of it's treated effluent on land adjacent
to it's TP Smith southwest treatment
facility. IN 1972 soils explorations
for structural foundations of the site
should sands exist up to forty-five feet
below the surface . . .
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remember the term forty-five feet below the surface.
"These sands of the Lakeland series, which
charaterizes a large portion of the soils
in the southwest overlay the St. Marks'
formation of the Florid inaquefer and are
capable of accomodating very large hydraulic
loadings."
very large hydraulic loadings.
"In the southwest the proximity of the
Apalachicola National Forest and the po-
tential for a land swap with the city of
Tallahassee makes slow rate land applica-
tion a viable alternative in this area.
Investigations for suitable land applica-
tion sites will include examining the
potential for expanding the city's
present disposal site in the south-
west as well as examining potential
sites within the Apalachicola Nation-
al Forest, less approximate to resi-
dential areas.
page 91.
"As in the Southeast, the southwest
too will be investigated further for
possible rapid infiltration sites.
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The current land disposal site in the
southwest and other sites within the
Apalachicola National Forest will be
examined for possible disposal loca-
tions as described earlier. The soils
are capable of accomodating large hy-
draulic loadings, making the area mini-
mal to this method of treatment dispo-
sal. "
Well, so far so good. Looks like you may have to go back and
do the microbiological monitoring. Okay we come over here to
the draft, Alternatives Evaluations, volume two, Detailed
Analysis Task Report, page 1-7.
"The EIS was initiated as a response to
a number of issues raised by organiza-
tion and individual citizens during the
201 study and during the review period
after the negative declaration issued by
EPA in February 197 8. A summary of these
issues follows. Number one, land applica-
tion impacts ..."
et cetera, et ccetera, the same paragraph you've seen else-
where. Come over here to page Roman numeral VI-IX.
"An evaluation of the suitability of land
application within the Tallahassee-Leon
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County study area must also consider the
parameters shown in table 2.62. The EIS
evaluation procedure began by simultan-
eously analyzing detailed soils of infor-
mation. "
I stress detailed soils of information.
"Vegetation Maps and Aerial Photo-
graphs; Potential land application
sites in each of the proposed service
areas were identified and a terrestrial
survey of the potential sites was con-
ducted by the EIS study consultant.
For sane parameter, such hydraulic con-
ductivity CAT unexchanged capacity,
sodium absorption, land acquisition
methods, follow up discussions and
field tests at the recommended sites
may need to be conducted."
I would consider that if I was going to be
looking at a site for spray irrigation that hydraulic con-
ductivity would probably be one of the first things I looked
at and back here I thought it said detailed soils analysis,
but, okay, we should go on. We come up here to a paragraph
on page Roman Numeral VI-LXI which states;
"The potential southwest site with it's
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predominate Albany and Leon fine sands
has excellent bacterial and viral remov-
al characteristics but the site is marked
by a shallow water table during the wet
months of the year."
You remember the forty-five that I mentioned earlier,
forty-five feet ground water. Somehow I don't think that
forty-five feet is shallow. If you'll get the United States
Department of Agricultural Conservation Service Soils maps
out, you'll find that there is no Albany variant and there is
no Leon fine sand in the Southwest site. I have the soil
legend here, which the predominant soils in the area are
curshal sand, ortega sand, alpine sand and blem fine sand
with hydraulic conductivity rates that range from 21.5 inches
per hour to 4.7 inches per hour as a hydraulic conductivity.
So somewhere along the line somebody got some misinformation
considering we've been doing spray irrigation at this
particular location for many years and have applied very high
hydraulic loadings. The fact that the site was abandoned
because the soil is quote "subject to flooding" which has
never been observed in the area, I think, is a piece of data
that the EPA should look very closely at when evaluating this
entire study.
Thank you.
CHAIRMAN TRAINA: Thank you, Mr. Leseman. Excuse
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me, could you just — let me just make a comment that if I
had any doubt as to what your position was in the beginning
of your statement, it's certainly been clarified. I take it
that you don't -- you not only disagree but you somewhat — I
wouldn't say vehemently, but you certainly positively
disagree with the findings of the EIS. Is that a correct
surmise on my part?
MR. LESEMAN: That's correct.
CHAIRMAN TRAINA: Let me ask you, Mr. Leseman, are
you representing the City. Is this the City's official
position?
MR. LESEMAN: No, this is not the City's official
position. I am simply pointing out some of the things which
are supposedly fact, which are indeed not fact.
CHAIRMAN TRAINA: I'd like to ask Mr. Crum if he'd
like to comment back on that.
MR. LESEMAN: Okay.
CHAIRMAN TRAINA: I think you've raised some rather
interesting points. Now how valid they are, I don't know.
MR. CRUM: Okay, it's, I think, it's very difficult
tonight to answer each one of the points you've raised speci-
fically. I can assure you that in the final EIS we will. I
think probably one thing that you've pointed out that I
think's been a concern for seme time is that the lack of a
microbiological study, the study of viruses, and I think our
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position has been, for. same time, that if a southwest spray-
field had been part of an alternative considered for the
draft Environmental Impact Statement that we would perform
!
that study. And that -- we've said that and I think that's
been our position.
MR. LESEMAN: I agree, that's exactly what you
said, you know, if there was an alternative you'd do the work
and then you eliminated it based on false data. j
MR. CRUM: Okay, so that's ... 2
i
MR. LESEMAN: That's the main concern.
MR. CRUM: I can assure you that we will address
each one of those points of — that you perceive to be or
whatever false data and — in -- comprehensively in our final
EIS.
CHAIRMAN TRAINA: Let me suggest, Mr. Leseman, that
if you can, summarize those questions. Because I think it
might be difficult to get them out of the transcript. So if
you can send us that in writing we would appreciate that.
MR. LESEMAN: I will.
CHAIRMAN TRAINA: Thank you very much, sir.
MR. LESEMAN: Thank you.
COURT REPORTER: May I ask for a moment. I'm pick-
ing up a radio station.
i
CHAIRMAN TRAINA: A radio station. i
i
COURT REPORTER: I'd like to be sure we're getting |
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a recording.
CHAIRMAN TRAINA: I certainly hope it's nice
music.
(Brief pause while Reporter changed tapes.)
COURT REPORTER: We're ready.
CHAIRMAN TRAINA: All right, thank you.
I'm not to sure here, both, under "Do you wish to
speak?", I think both a "yes" and a "no" might have been in-
dicated. So let me just ask; Mr. James Carter, would you
like to make a statement, sir?
MR. CARTER: No, no.
CHAIRMAN TRAINA: Okay.
MR. CARTER: I didn't have my glasses on.
CHAIRMAN TRAINA: You can't speak without your
glasses; is that it?
MR. CARTER: No, I didn't have them on when I fil-
led out the card.
CHAIRMAN TRAINA: Oh, okay. I have that problem
too, I can't speak without my hands.
Okay. Mr. Glenn Dykes, with the Florida Department
of Department -- Environmental Regulations, excuse me.
MR. DYKES: I didn't get up while ago when the
State, you said you had said everybody in the State had spok-
en but I didn't want to be first in line.
CHAIRMAN TRAINA: Well I realize that in Florida
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that not one person represents the DER. I learned that after
2 5 years working in this area.
MR. DYKES: I don't know why you figured that out,
Paul, I mean . . .
CHAIRMAN TRAINA: So, we welcome any and all opin-
ions from the DER.
MR. HOOFNAGLE: We have that trouble in EPA, too.
CHAIRMAN TRAINA: Yes, I know. It's very rare that
I get the opportunity though to say the same about the State.
I guess that's on the record.
MR. DYKES: My name is Glenn Dykes, D-y-k-e-s. I'm
a professional Engineer and Administrator of the Drinking Wa-
ter program for DER. I have been employed 2 5 years in the
drinking water program for the state and, of course, our main
concern as you well realize is protection of the ground water
resource. Since 90 -- 92%, the percentage keeps going up as
we add more plants, of course, they keep taking from the
ground water and that's getting higher and higher and I think
that's primarily why I would like to address seme of my con-
cerns, with regard to the EIS.
I would concur that it's cheaper to take no action.
I would debate whether or not it's environmentally sound.
The ostrich approach, I think, has been tried a number of
times. I think it only comes back to haunt us later on. And
I think planning in the near sight is a heck of a lot better
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than the far end when we have to buy up some of these --
these plants, or end up with some counties with 20 0, 300
wastewater treatment plants with no means of combining them
all together. And then we've got 200 to 300 headaches that
somebody has to operate, maintain and try to monitor, which
there's very little monitoring being done.
The alternative states that there is no problem or
potential problem from — or ill effects on the ground water
quality. This, too, I would debate since I think the basic
water supply for this particular community does, no doubt,
come from the north. Northeast, more than likely, would
supply some of the city's wells. In the carstopography the
lakes, sinkholed controlled discharge into sinkholes, sane of
the areas we're not too sure and what the overburden is over
the limestone. And I really didn't see that many soil borings
to make too much determination on as to what the overall
quality of, or protection of, the ground water resource there
is. I did look at the septic tank map and if all of those
shaded areas are supposedly adequate for septic tanks I would
debate that because my house sits in one of those shaded
areas and I would hate like hell to have to dig through that
i
clay to get a septic tank in 'cause I don't think it would
work to well. So, I would debate the map if that's what that
j
shaded area really is supposed to be, that that's acceptable
for septic tank installations.
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Of course it was brought up that there may be some
potential threat from the carstopography and I think we would
all agree that with some of the lakes -- like I'm on --
you're discharging directly into sinkholes. Lake Lafayette
is a sinkhole control. Certainly this is a problem and I
think we'd have to address it somewhere down in the future.
Insofar as on-site treatment plants, I think, as I
indicated there are a number of counties in the state that
have proven that this is almost a disasterous approach. When
you've got two to three hundred of them and then the county
comes in to take over the operation or tries to combine it
into an overall utility for the county, it's one bunch of
nightmares. And we've had some that, you know, they've tried
to do it for years and we've still got all the on-site sewar-
age treatment plants. I would debate, even if they're con-
structed properly, that they're going to be operated and
maintained. Because that's some of our biggest headaches in
water and wastewater, is operation of the small systems. I
think it's always been a better approach, from a regulatory
agency standpoint, if we can combine them into bigger
systems, to get rid of the three hundred headaches and try to
avoid them, if at all possible. From that standpoint, I
think it's false planning to say that we're going to go or
j
sit and the future or the year 2000 is going to depend on j
on-site disposal facility. I think that's really a backward !
j
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approach, it's regression. I think we've passed that point
in the state of Florida and I think a thriving state, like
Florida, has to look a little bit further and I think we have
to plan for this. The monitoring of the small plant
certainly is not going to be as good as some of the data that
I'm sure Mr. Leseman can provide on teh wastewater facilities
for the city of Tallahassee, he probably gets reems of it.
Tom, back there, he can probably -- has to look at some of
the reems of data that's generated by the test facilities
that he has, but I'm sure that you're not going to get —
you'd be lucky to get one sample per month out of any on-site
treatment plant. And, of course, with on-site septic tanks
and particular multiple housing septic tanks which I saw re-
cently a recommendation in Manatee County that HUD was recom-
mending big septic tanks for apartment complexes. I think,
here again, we're going backwards with some of our activi-
ties.
There was also some discussion about use of cover
crops. It implied that some of the small treatment plants of
the uptake — and I don't think we're going to have any major
landspreading operations on any on-site treatment plant.
Most of the them will be perch ponds, if we're lucky and if
we're lucky they won't find a hole in the strata and go right
straight down into it like we have in some areas of the
state.
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The overall approach, as I see it and as I read it,
i
I think is contrary to the ground water strategy of EPA,
which is set up to protect the ground water resources, parti-
cularly those that are potable. And I see this as a direct
opposition to that strategy. The economic feasibility over-
all, I think if we're going to consider some of the costs of T"
this approach of doing nothing and let nature take it's ^
course and let's see how many treatments plants or septic
tanks, maybe at 3 5% treatment of the waste, can contaminate
the water supply. And the potential threat does turn into a
real threat, then we have to look at complete treatment for
the city system, on the water supply side. And that doesn't
come cheap when you've got wells spread out all over this
county and then you've got to readdress the distribution and
put in two or three plants, maybe, and that's not as economi-
cal, of course, as putting in one, but there's an awful lot
of costs that would be involved in that approach. Overall I
would think that at present we might possibly, it's not feas-
ible to extend in some of these areas, maybe the density
T-
isn't great enough. And the no action status may be appro-
8
priate here but I think in the long range, I don't think it
i
is. I think we've got to look a little bit deeper than that
and to plan, at least plan for trunk lines to pick up the se-
wage as it's developed in the future.
Thank you.
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CHAIRMAN TRAINA: Thank you, Mr. Dykes. That was a
very thoughtful statement and we appreciate it. I assume,
Mr. Dykes, that the reason Mr. Hoofnagle asked for an exten-
sion was to incorporate some of these comments in the offi-
cial state position of the report upon receiving them.
Mr. Mike Schneider? We're not very formal you
could have left that coat off, but I'll leave it up to you.
I heard the air conditioner go off a few minutes ago, so I
had to take off my jacket. I understand we're out of power
here so i feel like the astronauts. Excuse me, Mr.
Schneider.
MR. SCHNEIDER: Before I give my comments I would
£o take up two items. One, I would imagine, in behalf
of everyone here; I would like to request a copy the proceed-
ings be made available here in this area. Preferably here at
DER.
CHAIRMAN TRAINA: Yes, I don't know what Ms.
Stokes' contract calls for but certainly we're going to ask
her now if you would make a copy available of the transcript
directly to Mr. Hoofnagle and his office in DER.
MR. SCHNEIDER: Thank you.
MR. HOOFNAGLE: I'm up in Suite 500, in this build-
ing.
CHAIRMAN TRAINA: What — can we ask you, Ms.
Stokes, when your transcript will be available?
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COURT REPORTER: I think the order has requested
ten day, working days.
CHAIRMAN TRAINA: Okay. So that will be available
in ten days, both in DER office and EPA.
MR. SCHNEIDER: Thank you, sir. The second item
would be that I would like to state at this time that Mr.
Leseman's presentation is the City's official position on the
subject that he spoke to.
CHAIRMAN TRAINA: Thank you, sir.
MR. SCHNEIDER: Monday in the Jacksonville paper, a
rather large article came out:
"City's Master Sewer Plan Mired In
Inconsistency."
It goes into quite a bit of detail of the problems they've
had there with package treatment plants and the problems
there. Today, when I got heme I received another newspaper
and the headlines here read:
"Regional Wastewater System Replaces
Sixty Substandard Plants."
Orange County in Orlando. I worked on a day to day basis
with this Orlando project several years ago and it is mind-
boggling to see that this has gone to the problem that it
has.
Gentlemen, I'd like your estimate as to when in the
Tallahassee Democrat, we'll see this same story about this
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area. Rather than stretch out this meeting, I'll give you a
letter from the Mayor with staff's comments. There's also a j
i
letter form Mr. Jetter. Written comments point out numerous '
shortcomings of the EIS. Errors fall into categories such i
as; complete contradictions, technical inaccuracies, unfac- j
I
[
tual reporting of existing situations and unrealistic expecta
tions of septic tank regulation beyond state standards. Much
}
of this paper was put together hundreds of miles from here
using questionable source material for the specific task.
9
The source material appears to have been used without fol- !
!
low-up investigation to determine xf the literature was ap- I
I
plicable to the situation found here. J
Gentlemen, I thank you for your time and your at- !
tention.
CHAIRMAN TRAINA: Thank you very much, sir. We
will incorporate that material you submitted to us for the
record.
i
MR. SCHNEIDER: Thank you, sir. |
CHAIRMAN TRAINA: Mr. Rhett White?
MR. WHITE: I'm here, I'm considering 'cause if I
had sane statements I think I'd do just as well to keep my
poise and to keep my mouth shut.
CHAIRMAN TRAINA: Sir, again, this is your oppor-
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tunity here so . • • j
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MR. WHITE: There are a lot of big guns and I don't j
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have the material that Bill Leseman has and it's hard to de-
cide whether you like ice cream or cake, you know, I —
there's so many, to be serious . . .
CHAIRMAN TRAINA: Mr. White, would you like to come
up here and just ramble on for us. Seriously, we would like
to hear from you, I think you, as I see it, you represent or
you are with the County Health Department and certainly we'd
like to hear the benefit -- get the benefit of your experi-
ence.
MR. WHITE: The thing is . . .
CHAIRMAN TRAINA: You see to be a very experienced
individual, if I can't tell by the white hair.
MR. WHITE: Well my hair's gray for twenty-five
years now.
CHAIRMAN TRAINA: Yeah, so is mine.
MR. WHITE: First, before anyone working with HRA
says doodily, you should clear it with everyone, I mean,
everyone except Mr. Reagan. And there are so many things go-
ing on in the state of Florida now and I am being quite ser-
ious that the problems that Florida faces. The Department of
Environmental Regulation has had more than their share of
problems with water quality, and the Department of Natural
Resourse, at some times, thinks that we can get a lot of wat-
er from recharge if we can gather it from anywhere. The
Florida Geology Department at FHU points out that we are tak-
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ing more water out of the ground than we are putting in, con-
sequently our water table is dropping rapidly. We're having j
salt water intrusion. It just so happens that personally I
think the septic tanks could work if they were installed pro-
perly but we're still using 1930 criteria for 1980. We're
using technology now that was developed in the forties,
fifties and sixties and I simply can't keep up with the tech- ^
nology that's going on from day-to-day. The HRS has planned ^
a complete revision of their septic tank chapter to cope with
some of these problems. I have no idea to what portions the
Legislature will look at these problems, what will come out
of the mill. Leon County is very aware of these problems and
they're aware of this EIS study. They're aware of their lim-
ited alternative. A lot of it, of course, is based on econo-
mics. They want to do something to up-grade the existing or
impending problems that we would have, or the Regulations, so
we don't have the problems. It would be very hard to say
that the septic tank will work here or it won't work there or
this is better for one or something is better for the other.
You know, it's like a method of transportation, there are so
many ways to get from point "a" to "b". I would be almost
deciding which is better for the moment, maybe for the next
tweny minutes "a" would be better but for later on "b", "c"
or "d" would be equally better and things change so much it's
— the material coming out and technology is fantastic and I
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don't know. We're taking twenty-five million gallons of wat-
er here, perhaps from Leon County, it used to go down the ri-
ver. Now at least part of it's going back into the ground.
Is this going to be an asset or a liability in twenty years.
The only thing I think that I could state and agree with Mr.
Dykes, is that these small package treatment plants, in my
fifteen years, have never worked satisfactorily. Tanks do or
don't work depending on the conditions, criteria, but package
plants have never been maintained; that I've seen anywhere in
the state of Florida.
Thank you.
CHAIRMAN TRAINA: Thank you very much, Mr. White, I
appreciate you're coming up.
The next card's not indicated whether it's a yes or
no wishing to speak, so let me call the name and ask the in-
dividual, Mr. George Hatt?
MR. CRUM: Flatt.
CHAIRMAN TRAINA: Flatt?
MR. FLATT: No, I have no comments.
CHAIRMAN TRAINA: No comments?
MR. FLATT: No.
CHAIRMAN TRAINA: Same with the Jessie Brown, it's
not indicated ...
MR. CRUM: Ms.
CHAIRMAN TRAINAr I'm sorry, excuse me, Miss Jessie
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Brown, I'm -- I do know sane male Jessie's and I'm certainly
please to know a female Jessie.
MS. BROWN: Well I'd — my name is Jessie Brown.
I'm a citizen living near the sprayfield that has — the pro-
posed sprayfield that has Mr. Leseman so upset. I didn't
plan to speak but since he was so intent that things didn't
go his way in that area, I would like to say that I think the
consultants didn't do the testing there because they felt
that with as much open land as there is in Leon County there
is no need in putting a sprayfield near indi — human habi-
tat, let's put it that way. You can test and test and test
and perhaps you won't find the virus that time but there is a
scientist in the Tampa area that did find it one day. We
have seen these test results and I'm not convinced that ten
years down the road that virus isn't going to appear in my
well or my neighbor's well. I think the city was totally in-
sensitive to propose putting a sprayfield within two hundred
feet of a person's hcxae and I'll believe it's safe when Mr.
Leseman buys that man's home and proposes to live there him-
self with that sprayfield there.
CHAIRMAN TRAINAj Thank you, Ms. Brown.
I have again, no indication whether you wish to
speak or not, Glenn E. Carter.
MR. CARTER: No, I think it was all just said.
CHAIRMAN TRAINA; Thank you, Mr. Carter.
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I'm not too sure which is the first name here, I
believe it's Joe Koelemij. (Mispronunciation.) Koelemij,
excuse me, sir. That's John Koelemij.
COURT REPORTER: Would you spell your name, sir?
MR. KOELEMIJ: Yes, ma'am. It's K-o-e-l-e-m-i-j,
it's pronounced Coolemy, not Hotemy but coolemy. I almost
was hot but the air conditioning went back on.
I'm a citizen of Leon County, I've been here for
some twenty — what — seven years. I'm a homebuilder, I
have developed land. I'm a member of the Citizen Advisory
Committee that helped on this EIS program and I felt compel-
led when I got this report to really come and just make a few
observations.
One is that in my estimation that the original
question for -- of the purpose of the EIS has never been an-
swered. The secondary impact and the region, you know,
should we have a sewer system on the north side of town and a
sprayfield down and so we approve part and now we're going to
study the other part. And because there are some question
that were raised by meetings that were held with people that
objected to that plan at the time, that question has not been
answered in this report. The basic question of the EIS, the
question why it was all started and why we have paid, I don't
know how much money and I think that the consulting firm and
I -- I'm not an engineer, I'm just a homebuilder, but I've
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worked with engineers and I've worked with the architects.
And — but I think that the people that you employed to do
this job have not done a good job. What I am very concerned
about is this, that in my — and I want to tell you this,
that I, as I said to you before, I've been a homebuilder
since 1954, I've been President of my local association twice
and I've been President of the Florida Homebuider's Associa-
tion, I was that in 196 4 and I hope in January of this coming
year to be elected as a national officer of NAHB. I've built
in Jacksonville, in Broward County and in Tallahassee but
mostly in Tallahassee, but I've lived through the nightmare
of Duval County. And when I read alternative four, which is
no action and, you know, we didn't ask for action in a sense.
I think that when a proposal was submitted of the 201 Plan —
and the 201 plan is a Federal plan, and that normally ask for
funding at whatever levels that the Federal Government might
decide or the Congress might decide to have that particular
year - so it was studied and they say "no action-, that's
alternative number four. X think that's where they departed
from what -- the question that was raised to begin with. Now
the fact that we don't want federal money is very moot at the
present time. The citizens, in November, decided that this
Government is going to be less government and that's why they
" elected President Reagan and that's why we have the attitude
25 11 that is prevailing in this country today. And many citizens
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will agree with you that that is better, maybe, for us but to
say that because you have no federal action you should go do
the wrong thing and to tell a community, like Tallahassee, ^
13
that we should therefore go to septic tanks and to small sew-
age treatment plants, to me, I can't understand. I don't un-
derstand that an Engineering Firm, that you have hired, can
make that recommendation. If I look at the experience a few
years back, when I was President of the Florida Home Builders
Association, we had a moratorium on the use of septic tanks
in the state Florida, I mean, Mr. White probably remembers
that, but we had an absolute moratorium; no more septic tanks
because there was infiltration and there was all kind of
problems with it. There was health problems with it. Later
on when the Corp of Engineers made a study it was relieved,
the Legislature, in it's infinite wisdom, made same more re-
lief; which I think went maybe too far in giving relief to
the use of septic tanks. Last year in -- a couple of months
ago we adopted a comprehensive plan of the city and Leon
County and the city of Tallahassee. And this comprehensive
plan has very detailed prescriptions for us, as developers,
T~
to live by, and the community to live by; which is less urban
sprawl, less roads, less sewer line, less water lines —
don't go out that far, have more density and green space in-
between and here we are saying we're going to build septic
tanks. Septic tanks require a certain of area to build the
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tank and to have the drainfield to work it properly and if
the soil is not sufficient or good in absorption therj you've
got to use more soil and more — the lot has to be larger.
So we create urban sprawl which is against the plan that we
adopted as citizens of this county. But somebody from Phila-
delphia comes in and said that's how we're going to do it.
Now, also it effects the water table, it effects the ground
water table. The small sewage treatment plants — when I was
— when we were building in Duval County they had small sew-
age treatment plants because the city was way behind. Tal-
lahassee has been very progressive in it's building of sewer
systems, builders, they had a tremendous program years ago by
which builders and developers put up money with the city to
in advance pay for trunk lines or pay for collection systems
and they had a rebate system by which over the course of some
twenty years we could get our money back, but in the mean
time that system was in the ground, we had curb and gutters
and we had a nice looking community; no open ditches. And I
tell you this, I was proud of that when I came here and I've
developed many subdivisions that — where people are now liv-
ing that we built that way. In Duval County it was differ-
ent. You tied in to a little sewer plant and the developer
had the sewer system and he's charged seven dollars a month
and — for the sewer treatment and two dollars, in the first
place where the sewer plant was built it took a number of
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acres, the lots are rounded where not -- you could not get
FHA or VA financing because of either the smell, the odor, or
whatever it is, that you don't want to live next to a sewer
plant. So there was an economic impact that was substantial
and maybe poor people ultimately wound up living there, I
don't know. But then when the city of Jacksonville decided
to go into a tremendous revamping of their sewer systems, for
which EPA paid and helped pay, and because they thought that
was the answer, you see, they bought out all those little
sewer treatment plants. You know how they bought them? They
bought them on the basis of the rate of return and they paid
fortunes for these sewer plants, to buy them out and to
incorporate them into their system. I don't know ]that —
that the people that bought their home and paid for the
installation of whatever system was put in place at that
time, later on through taxes paid again for the city of
Jacksonville to buy that system and to incorporate it into
their large system. Of course, EPA paid part of that bill,
but it's still the same tax payer that pays for it. That is
why I don't understand how we really can forget all that and
why an Engineering Firm can come up, looking at the
experience and the practical experience that we have lived
with in the state of Florida alone, to come up with this
recommendation. And when it says here under number 4,
"That the expansion of the present
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wastewater system will continue only
until the limits of phase I expansion
are reached."
So then the city cannot do anymore except fill in.
"New growth in wastewater generations
will be handled by on-site and small
community systems."
Now that's the sentence that is damaging to the future of
this community. You won't even let us do it on our own bill
If — this report could be used by somebody who might be
against the idea of a central system by saying EPA, which is
kind of like God, the Federal Government said that the only
way to do this and to live in the future is . . .
CHAIRMAN TRAINA: Mr. Koelemij, we've been called a
lot of things . . .
MR. KOELEMIJs I know that.
CHAIRMAN TRAINA: but I don't think anybody's cal-
led us God before.
MR. KOELEMIJ: No, but, you know, well some people
believe in that and some people will use it and that is why i
take issue with the meaning of this report, your statement,
your EIS statement. It's like a Bible because some people
will use it as such. And you say that the city should not
expand. What if the city wants to do it on their own dollar (
and without the help of the Federal Government. I think you
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should — you should not make such a statement that, you
know, that could be very damaging to the future growth of
this community; the healthy growth.
CHAIRMAN TRAINA: Mr. Koeleroij, let me just comment
there, as I heard Mr. Crum in his statement and certainly
it's my position. Let me tell you, other than being a Hear-
ing Officer, my real responsibility is that I do -- I am re-
sponsibility for the Grants program, the Wastewater Treatment
Grants program in the region. But his statement stated that
certainly EPA has no objection and could have no objection
for the city proceeding whatever way it wants to go. This
tentative decision this evening, the EIS, only addresses as
to whether the federal government will contribute to that
proposal.
MR. KOELEMIJ: Well, I would hope then, that his
report, his final statement would make that differentiation
and would make that notation because if we want to do it on
our own we don't need the federal government. And I don't
mean it that way because we do need each other, but, if at
some point or other the federal government is of the mind
that it will not spend the dollars, and, if other citizens
want to spend the dollars without the overhead of the federal
government, then you should allow us the opportunity to do
that and not condem it, so to speak. And that is what this
could be taken as, that it is a condemnation of that effort,
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if it were done by the city of Tallahassee or this community
on it's own. And I really want to stress that point very
heavily. I want to tell you furthermore, one thing and it is
this, that -- and you probably have noted that I have a funny
accent -- and I was born and raised in the Netherlands.
CHAIRMAN TRAINA: I thought you were raised in New
York like I was, sir.
MR. KOELEMIJ: No, that's not right. No, I was
born and raised in the Netherlands and when I listen to all
the and i was back there for, you know, last month again
for a visit with my family and when I — I hear some of the
complaints that are made about environmental things that hap-
pen and when I think back and read back and look again at the
way they have protected themselves against, you know, the
ocean where they have created the polders, where they have
created new lands, where they planted new trees. You know,
nothing is impossible for people to build an environment in
which they can provide shelter and I am a person who is in
the business of providing shelter. I have nothing to do with
the growth of this country and the growth of this state but
^ have to provide shelter for the people to
somehow or other we hav P
live and we can make it so ~ right now already because of
interest rates, 90% of the people who .it to buy shelter
.. ... »nd if we are building roadblocks in the
can't afford it. Ana "
, «n which we have to build shelter and in
way to develop l^nd
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whatever manner the community lets us build it, we've got to
watch that the cost does not exceed the ability of our chil-
dren to afford to pay for it. And that is why I'm speaking
and I think that's very important. It's important to me, to-
day but it is much more important to my eleven year old who
might want to become a builder, but I hope he doesn't. And
with that, I really appreciate you're letting me speak.
Thank you very much.
CHAIRMAN TRAINA: Thank you very much, sir. And
let me say for your benefit and for the others that the ten-
tative action that we're considering tonight certainly — and
I can assure you, speaking on behalf of EPA — does not pre-
clude the city from proceeding in whatever course the city
elects to proceed in. What we're tentatively proposing to-
night or what has been proposed is that the Federal Govern-
ment would not participate in that decision, financially. I
want to make that very clear. And I think that based on
frankly, your comments and comments we had received prior to
this evening, that the Environmental Impact Statement would
— will clarify that point. And that is that the decision
here tonight only addresses federal funding not any kind of
direction or control from the federal government that the
city of Tallahassee can or cannot do whatever it wants to do.
That is certainly a decision the city of Tallahassee needs to
make and frankly I would hope in conjunction with the other
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people who have raised objections to the earlier proposals
and I would assume the city would take into account those
concerns as it make it's decisions.
Mr. J. D. — or I shouldn't say Mister — J. D.
Boone Kuersteiner? I guess it's safe to say it's Mr. now.
MR. KUERSTEINER: When I was working with the
Department/ I used to get a lot of the same names that you
did but . • •
CHAIRMAN TRAINA: Were you ever called GOD?
MR. KUERSTEINER: No, there were other words that
preceded and followed after that.
CHAIRMAN TRAINA: I didn't -- yeah, I was going to
a word after that that we've been cal-
say there was usually a wora
led but never . . •
MR. KUERSTEINER: Mr. Hearing Officer, my name is
Boone Kuersteiner, I'» » Attorney with the Law tin. of Aker-
man, Senterfitt * Eidson. Me have the pleasure of represen-
ting the Fall Chase special Taxing District, which is a spe-
• , • Aivtrict located in the eastern portion of Leon
cial service district xuw
—substantial portions of our client's
County. We have some substanti
property is located within the area identified and referenced
i„ the Environmental Impact Statement as being the Mk. Lafa-
-««« soecific comments that direct thems-
yette area. I have some speexnc
i impact Statement. And the ques-
elves to the Environmental imp
• k* have is well why is this relevant at this
tion that you might have is
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point in time, you know, we're talking about federal funding
and which direction should you go on federal funding but I
think that based upon your personal experience and those of
Mr. Crum and the members of this — of the audience we know
that, once these Environmental Impact Statements get publish-
ed, they somehow start floating to the top and pretty soon
they're floating around as part of the gospel. So, conse-
quently we feel compelled to bring to your attention certain
matter that are of a technical nature that have been an area
of concern to us, as related to the draft, Environmental Im~
pact Statement.
The first area of concern is that the maps in the
document have failed to identify the Lake Lafayette area in
T-
it's correct posture. It's failed to recognize the four dis-
18
tinct hydrological basins that exist in the area referred to
in the document as being the Lake Lafayette basin.
Secondly, that as it relates to the inadequacies in
the map, the map have taken the upper basin in it's entirety,
and a total of four and seventy-three acres, and treated it
in one big broad stroke as being a marsh when, in fact, the
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correct designation of the marsh areas as it relates to that
19
specific area is more on the lines of 112 acres. So the map
has four times embellished the actual size of the upper Lake
Lafayette basin marsh areas.
The third variable or the third concern, as it re-
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lates to the map designation/ is that the maps that are used
in the draft, Environmental Impact Statement are not consis-
tent with the US Geological Quad sheets for the area and we
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would encourage the EPA to bring their maps into consistency
with EPA. And we have a secondary of concern, that deals
with the water quality data that was represented in the draft,
Environmental Impact Statement, to have been performed as it
relates to Lake Lafayette. The data that was collected fails
to distinguish between the upper Lake Lafayette basins the T
basin and the other four — other three basins in the Lake 21
Lafayette area. It's the upper Lake Lafayette basin that is
receiving a significant amounts of urban storm water run-off.
And that's not adequately addressed in the draft, Environmen-
tal Impact Statement. A third area of concern is that the
draft Environmental Impact Statement as it relates to the
Lake Lafayette area seems to operate under the premise that
the Lake Lafayette area has a flowing system moving from east
to west and there's a linkage within that system. That's
that is an incorrect assumption.
Then on table number 4.6 there's a reference to
protected plants and it's referenced to section one or sec-
tion 581.185 of the Florida Statutes. That statute, we be-
lieve, has been incorrectly interpreted in the draft Environ-
mental Impact Statement. What that statute does in Florida
is that it protects horticultural interest and prohibits the
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harvesting of the species identified in the statute unless
you have consent of the landowner. It's not a rare and en-
dangered species list that is a prohibition against harvest- J
ing rather it is a permitting-type statute, requires permis- 2
sion of the landowner before you utilize it. The -- we would J
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also — we have a technical assessment's been prepared by one j
of the consultants for the district that we'd like to leave !
I
as an Exhibit. We also have a USGS Quad sheet that we'd like
to introduce into the record as our second exhibit. The
third exhibit would be a copy of section 158.18 5 for the sta-
tutes and the fourth exhibit we'd like to introduce is cor-
respondence, it's referenced in the first exhibit. And that
correspondence is correspondence from our office on behalf of
our client to EPA dated July 9, 1980 concerning -- pardon me,
that's July 9, 1981, excuse me, which has attached several
technical reports that are site specific technical informa-
tion relating to biological and geological features in the
upper basin area and they address such things as the incor-
rect map designations in the EIS base maps, the improper
treatment of the Lake Lafayette area as a single flow-through
system. The attachments to that July 9th correspondence ad-
dress the improper designation of the basin in terms of
acreage unit. The scientific and technical errors and defic-
iencies that were incorporated or that were made in some of
the study documents, and we don't know whether or not those
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have been corrected or not. So for the purpose of the record
we'd like to make this July 9th correspondence part of the
record. And also there is an opinion, a 1979 opinion of the
Circuit Court in and for Leon County determining that the De-
partment of Environmental Regulations attempts at regulating
the upper Lake Lafayette basin as a Lake are inappropriate,
incorrect; that it cannot be regulated as a Lake and there-
fore be considered waters of the state. In terms of specific
recommendations that -- we would request that the United
States Environmental Protection Agency incorporate into the
EIS — we would first ask that the maps be amended to proper-
ly designate the upper Lake Lafayette basin, in terms of by
name, by size and hydrological condition. And we'd also re— T—
juest that that designation be extended to the other three 24
jnits within the upper Lake Lafayette basin. Secondly, we
fould urge and request that EPA use the USGS Quad sheets as
It's reference map, showing the four different basins in the T-
ipper Lake Lafayette area based upon showing those basins be- 25
.ng physically distinct and functionally unconnected. Third,
would request that the draft EIS distinguish between the
basins as it relates to water quality considerations. T-
26
he fourth area would be that the draft EIS statement be cor-
gcted to eliminate the implications and inferences that the
ake Lafayette system is a single flow-through system. And T-
ifth, we feel it'd be appropriate for EPA to correct the ^7
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misinterpretation of section 581.185 of Florida statutes.
And we'd like to, at this time, introduce for the
record a series of Exhibits. The first Exhibit being a cor-
respondence addressing the technical analysis of deficiencies
in the draft EIS statement. The second being a set of USGS
Quad sheets for the upper -- for the entire Lake Lafayette
basin. The third, the correct — the third is a reproduction
of Section 158.14 — or 185 for the statutes. And the last
is the — a composite Exhibit, the July 9, 1981 correspon-
dence to the EIS Project Officer in Region IV as it relates
to this draft Environmental Impact Statement with it's at-
tachments, and we'd request that they be incorporated into
the record at this time.
CHAIRMAN TRAINA: That request will be granted,
si r.
MR. KUERSTEINER: One last procedural question.
There was an extension of the time frame grant . . .
COURT REPORTER: Before you get into that, could I
change my tape?
MR. KUERSTEINER: Oh, sure.
COURT REPORTER: Thank you.
(Brief pause while reporter changed tapes.)
COURT REPORTER: We're on, sir. Thank you.
MR. KUERSTEINER: Okay. A procedural question that
we'd like some clarification from the Hearing Officer on is,
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there was an extension of the time granted to the Department
of Environmental Regulation for submitted additional com-
ments. Number one, will that extension apply to other part-
ies interested in submitted comments and number two . . .
CHAIRMAN TRAINA: Yes, I don't know exactly what
the Department wanted in terms of time but certainly that re-
cord will be open until such time as the department has sub-
nit ted those comments.
Van, could you give us an estimate of how long a
time you would need? We normally would keep this record open
'til November 20th.
MR. KUERSTIENER: Well lawyers love to procrasti-
ate so we'd like to know what the deadline is so we can do
t on the last day.
CHAIRMAN TRAINA: On the last day. Let me ask the
:ate, could you give us an estimate of ...
MR. HOOFNAGLE: We'd like between fifteen and thir- j
' days beyond November 20th.
CHAIRMAN TRAINA: Okay. Fifteen days would be . .
MR. KUERSTEINER: December 21 — January 1 . . .
CHAIRMAN TRAINA: I tell you, one of the problems
that EPA, although it's considered God among some of you,
s considered as delay bureaucracy among most people and we
: criticized quite a bit for delaying things, so we are
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under very tight schedules on these -- on these EIS's. Now,
I would like to suggest Van, that we keep it open 'til about
December 15th, is that too late, I mean, is that . . .
MR. HOOFNAGLE: That would be fine. I think after
that time we'd be in Christmas anyway.
CHAIRMAN TRAINA: Yes. I'm concerned that if we
get into Christmas why — Can we make a decision on that?
MR. CRUM: I think so, I think so.
CHAIRMAN TRAINA: All right. Let me just official-
ly say, if this is all right, sir, that we will keep the re-
cord open 'til December 15th.
MR. KUERSTEINER: Thank you very much.
CHAIRMAN TRAINA: Thank you, sir.
That concludes the individuals who, at least by
card, have indicated a desire to make a statement here. Let
me ask, at this time, is there anyone who I have not called
who would care to make a statement?
Yes, sir? Mr. Schneider?
MR. SCHNEIDER: I'd like to ask one other ques-
tion . . .
CHAIRMAN TRAINA: Yes, sir.
MR. SCHNEIDER: . . . based on your answers to
a couple of the comments.
CHAIRMAN TRAINA: Would you like to get up here,
sir; so the recorder could hear you?
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MR. SCHNEIDER: I'd be interesting in knowing, from
your comment, if you consider the EIS as a determination of
eligibility of EPA funds only?
CHAIRMAN TRAINA: Oh yes, sir.
MR. SCHNEIDER: Thank you.
CHAIRMAN TRAINA: Are there any other comments,
anyone who's previously made a comment who'd like to — care
to make another comment?
(No audible answer.)
CHAIRMAN TRAINA: Well, as I've indicated, the
hearing will now remain open until December 15th. . We would
ask that all written comments you'd care to give us should be
sent to Mr. John E. Hagen; Chief, EIS Branch; EPA Region IV;
345 Courtland Street; Atlanta, Georgia 30365. That address
as noted is on the bottom of the agenda that you got at the
front desk.
MEMBER OF AUDIENCE: The zip is different on that,
30365 . . .
CHAIRMAN TRAINA: Didn't I say 30365?
MR. HOOFNAGLE: Yeah.
(Member of audience.) I thought you said 61.
CHAIRMAN TRAINA: I guess it's my southern Georgia
iccent that throws you and I apologize for that even the
lentleman from the Netherlands understood me but -- you know,
t's always a delight to come to Florida because it's Florida
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and seriously it's because the people show such an interest
in the environment. I have to tell you that our region in-
cludes eight states in the southeast and sometimes we have
hearings in which absolutely nobody comes. So, it's . . .
(Member of audience.) That ought to be a bless-
ing.
CHAIRMAN TRAINA: No, not really 'cause it really
doesn't make us feel that we're really getting a response to
what we're doing or not doing. But I want to thank each and
every one of you for coming out this evening, I'm sure that
there were other things that you probably could have been
gainfully doing tonight, but we want to thank you. We will
consider the comments that were made this evening through the
transcript. We will consider comments that are sent to us in
writing. The final -- Let me just end on this, that the fi-
nal EIS will consist of the Agency's final decision. A sum-
mary of the draft EIS, any pertinent additional information
or evaluations developed since publication of the draft, re-
visions to the draft, comments received and EPA's responses
to those comments in the transcript of this hearing will all
be included. Those of you who commented tonight or submits
comments will receive a comment of the EIS provided you fill
out one of these little cards and give us an address.
Again, on behalf of EPA and the Florida Department
of Environmental Regulation, we thank you for coming and this
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hearing is now adjourned.
(Whereupon, at 9:03 p.m., November 5, 1981 tile
hearing in the above-entitled matter was closed.)
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CERTIFICATE
This is to certify that the attached transcript of the
i
ledings before the ENVIRONMENTAL PROTECTION AGENCY, WATER |
MANAGEMENT DIVISION, REGION IV, ATLANTA, GEORGIA
In the Matter of:
ENVIRONMENTAL IMPACT STATEMENT )
ON PROPOSED WASTEWATER MANAGE- )
MENT FOR THE CITY OF TALLAHAS- )
SEE, LEON COUNTY, FLORIDA )
Date: Thursday, November 5, 1981.
Place: DER Courtroom
Florida Department of Environmental Regulation
260 0 Blaire Stone Road
Tallahassee, Florida 32301
were held as herein appears, and that this is the original
V-160
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RESPONSES TO ORAL COMMENTS
T-l. See the responses to comments W-26 and W-123 through W-127
T-2. See the responses to comments W-26 and W-123 through W-127
~ • Tfie problem of operating and maintaining a large number
of small community and individual on-site systems is recocrnized
as a major limitation of Alternative 4. It is for this reason
that the implementation of some form of management agency and
monitoring program is part of the recommended plan. These rec-
ommendations are discussed in Chapter III, Part C of the Draft
EIS and in the responses to comments W-20 through W-25.
(2) See the response to comment W-116.
T-4 The response to comment W-80 contains a description of the
methodology and sources used in the development of this map.
T-5. See the response to comment T-3 (1).
^ • 1affl0r^Hon of a management agency to enforce proper
T-6. The ^mPfemfn^f!Lion and the implementation of a groundwater
siting and inst^1 recommended. Soil percolation rates in
monitoring Pf°9r*?\ st of the future growth is projected to
the Northeast, whe . , high. This in itself may discourage
occur, are noJ DOnds. Furthermore, the underlying geo-
the use of percolat P and Hawthorne formations,
logical _^ction to the Ploridan aquifer. In south-
provide additional p c nds ^ cause problems because
ern Leon County, tn® soils and the prevalence of sink holes,
of rapidly permeao oro-iected in this area, however, as much
of^^is^generally undesirable for home construction as well.
siting, installation, and operation and
T-7. With proper desig / sman community systems will provide
maintenance, on-site t llv SOund treatment and disposal of
effective and „No_.Fe
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T-8. Comment noted.
T-9. See the responses to comments W-15 through W-96.
T-10. Comment noted.
T-ll. The management agency is proposed to provide the authority
and personnel to enforce correct and regular maintenance for
package plants.
T-12. Comment noted.
T-13. Comment noted. See the response to comment T-7.
T-14. See the response to comment W-79.
T-15. The intention of an EIS is to evaluate a proposed action
for environmental soundness and cost effectiveness. That is,
does the proposed action achieve the desired goal with the least
amount of or the most acceptable environmental impacts? The pur-
pose of this evaluation is to determine whether the Federal gov-
ernment will contribute to the proposed action.
In order to evaluate the proposed action, other alternatives are
developed which represent other approaches to wastewater manage-
ment. The alternatives can then be compared to one another. The
selection of Alternative 4 by the EPA represents their decision
that the controlled use of on-site and small community systems in
developing areas of Leon County is the most cost-effective alter-
native, and that this is the only alternative that the Federal
Government would commit funds to. It does not represent a direc-
tive to the City of Tallahassee and Leon County to proceed with
this plan. The City and County may proceed with any plan they
would like to, but Federal financial aid is only possible if
Alternative 4 is implemented.
T-16. See the response to comment T-15.
T-17. See the response to comment T-15.
T-18. An addition to the DEIS will be noted in Chapter IV of the
FEIS, "Revisions to the Draft EIS and Additional Information."
This addition will consist of a statement that Lake Lafayette can
be regarded as four separate sections, as a result of man-made
restrictions, and a reference to a document by the Trustees of
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the Internal Improvement Trust Fund, FDNR, that Mr. KuersfPinpr
has provided. ""fteuer
T-19. Comment noted. The delineation and definition of Lake
Lafayette, although a point of argument within the community, is
not an issue in this EIS. The sources of all base maps used in
the DEIS and FEIS have been noted. Most maps of the area show
Lake Lafayette differently from each other as well as from the
USGS quad sheets for the area. All of the maps in the DEIS were
adjusted to reflect the delineation of Lake Lafayette on the USGS
quad sheets. Because of differences in scale and the origins of
the various maps used in the EIS, the level of detail of the USGS
quad sheets could not be maintained. These maps have been
approved by the EPA as acceptable for the purposes of the EIS. A
statement will be added to the DEIS which refers the reader to
the USGS quad sheets for the detailed delineation of Lake Lafay-
ette. This addition will be noted in Chapter IV of the FEIS
"Revisions to the Draft EIS and Additional Information." '
T-20. Comment noted. See the response to comment T-19.
~ /rf the Draft EIS is to summarize the work com-
T-21. The purp°se of and tQ present the selected alterna-
pleted in *h(r environmental impacts, and recommendations
tive with its costs, mitiaation of adverse impacts. For the
for implementation Kuersteiner, we refer him to the
discussion requested y * Seqment I Draft Report of this
Environmental MoniSethis document the results of water quality
EIS. On page 51 of Wis discussed;
sampling of Lake Lafayet
results indicate that the Lake
"The water
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T-22. Mr. Kuersteiner has not specifically identified a state-
ment or section of the DEIS where Lake Lafayette has been identi-
fied as a flowing system moving from east to west. The area
known as Lake Lafayette is hydrologically complex, consisting of
marshes, streams, a major sinkhole, and several man-made
restrictions such as the dikes which create the Piney Z Lake and
the railroad embankment. No attempt has been made in this EIS to
quantify the hydrology of Lake Lafayette as it is not relevant to
the purpose of the study.
T-23. Section 581.185 of the Florida Statutes is an act relating
to the "Preservation of native flora of Florida." As such it
establishes requirements to obtain a permit or written permission
from the land owner to harvest certain flora from public or pri-
vate lands; specifically the Act states, "The purpose of the per-
mitting requirements imposed under paragraph (a) is to encourage
the propagation of endangered or depleted species of flora and
provide an orderly and controlled procedure for restricting har-
vesting of native flora from the wilds, thus preventing wanton
exploitation or destruction of Florida native plant populations."
For this purpose the Act provides a list of endangered and
threatened plants. It also creates the Endangered Plant Advisory
Council which is responsible for periodically reviewing and
updating the list.
The list provided by Section 581.85 was used to identify flora
protected by Florida law from the species of plants identified in
field investigations of potential sprayfield sites. The consult-
ant believes the Act was utilized appropriately.
T-24. See the response to comment T-19.
T-25. See the response to comment T-19.
T-26. See the response to comment T-21.
T-27. See the response to comment T-22.
V-164
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VI. COORDINATION WITH FEDERAL, STATE, REGIONAL
AND LOCAL AGENCIES
Federal Government Contacts
Contact
Federal Emergency Management
Agency
Region IV, Atlanta, GA
U.S. Fish and Wildlife
Service Asheville, NC
U.S. Forest Service
Tallahassee, FL
Purpose
Obtain National Flood Insurance
Program Rate Maps
Obtain protected species infor-
mation
Obtain vegetation information
about Appalachicola National
Forest
gtate and Government Contacts
Contact
Purpose
Florida Dept. of State,
Division of Archives/ History
& Record Management
Florida Game and Freshwater
Fish Dept.
Florida Dept. of Environ-
mental Regulation
Obtain archeological and historic
survey results
Obtain fisheries information
Obtain water quality information
Regional and Local Contacts
Contact
Tallahassee-Leon County
Planning Department
Leon County Department
of Public Works
Tallahassee Office of
Management and Budget
Purpose
Obtain land use, population,
socio-economic data. Obtain
208 Plan information
Obtain local floodplain
management information
Obtain capital budgets
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Tallahassee Historic
Preservation Board
Post, Buckley, Schuh &
Jernigan, Inc.
Environmental Science &
Engineering, Inc.
Wm. M. Bishop Engineers, Inc.
Tall Timbers Research
Station
Tallahassee Water Quality
Laboratory
Obtain historic preservation
information
Obtain 208 Plan background
information
Obtain 208 Plan background
information
Obtain 201 Plan background
information
Obtain terrestrial ecosystem
information
Obtain water quality sampling
results
VI-2
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VII. LIST OF PREPARERS
U.S. Environmental Protection Agency, Region IV
Robert B. Howard Chief, EIS Preparation Section
W. Bowman Crum Current Project Officer
Richard D. Green Prior Project Officer
Gannett Fleming Corddry & Carpenter/ Inc.
Thomas M. Rachford
Albert T. Bain
Mark M. Flaherty
James R. Fuller
Sara F. Frailey
John W. Jacobs
Richard C. Callahan
Claude Terry & Associates, Inc.
Claude E. Terry
Louise B. Franklin
Robert J. Hunter
Thomas C. Mather
James C. Hodges
A. Anita Patterson
Senior Project Manager
Project Manager
Environmental Engineer
Environmental Engineer
Environmental Engineer
Environmental Scientist
Environmental Scientist
Project Executive
Project Manager, Environmental
Planner
Environmental Scientist
Environmental Scientist
Environmental Scientist
Environmental Scientist
VII-1
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