United States
Environmental
Protection Agency
Region 4
345 Courtland St. NE EPA
Atlanta, GA 30365 August 89
FINAL ENVIRONMENTAL
IMPACT STATEMENT
T
CF MINING CORPORATION
HARDEE PHOSPHATE COMPLEX II
HARDEE COUNTY, FLORIDA
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LIBRARY
US EPA Region 4
AFC/9th FL Tower
61 Forsyth St. S.W.
Atlanta, GA 30303-3104
FINAL ENVIRONMENTAL IMPACT STATEMENT
for
PROPOSED ISSUANCE OF A NEW SOURCE NATIONAL POLLUTANT
DISCHARGE ELIMINATION SYSTEM PERMIT
to
CF MINING CORPORATION
Hardee PhosphaCe Complex II
Hardee County, Florida
Prepared by:
U.S. ENVIRONMENTAL PROTECTION AGENCY
Region IV
Atlanta, Georgia 30365
In Cooperation With:
U.S. ARMY CORPS OF ENGINEERS
Jacksonville District
Jacksonville, Florida 32201
EPA -8=)-e>C>l
CF Mining Corporation has proposed an open pit phosphate mine and " (
beneficiation plant on a 14,994-acre site in Hardee County, Florida. CF
proposes to mine 14,647 acres, all of which would be reclaimed, and would
produce 97 million tons of phosphate products over a 27-year period. The EIS
examines alternatives, impacts, and mitigative measures related to air,
geology, radiation, ground water, surface water, ecology, and other natural
and cultural systems.
Comments will be received through January 19. , 1990
Comments or inquiries should be directed to:
Heinz J. Mueller, Chief, Environmental Policy Section
U.S. Environmental Protection Agency--Region IV
345 Courtland Street, NE
Atlanta, Georgia 30365
l404) 347-3776
Approved by:
^1.* A. JLa
<9reer C. Tidwell 1
October 30, 1989
Date
Regional Administrator
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CF89-Z.1/FEIS.1
8/03/89
SUMMARY SHEET FOR ENVIRONMENTAL IMPACT STATEMENT
CF MINING CORPORATION
Hardee Phosphate Complex II
Hardee County, Florida
( ) Draft
(X) Final
U.S. Environmental Protection Agency, Region IV
345 Courtland Street, NE
Atlanta, Georgia 30365
1. Type of Action: Administrative (X) Legislative ( )
2. Description of CF Mining Proposed Action:
CF Mining Corporation (CF), is proposing to construct and operate a phosphate
mine and beneficiation plant in Hardee County, Florida (Figure 1). The EPA
Region IV Administrator has declared the proposed facilities to be a new
source as defined in Section 306 of the Federal Clean Water Act of 1977.
In compliance with its responsibility under the National Environmental Policy
Act (NEPA) of 1969, EPA Region IV has determined that the issuance of a new
source National Pollutant Discharge Elimination System (NPDES) permit to the
proposed mining and beneficiation facility would constitute a major federal
action significantly affecting the quality of the human environment.
Therefore, this Environmental Impact Statement has been prepared in accordance
with the requirements of NEPA and EPA regulations at 40 CFR Part 6.
CF's proposed mine operation is planned to produce approximately 2 million
tons per year of wet phosphate rock for the first 7 years of mining and 4
million tons per year during the following 20 years of the 27-year mine life
(Figure 2). During mining, all of the rock mined from the project site will
be shipped to fertilizer plants for conversion to finished fertilizer, with
100 percent of the tonnage going to CF's existing phosphate fertilizer
manufacturing facilities at Plant City and Bartow. To accomplish these
operational objectives, CF proposes'to mine approximately 14,647 acres (99
percent) of the 14,994-acre site. A beneficiation plant and temporary rock
1
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CENT ft At FIOMDA LAMOXMll
ro
Figure 1
GENERAL LOCATION OF CENTRAL FLORIDA PHOSPHATE
DISTRICT AND THE CF INDUSTRIES EXISTING MINE
AND PLANNED MINE EXPANSION
U.S. Environmental Protection Agency, Region IV
Environmental Impact Statement
CF INDUSTRIES
Hardee Phosphate Complex II
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LEGEND
A - Dragline I
B - Dragline II
1-1 - Mining Years
- Preserved Areas
SOURCE: CF Industries
Figure 2
DRAGLINE MINING SEQUENCE
U.S. Environmental Protection Agency, Region IV
Environmental Impact Statement
CF INDUSTRIES
Hardee Phosphate Complex II
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CF89-Z.1/FEIS.2
8/03/89
storage facility would also be constructed on site. The initial phase of the
proposed action includes land clearing and open burning in advance of the
mine. This cleared acreage in front of the mining operation will average
approximately 80 acres. The mining operation will employ a single 55-cubic-
yard dragline supplemented, beginning in Mine Year 8, with a second similar
dragline. The mined matrix will be slurrified and transported via pipeline to
the beneficiation plant for washing. This separates pebble product, clay, and
fines and facilitates additional product recovery via flotation. The wet rock
will be stored temporarily at the plant. CF plans to construct an access
railroad spur linking the plant with the Seaboard Systems Railroad that
presently bisects the property. CF will rail ship the wet rock product to the
receiving phosphate fertilizer plants.
The waste disposal method proposed by CF is sand/clay mixing. Sand/clay
mixing refers to a process in which sand and clay components, separated during
mining and beneficiation, are recombined into a suitable mix for disposal in a
previously mined area. In the proposed CF process, the waste clay generated
from the beneficiation processes is routed to a containment area for interim
storage and subsequent consolidation to higher percent solids. The sand/clay
mixture is then pumped from the mix tank to a designated disposal site.
Disposal areas are designed to receive sand/clay mix over mined lands to final
fill elevations that consolidate to within approximately 2 to 3 feet above the
average pre-mining elevation by the end of the reclamation period. To
complete this waste disposal cycle, an aboveground settling area is necessary
to receive diluted clay slurries for storage and consolidation to use in sand-
clay mixing. To satisfy this requirement, CF plans one aboveground settling
area subdivided into three compartments. During the last 3 years of mining,
this aboveground settling area will also be mined and reclaimed.
Water is important in CF's proposed phosphate mining operations. Vater is
used as a medium in which to transport ore from the mine site to the plant, to
transport the feeds and products through the plant, to process the product,
and to transport the waste products away from the plant to disposal sites.
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CF89-Z.1/FEIS.5
8/03/89
These processes require large quantities of water. In the proposed project,
93.5 million gallons per day (MGD) (more than 90 percent) of the water to be
used will be supplied from the recirculation system, and an average 7.85 MGD
will come from ground water sources (primarily to meet flotation process
demands).
The mine water recirculation system consists of the settling area,
beneficiation plant, active and mined-out pits, active sand/clay mix storage
areas, and water return ditches. The settling area, tailings storage area,
and return water ditches act as a water clarification system, returning
decanted water to the beneficiation plant. Recycled water returns to the
recirculation system several times to be reused, while a portion is
continually being lost by entrainment in sand and clay and being replenished
to some degree by rainfall. However, since rainfall varies seasonally and is
approximately equal to evaporation, some outside source of water (either
surface or ground water) will be required.
Due to seasonal variables, an alternate source of water (i.e., ground water)
must still be available during periods of water deficit for the operation of
the flotation process and as makeup during the dry season. Conversely,
discharges may be necessary during the rainy season if storage capacity in the
system is exceeded. In the proposed project, the water discharge would be to
surface waters (Doe Branch and/or Shirttail Branch) directly or, as required,
to Payne Creek via sheetflow through adjacent wetlands.
The proposed reclamation plan is based upon the use of waste sand/clay mix
material as backfill over most of the mined area. The proposed plan is
designed to return the site to a land form and use compatible with the
surrounding area, which is primarily agricultural. The reclaimed site will
consist primarily of improved pasture, forested uplands, restored marshes,
lakes, and areas to be preserved by CF. With reclamation, Che acreage of
improved pasture, forested uplands,~ freshwater marsh, freshwater swamp, and
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CF89-Z.1/FEIS.6
8/03/89
lakes will increase. The acreage of palmetto prairie, field and row crops,
and citrus will decrease (Figure 3).
3. Alternatives Considered:
CF has developed an integrated plan for the mining and processing of phosphate
rock at their Hardee Phosphate Complex II mine. This plan consists of a
number of individual components linked to provide a total project capable of
meeting CF's goals. The identifiable components included in the project are
as follows:
• Mining,
• Matrix transport,
• Matrix processing,
• Waste sand and clay disposal,
• Process water source,
• Water management plan,
• Reclamation, and
• Wetlands preservation.
Various methods (i.e., alternatives) are available to satisfy the objectives
of each of these components. These are summarized below:
Component
Mining
Matrix Transport
Matrix Processing
Waste Sand and
Clay Disposal
Objective
Remove overburden and
deliver matrix to a
transport system.
Transport matrix from
the mine to the
beneficiation plant.
Process the matrix to
separate the phosphate
rock produce from the
waste sand and clay.
Dispose of the waste
sand and clay generated
by matrix processing.
Alternatives Considered
Dragline Mining, Dredge Mining,
and Bucketwheel Mining
Slurry Matrix Transport,
Conveyor Transport, and
Truck Transport
Conventional Matrix Processing
and Dry Matrix Processing
Sand/Clay Mixing and
Conventional Sand and Clay
Disposal
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Cfi urcu 41"
COMPLEX II
Figure 3
POST-RECLAMATION LAND USE:
COMPLEX II, EASTERN SECTION
U.S. Environmental Protection Agency, Region IV
Environmental Impact Statement
CF INDUSTRIES
Hardee Phosphate Complex II
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Cft HPCH 47JI
Cmi ft ktttt . tat
?l) tMPItOVEO PASfUie
411 PINE FLAlWOOOS
432 OIHCR HARDWOODS
SJO lAKtS
•II VflCSHWAUH SWAMP
• 4 1 mCSMWAlIR MARSH
COMPLEX II
Figure 3 (Page 2 of 2)
POST-RECLAMATION LAND USE:
COMPLEX II, WESTERN SECTION
U.S. Environmental Protection Agency, Region IV
Environmental Impact Statement
CF INDUSTRIES
Hardee Phosphate Complex II
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CF89-Z.1/FEIS.9
8/03/89
Process Water
Source
Water Management
Plan
Reclamation
Wetlands
Preservation
Provide a continuous
source of fresh water
for use in matrix
processing and as make-up
for losses to the
recirculating system.
Provide a means to reduce
the amount of water in
the recirculating
system.
Return the mined site
to useful productivity.
Provide for the
protection of wetland
functions.
Ground Water Withdrawal and
Surface Water Impoundment
Discharge to Surface Waters
and Use of Connector Wells
CF's Reclamation Plan,
Conventional Reclamation, and
Natural Mine Cut Reclamation
CF's Plan Includes Mining
and Restoration of All
Category I-C, I-D, II, and
III Wetlands On site;
Preservation of All Category
I-A Wetlands; and the EPA
Alternative of Preserving
All Category I Wetlands
A brief description of each of the alternatives listed as well as the no-
action alternative is presented in the following paragraphs.
Mining
Dragline Mining--CF proposes to use a single large (55 cubic yards) dragline
to move overburden and mine matrix during the first 7 years of operation. In
Mine Year 8, a second similar 55-cubic-yard dragline would be added to
supplement the first unit. Other than the fact that CF proposes to initially
mine with a single large dragline (rather than two units), the proposed mining
method is as conventionally practiced in the Florida phosphate industry.
Dredge Mining-.TK« three most common dredge types are the bucket line, cutter
head, and bucketwheel. Each is basically a large, barge-mounted machine
consisting of a continuous digging apparatus mounted on a long boom extending
below the water surface. The bucket line's chain-carried buckets continuously
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CF89-Z.1/FEIS.10
8/03/89
transfer material up to the barge, while the other two units pump material
from beneath the water to the surface via a suction pipe.
Bucketwheel Mining--Bucketwheel excavators are large continuous mining
machines which excavate material with a series of buckets mounted on the
periphery rotating wheel and drop it onto a conveyor belt system. Overburden
would be routed for disposal in previously mined areas, while matrix would be
sent to the beneficiation plant.
Matrix Transport
Slurry Matrix Transport--Slurry matrix transport is used at most existing
Florida phosphate mines. Matrix would be placed into a pit and mixed with
recycled water [11,000 gallons per minute (gpm)] from high pressure nozzles,
breaking down the clay and sand matrix into a slurry (35- to 40-percent
solids) which would then be transported via pipeline to the beneficiation
plant by a series of large pumps operating at approximately 15,700 gpm.
Conveyor Matrix Transport--Conveyor matrix transport would require that matrix
be placed onto a belt conveyor at the mine for transport to the beneficiation
plant. To minimize the number of transfer points and still maintain mobility
of the conveyor sections, such a conveyor belt system would most likely
include belt sections of up to 2,000 feet in length.
Truck Matrix Transport--A dragline would load the trucks, which would then
transport the matrix via haul roads to the beneficiation plant. At the plant,
matrix would be dumped and/or washed out of the trucks.
Matrix Processing
Conventional Matrix Processing--Conventional matrix processing involves the
separation of phosphate rock from waste sand and clay using a series of wet-
process operations. These consist of washing, feed preparation, and
flotation. This is the only method -of matrix processing in operation in the
Florida phosphate industry today.
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CF89-Z.1/FEIS.11
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Drv Matrix Processing--The general concept of dry processing involves the
production of usable phosphate product from matrix directly following its
excavation and drying. The method used would probably involve both air
separation and electrostatic separation. There are no such plants in
operation in the Florida phosphate industry today.
Waste Sand and Clav Disposal
Sand/Clav Mixiny--Sand/clay mixing involves the recombining of the waste sand
and clay removed from the phosphate matrix during separate processing steps.
In the CF mix process, the waste clay generated from the beneficiation
processes is routed to a containment area for storage and subsequent
consolidation to higher percent solids. When clay consolidation reaches the
12- to 18-percent range, it is removed by dredge and pumped to a mix tank,
where mixing with dewatered sand tailings from the beneficiation plant takes
place. The sand/clay mixture is then pumped from the mix tank to a designated
disposal site. Disposal areas are designed to receive sand/clay mix over
mined lands to final fill elevations that consolidate to within approximately
2 to 3 feet above the original average pre-mining elevation by the end of the
reclamation period.
Conventional Sand and Clav Disposal--Conventional methods for disposing of the
waste sand and clay removed from the phosphate matrix during processing
involve their impoundment in separate areas surrounded by high dikes. For the
proposed mine, as much as half of the area to be mined would be covered with
waste clays impounded above-grade and surrounded by such dikes.
Process Water Soureaa
Ground Water Withdrawal--The major source of fresh water used at the mine
would be two on-site deep (1,200-foot) wells. The mine field would likely
consist of a primary production well, a standby production well, and two
potable water wells. The production wells would have a capacity of 10.57 HGD,
with an average daily pumping rate of about 7.85 HGD.
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CF89-Z.1/FEIS.12
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Surface Water Impoundment--The most readily available fresh water source which
could be utilized by CF would be surface water from nearby creeks and rivers.
Since the creeks on the site typically exhibit low flows, or even intermittent
flows, the quantity available for use as process water could best be provided
by impoundment within a reservoir system constructed on the site.
Water Management Plan
Discharge to Surface Waters--Seasonal changes in rainfall and evaporation
rates will affect the active water volume of the recirculating water system.
When heavy rainfall occurs, the system may become overloaded, forcing a
discharge to an existing natural drainage (either Doe Branch or Shirttail
Branch) through a control structure. An alternative discharge to Payne Creek
by sheetflow into wetlands is also proposed.
Use of Connector Wells--Connector wells would serve to reduce the amount of
water in the recirculating system by dewatering the surficial aquifer (a
source of water inflow to the system) in the vicinity of the active mine pit.
This water would be pumped downward through wells into a deeper aquifer and
serve as a source of recharge to that aquifer.
Reclamation Plan
CF's Proposed Reclamation Plan--CF's proposed reclamation plan consists of
five general types of restoration. The land capabilities and reclamation
plans for the mined areas are closely related to the types of landforms
created by the waste disposal plan. The acreages of the landforms remaining
after mining and waste disposal are as follows:
Lantffgra
Acreage
9,083
2,213
Sand/Clay Mix Areas
Sand Tailings Fill Areas
with Overburden Cap
Mined Out Areas for Land
2,399
and Lakes
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CF89-Z.1/FEIS.13
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Overburden Fill Areas and 1,230
Disturbed Natural Ground
Reclamation will proceed from the third year of mine operation, with the final
areas mined being reclaimed in the 35th year after operation begins.
Conventional Reclamation--Conventional reclamation is reclamation associated
with the separate disposal of sand and clay wastes (i.e., conventional sand
and clay waste disposal). Reclamation would consist of allowing a crust to
form over impounded clays, seeding these areas with forage species, and
creating extensive land and lakes land forms in those areas of the site not
covered with impounded clays. The revegetation of these areas would likely
consist of forage species plantings on most land areas, with forest tree
plantings along the edges of the lakes.
Natural Mine Cut; Pan!amation--Natural mine cut reclamation would amount to
leaving mined-out areas in windrows, with sand-clay mix deposited between
windrows. Mined areas would be allowed to revegetate naturally, as has been
the case in many of the older central Florida mines. The resultant use of the
mined-out land would be largely for fish and wildlife habitat, with some
pastureland.
Wetlands Preservation
CF proposes to preserve from mining approximately 69 acres, which account for
all but 2 acres of wetlands designated as Category I-A (mainstem stream
wetlands) on the project site. The 2 acres proposed for disturbance would be
required for the dragline crossing of Horse Creek. There are approximately
695 acres of wetlands on site designated Category I-C and I-D (headwater and
special concern wetlands EPA also considers worthy of preservation and
protection) which CF has included in its mining and waste disposal plans.
EPA opposes mining of any Category I wetland. CF is currently proposing to
preserve only those designated Category I-A, and has included the Category I-C
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CF89-Z.1/FEIS.14
8/03/89
and I-D wetlands in their mine plan and waste disposal plan. However, CF has
acknowledged EPA's opposition to any such mining, and has agreed that mining
will not be scheduled in those areas unless and until EPA reconsiders, based
upon proven re-creation of functional hardwood swamp communities and large
wetland systems, its present Category I designation.
The No-Action Alternative
The no-action alternative by EPA would be the denial of an NPDES permit for
the proposed project. The effect of permit denial would be to precipitate one
of three possible reactions on the part of CF: 1) termination of their
proposed project; 2) indefinite postponement of the proposed project; or
3) restructuring of the project to achieve zero discharge, for which no NPDES
permit would be required.
Termination of the planned project would allow the existing environment to
remain undisturbed and the present socioeconomic and environmental trends to
continue.
If EPA were to deny CF Industries' NPDES permit application, the project might
be postponed for an indefinite period of time and then be pursued by either
this applicant or another mining company. This could be expected to occur
when high grade phosphate reserves become depleted and the resource retained
on the proposed site becomes valuable strategically as well as economically.
Also, CF Industries would still execute a mining project provided the project
could be performed with zero discharge to surface waters. Under zero
discharge conditions, neither an NPDES permit nor an Environmental Impact
Statement would be required.
4. Mitigation Measures:
Mitigation measures which would serve to reduce the impacts of the project on
the surrounding environment were developed from inputs received from the
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CF89-Z.1/FEIS.15
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preparers of the various sections of the Environmental Impact Statement.
These are described below:
• Pile overburden such that the volume available for belowground waste
disposal is maximized;
• Use "toe spoiling" to reduce the radioactivity of reclaimed surface
soils;
• Cover reclaimed sand-clay mix disposal areas with low activity soil to
reduce gamma radiation levels;
• Cover reclaimed sand tailings disposal areas with low activity soil to
reduce gamma radiation levels;
• Use recirculated mine water, rather than surficial aquifer water, for
pump seal lubrication;
• Restrict mining along the preserved portion of Horse Creek to only one
side of the stream channel at a given time;
• Monitor both the surface and ground water quality to assess the
effects of mining and reclamation;
• Protect upstream wetland areas and use as a seed source to recolonize
the disturbed downstream unit after mining of a stream segment is
complete and restoration begins;
• Use best available scientific information to reestablish the desired
surficial zone in restoration areas and habitat-specific topsoil and
root mass to the extent feasible;
• ^ Design a productive littoral zone in newly created lakes systems to
enhance habitat values and water quality;
• No mining will be conducted on Category I wetlands. CF has
acknowledged EPA's opposition to any such mining and has agreed that
mining will not be scheduled in those areas unless or until EPA
reconsiders its present Category I designation;
• Implement a program to reduce impacts on the eastern indigo snake, a
threatened species which occurs on the site; and
• Control of fugitive emissions by reducing pre-mine land clearing
during the dry season and utilization of approved dust control
techniques on internal access roadways.
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CF89-Z.1/FEIS.16
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5_ p.PA/s Preferred Alternatives ant} Recommended Mitigating Measures:
The alternatives evaluation for the proposed project is presented in
Section 2.13 of the E1S. Based on analyses described in this section, EPA's
preferred alternative for each of the project components is as follows:
Component fifft PMftTO*
Hining Dragline Mining
Matrix Transport Slurry Matrix Transport
Matrix Processing Conventional Matrix Processing
Waste Sand and Clay Disposal Sand-Clay Mixing
Process Water Source Ground Water Withdrawal
Water Management Plan Discharge to Surface Waters
Reclamation CF's Proposed Reclamation Plan
Wetlands Preservation Preservation of Category I Wetlands
As indicated above, EPA's preferred alternatives for the various project
components are in agreement with CF's proposed action, with the exception of
mining in Category I-C or I-D wetlands. EPA's preferred project action
involves the preservation of all Category I-C or I-D wetlands. CF will not be
allowed to mine Category I-C or I-D wetlands until such time they can provide
documented evidence to EPA s satisfaction that these functional hardwood swamp
communities and functional large wetlands systems can be successfully
restored. Implementation of most of the mitigation measures described in the
previous section is proposed as a condition of the NPDES permit for the
project. The measures excluded as conditions of the permit are the capping of
all waste disposal areas with low activity overburden and the use of
recirculated mine water to meet pump seal requirements. While environmental
impacts might be reduced by these two actions, forced implementation is
considered to be impractical on the scale of the proposed mine-both for
economic and technical reasons.
All other mitigation «m.> ll»t.d In Section 4 abov. «. propc.d ..
conditions of the NPDES permit for the CF project.
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CF89-Z.1/FEIS.17
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6. Identified Issues and Concerns:
The DEIS was made available to the Council on Environmental Quality (CEQ) and
the public on June 6, 1988. A joint public hearing to receive comments on the
DEIS and the Draft NPDES permit and state certification was held in Wauchula,
Florida, on July 21, 1988. The comment period remained open through August 5,
1988, (a 2-week extension was granted FGFWFC at their request). Written and
verbal connents were received from the following agencies and individuals.
Federal Agencies
U.S. Department of the Interior, Office of Environmental Project Review
U.S. Army Corps of Engineers, Vic Anderson (verbal)
State Agencies
Florida Department of State, Division of Historical Resources
Florida Department of Agriculture and Consumer Services
Florida Game and Fresh Water Fish Commission
Florida Department of Environmental Regulation
Interested Croups or Individuals
CF Mining Corporation
Ken Morrison, Ridge Audubon Society
Dr. Carl U. Smith, Florida Bipartisan*
Faye Dobbs, Concerned Citizens League of America, Inc.
All questions and comments on the DEIS, written and verbal, are individually
addressed in Section 3, Public Participation, of tha final EIS. Comments that
resulted in changes to EPA's recommendation are discussed in the following
paragraph.
CF Mining Corporation, In a letter to EPA dated August 4, 1988, (see
Section 3.1) requested modifications to proposed NPDES permit conditions and
provided supporting information designed to show that soma water quality
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CF89-Z.1/FEIS.18
8/03/89
monitoring and planning requirements are not needed. In response to the
comments of Section 3.2, EPA determined that some monitoring and planning
requirements could be deleted or modified based on information provided by CF
Mining Corporation.
7. Summary nf the Environmental Impacts of the Alternatives:
The impacts of CF Mining's proposed action, EPA's preferred alternatives and
mitigating measures, and the no action alternative are summarized in Table 1.
8. EPA's Proposed Action:
Pursuant to provisions of the Clean Water Act of 1977, EPA proposes to issue a
NPDES permit to CF Mining Corporation for their proposed Hardee County,
Florida, phosphate mine. EPA's proposed action will impose as permit
conditions the performance of all mitigating measures identified in CF's
proposed action as well as those additional mitigating measures developed by
EPA which were recommended for implementation.
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Table 1. Comparison of Che Envirorraental Impacts of ihe Alternatives
EPA's Preferred Alternatives
Discipline CF's Proposed Action and Mitigating Measures
Air Quality, Minor increases in fugitive
Meteorology, dust emissions and emissions
and tbise from internal eontousL ion
engines; minor (missions of
volatile reagents; increased
noise levels in the vicinity of
operating equipment.
Geology and Disruptions of the surface
Soils soils and overburden strata
over the mine site; depletion
of 97 Million short tons of
phosphate rock resources;
creation of a reclaimed soil
material which should be
superior to existing soils.
Saiu as CF's proposed action.
Sane as CF's proposed action.
Radiation Disruption of the natural
distribution of radioactive
material within the overburden
aid phosphate matrix; increasul
radiation levels fron reclaimed
surfaces.
Same as CF's proposed action,
except that reclaimed surface
soils would contain less radio
act ivc material because of toe
spoiIing.
Ground Water Withdrawal of ground water at Saroa as CF's proposed action,
an average rate of 7.85 mgd;
lowering of surficial aquifer
in the vicinity; possible local
contaaination of surficial
aquifer adjacent to sand-clay
mix disposal areas.
Teimination
The No Action Alternative
Postponement
Achieve Zero
Discharge
Ni change in meteo-
rology & noise levels
present; possible air
quality changes fron
other sources.
Sane as CF's proposed
action.
Sane as CF's proposed
action.
Nu change in geology;
no change in site
soils (i.e., increased
productivity); preser-
vation of 97 million
short tons of plws-
phate rock reserves.
Ibssible increased
phosphate recovery and
mare effective sani-
clay mix disposal,
reclamation, and wet-
lands restoration.
Increased dike heights,
and water storage capa-
city; probable infringe-
ment on preserver! areas;
less desirable reclama-
tion plan.
N) change in radiation
characteristics of the
sile.
No change in existing
ground waLer quantity
and quality.
Sane as CF's proposed
act ion.
Probable increase in area
covered with waste
clays—the reclaim^
miterial having the
highest rarlioaet ivily
levels.
Possible reduction in
ground water with-
drawals because of nure
effective dewatering of
waste materials.
S,me as CF's proposed
act ion.
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Table 1. Comparison of the Environmental Impacts of the Alternatives (Gbntinued, Page 2 of 2)
The No Action Alternative
EPA's Preferred Alternatives Achieve Zero
Discipline CP's Proposed Action and Mitigating Measures Termination Postponement Discharge
Surface Water Disruption of surface water
flows frao the mine site; minor
reduction in flows following
reclamation; degradation of
water quality due to discharges
fran the mine rater system.
Same as CF's proposed action.
Aquatic Ecology
Destruction of aquatic habitats
on the nine site; aquatic
hdbitat modifications die to
reduced surface water flows ani
addition of contaninants to
creeks flowing fran the site.
Terrestrial Destruction of terrestrial
Ecology habitats artl loss of indivi-
duals of sane species on the
mine site; creation of modified
habitats following
reclanation.
Same as CF's proposed action.
N> change in surface
water quantity; sur-
face vater quality
would be dependent
upon future land uses
in tie site area.
tt> change in existing
aquatic ecolqgy.
Sane as CF's proposal action,
except that the wildlife habitat
on the reclaimed mine site will
be more extensive (both marsh and
forest).
(to change in existing
terrestrial ecolqgy.
Sane as CF's proposed
action.
Sane as CF's proposed
action.
Possibly nore effective
reclanation and wet-
lands restoration.
Elimination of surface
water quality impacts
resulting fran discharge
fran mine water systen;
increased probability of
dike failure impacts.
Elimination of habitat
modification resulting
fran discharge Gram mine
water systen; increased
probability of dike
failure impacts.
Probd)le creation of
increased reclaimed Land
areas of limited us?
(e.g., pasture).
Socioeconanics Generation of jobs with
caaparatively high incanes; ad
vaiorea and sales t» revenue
for Hardee County; severence
tax revenue for the state, Land
Reclanation Ttust Fund, and
Florida Institute of Riosphate
Research; some population
influx to Hardee (butty;
increased demands for housing,
transportation, fire protec-
tion, police, and medical
services.
Sane as CF's proposed action.
ffe increase in enploy-
ment; no increase in
tax revenues; less
danani for transporta-
tion, housing, fire
protection, police anl
medical services; con-
tinuation of phosphate
rock market uncertain-
ties for CF and a loss
of their investment.
Continuation of phos-
phate rock market
uncertainties for CF
and potential increased
project costs; possible
improvement in supply/
demand for housing in
Hardee (binty.
Sane as CF's proposed
action.
-------
CF89-Z.1/FEISTOC.1
8/03/89
FINAL ENVIRONMENTAL IMPACT STATEMENT
TABLE OF CONTENTS
SUMMARY SHEET FOR ENVIRONMENTAL IMPACT STATEMENT
S?Sti9Tl Page
1.0 PREFACE 1-1
2.0 ERRATA 2-1
3.0 PVBLIC PARTICIPATION 3-1
3.1 WRITTEN COMMENTS 3.1-1
3.2 RESPONSES TO WRITTEN COMMENTS 3.2-1
3.3 HEARING TRANSCRIPT 3.3-1
3.4 RESPONSES TO TRANSCRIPT COMMENTS 3.4-1
4.0 COORDINATION LIST 4-1
5.0 LIST OF PREPARERS 5-1
6.0 APPENDIX 6-1
6.1 DRAFT NPDES PERMIT FOR CF MINING CORPORATION, A-l
HARDEE COMPLEX II, HARDEE COUNTY, FLORIDA
-------
PREFACE
-------
CF89-Z.1/PREFACE.1
8/03/89
1.0 £E£E&££
In June 1988, the Environmental Protection Agency published and distributed a
Draft Environmental Impact Statement (DEIS) on the proposed CF Mining
Corporation, Hardee Complex II Phosphate Mine. The DEIS was written pursuant
to the National Environmental Policy Act (NEPA) of 1969. While the DEIS was a
complete document, much of the detailed technical information and supporting
data were presented in a Supplemental Information Document (SID). The DEIS
was distributed to the appropriate federal, state, and local agencies and to
interested individuals. The SID was available for review at a number of
locations and was distributed on a limited basis.
This Final Environmental Impact Statement (FEIS) has been prepared to conform
with the Environmental Protection Agency (EPA) regulations (40 CFR Part 6) for
implementing NEPA. The essence of the NEPA decision process is contained in
the Summary Sheet for the FEIS; it describes the existing problem requiring a
decision, summarizes alternatives including mitigative measures and their
associated impacts, Identifies major concerns and Issues, and presents EPA's
conclusion and decision.
In an effort to avoid excessive paperwork and costly reproduction, the DEIS
text has not been reprinted in the FEIS. The supporting information furnished
in the DEIS and its SID should be reviewed and are incorporated herein by
reference.
1-1
-------
ERRATA
-------
2.0
ERRATA
Page Paragraph Line
Correction
2 11
14 Table 1
15 Table 1
Each reference Co "CF Industries, Inc." should read
"CF Mining Corporation."
"(99 percent)" should read "(98 percent)"
Radiation, EPA Preferred Alternative, delete all after
"same as CF's proposed action" (CF will use toe
spoiling mitigation procedures).
Aquatic Ecology, CF's Proposed Action, add "Increase
in aquatic habitat area following reclamation."
2-1
-------
PUBLIC PARTICIPATION
-------
CF89-Z.1/FEIS3.1
8/03/89
3.0 PUBLIC PARTICIPATION
The Draft Environmental Impact Statement (DEIS) was published in June 1988 and
made available to the Council on Environmental Quality and to the public. A
public notice appeared in the local newspapers. The Federal Register
(Volume 53, No. 122) dated June 24, 1988, announced the availability of the
DEIS and the proposed issuance of an NPDES permit. The DEIS was provided to
numerous federal, state, and local agencies as well as concerned individuals,
interest groups, and public officials.
A notice of the public hearing was published on June 20, 1988, in the Polk
County Democrat and tfauchula Herald Advocate. The public meeting was held in
Wauchula, Florida, on July 21, 1988, and was attended by approximately 20
participants. The comment period on the DEIS remained open through August 5,
1988. In addition to the public input afforded by the hearing (transcript
provided herein). A number of letters and verbal comments were received
during the comment period and are included in this final EIS.
The designations in the margins of the letters (W-l through W-42) identify
those specific comments for which responses have been developed. These
responses follow the letters. In a similar manner, the designations in the
margin of the hearing transcript (T-1 through T-8) identify these comments
which have been responded to in the pages immediately following the
transcript.
3-1
-------
PUBLIC PARTICIPATION
3.1 Wr1tten Comments
-------
STATE OF FLORIDA
FLORIDA DEPARTMENT OF AGRICULTURE S CONSUMER SERVICES
OOYLE CONNER. COMMISSIONER * 3125 CONNER BLVD. TALLAHASSEE 32399-1650
June 20, 1988
Ms. Maryann Gerber
Project Monitor
Environmental Protection Agency
Region IV
345 Courtland Street. Northeast
Atlanta, Georgia 30365
Dear Ms. Gerber:
Recently, our staff had the, opportunity to review the draft EIS for the
CF Corporation, Hardee Phosphate-Complex II Mine and Beneficiation Plant.
We offer the following comments:
In regards to reclamation of forested, wetlands, approximately 1,410
acres, we recommend that cypress be considered as a suitable species.
Cypress should do well in this habitat and has proven to be a valuable W— 1
economic species.
Also, I would strongly encourage that efforts be made to salvage all
merchantable timber during initial land clearing efforts. There now W-2
exists markets for both hardwood and softwood products in this region and
this resource should not be lost by piling and burning.
The Division of Forestry's district office In Bradenton, Florida could
provide information on potential procurement interests for these timber
products. The person to contact would be Doug Voltolina, District
Forester, at 813/756-7343.
Harold K. Miltell, Director
Division of Forestry
904/488-4274
HKK/bgc
cc: Doug Voltolina, Bradenton District Forester
¦ :w iv
¦ ¦¦¦ * », CfA
-------
FLORIDA DEPARTMENT OF STATE
Jim Smith
Secretary of State
DIVISION OF HISTORICAL RESOURCES
R.A. Gray Building
Tallahassee, Florida 32399-0250
(904) 488-1480
July 11, 1988
Mr. Robert B. Howard, Qiief
NEPA Compliance Section
U.S. Environmental Protection Agency, Region IV
345 Courtland Street, N.E.
Atlanta, Georgia 30365
in Reply Refer To:
Robert C. Taylor
Historic Sites Specialist
(904) 487-2333
Project File No. 881468..
RE: Review of Draft ESiviromental impact Statement:
"CF Mining Corporation, Hardee Phosphate canplex II
Hardee County, Florida, Primary Document"
Dear Mr. Howard:
In accordance with the procedures contained in 36 C.F.R., Part 800
("Protection of Historic Properties"), we have reviewed the above referenced
projects for possible impact to archaeological and historical sites or properties
listed, or eligible for listing, in the national Register of Historic Places.
The authority for this procedure is the National Historic Preservation Act of
1966 (Public Law 89-665), as amended.
, , .Vvwro vafafgncGd doctftient. We note that previous
We have reviewed the above reference^ ^ ^ ^
consultation with this "9"*? J ^ UDon ccnpliance with the stipulations on page
enclosure). Therefore, STSaSS. effect on any sites listed, or
7-4, the proposed project wi of Historic Places, or otherwise
eligible for listing, m the
of national, state, or local significance.
. . -oneeming our comments, please do not hesitate to
contact £! ^ P1°tida'S
archaeological and historical resources are appreciated.
Sincerely,
-7*1
kt5eorge w. Percy, Director
'Division of Historical Resources
and
State Historic Preservation Officer
W-3
GWP/rct
Enclosure (1)
$ JUL 13 1933
JijrassEnns
-¦fGIOH IV
Archaeological Research
(904) 487-2299
epa-resioh
Florida Folldife Programs
(904) 397-2192
Historic Preservation
(904) 487-2333
Museum of Florida History
(904) 488-1484
-------
July 11,1988
Director, Environmental Permitting Division
EPA, Region IV
Atlanta, Georgia.
Dear Sir:
I am writing as the scientific consultant and representative of Florida
Bipartisans, a major civic organization of Central Florida. 1 am writing also
as one of the main originators of experimental environmental science in Florida
and in the nation(i.e. as one of the first to conduct controlled environmental
studies on marine vertebrates and on human exposure to electromagnetic radiation
and CRT-display work). You can find a summary of my activites as a scientist
in Vho's Who and American Men of Science.
Our purpose in writing1'toyou is to oppose strongly a recent statement of your
agency and an environmental-impact statement of your agency, which state that a
planned phosphate mine of 15,000 acres of CF Mining Corposration In northern
Hardee County will not have a significant Impact on water bodies, wildlife and
plant ecology of the proposed mining region. We consider these statements of..
Reynolds, Smith and Hill and of your Maryann Gerber as nothing but a series of
fabrications and falsehoods intended to mislead Florida citizens about the
devastating impacts of the proposed mine on wetlands, animal life, irreplaceable
tree and plant life and residents. The following specific objections to any minin
in the proposed area are as follows. These objections are being filed with the
office of Senator Btfb Graham who is being asked to Investigate in full the
accuracy of the statements of Maryann Gerber and of your environmental consultants
relative to the effects of phosphate mining on the Hardee County area, We are
seeking Senator Grahami action since the proposed mine directly threatens the W
fresh drinking water resources of the lower Peace River system and of the regions
around Charlotte Harbor and Fort Meyers.
1) Florida's constitution (Article 10, Section 11) specifically prohibits w-5
any government authorization of private use of sovereign land (in the instant
case Payne Creek, the flood plain of Payne Creek, Horse Creek and the Peace River
system) if such use is contrary to the public interest. We consider our organiza-
tion a significant body representing the public Interest In environmental matters
in Central Florida and knowledgeable of all of the pertinent facte In the present
Instance. That is to say, we oppose on Florida constitutional grounds any private
use by a mining company of Payne Creek, the flood plain of Payne Creek, Horse
Creek and the Peace River system. Our reason for this contrary public interest
is indicated above but is also based on additional facts summarized below.
2) We strongly oppose the issuing of any permits to mine the proposed Hardee
County region because of the unmatched richness of the region in irreplaceable
wildlife and plant life. Florida Game and Fish Commission wildlife experts have
identified many endangered animals of the region whose extinction will be rapidly
hastened by the mining — i.e. wood storks, Indigo snakes, gopher tortoises, red
cockaded woodpeckers, southern bald eagles, sandhill cranes, American kestrels,
roseate spoonbills, burrowing owls, and Florida black bears. Florida laws prohibit
the capturing or disturbing the habitat of most of these enlmals. We demand that
the law be applied In the instant case to any person connected with CF v-twfng W-7
Corporation who disturbs or Is responsible for disturbing any of thpse named
animals and that criminal charges be lodged for such actions. We view the statements
of Maryann Gerber of your Department as an open invitation to any corporation
or group of irresponsible persons to capture, displace, harass and kill at their
-------
-2-
pleasure indigo snakes, gopher tortoises, roseate spoonbills, and wood storks.
3) We oppose the proposed EPA mining permit as a major threat to the civil
rights and lives of the residents who inhabit northern Hardee County and southern
Folk County. Their lives will be ruined for all future time because of: (a) the
creation of another vast cone of depression of the water table in the area; (b)
drawdown of the water system of Payne Creek, Horse Creek and the Peace River
system generally, and of wells and irrigation wells over a wide adjoining- area; W-lO
(c) contamination and pollution of wells, the aquifer and Payne Creek, Horse Creek
and the Peace River system south of Polk County; (d) increase in radon contamination
of southern Polk County and northern Hardee County by a pollutant now recognized
scientifically as the most deadly pollutant known, and one with no minimal
standard of exposure. W-'
4) Our opposition is based on the false claims that strip-mined bench-
mined land and wetlands can be reclaimed and retuijed to their original atate
as evolution-structured and organized ecology. Extensive experience and research
by the Florida Institute of Phosphate Research itself has indicated that mined
hardwood wetlands cannot be reclaimed successfully after mining, and that no
W-14
wetlands region of any size has been reconstituted as a viable water body. We
W-15
state categorically therefore that statements of your Maryann Gerber regarding
the potentials for mining-company reclamation of wetlands and hardwood wetlands
areas of the proposed mining region are nothing but irresponsible fabrications
which have no technical substantiation.
5) We oppose the proposed EPA mining statements and the intention to issue 16
permits for the northern Hardee County area because of the threat to the rnalor
wetlands of the area. These wetlands are essential not only for survival ad
expansion of critical wildlife resources, but are equally essential to mai t i
the hydrologic pressure exerted by fresh water of the Peace River system ° °
the lower salt-water aquifer, especially in the region of Charlotte HarborP°Pflvn«
Creek, Horse Creek and their surrounding wetlands are critical compon t "f h
hydrologic fresh water aquifer and surface water systems which serve ^ h l t
against salt water intrusion of the fresh water aquifer in all ofsouthwes"
Florida.
We request that this statement be filed as a part of the famai
of the content of the hearing in W^phula on July 21. We request Pr®8*nCation ,
demand — that all concerned public-interest groups allied with # fact» w-l'i
by private use of the Peace River system by a mining corooraH«-°r , cted
County, particulary the people of the Charlotte Harbor are, be noMfJ /f Pollc
timely way of the forthcoming hearing. If no such notices ¦» in a
propose to object to the illegality of the Wachula hearina u. ? out' we
would like to receive at once the full information about- Particular,
of th* hearing. 0ut the clM th. agenda
Yours,
irl 0. Smith
1001 Tower Blvd.
Lake Wales, Fla. 33853
Tel. (813) 676 7020
-------
^Qidcje. cAudubon sSoclety
INCORPORATED
Post Office Box 148
BABSON PARK, FLORIDA 33827
(813)638-1355
Associated with the Florida Audubon Society and the National Audubon Society
July 16, 1988
To: Environmental Protection Agency
Re» Hardee Phosphate Complex No. 2
We request that this statement be included in the record of
the public hearing to be conducted on July 21, 1988 in Wauchula.
The Ridge Audubon Society is very much concerned about the
environmental impacts that will result from phosphate mining
on some 14,000 acres in Hardee County just south of the Polk
County line.
We note that EPA proposes to allow the discharge of excess w-i a
mining water into three tributaries of Payne's Creek which
ultimately feeds the Peace River* We believe that such action
might be in violation of the Florida Constitution. We ask
that such discharges not be allowed. Potential pollution of
the Peace River cannot be tolerated.
The Tampa Tribune of June 2, 1988 contains this statement:
The effect of mining on most animals would be minimal because
they will move from the mining site until after reclamation
occurs, she (Maryann Gerber) said.
This statement by an EPA representative shows lack of recog-
nition of biological realities. Most of the wildlife evacuees w_19
from the CF Mining Corp. site will die because most of the eco-
logical niches which they will attempt to inhabit are already
occupied by others of their species. There are only a limited
number of place settings at the biological table.
In every instance, mitigation results in a net loss of habitat
and hence of population. At some point we need to shout HALT! w-20
if the continuing destruction of endangered species* habitat
is to be brought under control. What better time than now?
/ Conservation Chairman
-------
GRADY V. WHITAKER
President
(813) 533-7869
CONCERNED CITIZENS LEAGUE OF AMERICA l//a,
870 SUNUP DRIVE
BARTOW. FLORIDA 33830
Recognized And Respected Throughout The Nation
JAMES C. BRYCE
Founder - Retired
Ocala <904) 694-3386
J. P. PUBCELL
Advisor
(8131 644-9879
July
ion
*ussa»wJSR
MIS 11388
Ms. Maryann Gerber
% U.S. Environmental Protection Agency
3^5 Courtland Street, N.E.
Atlanta, Georgia 30365
Dear Ms. Gerber: ~ cpT-RtSIOW IV
AIJJWTAj
Thank you for holding the C.F. Industry Hearing in Wauchula
last week. The Federal is our only solution to saving wetlands,
water, birds, and animals. Department of Environmental Reg-
ulations has Just OK* ed valuable wetlands to be mined. The
Gooch Grove Wetlands and South Prong Alafia River wetlands. Unless
Federal acts phosphate mining will continue to destroy us.
Under Part XZZX 111 page A 33— number 12— quote '• Assure EPA
that sufficient buffers are established to protect the wetlands
from dewatering" unquote Thats a nightmare of a statement. To w-21
your satisfaction how is this done? Will all C.F. Industries
have to do is get Southwest Florida Water Management to say that
they did not break our regulations. The only regulations that
SWFWMD enforces on phosphate is that you must not over pump
your Consumptive Use Permit. The fox watches the hen house
and they never over pump.
Page 3-3^—3.3.I.I These dewatering wells, injection wells
recharge wells, or connector wells which ever one chooses to*call
the rape of our land and death with cancer. The contamination w 22
of drinking water with Radium 226 should be decreased and not
increased. Hundreds of thousands of acres of land left for the
people to breathe the contaminated air with Ra. 226. Phosnhate
Economics should not be allowed to destroy us. pnaue
Wildlife needs protection. Very very few fish in the Peace bwoP
now. Recreation of lakes for alligators. These allittai^ tlZl
got to eat. How will this be accomplished? Tortoises w-23
rltorial animals and they are slow,. They share thSJ v, ViZ
the Indigo ,»]». What suarant.e It proteluon
Am enclosing two Mulberry Press issues, people have «« * ,.
water rights if phosphate Is their neighbor. WILL You m?lV 7
Faye Dobbs
P.O. Box 3^07
Lakeland, Florida 33302
FOB QOD, A AMERICA AND CONSTITUTIONAL OOVKJUMXNT
-------
Draft Permit FL0040177
CFHC Comments
August 4, 1988
Page 1 of 3
In reference to the draft permit, the following comments are
provided:
a. Part I.A.I., Outfalls 001, 002,
Limitations and Monitoring Requirements.
and 003. Effluent
The EPA has included the effluent characteristic fluoride
in the monitoring requirements. As indicated in my discussion
with Steve Richardson, EPA, on July 27, 1988, CF submits that
fluoride should be removed from the list of parameters required
for monitoring. CF believes that the nature of the fluoride
source in our operation, and past operational data fully support
this position.
Fluoride occurs naturally in the phosphate rock in an insoluble
state: CF's mining and beneficiation processes do not act
in any way to liberate or dissolve the small percentage of
fluoride in the rock. Therefore, fluoride concentrations
in the process water discharges are not expected to exceed
the natural background of the receiving waters or the applicable
water quality standards.
CF's operational records at the Complex I mine substantiate
the position that the proposed operation will not contribute
fluoride in concentrations that cause violations in the
discharge or in the receiving streams. EPA made this
determination in 1983, when the requirement for fluoride
monitoring was removed from permit FL0035271 for Outfalls 001
and 002 at the Complex I mine. CF believes that the documented
similarity of the operations and ore bodies between the
Complex 1 operations and the proposed Complex II operations
provides for a similar determination to be made for the subject
permit.
Enclosed for your review is the following information which
supports CF's position:
Attachment I
Attachment II
Attachment III
Attachment IV
Complex I Outfall 002 Postdischarge Data
(1981 - 1983) Monthly Fluoride Analysis
Complex I Weekly Fluoride Analysis
(1982 - 1983) Receiving Stream, Hickey
Branch
Complex I Outfall 003 Postdischarge Data
(1987 - 1988) Monthly Fluoride Analysis
Complex 1 Weekly Fluoride Analysis
(1987 - 1988) Receiving Stream, Payne Creek
Attachment V
Complex I, Mine Discharge Water Analysis
from Baseline Study - EIS
-------
Draft Permit FL0040177
CFMC Comments
August 4, 1988
Page 2 of 3
Attachment VI Complex II. Receiving Stream Water Quality
from Baseline Study - EIS
Attachment VII Location Map
Attachment VIII Characterization of Discharge from
Supplemental Information Document
The information submitted in Attachments I through IV documents
the fact that the fluoride discharge limitation of 10, mg/1
is being constantly met in CF's current discharge and in the
receiving streams, Payne Creek and Hickey Branch. It is also
that the proposed receiving streams for the
Complex II discharges do not exhibit a high' fluoride
concentration (Attachment VI), and the established level of
fluoride concentration in historic discharges at the Complex I
mine (Attachments I, III, and V), is well within the discharge
limitation. In addition, as noted in _ ,
Supplemental Information Document (Attachment VIII), the amount
of groundwater necessary for make-up water for the Complex II
mine will be greater than is currently used at the Complex I
mine with the probable result that expected fluoride
concentrations from Complex II discharges will be even lower
than those documented for Complex I. In consideration of
the foregoing, CF believes that EPA can respond favorably
to the request for relief from fluoride monitoring for proposed
Outfalls 001, 002, and 003 in the subject permit.
b. Part I.A. Notes: c. Outfalls 001, 002, and 003.
CF requests inclusion of monitoring for gross alpha particle w-25
activity and combined radium 226 and 228 under the monitoring
relief provided by this Note. The discussion in the draft
EIS Supplemental Information Document under Section 5.1.2.5,
pages 5-19 through 5-24, states that historical data and the
baseline monitoring for the EIS show all surface water and
mine discharge measurements for these two parameters to be
less than the FDER water quality limitations (see
Attachment IX). Therefore, CF feels it is appropriate to
provide for relief from continued monitoring for gross alpha
particle activity and combined radium 226 and 228 after
sufficient monitoring has been performed to clearly demonstrate
compliance.
c. Part I.A.3. Outfalls 001, 002, and 003.
This monitoring requirement calls for submittal, within sixty
days after the effective date of the permit, of a plan of
study to establish a program sufficient to demonstrate
compliance with the Biological Integrity Standard. The timing
-------
Draft Permit FL0040177
CFMC Comments
August 4, 1988
Page 3 of 3
of the required submittal, relative to the uncertainty of
an operating schedule for Complex II, was discussed with Steve
Richardson, EPA, on July 27, 1988. Based on that discussion,
CF proposes that the date for submittal of the plan of study w-26
be set at eighteen months prior to the commencement of
operations at the Complex II mine. This lead time should
be ample for all necessary agency reviews and responses by
CF.
By tying the submittal date to the start of operations, CF
will avoid the unnecessary expenditures required to develop
a detailed plan of study before a firm schedule of operations
has been developed. Also, by deferring the submittal date,
the plan of study will be more timely as to potential changes
in water quality standards and/or sampling methodology relative
to the assessment of biological integrity.
In consideration of the above stated potential for changes
that could affect the plan of study design, CF proposes that
the first sentence of Part I.A.3 Outfalls 001, 002 and 003
be changed to read: "The Biological Integrity Standard,
Chapter 17-3.121(7), Florida Administrative Code, to the extent
applicable as amended from time to time, shall not be violated
by the facility's discharge of wastewater." This proposed
language change will provide for a more workable monitoring
requirement at the time proposed for submittal of the plan
of study if changes do occur in the standards and/or the
sampling methodology.
d. Part IV.A.2. Best Management Practices, Implementation.
The Best Management Practices plan is required under the draft
permit to be prepared six months after the effective date
of the permit and implemented no later than eighteen months
after the effective date of the permit. Due to the uncertainty
of the operating schedule for the Complex II mine, CF proposes
that the preparation of the plan be required eighteen months
prior to the commencement of operations ana that plan w~27
implementation be no later than eighteen months after the
plan is prepared or the commencement of operations, whichever
is earlier. This lead time should be ample for all necessary
agency reviews and responses by CF.
The development of a Best Management Practices plan before
a schedule of operations has been finalized does not seem
to be an efficient approach. By tying the plan development
to a start of operations date, the plan will address the final
design of the facility and any changes in the proposed operation
of the facility. This will avoid development of a plan that
may require modification before the engineering is complete
and the operations are commenced.
-------
FLORIDA GAME AND FRESH WATER FISH COMMISSION
C. TOM RAINEY, D.V J»L
Chairman, Miami
MRS. GILBERT W. HUMPHREY
Vice-chairman, Mirrrwikee
THOMAS L. HIRES, SR.
Lake Walea
WILUAM G. BOSTICK, JR.
WtaarHiwa
DON WRIGHT
Oriando
ROBERT M.BRANTLT.1
ALLAN L. EGBERT, PIUJ,,
FARRIS BRYANT BUILDING
620Sou* Meridian Sbm
Florida 32399-1600
(904) 48W9C0
August 18, 1988
Ms. Maryann Gerber
Project Manitor
Environmental Protection Agency
Region IV
345 Courtland street, N.E.
Atlanta, Georgia 30365
WWRWMEIUM. ASttSSEMMT BMHtfl
MaEJMZfn)
fiilkjliU \] &
EPA-P.EGI0N IV
A TLAj; i A,
BE: Draft Environmental Xnpact
Statement CF Mining corporation
Hardee Ehosphate Ocnplex U
Hardee County, Florida
Dear Ms. Gerber:
Ihe Office of Enviiamaental Services of the Florida Game and Fresh
Water Fish Caanissian (FSFWPC) has reviewed the referenced EnvircnmBntal
Inpact statement (EIS) and provides the following ocozaents.
Hie EIS addresses the CF Industries proposal to construct and
operate a phosphate mine en a 14,994-acre sits in northwest Hardee
Ccwrrty, Florida. J^Fprodnately 14,647 acres of land are proposed far
®ining during a 27-year period. Significant existing on-site habitats
occur cn about 91 percent of the area, including 6,957 acres of palmetto
prairie (46%), 733 acres of pine flatwoods (5t), 2,354 acres of upland
hardwood forest (16%), 2,340 acres of freshwater narsh (16%), and 1,240
acres of freshwater swamp (8%). Portions of tan drainage units within
the Peace River basin occur en-site. Significant drainage systons
include Brushy creek, Shirttail Branch, Plunder Branch, Doe Branch,
I*ttis Creek, Horse Creek, and Goon's Bay Branch.
Bie diverse on-site ecological systms provide habitats fbr a wide
variety of flora and fauna. Eight state-listed wildlife apeciee are
Known to occur cn the CF mine sits; these include the waodstade, Florida
sandhill crane, little blue heron, snowy egret, roseate spoonbill, tri-
oolcsed heron, gopher tortoise, and eastern indigo snake. Other state-
listed species likely utilize enrsite habitats. Seme 65 species of
-------
Ms. Maryann Gerber
August 18, 1988
Page 2
amphibians and reptiles, 138 species of birds, euid 36 species of mammals
inhabit or potentially occur within the principal wildlife habitats of
the CF site. At least three state-listed plant species evidently occur
anr-site in wetlands or palmetto prairies.
As described, proposed mining operations will eventually result in
the removal of about 27 percent of the upland forest lands, 5 percent of
the rangelands, end 5 percent of the wetlands of Hardee County. Many
small, shallow depressions, totalling 550 acres, will be mined and not
reclaimed. Ifcese wetlands are significant features of the sub-basins,
important in shallow aquifer recharge, and important in providing stream
baseflow. On-site stream systems are also heavily influenced by wetlands
occupying another 3,000 acres of the area. Plans include the
preservation of 69 acres of large main-stem stream wetlands associated
with Horse creek. However, an additional 695 acres of tributary and
special concern (Category I-C or I-D) wetlands, are proposed to be mined.
Mining and reclamation activities will produce new landfanns
consisting of 61 percent sand/clay mix, 15 percent sand tailings, 16
percent land and lakes, and 8 percent overburden fill. Ihese
are planned to be reclaimed to pasture (45%), forested upland (23%)
herbaceous wetland (17%), and forested wetland (9%).
According to the EXS, a u.hmh'1 reclamation plan will be
developed to" 1) restore natural drainage basins; 2) restore the natural
functions of lakes, streams, and wetlands; 3) reestablish cinmpa qj.
strips of upland natural habitat within other proposed uses; 4) monitor
the success of mine restoration on an annual buds to assure that post-
mining reclamation successfully meets the objectives of the state's^
permit requirements.M In addition to preservation of 69 acres of main-
stem stream wetlands of Horse Creek, EEA's preferred action involves the
preservation of tributary and flpetrlal concern wetlands until CF
demonstrates the successful restoration of function*! ,
conmunities and large wetland systems.
me EXS specific that "each sequential 80-acre tract of lam
scheduled for mining ehculd be surveyed prior to clearing operations
the capture and removal of gopher tortoise, indigo snakes and if
present, sandhill crane fledglings. Ihese animal species' should h*
relocated to other suitable habitat that would not be impactedbv m-in^
or that has been previously restored." As stated, "alll3ldlife
toct Jiariaa <*.
-------
Mis. Maryann Gerber
August 18, 1988
Page 3
* Ihe Impart of mine operations an local populations of certain
species will be severe. The existing site is an important
feeding and staging azea far wading birds. Of special r«npr!orY71
is the potential elimination of Florida Handbill crane nesting
sites. The degree to which this will occur cannot be
adequately determined from the existing information.
* The reestablishment of substantial wetland systems depends an
the ability to reclaim 25 to 30 percent of sand/clay mix sites
to wetlands. She long-term maintenance of hydric soil w~29
r!nffvH-HrtrH« over this extensive an area is questionable.
Lilcewise, the ability to reclaim wetlands an sand tailings
returned to grade without an underlying confining layer is
uncertain.
* There has been no adequate demonstration that the functional
values of forested wetlands car large scale, diverse marsh
systems can be created and maintained over time on mined land. w-3o
Furthermore, using current evaluation approaches, adequately
determining the success of forested wetland reclamation may
require 10-20 years after completion of mining and reclamation
within a specified drainage basin.
* lha removal of the phosphate matrix (averaging 24 feet thick
on-site), which serves as a confining layer below the surficial
aquifer, increases the connection between the surf icial and H_31
deeper aquifer. Where the deeper aquifer maintains a lower
potenticmetric surface, the reclaimed water table will
establish at lower levels than prior to mining. Ibis, coupled
with high evapctranspiration sates of open water bodies, often
results in a substantially lower water table in the vicinity of
large reclaimed land and laloe systems. Significant
mortifications of the hydrologic regime would threaten the
ecological integrity of nearby preserved wetland and riparian
systems.
* 3he physical properties of the surf icial aquifer will be
substantially altered by sancVday mix reclamation.
Groundwater ischaicye and base ¦eepwga to area streams will be
reduced.
* Hm potential downstream wetland effects include a levering of
water levels, increased sedimentation, lowered ground water w-33
tables, erosion, and lonyterm hytooperiod alterations.
* On propoeed primary discharge of mine-water is £eon the
recirculation system into Shirttail Branch and^ar Doe Branch.
An alternete surface water discharge location is also proposed
-------
Ms. Maryann Gerber
August 18, 1988
Page 4
W-34
W-35
for Payne Creek. Mine-water discharges are likely to degrade
the quality of these receiving waters and aquatic habitats.
Stream system habitats and organisms may be adversely affected
due to the high nutrient content of reclaimed soils and the
projected future land use (principally improved pasture).
Ihe proposal provides for the mining of nearly 7,000 acres of
palmetto prairies with reclamation replacement by improved
pasture. Pasture land provides little physical structure, has w-36
only a single layer of herbaceous vegetation, and lacks a high
diversity of wildlife, current plans will result in a
permanent loss of habitat for many wildlife species.
W-37
* Upland forests are unlikely to be restored to a native
condition on mined land using the proposed reclamation
techniques. Reclaimed forests typically maintain lower floral
and faunal diversities than native forests.
Because of the likely intensive and extensive impacts to and
wildlife resources associated with this project, we reccmmend against the
mining of this large, ecologically significant area of Hardee County.
However, we provide the following recommendations should mining be permitted.
We oppose the mining of Significant wetland and stream systems.
Specifically, we reccnmend wetland preservation of the Horse creek system up
to the 25-year floodplain. Moreover, we recommend deleting the prcposed W~38
mining tract to the west of Horse Creek to prevent title crossing of dragline
pipeline, and other facilities that would disturb Horse Creek. We further '
support the preservation and protection of all EEA Category I wetlands on-
site. other wetland systems should be conserved to the greatest degree
possible.
W-39
m ihi »imiHijd the application of DER wastewatar-to-wwtlarris standards
(F.A.C. 17-6.055) where mine-water discharge to wetlante occurs. Acolication
of these standards would help to ensure the protection of aquatic habitats «*i
animals during the 27 years of mining. Since the mine is an industrial ratw
than domestic waste source, we understand that this my reouire an n-u-unu.i
to F.A.C. 17-4*243(4) • Iter. iHm. i. fraittad,
headwater wetlands as ogosed to the proposed alternate downstream acouStion
through a ditch system to nazxcwnr floodplain segments of Payne crMk^^
Planned discharge to primary sites that are proposed far mining is
inappropriate. At least one wetland/tributary system primarily deeinr»f*rt ^
•riM-wtar dladiarg* tfmld tm (navnd W«diing.
extensive wetland systems throughout the mine is preferred.
5* tog to to ^
may be lessened through reclamation. Where wetland mining ^rrm
-------
Ms. Maryann Gerber
August 18, 1988
Page 5
suitable wetland topsoil should be used extensively in reclamation, such as in
wetlands established an reclaimed sand tailings and sand/clay areas
(including drainage channels), as wall as in littoral zones of reclaimed W_4Q
lakes. Furthermore, we recemnend against the reclamation of extensive land
and lake systems located near the Horse creek flocdplain, in order to maintain
drainage patterns and protect stream flew.
Ma further recsumtraxJ the use of tcpsoil in upland area reclamation (pre-
strip method) to lessen the impacts to resident upland wildlife populations. w-Al
This includes the use of palmetto prairie topsoil. Palmetto prairies maintain
many indigenous herb species and support a rich wildlife assemblage. Recent
upland topsoil use within the industry suggests this to be an effective
reclamation alternative. New investigations should be undertaken at Complex I
to resolve the applicability of palmetto prairie tcpsoil under
sand/clay mix conditions. Priority should be given to upland topsoil sites
located to buffer preserved and reclaimed streams/lakes and to link wildlife
habitats. Other tqaland areas should be enhanced with pine, hardwood, and
forage/cover plantings to establish potential multiple-use cpen woodlands.
Our wildlife relocation policy states, "the FGEVJPC does not generally
sanction or ccndcne, and typically discourages, relocation of wildlife,
especially as a perceived solution to land de^cpaant/conflicts.11 For this
reason, habitat related mitigation measures shculd be sought to protect the w-42
Florida sandhill crane, gopher tortoise, and eastern indigo snake in lieu of
relocation. The applicant shculd undertake a prugram to identify sandhill
crane nesting locations and iirportant gopher tortoise and indigo snake
habitats and preserve key habitats. _The restoration and long term protection
of suitable upland habitats may be considered to of feet the disturbance of
preserved sites. The relocation of gopher tortoises, most likely to suitable
reclaimed upland habitats, may be permitted under existing Gcanissicn
guidelines, m ¦>¦»» ¦¦¦¦¦¦ the protection of Hwt-eri plant species through on-
site preservation and post-reclamation reestablishmerxt.
Sincerely,
BJH/Jap/je
ENV 4-1-3
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PUBLIC PARTICIPATION
3.2 Responses
-------
Revised 8/2/89
3.2 RESPONSES TO WRITTEN COMMENTS
See Section 3.0 for original letters and complete comment language.
FDACS
W-l "cypress should be considered as a suitable [reclamation] species"
Cypress trees, as well as other native species, will be used for
revegetation of reclaimed mining areas where soil and ground water
conditions are suitable for each type of vegetation. Cypress
trees will be planted primarily in freshwater swamp areas which
will comprise approximately 1,410 reclaimed acres of which more
than 1,195 will have been disturbed during mining.
W-2 "efforts be made to salvage all merchantable timber during Initial
land clearing efforts."
All merchantable timber cut during land clearing operations will
be salvaged by subcontractors when they are available and when
conditions make salvage economically feasible for the
subcontractor.
FDOS
W-3 "CF Industries [Mining Corp.] should retain a professional
archeologlst to perform salvage excavation on the regionally
significant sites ... prior to raining ..."
CF Mining Corporation employed a professional archeologlst to
evaluate the proposed raining site. Six regionally significant
archeologlcal sites were located and defined on the mining site.
The archeologlst found no artifacts of significance in the 1976
site evaluation and was not required to complete a phase two
boundary delineation. The development approval for the mining
site requires that 1f any regionally significant artifacts are
uncovered during mining operations, the property owner will notify
the State Historical Preservation Officer. In addition, mining
activities 1n the Immediate area of the uncovered regionally
significant artifacts will cease.
Dr. Smith
W-4 "proposed mine directly threatens the fresh drinking water
resources of the lower Peace River system..."
The proposed EPA NPOES permit and the FOER permits are designed
to ensure that surface water discharges do not significantly
impact the watercourses and water resources of Hardee and
surrounding counties. The surface water system required for
3.2-1
-------
approval of surface water quality and quantity permits 1s designed
to assure acceptable water quality off site. The surface water
system provides for recirculation and recycling of the majority
of water stored in the system so that treated process water will
normally be discharged off site only during wet season rain
events. The proposed NPDES permit will require compliance with
state water quality standards 1n the receiving waters. Section
2.6.3 of the Environmental Impact Statement provides a detailed
description of the wastewater discharge system and its
environmental protection features.
W-5 "government authorization of private use of sovereign land ...
Payne Creek, Horse Creek and the Peace River system ... [1s
prohibited by Florida Constitution, Article 10, Section 11] 1f
such use is contrary to the public Interest." (Emphasis 1n
original)
Article X, Section 11 of the Florida Constitution concerns title
to sovereignty lands and private uses of such lands. The section
states that "The title to lands under navigable waters, within the
boundaries of the state, which have not been alienated, including
beaches below mean high water lines, is held by the state, by
virtue of its sovereignty, in trust for all the people. Sale of
such lands may be authorized by law, but only when 1n the public
interest." "Private use of portions of such lands may be
authorized by law, but only when not contrary to the public
interest." Such private uses may be authorized by administrative
agencies such as FDER, operating within statutory authority.
Legislative policy for surface water permitting 1s that water
quality be protected by providing "that no wastes be discharged
into any waters of the state without first being given the degree
of treatment necessary to protect the beneficial uses of such
water." Section 403.021(2) F.S. Wastewater discharge permits
Issued by technically qualified administrative agencies such as
FOER 1s the method selected by the Florida Legislature to assure
that discharges to public watercourses are "not contrary to the
public Interest."
W-6 "many endangered animals of the region whose extinction will be
rapidly hastened by the mining...11
The mine site does not contain any known, regionally important
breeding areas, dens, nests, or rookeries of endangered species.
The existing wildlife habitat on the mine site may contain
potential breeding and feeding areas and/or provide travel
corridors for endangered species and these capacities can be
maintained 1n large portions of the site through the proposed
mining/reclamation methods.
EPA has performed all consultation procedures with other
governmental agencies 1n accordance with the requirements of
3.2-2
-------
Section 7 of the Federal Endangered Species Act of 1973, as
amended. A biological assessment of proposed construction and
operation activities was provided to F1sh and Wildlife Service
(FWS). This assessment included Impacts on threatened and
endangered species and proposed efforts to eliminate, reduce or
mitigate any adverse effects. FWS commented that the assessment
"adequately addresses endangered species concerns." Endangered
species on the CF site are the wood stork and the eastern 1nd1go
snake. FWS found that "this project 1s not likely to jeopardize
the continued existence of the wood stork or Indigo snake," but
recommends a relocation program for the Indigo snake. The FWS
also stated that "Based on our review of the reclamation plan,
suitable feeding habitat will be created and available for wood
stork feeding."
CF Mining will adhere to approved guidelines of state and federal
agencies regarding protection of nesting sites encountered during
mining. The National Environmental Policy Act conditions forthe
proposed NPDES permit Includes condition C-7 requiring
Implementation of a program approved by US FWS and FGFWFC to
reduce Impact on the 1nd1go snake. Every attempt will be made
during the restoration process to duplicate the habitat conditions
after the area has been mined so that the utility of particular
areas of habitat for each species can be prolonged Indefinitely.
Through a combination of maintaining and restoring a variety of
wildlife habitats throughout the active mining of the land (see
Page 5-4 of the draft EIS for a description of habitat types), the
proposed action only constitutes a temporary disruption of the
existing wildlife habitats and species associated with the mine
site.
The wetlands that are being created 1n the phosphate mining
district Include both herbaceous and forested systems. The
projects are all designed to meet the requirements of the Florida
Department of Natural Resources (ONR) and most were designed to
meet permit requirements of the Florida Department of
Environmental Regulation (DER).
In order to be deemed a successful project by the DNR, the project
must meet the success criteria detailed 1n the DNR's Mandatory
Phosphate Mine Reclamation Rules, Chapter 16C-16 FAC. These
Include considerations of tree density, ground coverage, water
quality, drainage patterns and aquatic and wetland wildlife
habitat.
The DER establishes success criteria 1n each of the permits Issued
for wetland reclamation projects. Currently, the success criteria
assigned to permits include:
A. An average of at least 400 trees per acre shall be growing
above the herbaceous stratum;
3.2-3
-------
B. The tree cover shall exceed 33 percent of the total area;
C. At least 80 percent of the understory veqetation shall be
wetland species as listed by DER. Cattail, primrose willow
and exotics shiil oe limited Lo ten percent or less ot the
total cover; and
D. The restoration area shall have a similarity of 0.6 (using
Morisita's index), and 75 percent of the species richness
of a control area or premining area.
W-7 "Florida laws prohibit the capturing or disturbing the habitat of
most of these animals."
Adequate protection for the habitat of protected species of
wildlife is defined by state and federal statutes which authorize
regulatory agencies to require permits or to comment on permit
applications for development. The mining plan is specifically
designed to minimize impact on wildlife habitat of protected
species.
The Wildlife Code of the State of Florida, Chapter 39, Florida
Administrative Code, lists specific prohibitions applicable to all
wildlife, including regulations on hunting, molesting, capturing,
selling, transporting, and taking of nests or eggs. The Florida
Endangered and Threatened Species Act of 1977, Section 372.072,
Florida Statutes, provides recommendations for the management of
protected species, but lists no specific prohibitions regarding
endangered species. The Florida Panther Protection Act, Section
372.671, Florida Statutes, prohibits the killing of the Florida
panther, but does not set aside panther habitat in Florida.
None of the above-referenced State of Florida laws establish
regulations against habitat alteration, rather, these laws deal
with direct physical impacts to protected species. CF will strive
to avoid harm to protected species encountered during mining of
the property. An approved program will provide for reduction of
mining impacts on the indigo snake. The unavoidable, temporary
impacts to wildlife habitat will be mitigated to the fullest
extent possible after mining of each area is completed. Current
Florida laws governing wildlife protection do not specifically
require the preservation of endangered species habitat. Since the
long-term plans for the property are complete restoration, mining
will not cause the permanent removal of wildlife habitat.
Therefore, the proposed mine/reclamation plan 1s consistent with
Florida laws prohibiting the capturing or harassment of endangered
animals. The conceptual mining plan is approved by the Florida
Department of Natural Resources with comments made by the Florida
Game and Fresh Water Fish Commission.
3.2-4
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EPA has performed all consultation procedures with other
governmental agencies in accordance with the requirements of
Section 7 of the Federal Endangered Species Act of 1973, as
amended. A biological assessment of proposed construction and
operation activities was provided to Fish and Wildlife Service
(FWS). This assessment included impacts on threatened and
endangered species and proposed efforts to eliminate, reduce or
mitigate any adverse effects. FWS commented that the assessment
"adequately addresses endangered species concerns." Endangered
species on the CF site are the wood stork and the eastern indigo
snake. FWS found that "this project is not likely to jeopardize
the continued existence of the wood stork or indigo snake," but
recommends a relocation program for the indigo snake.
Award of federal and state permits signifies a finding of adequate
habitat protection as measured by federal and state law
requirements. Habitat impact following reclamation will be much
less than that which would typically result from other types of
development.
W-8 "residents who Inhabit northern Hardee County and southern Polk
County ... lives will be ruined for all future time because of:
(a) the creation of another vast cone of depression of the water
table 1n the area.*
A cone of depression results when pumping water from an aquifer.
The cone ceases to exist within a relatively short time after
pumping stops. Wells will be used only for process makeup water
because the majority of water is supplied by recycling of water
in the system.
A consumptive use permit has been approved by the Southwest
Florida Water Management District (SWFWMD). A primary criterion
of the permit is that proposed withdrawal not Interfere with
existing legal uses of water and is consistent with the public
interest (see Section 373.223 FS). The effect of drawdown within
the well on surrounding water uses is evaluated in the permitting
process.
W-9 "(b) drawdown of the water system of Payne Creek, Horse Creek,
and the Peace River system generally."
No withdrawal of surface water is proposed for mining. Process
water will be supplied primarily by recycled water in the system
and makeup water from the aquifer. The effect of ground water
withdrawal on other legal uses of water including instream uses
is evaluated 1n the SWFVIMD consumptive use permitting process.
The effects of withdrawals from the aquifer will be localized on
the site (see Section 373.233 FS, and EIS Section 2.6.2.1).
3.2-5
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W-10 "[drawdown] of wells and Irrigation wells over a wide adjoining
area;"
Withdrawal of groundwater from wells 1s not continuous under the
proposed mining plan. Groundwater will be withdrawn only as
required to make up recycled process water. Only when pumping of
wells for mining purposes begins will a cone of depression be
created around each well. A criterion of the Southwest Florida
Water Management District consumptive use permit 1s that the cone
of depression be limited so that mining withdrawals do not
significantly and adversely affect existing wells off site. The
volume of withdrawals needed for mining has been significantly
reduced because of the recirculation of process water.
W-ll "(c) contamination and pollution of wells, the aquifer..."
The surface water system 1s designed to protect ground water
through extensive reuse of process water and treatment of process
water prior to discharge, normally only 1n wet weather conditions,
to surface waters off site. Section 3.4.2.1 of the EIS discusses
the effects of mining on the ground water system.
No direct discharge to ground water will occur so that occasional
discharge of treated water will reach ground water only after
percolation through soils which provides further water quality
treatment.
W-12 "[contamination and pollution of] Payne Creek, Horse Creek, and
the Peace River system south of Polk County;"
The proposed EPA NPDES permit and the FDER permits are designed
to ensure that surface water discharges do not significantly
impact the watercourses and water resources of Hardee and
surrounding counties. The surface water system required for
approval of surface water quality and quantity permits 1s designed
to assure acceptable water quality 1n waters of the state and U.S.
The surface water system provides for recirculation and recycling
of the majority of water stored 1n the system so that treated
process water will normally be discharged off site only during wet
season rain events. The proposed NPDES Permit will require
compliance with state water quality standards in the receiving
waters. Section 2.6.3 of the Environmental Impact Statement
provides a detailed description of the wastewater discharge system
and Its environmental protection features.
Surface water runoff characteristics from lands reclaimed under
Florida Department of Natural Resources reclamation procedures 1s
expected to be similar to premlnlng characteristics. Land
contours and elevations will be similar to premlnlng conditions.
A requirement for Florida surface water permits 1s that
postdevelopment surface water flows be similar to predevelopment
runoff characteristics.
3.2-6
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W-13 "(d) Increase In radon contamination of southern Polk County and
Northern Hardee County..."
There is no Indication that mining operations will result in the
increase of Radium 226 levels 1n the drinking water. Long-term
monitoring of the surfidal and Florldan aquifers at the existing
CF Mining Corporation's Hardee Phosphate Complex I site reveals
little change 1n Radium 226 concentrations following mining
operations.
The data in the attached table compares the Radium 226 levels for
two wells, PU-A and PW-B, located at the existing mine with the
results of the background sampling conducted as a part of the EIS
monitoring program for the Florldan Aquifer wells, LF-4, LF-5, and
LF-6. The data Indicates that mining operations did not result
in an Increase 1n the level of Radium 226 1n the drinking water
at the Complex I site.
The likelihood of radon contamination of the air 1s primarily
related to procedures used 1n mined land reclamation. During
mining, the overburden containing phosphate traces and associated
radioactive materials are placed at the bottom of the disposal
area 1n a procedure called "toe spoiling." This process will
result 1n the covering of these materials with a thick cap of
overburden during the reclamation process and thereby
significantly restricting the release of radon gas to the
atmosphere.
The slight Increase 1n radon gas emanation that may be recorded
following the reclamation process does not present a substantial
health hazard to the general public. The gas will be quickly
dissipated in the air and concentrations will not build up to
harmful levels. Additionally, the mine site 1s in a rural
location and, with the long-range plans by the county to protect
the rural agricultural base of the area, significant population
Increases 1n the area do not appear likely.
A 1978 study by Florida Department of Health and Rehabilitative
Services found a higher percentage of homes with radon problems
located on unmlned phosphate lands than on reclaimed lands.
Additional studies since 1978 have had Inconclusive results. The
reclamation plan for the future use of CF Mining Corporation lands
is primarily for improved pasture and undeveloped uses and does
not Include residential uses of the property. Any buildings
constructed on reclaimed lands will be subject to state radon gas
regulations 1n Chapter 10D-4 FAC. Chapter 10D-4 provides
construction and testing procedures required to assure safe levels
of radon gas.
3.2-7
-------
W 13
Radium 226 Data for Groundwater at CIMC's Hardee Phosphate Complexes I and II
Complex II Background Wells
Radium-226, pCi/1
Well No. 5/76 10/76 4/77 10/77 4/78 10/78 4/79 4/80 9/81
Floridan Aquifer
LF-4 5.86 6.49 6.38 6.23 6.19 6.08 3.43 2.89 8.00
LF-5 1.59 2.08 1.82 1.97 2.15 1.67 1.04 1.51 *
LF-6 1.56 1.68 1.97 1.38 1.65 1.19 0.58 1.06 *
Complex I Production Wells
Radium-226, pCi/1
Well No. /79 /80 /81 /82 10/83 10/84 4/85 11/85 2/86 2/87 -i/t8
Floridan Aquifer
PW-A 1.02 1.16 .93 * * * * * 0.9 0.7 1.6
PW-B * 1.52 * 3.0 2.2 1.2 0.8 1.0 0.7 0.9 1.5
*Not measured. Not all wells were sampled each year. The wells were only 100 feet apart and drawing from
the same zone.
Note: For comparison of pre- and post-mining data, the mining operations at the Complex I
mine began in October 1978.
Sources: CF Data, 1976-1988.
ESE, 1982.
-------
W-14 "mined hardwood wetlands cannot be reclaimed successfully after
mining..."
The vast majority of forested wetland reclamation projects in
Florida are being carried cut by phosphate mining companies
(Robertson, 158tt;. Most of these projects have been undertaken
in the last decade and do not yet support a tree canopy. However,
live tree density and trends in tree growth are promising on many
projects that have been monitored, such as the stream reclamation
projects being conducted by Mobil Mining and Minerals Company
(Gurr and Associates, Inc., 1988). While wetland trees such as
cypress show promising growth in reclamation projects, there is
no substantiation that hydric forests or borderland hardwood
forests can be restored to the structural and functional
equivalent of the wetlands that have been eliminated.
Many large wetland reclamation projects have been undertaken by
the phosphate industry and several have received commendation from
environmental organizations and agencies. International Minerals
and Chemical Corporation received the 1987 Environmental
Achievement Award from the National Wildlife Federation's
Corporate Conservation Council for the 500-acre Peace River
Floodplain Project and also received the 1985 Conservation Service
Award from the U.S. Department of the Interior for the 55-acre
Parcel B Project (Germond, 1989). Agrlco Mining Company received
the Environmental Achievement Award from the National Wildlife
Federation's Corporate Conservation Council in 1985 for the 158-
acre Morrow Swamp reclamation project (Holloway, 1989). The
projects cited included a total of 172 acres of reclaimed forested
wetlands with a variety of hardwood wetland species. These awards
indicate real progress in the ability to reclaim integrated
wetland systems by the phosphate industry.
W-15 "no wetlands region of any size has been reconstituted as a viable
water body."
Many functioning wetlands, primarily herbaceous, in Florida have
been created, recreated, restored, or enhanced in recent years.
Since FDER and the water management districts have been required
to keep records of wetlands lost and gained (by the Henderson
Wetlands Act of 1984), there has been little net loss of state
regulated wetlands as a result of regulated development. Many of
these wetlands are currently in the process of reclamation, but
are under regulatory agency-approved plans, which are based on
successful reclamation demonstrations. Much of this work has been
developed by phosphate mining reclamation research.
Many large wetland reclamation projects have been undertaken by
the phosphate Industry and several have received commendation from
environmental organizations and agencies. International Minerals
and Chemical Corporation received the 1987 Environmental
Achievement Award from the National Wildlife Federation's
3.2-9
-------
Comorate Conservation Council for the 500-acre Peace River
Floodplain Project and also received the 1985 Conservation Service
Award from the U.S. Department of the Interior for the 55-acre
Parcel B Project (Germond, 1989). Agrico Mining Company received
the Environmental Achievement Award from the National W-. lal ife
Federation's Corporate Conservation Council in 1985 for the 158-
acre Morrow Swamp reclamation project (Holloway, 1989). These
awards indicate real progress in the ability to reclaim wetlands
by the phosphate industry.
W-16 "EFA...intention to issue permits for the northern Hardee County
area [is a] threat to the major wetlands of the area..."
EPA has recommended that no Category I wetlands be mined and CF
Mining Corporation has agreed to preserve Category I-A wetlands.
Mining will not be scheduled in Category I-C and I-D wetlands
until such time as reclamation technology has progressed to the
extent that fully functional wetlands can be restored. At such
future time, EPA may reevaluate the I-C and I-D wetlands and
remove some or all restrictions on mining these areas (see
attached Tables W-16A and W-16B).
The CF Mining Corporation reclamation plan requires equal
replacement of wetlands that are mined. Upon completion of
reclamation of mined lands, there will be no resulting loss of
wetlands areas or functions.
CF Mining Corporation has agreed to not schedule mining in any EPA
Category I wetlands, including hardwood wetlands, until EPA
reconsiders, based upon proven recreation of functional hardwood
communities, its present Category I designations.
W-17 "demand — that all concerned public-interest groups allied with
or affected by private use of the Peace River system ... be
notified in a timely way of the forthcoming hearing."
All required EPA hearings on the NPDES permit application of CF
Mining Corporation have been noticed as required by law. This
included extensive mailout of individual notices to known
interested persons and those requesting notice. This included
both media and Individual notices designed to insure that all
interested parties and persons were aware of the permitting
process. EPA Region IV maintains in its records the mailing lists
used for required hearings.
3.2-10
-------
Table W-16A. Acreage to be Disturbed and Preserved—No Mining of Category
I Wetlands
Description Acres
Areas to be Disturbed
Mining Operations 13,952
Plant Site 60
Set Backs from Roads and Property Line* 218
Subtotal 14,230
Areas to be Preserved**
Category I-A Wetlands Contiguous with Horse 69
Creek
Category I-C Wetlands 121
Category I-D Wetlands £74
Subtotal 764
AREA OF MINE SITE TOTAL 14,994
*The set backs may be disturbed by access roads, utility corridors, temporary
storage of overburden, perimeter ditching and related mining activities.
**Th1s acreage does not include strips around preserved wetlands or oddly
shaped areas that may not be accessible with the dragline. Two acres of
Category I-A wetlands will be disturbed by a dragline crossing.
Sources: CF Industries, 1984.
Hunter Services, Inc., 1989.
3.2-11
-------
Table U-16B. Existing and Post-Reclamation Land Use--No Mining of Category I Wetlands
Land Use Existing Proposed Disturbance Post-Reclamation
Code*
Type
Acres
Percent
Acres
Percent
Acres
Percent
211
Row Crops
13.1
0.09
13.1
0.09
212
Field Crops
44.1
0.29
44.1
0.31
--
213
Improved Pasture
1,310.3
8.74
1,310.3
9.21
6,659.0
44.41
231
Orange Grove
2.6
0.02
2.6
0.02
--
--
321
Palmetto Prairie
6,957.2
46.40
6,957.2
48.90
--
411
Pine Flatwoods
732.7
4.89
732.7
5.15
1,500.0
10.00
422
Other Hardwoods
2,354.0
15.70
2,354.0
16.54
1,900.0
12.67
520
Lakes
--
--
--
--
1,055.0
7.04
621
Freshwater Swamp
1,240.4
8.27
742.3
5.22
1,410.0
9.40
641
Freshwater Harsh
2.339.6
15.60
2.071.7
14.56
2.470.0
16.47
TOTAL
14,994.0
100.00
14,228.0
100.00
14,994.0
99.99
~Based on Florida Land Use and Cover Classification System (Florida Department of Administration. 1376).
Source: CF Industries, 1984.
Hunter Services, Inc., 1989.
-------
Mr. Morrison
W-18 "discharge of excess mining water Into three tributaries of
Payne's Creek ... night be 1n violation of the Florida
Constitution."
Article X, Section 11 of the Florida Constitution concerns title
to sovereignty lands and private uses of such lands. The section
states that "The title to lands under navigable waters, within the
boundaries of the state, which have not been alienated, Including
beaches below mean high water lines, 1s held by the state, by
virtue of Its sovereignty, 1n trust for all the people. Sale of
such lands may be authorized by law, but only when In the public
Interest." "Private use of portions of such lands may be
authorized by law, but only when not contrary to the public
Interest." Such private uses may be authorized by administrative
agencies such as FDER, operating within statutory authority.
Legislative policy for surface water permitting 1s that water
quality be protected by providing "that no wastes be discharged
Into any waters of the state without first being given the degree
of treatment necessary to protect the beneficial uses of such
water." See Section 403.021(2) FS. Wastewater discharge permits
Issued by technically qualified administrative agencies such as
FDER 1s the method selected by the Florida Legislature to assure
that discharges to public watercourses are "not contrary to the
public Interest."
The proposed EPA NPDES permit and the FDER permits are designed
to ensure that surface water discharges do not unacceptably Impact
the watercourses and water resources of Hardee and surrounding
counties. The surface water system required for approval of
surface water quality and quantity permits 1s designed to assure
acceptable water quality off site.
The surface water system provides for recirculation and recycling
of the majority of water stored 1n the system so that treated
process water will normally be discharged off site only during wet
season rain events. The proposed NPDES permit will require
compliance with state water quality standards 1n the receiving
waters. Section 2.6.3 of the Environmental Impact Statement
provides a detailed description of the wastewater discharge system
and Its environmental protection features.
Surface water runoff characteristics from lands reclaimed under
Florida Department of Natural Resources reclamation procedures Is
expected to be similar to premlnlng characteristics. Land
contours and elevations will be similar to premlnlng conditions.
A requirement for surface water permits is that postdevelopment
surface water flows be similar to predevelopment runoff
characteristics.
3.2-13
-------
19 "Most of the wildlife evacuees from the CF Mining Corp. site will
die because most of the ecological niches which they will attempt
to Inhabit are already occupied by others of their species."
Since the property will be mined on a phased schedule within
relatively small tracts of land (80 acres), some species displaced
by mining will be able to move Into adjacent habitats abundant
within the region. These habitats should be able to maintain some
number of the individual animals that emigrate from mined areas.
The breeding populations of species existing on site will be
lowered throughout the mining period. As mining progresses, old
mining tracts will continuously be restored, so that they may
absorb some wildlife displaced 1n nearby mining tracts.
Eventually, after the entire property is mined, the whole area
will be slowly recolonized by plant and animal species.
EPA has performed all consultation procedures with other
governmental agencies 1n accordance with the requirements of
Section 7 of the Federal Endangered Species Act of 1973, as
amended. A biological assessment of proposed construction and
operation activities was provided to Fish and Wildlife Service
(FWS). This assessment included Impacts on threatened and
endangered species and proposed efforts to eliminate, reduce or
mitigate any adverse effects. FWS commented that the assessment
"adequately addresses endangered species concerns." Endangered
species on the CF site are the wood stork and the eastern indigo
snake. FWS found that "this project 1s not likely to jeopardize
the continued existence of the wood stork or indigo snake," but
recommends a relocation program for the Indigo snake.
20
¦mitigation results 1n a net loss of habitat and hence of
population."
Reclamation of the mine site will not result in a net loss of
habitat, but will rather promote the establishment of different
habitat types and areas of specific habitat compared with the
premlnlng condition. The mining plan is designed to maintain a
^ Table"3 ifn',,!' A11 durln9 Uning and
use/cover fol 1 ow^ng mwl™ ex,St1"9 and proposed 1and
J*?" J °f„ ha"ta* Vp«,w"l be established or replaced
m^Sfnrrt H^Vln.'t0rf h.hft,» l^ i'a,'Sny of "Midlife Will b«
maintained. Hltlgated habitats will be ecologlcallv sound in that
the reclamation plan will provide for the needs of X spec 1«!
ranges, an of which need large areas with diverse habitats to
provide their feeding, breeding, and cover necessities Of
wild! Ife w1 ll^take th,«\VSited W*?to sipport
successionIcciim on th« SIch 1ts Premining levels. As
SSiHe Pr«Pt'o?eS'. ** e,rry1°9 C,pic1ty
3.2-14
-------
In particular, the creation of lakes on the property should prove
to be a valuable Improvement to the site. Lakes will be naturally
populated with native fish and planted with native vegetation 1n
order to support aquatic birds and reptiles.
Fayt? ppfrfr?
Vf-21 [How will] sufficient buffers [be] established to protect the
wetlands from dewaterlng [?]¦
The water levels In wetlands and sensitive off-site unmlned areas
are designed to be protected by use of perimeter ditches 1n which
the water level will be maintained at or above the average water
table elevation, which will prevent potential drawdown of the
water table within the wetland. The perimeter ditch will be
located within a 35-foot minimum distance between the protected
wetlands and mining activity. No ditch will be dug deeper than
any clay aquaclude existing at that location. The draft NPDES
permit proposed for CF Mining Corporation requires, as part of
permit condition C-12, that "CF shall preserve all Category I
wetlands on site from mining activities. CF must monitor the
effectiveness of design controls to minimize any adverse effects
of adjacent mining operations, mine on only one side at a time,
and assure EPA that sufficient buffers are established to protect
the wetlands from dewaterlng."
Mining activities which have the potential to affect confining
layers supporting protected wetlands will be conducted 1n such a
way as to minimize lowering of water table elevations. The
perimeter ditch will function to prevent the water table 1n the
protected wetlands from being artificially lowered by mining
activities.
W-22 "The contamination of drinking water with Radium 226 should be
decreased and not increased."
There Is no Indication that mining operations will result 1n the
Increase of Radium 226 levels 1n the drinking water. Long-term
monitoring of the surflclal and Florldan aquifers at the existing
CF Mining Corporation's Hardee Phosphate Complex I site reveals
little change In Radium 226 concentrations following mining
operations.
The data 1n the table following Page 6 compares the Radium 226
levels for two wells, PW-A and PW-B, located at the existing mine
with the results of the background sampling conducted as part of
the EIS monitoring program for the Florldan Aquifer wells, LF-4,
LF-5 and LF-6. The data Indicates that mining operations did not
result In an Increase In the level of Radium 226 1n the drinking
water at the Complex I site.
3.2-15
-------
Table 3.7.2-1. Existing and Post-Reclamation Land Use
Land
Use
fcxistina
Proposed
Disturbance
Post-
Reclamation
CoOc'
Type
Acres
7o
Acres
%
Acres
%
211
Row Crops
13.1
0.09
13.1
0.09
212
Field Crops
44.1
0.29
44.1
0.30
213
Improved
Pasture
1,310.3
8.74
1,310.3
8.78
6,659
44.41
231
Orange Grove
2.6
0.02
2.6
0.02
--
321
Palmetto
Prairie
6,957.2
46.40
6,957.2
46.61
--
411
Pine
F1atwoods
732.7
4.89
732.7
4.91
1,500
10.00
422
Other
Hardwoods
2,354.8
15.70
2,354.8
15.78
1,900
12.67
520
Lakes
--
1,055
7.04
621
Freshwater
Swamp
1,239.9
8.27
1,194.8
8.00
1,410
9.40
641
Freshwater
Marsh
2.339.3
15-§0
2,315-4
15,51
2,470
16.47
TOTAL
14,994.0
100.00
14,925.0
100.00
14,994
99.99
*Based on Florida Land Use and Cover Classification System, 1976.
Source: CF Industries, 1984.
3.2-16
-------
In 1977, the EPA investigated radiation levels 1n groundwater due
to radium in mineralized areas that were both unmlned and mined
1n the seven-county phosphate mining district. Study findings
Indicated that a detrimental effect by phosphate mining on Radium
226 1n the upper Florldan aquifer 1s not documented. Also, Radium
226 concentrations were not significantly different in
nonmlnerallzed and mineralized unmlned and mined areas (Texas
Instruments for USEPA, 1978).
The Florida Phosphate Council conducted a detailed comprehensive
study of the groundwater and mine surface water to assess.the
potential for water quality impacts of phosphate operations to the
groundwater. The study, conducted 1n 1982-1983, was done in
cooperation with the Florida DER. Twenty mine sites were Included
in the study. The sampling and analyses were performed by outside
contractors in accordance with the Water Data Acquisition Program
agreed on by the OER. The results of the study were used by the
FDER in assessing the level of groundwater monitoring that would
be required for the Individual mines under the requirements of
Chapters 17-3 and 17-4, FAC.
Based on this study, the FDER ruled out radiological contamination
of groundwater by mine wastes and reclaimed lakes as an area of
groundwater concern.
W-23 [How will] fish 1n the Peace River...alligators...tortoises
...Indigo snake [habitat be protected?]"
Surface water flow off site from the mined areas of the property
will only occur 1n wet weather situations and water quality will
be periodically monitored to demonstrate compliance with NPDES
permit conditions. This monitoring program will ensure that fish
and wildlife located 1n downstream reaches of the Peace River are
not affected by mining operations.
At one time, heavy poaching for hides and destruction of wetland
habitat threatened the existence of the American alligator.
Therefore, the alligator was federally classified as an endangered
species. Through this protective status, the alligator made a
remarkable recovery 1n the State of Florida. This large reptile
1s now fairly common throughout Florida and has been declassified
to threatened due to Its s1m11ar1ty-of-appearance status to the
crocodile. The current status of the alligator Is mandated to
help ensure the protection of the endangered American crocodile.
The appearances of the alligator and crocodile are so similar that
listing of the alligator Is maintained to avoid accidental deaths
to crocodiles that might result from their physical similarity to
alligators. Other state laws protect alligators from molestation
or poaching, however a permit can be obtained to destroy nuisance
alligators or to hunt alligators for their meat and hides (Feeding
and Enticement of Alligators or Crocodiles Act, Section 372.667,
FS, Poaching of Alligators Act, Section 372.663, FS).
3.2-17
-------
The American alligator is judged to be common within the wetland
and aquatic habitats on and downstream from the CF mine site. If
EPA removes some or all of the restrictions on mining of Category
IC and ID wetlands, the proposed mine plan will eliminate 98.1
percent (3,511 acres) of existing or potential alligator habitat
during the planned mine life of 27 years. Although some
individual alligators may be eliminated, most will disperse and
relocate to adjacent habitat during premining clearing operations.
The reclamation plan, which provides for the creation of 1,055
acres of lakes, 1,364.9 acres of freshwater swamp, and 2,446.1
acres of freshwater marsh, will Increase alligator habitat on the
property by 38.6 percent (1*355 acres) over a 35-year period. In
addition, alligators readily colonize reclaimed phosphate pits
(lakes) and, therefore, the proposed system of restored/created
wetlands/lakes should provide ample habitat for the future re-
establishment of these adaptive, resilient reptiles.
The proposed mining operations will eliminate much of the natural
gopher tortoise and 1nd1go snake habitat on the CF Mine site.
Recreated pine flatwoods habitat may support future populations
of gopher tortoises. The 1nd1go snake utilizes a variety of
upland and wetland habitats and may persist throughout the site
following reclamation. NPDES permit condition C-7 requires CF
Mining to Implement an approved program to reduce mining Impacts
on the indigo snake. Reclaimed mine land and/or other potential
natural habitat areas designated as conservation/preservation
lands will be utilized as the relocation sites for any threatened
reptiles.
r.F Mining Corp. Comments on Draft NPDES permit:
W-24 "Fluoride should be removed from the list of parameters required
for [effluent] monitoring."
EPA does not Impose monitoring requirements for fluoride for any
discharge locations for which long-term discharge data is
submitted to the EPA in support of the removal of fluoride from
the list of parameters required for monitoring. The EPA can
identify which discharge permits within the phosphate mining
industry require monitoring for fluoride based on discharge
monitoring records. The monitoring data submitted by CF Mining
from the Hardee Complex I mine clearly indicate that the proposed
discharges from the Complex II mine will not cause violations of
Florida's fluoride standard 1n the receiving waters. Therefore,
EPA finds that effluent monitoring for fluoride 1s unnecessary to
ensure compliance with the state standard and agrees to delete the
fluoride permit limits and monitoring requirements
3.2-18
-------
Vi-25 "CF requests Inclusion of monitoring for gross alpha particle
activity and combined radium 226 and 228 under the monitoring
relief provided by this Note. [Part I.A. Notes:C.]'
EPA has eliminated gross alpha particle activity and Radium 226
and 228 from the 11st of parameters required for monitoring of
mine discharge permits in cases where long-term discharge data
were provided to support this position. CF has requested that
provision be made 1n the permit for relief from monitoring
requirements based upon their demonstration that phosphate
operations do not discharge waters that have the potential to
result 1n water quality violations for the stated parameters.
EPA finds the Information submitted by CF Mining 1s adequate to
support this request and agrees to make the requested permit
changes.
W-26 "CF proposes that the date for submittal of the plan of study be
set at eighteen months prior to the commencement of operations at
the Complex II mine [Part I.A.3.]"
EPA agrees that this request is reasonable and will revise the
permit accordingly.
W-27 "preparation of the [Best Management Practices] plan be required
eighteen months prior to commencement of operations and that plan
Implementation be no later than eighteen months after the plan 1s
prepared or the commencement of operations, whichever 1s earlier."
[Part 1V.A.2.]
fgfwfc
W-28
EPA agrees that this request 1s reasonable and will revise the
permit accordingly.
"The 1moact of mine operations on local populations of certain
soecles will be severe ... feeding and staging areas for wading
birds ... elimination of Florida sandhill crane nesting sites."
Cateaory IC and ID wetlands will not be scheduled for mining
unless EPA agrees that reclamation technology has proceeded to the
pytent that fully functional wetlands can be restored. Therefore,
wadino bird habitat 1n these wetlands may be left undisturbed and
mav continue to provide some feeding and nesting requirements of
these soecles. Aquat 1 c and wetland habitats will remain available
on the property throughout all mining stages. Category II
wetlands will be subject to mining, and as such will lose their
abiiitv to support wading birds while mining occurs. However,
thi« wetlands will be restored to augment aquatic and wetland
habitats on site. The site mitigation plan Includes Increases In
tntai acreaae of marshes and swamps, and also Includes the
Monitoring of th«. cr«ted wetlands .long
Slthnatural repopulatlon of native fish and vegetation should
3.2-19
-------
encourage use by sandhill cranes and various species of herons,
egrets, and other wading birds. Marshes can be restored
relatively quickly, but succession leading to swamps will take
decades. Eventually, the increased percentage of wetlands on the
property should allow the sustenance of higher densities of
aquatic and wetland species than the premining condition provided.
If Florida sandhill crane nests are encountered, they will not be
disturbed during the breeding season. Florida sandhill cranes are
known to return to areas where previous nests have been destroyed.
With proper mitigation, mined wetlands will be restored so that
Florida sandhill cranes can re-establish nesting areas. The
populations of wading birds at the CF property are expected to be
lowered, but not eliminated, during mining. These species should
be able to repopulate the area gradually as mitigation progresses
and created wetlands mature.
W-29 The reestabllshment of substantial wetlands systems depends on
ability to reclaim ... sand/clay mix sites ... maintenance of
hydrlc soils ... without confining layer..."
The proposed sand/clay mix reclamation was developed from actual
sand/clay mix reclamation techniques utilized at CFMC's Hardee
Complex I Mine (HCI). Through 1986, 199 acres have been mined and
reclaimed through vegetation planting in a one-year establishment
period utilizing sand/clay mix reclamation techniques. Of this
199 acres, 32 percent have been established as forested wetlands
and six percent as freshwater marsh.
The sand/clay mix reclamation techniques accomplished at HCI
include both (1) complete backfilling with sand/clay mix with no
cap and (2) overburden and/or tailings backfill with a sand/clay
mix cap. The referenced areas have been selectively monitored by
CFMC, Lotspeich & Associates, Ardaman & Associates, and
Conservation Consultants for the various parameters to document
successful reclamation. Monitoring reports are also required and
are available on 45 acres of the referenced reclamation for DER
dredge and fill permit No. 250627469. All reports indicate a
positive trend towards successful reclamation of these referenced
sand/clay mix reclamation areas.
Evidence to date Indicates that the sand/clay mix soils provide
similar moisture holding characteristics exhibited by naturally
occurring hydric soils. A list of Hardee County hydric soils is
attached (W-29). Therefore, long-term maintenance of hydric soil
conditions are not anticipated to be a problem.
CFMC does not plan to reclaim wetlands on pure sand tailings
without a confining layer. CFMC has been successful at HCI
«>s.ai c ® layer and will utilize the
method which is most effective, economical and practicable.
3.2-20
-------
As stated above, the sand/clay mix soils, which have been utilized
in reclamation of CFMC's Hardee Complex I Mine (HCI}, exhibit
moisture holding characteristics similar to naturally occurring
hydric soils. It is difficult to provide a quantified comparison
between sand/clay mix soils and natural soils due to the lack of
research data for all moisture holding parameters of sand/clay mix
and for specific natural soils at the CFMC sites.
Evidence of the sand/clay mix and natural hydric soils
similarities is based on observations comparing the success of HCI
sand/clay mix reclamation areas with the naturally surrounding
floodplains. The wetland and floodplain tree species growing in
the sand/clay mix soils have exhibited no signs of stress due to
prolonged drought conditions during the spring of 1989. A similar
response of trees growing in the natural floodplain areas has been
observed.
Limited research data for moisture content in sand/clay mix
reclamation soils is available. The Florida Institute of
Phosphate Research (FIPR) sponsored a study performed by Ardaman
& Associates, Inc. which showed the first CFMC sand/clay mix
reclamation area of 110 acres to have an average moisture content
of 28 percent.
In addition, a recent FIPR research program was conducted by
Bromwell & Carrier, Inc. to study agricultural crops on CFMC
sand/clay mix. "Field moisture content measured at 1/3 bar (soil
water suction) 1s a measure of a soil's capacity to hold and
retain water. The CFMC sand/clay mixtures have higher field
moisture content than do sandy soils typically found in the
region" (Bromwell & Carrier, 1989). The research also found an
approximately 22-percent water holding capacity for the sand/clay
mix of a two to one ratio.
"The moisture retained in the soil between the field capacity
(1/10 to 2/10 bar) and the permanent wilting coefficient (15 bar)
is said to be usable by plants and as such is available water"
(Brady, 1974). The 22-percent moisture at 1/3 bar measured by
Bromwell 4 Carrier, 1989, and the average 28-percent moisture
found 1n the Ardaman & Associates report, 1988, indicate that the
moisture holding characteristics of the sand/clay mix soils are
comparable to the naturally occurring hydric soils.
Ardaman & Associates, Inc., 1988. Field Evaluation of Sand/Hav
gpplamatlon—Phase II. Florida Institute of Phosphate
Research Project #83-02-038. Bartow, Florida.
Brady, N.C., 1974. The Nature and Properties of Soils. MacMlllan
Publishing Co., New York.
3.2-21
-------
e W-
Symt
7
8
9
11
12
13
20
21
27
28
30
31
32
33
36
37
Hydric Map Units, Hardee County, Florida
MaD Unit Name
Basinger fine sand
Bradenton loamy fine sand, frequently flooded
Popasii mucky fine sand
Felda fine sand
Felda fine sand, frequently flooded
Floridana mucky fine sand, depressional
Samsula muck
Placid find sand, depressional
Bradenton-Felda-Chobee association, frequently
flooded
Holopaw fine sand
Hontoon muck
Pompano fine sand, frequently flooded
Felda fine sand, depressional
Manatee mucky fine sand, depressional
Kaliga muck
Basinger fine sand, depressional
3.2-22
-------
Bromwell & Carrier, Inc., 1989. Production of High Value Cash
Crops on Mixtures of Sand Tailings and Waste Phosohatic
Clavs. Florida Institute of Phosphate Research Project #86-
03-075. Bartow, Florida.
W-30 -no oemonstratlon that the functional values of forested wetlands
or marsh systems can be ... maintained over time on mined land."
The vast majority of forested wetland reclamation projects in
Florida are being carried out by phosphate mining companies
(Robertson, 1988). Most of these projects have been undertaken
in the last decade and do not yet support a tree canopy. However,
live tree density and trends in tree growth are promising on many
projects that have been monitored, such as the stream reclamation
projects being conducted by Mobil Mining and Minerals Company
(Gurr and Associates, Inc., 1988). While wetland trees such as
cypress show promising growth in reclamation projects, there is
no substantiation that hydric forests or borderland hardwood
forests can be restored to the structural and functional
equivalent of the wetlands that have been eliminated.
Many large wetland reclamation projects have been undertaken by
the phosphate Industry and several have received commendation from
environmental organizations and agencies. International Minerals
and Chemical Corporation received the 1987 Environmental
Achievement Award from the National Wildlife Federation's
Corporate Conservation Council for the 500-acre Peace River
Floodplain Project and also received the 198S Conservation Service
Award from the U.S. Department of the Interior for the 55-acre
Parcel B Project (Germond, 1989). Agrico Mining Company received
the Environmental Achievement Award from the National Wildlife
Federation's Corporate Conservation Council in 1985 for the 158-
acre Morrow Swamp reclamation project (Holloway, 1989). The
projects cited Included a total of 172 acres of reclaimed forested
wetlands with a variety of hardwood wetland species. These awards
indicate real progress 1n the ability to reclaim integrated
wetland systems by the phosphate industry.
W-31 "the removal of the phosphate matrix ... which serves as a
confining layer ... [lowers] the reclaimed water table ... coupled
with high evapotransplratlon rates of open water bodies, often
results in a substantially lower water table ..."
Research on post-reclamation water tables 1s presently ongoing.
The Florida Institute of Phosphate Research Is currently funding
research which will address the types of comments and concerns
raised by FGFWFC. Indications within the industry are that the
surflclal groundwater table 1n reclaimed areas typically return
to premlnlng levels. Documented research to definitively answer
concerns raised here has not yet been conducted; however, it has
been noted that post reclamation water tables have returned to
both higher and lower levels than the premlnlng conditions.
3.2-23
-------
The response to W-32 provides additional information to respond
to FGFWFC comments regarding significant modifications to the
hydrologic regime.
-surficial aquifer will be suostantlally altered by reclamation
... ground water recharge and base seepage to area streams will
be reduced."
A hydrologic study of the CF Hardee Complex I Mine (HCI) was
performed in 1988 by Gurr & Associates to meet requirements of
Chapter 40D-4.051, Rules of the Southwest Florida Water Management
District. The HCI premining and post-reclamation soils were
classified into the Hydrologic Soils Groups A, B, C and D as
defined by the U.S. Soil Conservation Service (SCS).
Approximately 95 percent of the premining soils at HCI were
classified as Group D soils, which are soils that have high runoff
potential and have very low infiltration and transmission rates.
The proposed reclaimed soils in the study were analyzed as to how
they would correspond to SCS hydrologic soils groups by
considering soil textures, surficial water tables and elevations,
land surface contouring and impervious soil horizons.
Approximately 98 percent of the proposed post-reclamation soils
at HCI were classified as Group 0 soils.
Results of the HCI hydrologic study indicate a relatively
insignificant change from the total premining runoff rate. The
total post-reclamation, 25-year, 24-hour peak discharge rate was
approximately 0.06 percent lower than the premining total peak
discharge rate.
The best information available to plan the proposed reclamation
conditions at the Hardee Complex II Mine (HCII) is information
from the ongoing reclamation at HCI and the HCI hydrologic study.
Approximately 95 percent of the premining soils at HCI I are
classified as Group D soils. The proposed post-reclamation soils
at HCI I are estimated to be 84 percent Group D soil
classification.
By comparing the premining and post-reclamation soil
classifications between HCI and HCII, and through results to date
in HCI reclamation and the HCI hydrologic study, it is estimated
that the post-reclamation hydrologic conditions of HCII will be
+ten percent of the premining conditions.
The physical properties of sand/clay mix reclamation in respect
to the surficial aquifer have been tested by Ardaman & Associates.
The findings show that sand/clay mix has a lower permeability than
premining soils, but also can contain at least 28 percent water
after final consolidation is complete. Although, the transmission
properties of sand/clay mix are very slow, the significant water
storage capacity of sand/clay mix should allow the area and the
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surrounding system to function near premining conditions. This
water storage capacity can also be a source of ground water to the
surrounding areas 1n times of severe drought when the water table
1s critically low.
Based on the foregoing discussion, the post-reclamation watersheds
are not expected to be substantially different hydrologically from
the premlnlng conditions. Since the preminlng and post-
reclamation runoff is expected to be approximately the same,
ground water recharge and base seepage to area streams is expected
to be virtually the same following completed reclamation.
Monitoring was initiated in early 1988 to study the ground water
conditions of a sand/clay mix reclamation area at HCI. The future
results of this monitoring will yield better information towards
reinforcing reclamation success and predicting the ground water
conditions on future sand/clay mix areas.
W-33 "The potential downstream wetland effects Include a lowering of
water levels, Increased sedimentation, lowered ground water
tables, erosion, and long-term hydroperlod alterations."
Based on the premlnlng and post-reclamation SCS soil
classifications for HCI and HCII and the results to date 1n HCI
reclamation and the HCI hydrologic study, the post-reclamation
hydrologlc conditions of HCII are estimated to be near the
preminlng conditions (see response to W-32).
Erosion and off-site sedimentation will be controlled to comply
with Chapter 17-3, FAC, water quality standards and Chapter 16C-
16, FAC, reclamation standards, which are regulated by the
Department of Environmental Regulation and the Department of
Natural Resources, respectively.
W-34 "Mine-water discharges are likely to degrade the quality of
receiving waters ..."
The proposed EPA NPDES permit and the FDER permits are designed
to ensure that surface water discharges do not significantly
impact the watercourses and water resources of Hardee and
surrounding counties. The surface water system required for
approval of surface water quality and quantity permits 1s designed
to assure acceptable water quality off site. The surface water
system provides for recirculation and recycling of the majority
of water stored in the system so that treated process water will
normally be discharged off site only during wet season rain
events. The proposed NPDES permit will require compliance with
state water quality standards in the receiving waters. Section
2.6.3 of the Environmental Impact Statement provides a detailed
description of the wastewater discharge system and Its
environmental protection features. The final NPDES permit will
Incorporate current state antldegredatlon requirements.
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Surface water runoff characteristics from lands reclaimed under
Florida Department of Natural Resources reclamation procedures is
expected to be similar to premining characteristics. Land
contours and elevations will be similar to premininq conditions.
A requirement for surface water permits is that postaevelopment
surface water flows be similar to predevelopment runoff
characteristics.
Any development activity is likely to result in some changes to
the quality of receiving waters. The CF Mining Corporation mining
plan is designed to minimize significant quality and quantity
effects both during mining and afterward. The EPA NPDES permit
and the FOER permit require that surface water discharges meet
water quality standards designed to protect these natural systems.
Water quality monitoring and reporting procedures will allow any
unplanned effects to be promptly recognized and mitigated by means
of changed procedures.
W-35 "Habitats and organisms may be adversely affected due to high
nutrient content ..."
Surface water releases off site are planned to occur normally only
during wet weather conditions. Nutrients released during heavy
rainfall events will tend to be diluted and therefore result in
a lesser impact than would result from a continuous surface water
fl ow.
Following reclamation, there will be no significant land use
changes from premining uses. The area 1n improved pasture use and
lakes will be increased but this should decrease nutrient runoff
from premining uses, as described in Section 3.5.2.1 of the EIS
(see the table following Page 9 of this section).
W-36 "reclamation replacement by Improved pasture ... will result in
a permanent loss of habitat for many wildlife species."
Improved pasture will be increased from 1,310.3 to 6,659 acres on
the CF mine site. This increase in improved pasture acreage on
the property over other wildlife habitat types that currently
exist on the mine site (e.g., palmetto rangeland) could cause a
future shift 1n wildlife species compositions. However, this
shift would not necessarily be considered detrimental 1n terms of
regional wildlife populations. For example, the increase of
Improved pasture on the site may promote the increased use of the
area by sandhill cranes which often feed within shallow pools in
Improved pasture. In addition, due to the diversity of habitat
types planned in the reclamation of the site, it is not expected
that future wildlife species diversity will be substantially
altered from premining conditions.
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W-37 "Reclaimed . forests typically maintain lower floral and faunal
diversities..."
The exact complement of wildlife soecies that presently inhabit
the CF mine site cannot be expected throughout the life of the
mine or after the reclamation process is completed. However, it
is a safe assumption that given time the reclaimed land will
support a wide diversity of wildlife species and plant climax
communities, typical for each type of soil and water site
characteristic.
Succession on reclaimed lands in Florida begins with colonization
by a wide variety of herbaceous and shrub species. Unlike many
other areas of surface mining in the United States, Florida has
a high annual rainfall, long growing season and great diversity
of plants that contribute to this rapid revegetation. Natural
revegetation on upland sites typically culminates in mixed
hardwood forests, usually dominated by evergreen oaks. Studies
by Schnoes and Humphrey (1980) documented a wide variety of
vegetation and wildlife on naturally reclaimed upland forests in
Polk County, Florida. The natural reclamation of these areas
generally takes over 40 years from the time of mining to develop
into a mature forested system.
In order to accelerate the natural reclamation process, species
common to the targeted climax forest will be planted during the
revegetation phase of reclamation. In five to ten years many of
the planted trees will have developed a canopy and will begin seed
production. In an additional 20 years, it is likely that canopy
closure will have occurred over large areas as tree diameter,
height and crown 1s Increased. The stage will then be set for the
development of the area Into a mature forested system. The time
frame for the succession of reclaimed forests Into mature climax
systems will obviously vary depending on edaphic conditions, the
type of forest planted and other environmental factors.
Only a limited number of tree species were proposed in the
reclamation plan of the draft £IS. CF has used approximately 20
different native tree species in their current reclamation areas
and is expected to continue this practice at the Hardee Phosphate
Complex II (Sampson, 1989). This practice will provide a much
higher diversity of tree species than 1s typically observed on
naturally reclaimed forests.
As the reclaimed areas develop through the accelerated succession
stages, there 1s the possibility of invasion by exotic species.
Most invaders tend to be of the weedy or shrubby type and are
easily shaded out as the developing tree canopy begins to close.
This has been observed on sites within the industry involving
species such as cattail, primrose willow and saltbush. The
development of a good ground cover during revegetation 1s also
instrumental in reducing the risk from invader type species.
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Additional management programs may have to be implemented to
arrest a persistent invasion by a nuisance species.
W-38 "We oppose mining of significant wetland and stream systems ...
support the preservation ... of all EPA Category i wetlands ..."
EPA has recommended that no Category I wetlands be mined and CF
Mining Corporation has agreed to preserve Category I-A wetlands
and that mining will not be scheduled in Category I-C and I-D
wetlands until EPA agrees that recreation of hardwood swamp and
large wetland systems, respectively, has been proven feasible.
The CF Mining Corporation reclamation plan requires equal
replacement of wetlands that are mined. Upon completion of
reclamation of mined lands, there will be no resulting loss of
wetlands areas or functions.
CF Mining Corporation has agreed to not schedule mining in any EPA
Category I wetlands, including hardwood wetlands, until EPA
reconsiders, based upon proven recreation of functional hardwood
communities, Its present Category I designations.
W-39 "We recommend the application of DER wastewater-to-wetlands
standards."
DER wastewater to wetlands standards are designed for a specific
purpose, to allow use of some types of wetlands for treatment of
domestic wastewater on a limited trial basis. The many criteria,
conditions, and exemptions designed to make use of the rule and
standards acceptable do not apply to wastewater discharge from an
industrial operation. To apply waste quality standards other than
those designed for the specific uses being permitted would result
in significant design problems for regulator and regulated alike.
The current surface water recycling and treatment system meets DER
permitting requirements. Off-site discharge occurs normally only
during limited wet weather conditions. There is expected to be
no significant water quality impacts from surface water discharges
for these reasons.
W-40 "suitable wetland topsoll should be used extensively in
reclamation ..."
The topsoil recovered from mined wetlands may in part be
stockpiled for later use in the recreation of the wetland soil
matrix and as a potential seed source for revegetatlon of
reclaimed wetlands. However, CF mainly proposes to recreate
wetland systems through the development of a sand/clay mixture
matrix. The use of recovered wetland topsoll will only be
utilized in the reclamation process where 1t 1s feasible and
prudent to do so. The EIS Supplementary Information Document on
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pages 2-90 and 2-94 list the types and densities of vegetation
expected after reclamation.
W-41 "recommend the use of topsoil in upland area reclamation ..."
The util ization or palmetto prairie and other upland topsoil types
as a final cap in upland reclamation may be an effective
reclamation technique. However, upland topsoil availability,
location, and transport economics in relation to the ongoing
mining activities and reclamation must be considered.
CFMC has plans to research the effectiveness of capping with
upland topsoil by capping selected areas in reclamation with
palmetto prairie and other upland topsoils at HCI.
A priority consideration will be given to the placement of trees
and forage/cover in upland reclamation to provide the best
potential for multiple-use by wildlife while connecting these
upland areas with preserved and reclaimed streams and lakes. The
EIS Supplementary Information Document on pages 2-90 and 2-94
lists the types and densities of vegetation expected after
reclamation.
W-42 "habitat related mitigation measures should be sought to [restore
and protect] of suitable upland habitats •••"
Mitigation measures, as they are developed and approved for
various protected species, will be applied in suitable
circumstances during mining land clearing, matrix removal and
restoration. The most Important procedure will be management of
scheduled mining and reclamation activities to assure that a
matrix of various habitat types are available 1n each section of
the site at all times during and after mining.
Reclamation of the mine site will not result in a net loss of
habitat but will rather promote the establishment of different
habitat'types and areas of specific habitat compared with the
oreminina condition. The mining plan is designed to maintain a
varietv of types of habitat at all times during mining and
reclamation. Table 3.7.2-1 lists the existing and proposed land
use/cover following reclamation.
since a variety of habitat types will be established or replaced
through mitigation, the regional diversity of wildlife will be
maintained. Mitigated habitats will be ecologically sound 1n that
the reelamatlon pi an will provide for the needs of edge species,
interior species, top carnivores, and species requiring large home
ranaes all of which need large areas with diverse habitats to
provide their feeding, breeding, and cover necessities. Of
course, the overall capacity of the mitigated property to support
wildlife will take years to reach its premlnlng levels. As
3.2-29
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succession occurs on the mitigated property, the carrying capacity
of the environment will slowly be restored.
Effects of phosphate mining and reclamation activities on wildlife
habitat utilization 1n Central Florida have been documented in
past studies. Research by Schnoes and Humphrey (1980) documented
wildlife utilization at 24 phosphate-mined sites 1n Polk County,
Florida. The vegetation, small and large mammals, birds, insects
and herpetofauna (reptiles and amphibians) present were sampled
at mine sites of various types and ages. Unreclaimed spoil piles
exhibited rapid primary succession, culminating 1n oak forest with
high quality wildlife habitats. Colonization of mined,
unreclaimed areas began soon after mining. In addition,
developing vegetation supported large populations of small and
large mammals and birds. This study also documented the regular
use by tree swallows of phosphate-mined sites with lakes. Large
flocks of tree swallows alternated their feeding between wax
myrtle berries and Insects. Also, the combination of aquatic and
shaded terrestrial habitats 1n older unreclaimed pits and spoil
piles yielded many herpetofaunal species. Mined sites which had
been reclaimed to pasture provided wildlife habitat of less value
than unreclaimed sites for small and large mammals, birds and
herpetofauna. Although diversity and abundance of birds on
reclaimed pasture was lower than on unreclaimed sites, the Schnoes
and Humphrey (1980) study concludes that the open grassland
provided habitat for some bird species not found in other sites
and, therefore, 1t 1s clear that the presence of these pastures
serves to increase the avian diversity of the region as a whole.
Furthermore, the viability of reclaimed pasture for supporting
abundant Insects, grasses and cattle suggested that such reclaimed
sites can yield valuable biological communities.
Data from a wetland on a mined tract south of Bartow, Florida,
suggested that colonization by natural and Introduced vegetation
provides, "potential for mitigating some types of mining related
habitat loss" (Gilbert, King and Barnett, 1981). The fauna
encountered suggest utilization by "species with diverse habitat
requirements and Individuals representing high to low trophic
levels." In addition, settling ponds on phosphate-mined sites
were shown to posses a high potential for wood duck production
(Uenner and Marlon), yielding nesting rates similar to natural
habitat (Bellrose, 1981 et al. 1964).
3.2-30
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REFERENCES
Ardaman & Associates, Inc. 1988. "Field Evaluation of Sand/Clay
Reclamation—Phase II." Florida Institute of Phosphate Research Project
#83-02-038. Bartow, Florida.
Bellrose, F.C., K.L. Johnson and T.V. Meyers, 1964. "Relative Value of
Natural Cavities and Nesting Houses for Wood Ducks." Journal of
Wildlife Management, Vol. 28, pp. 661-676.
Brady, N.C., 1974. The Nature and Properties of Soils. MacMillan Publishing
Company, Inc., New York.
Bromwell & Carrier, Inc., 1989. "Production of High Value Cash Crops on
Mixtures of Sand Tailings and Waste Phosphatic Clays." Florida
Institute of Phosphate Research Project #86-03-075. Bartow, Florida.
Germond, G., 1989. "Personal Communication." Communications Coordinator, IMC
Fertilizer, Inc., Lakeland, Florida.
Gilbert, T., T. King and B. Barnett, 1981. "An Assessment of Wetland Habitat
Establishment of a Central Florida Phosphate Mine Site." Florida Game
and Fresh Water Fish Commission, Vero Beach, Florida.
Gordon F. Palm and Associates, 1983. "Water Data Acquisition Program, Surface
Water and Ground Water Quality, Florida Phosphate Council Members,
Lakeland, Florida.
Gurr & Associates, Inc., 1988. "1987 Annual Report, Wetland Vegetation
Monitoring for Mobil's Stream Reclamation Projects." Report for Mobil
Mining and Minerals Company, Nichols, Florida.
Gurr & Associates, Inc., 1986. "IMC Fertilizer, Inc., Kingsford Mine
Extension DRI," Lakeland, Florida
Gurr & Associates, Inc., 1988. "SWFWMD 40d-4 Phosphate Mining Exemption
Hydrologic Study for CF Industries, Inc.," Lakeland, Florida.
Holloway, T., 1989. "Personal Communications." Public Relations, Agrico
Mining Corporation, Mulberry, Florida.
Lotspeich, Carol S., 1989. Written Communication, Environmental Consultant,
Orlando, Florida.
Robertson, D.J., 1988. "Freshwater Wetland Reclamation in Florida, An
Overview." Florida Institute of Phosphate Research, Bartow, Florida.
Schnoes, R.S. and S.R. Humphrey, 1980. "Terrestrial Plant and Wildlife
Communities on Phosphate-Mined Lands in Central Florida." Florida State
Museum, University of Florida, Gainesville, Florida.
Texas Instruments, Inc., 1978. "Central Florida Phosphate Industry Areawlde
Impact Assessment Program, Volume VI: Land," Prepared for EPA.
3.2-31
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Wenner, K. and W. Marion, 1981. "Wood Duck Production on a Northern Florida
Phosphate Mine." Journal of Wildlife Management. Vol. 45(4), pp.
1037-1042.
Zellars-Williams, Inc., 1980. "An Analysis of Topsoil Replacement as a Means
of Enhancing the Agricultural Productivity of Reclaimed Lands."
Lakeland, Florida.
3.2-32
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3.0 PUBLIC PARTICIPATION
3.3 Hearing Transcript
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DRAFT ENVIRONMENTAL IMPACT STATEMENT POP.
CF MINING CORPORATION, HARDEE PHOSPHATE COMPLEX II
HARDEE COUNTY, FLORIDA
PUSLIC HEARING
TAKEN ON:
THURSDAY, JULY 21, 1988
AT OR ABOUT 7:00 P.II.
take:: at:
HARDEE COUNT" CIVIC C3CTER
WAUCHULA, FLORIDA
APPEARANCES:
AL J. SMITH, DEPUTY DIRECTOR
WATER MANAGEMENT DIVISION
US EPA - REGION IV
J. P. SUBRAMANI, ADMINISTRATOR
INDUSTRIAL WASTE SECTION, FLORIDA
DEPARTMENT OF ENVIRONMENTAL REGULATION
MARYANN GERBER, PROJECT MONITOR
NEPA C0HPLIAHC3 SSCTIOu, EMVIROIHENTAL
ASSESSMENT BRANCH, 'JS SPA - REGIOl! IV
J. RONALD RATLIFF, CONSULTANT
STEPHEN C. RICHARDSON, PERMITS SECTION
REPORTED BY:
PAMELA COLD I IIS,
Deputy Official Courz Reporter
MCCLELLAM COURT REPORTIJJG SERVICE
Scoring, Floriaci 3387C
3.3-1
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OPENING STATEMENT BY MR. SMITH 3
STATEMENT BY MR. SOBRAMANI 8
STATEMENT BY MS. GERBER 9
STATEMENT BY MR. RATLIPF 11
STATEMENT BY MS. GERBER 21
STATEMENT BY MR. RICHARDSON 21
STATEMENT BY KARL a. SMITH 26
STATEMENT BY PAYE DOBBS 31
CLOSING STATEMENT BY MR. SMITH 32
CERTIFICATE OP REPORTER 36
McCLSLLAN COURT REPORTING SERVICE
S«bring, Florida 33870
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MR. SMITH: Ladies and Gentleman* good evening. My
name is A1 Smith. I an the Deputy Director of the Water
Management Division of the U.S. Environmental Protection Agency, ;
Region IV, Atlanta. I
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The regional administrator of EPA, !
Mr. Greer C. Tidwell, appointed me as hearing officer. !
And J. P. Subramani on my left, representing DER, is
the co-chair of this particular hearing.
With me this afternoon are he# representing the !
I
State of Florida* Ms. Maryann Gerber, on my right, Project
Monitor, out of the Compliance Section of our Environmental
Assessment Branchy and Mr. Stephen Richardson on my left, on j
J. P.'a left, from the Permits Section of the Water Management
Division.
Back in the back taking your notes and your entree
and filling out the sheets when you came was Ms. Susanne Potter, <
now over here, and her sister Wanda Durham. Those two nice
ladies came down here free to the taxpayers to help with this
meeting; certainly Wanda did. I want to thank her personally
for that. i
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And Pan Colding over here is the court reporter, who
will keep the official record of this hearing.
This afternoon's hearing will address possible
actions by the Environmental Protection Agency with respect to
CP Mining Corporn*ion's purposed phosphate mine and
MCCLELLAN COURT REPORTING SERVICZ
Sebcing, Florida 33870 .
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beneficiation plant to be located near the town of Wauchula in
Hardee County, Florida.
The hearing is being held by EPA/ jointly with the
State of Florida/ Department of Environmental Regulations, for
the purpose of receiving comments on the Draft Environmental
Impact Statement# the proposed issuance of a National Pollutant
Discharge Elimination System Permit/ and consideration for state
certification of the permit.
The State of Florida has been requested to certify
the proposed NPDES permit in accordance with section four, 0,
one of the Clean Hater Act.
The purposed CF project was determined by the
administrator of EPA/ Region IV/ to be a new source under
section three/ 0/ six of the Federal Clean Water Act/
thirty-three/ OSC, twelve/ fifty-one.
Issuance of an NPDES permit to such a new source
facility is subject to the environmental review conditions of
the National Environmental Policy Act of 1969, known as NEPA.
This act requires federal agencies to prepare an Environmental
Impact statement/ EIS/ on major federal actions which
significantly affect the quality of the human environment.
Since issuance of an NPDES permit for the proposed CF
facility was determined to be such a major federal action/ a
draft EIS was prepared by EPA. And notice of its availability
was published in the Federal Register on June 24th» 198C.
McCLELLAN COURT REPORTING SERVICE
Seocing, Florida 33870
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I might add in teems of notice# over eight hundred
letters were mailed out locally. Newspapers were notified.
Documents have been available in seven different sources in and
around this area o£ the draft EZS.
The 1972 amendments to the Federal Water Pollution
Control Act# now referred to as the Clean water Act# created the
National Pollutant Discharge Elimination System# a national
permit program to control the discharge of pollutants into the
nation's water. Under this permit program# anyone who purposes
to discharge wastewater into waters of the United States must
receive a permit# which sets limits and conditions on the
discharge of the pollutants involved.
The NPDES permit is the basic enforcement tool for
water pollution abatement under federal law# and the permit
imposes legally enforceable limits on the discharger. Any
violation of the terms of the permit may subject the discharger
to civil and/or criminal penalties. Once the permit is issued#
the discnarger is legally bound to meet its requirements.
The draft NPDES permit proposed for CP's facility was
prepared by the staff of EPA# Region IV# using EPA effluent
guidelines and applicable State of Florida regulations and water
quality standard.
A fact sheet has been prepared which details the
rationale for the permit limitations and conditions.
As stated in the public noting? *11 pollutants
McCLELLAN COURT REPORTING SERVICE
Sebring# Florida 3387#
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limitations and other permit conditions are tentative and open
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! to comment.
A copy of the draft permit is included in the draft
EIS document.
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We have made available for examination here this
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1 afternoon copies of the public notice# permit fact sheet and an
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agenda for this hearing. A few copies of the Draft
Environmental Impact Statement are available also.
Those of you who don't have one and wish to try to
picfc up one preceding this meeting-
Are they at the door?
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MS. POTTER: They were distributed at the seats.
MR. SMITH: Each of these documents, as well as other
relevant documentation# and all comments received tonight or
submitted in writing# or to be received in writing, by
August 5th# 1988# they will become part of the administrative
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' record.
Some of you have already suomitted comments and they
! have become part of that record.
The information in the record will De used in
! evaluating the draft permit and in preparing the final permit
action.
In addition# you should be aware tnat all public
comments on the draft permit and EIS, whetner received here
fconight an^ transcribed cor the record or suomitted in writing
McCLELLAN COURT REPORTING SERVIC2
Sebring, Florida 33870
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directly to the EPA, will be summarised and addressed in the
final EIS.
This hearing is to be an EPA public information
hearing conducted pursuant to Forty CPR one, twenty-four point
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twelve "B*.
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Notice of this hearing was published in the j
p?1K Democrat and WWhUlft HUftlfl on the 20th of ,
June, 1988.
And as I said, over eight hundred copies were mailed
out.
Before we proceed further, I would line to ask
everyone who ha. not r.gi.t.t.d to do so Before you leave
tonight, w. nud yoo tor th« r.cord. X. uk that you do that |
now. If you haven't, and »o also that w. can »nd you copies of
the final BIS notice and final determination regarding this
permit.
EPA representatives are at the registration table and
will tak. this completed registration card.
This hearing will b« conducted informally, rules of
, m.nfeiM in a courtroom are not adhered to.
evidence and the formalities in o
There will 0., for inatanc. no eros. examination of people that
make presentations.
Any and all persons present desiring to do so can
».*« oral counts or submit to th. writtan record. Oral
presentations would o. limit.4 to aooui ten tinutes. Sut : can
MeCtttLAN COURT *®W1CE
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make exceptions oecause we don't have that many people that ace
offering talks tonight. So whatever you have to say, say it
tonight. If it gets too long# I may would have to.
Members of this panel up here, at the head up here,
are free to ask questions of people making presentations. We
will try to answer clarification-type questions, if we can; but
that will be a prerogative of the panel as to what kind of
questions we can or are capable of answering tonight. And most
of the time we will probably have to get back to you with the
answer.
As we proceed, 1 would ask that each person that is
going to make a statement, please step up to the microphone,
state his or her name and interest or organization that is
represented. This hearing is being recorded by a court recorder
and a transcript will be included in the public record and the
final EIS.
Having said all that, administratively, the restrooms
are m the back* if you need to. We will go for what I thin* is
a comfortable length of time. If we need a break, we will take
one. But we will be nere until those that want to be heard have
been heard.
I would like to now call on J. P. Subramani of the
State of Florida DER to make a statement concerning state
certification, if you would.
MR. SUBRAMANI: fftAnk you, Mr. Smith.
McCLELLAN COURT REPORTING SERVICE
sebring, Florida 33870
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Good evening, Ladies and Gentlemen. My name is
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| J. P. subcamani. I'm administrator of the Industrial waste
! Section» Tallahassee. I am here representing the Department,
| DER, and Secretary Claudeman (Phonetically).
I would like to also introduce Mr. Sam Sahebzamani,
who is sitting in the audience there, who is the Industrial
Waste Section permitting Head from our Tampa District Office.
He is here representing the district.
And also the Deputy Assistant Secretary, Dr. Garrty
: here.
Mr. Smith# I want to thank you and EPA for giving us
this opportunity to be here. Our purpose of being here is to
get your comments in relation to the certification request for
this purposed NPDES projset.
The Department has received the request for
certification on June 22nd, 1988. Since it is a new source,
I subject to the NEPA requirements, before the State of Florida
can issue such a certification, we do want to take comments from
i the public and consider them appropriately.
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I ThanK you again for letting us to be here,
j MR. SMITH: Thank you, Mr. Subramani.
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What 1 want to do now is ask Maryann Gerber, our EXS
! Project Monitor in Region IV to discuss tne E1S and EPA reviev;
; process, if you would.
MS. GERBER; Thank you, Mr.. Smith.
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1 Good evening. My name is Maryann Gerber and I am cne
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2 J EPA project monitor for this project. It is my responsibility
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3 ; to oversee the preparation of the Environmental Impact Statement
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4 and to assure the project's compliance with NEPA.
5 This evening I would like to briefly describe the
6 NEPA process, the EIS process and the development of this
7 specific EIS.
8 As was described in the opening statement, EPA has
9 determined that the proposed mining constitutes a new source
10 discharger and that issuance by EPA of a new source NPDES permit
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11 j is subject to the provisions of NEPA requiring preparation of an
12 EIS.
13 EPA is serving as the lead federal agency for the EIS
14 and is coordinating all project components with the Corps of
15 Engineers and the Florida Department of Environmental
16 Regulations.
17 The purpose of the EIS is to provide government
18 agencies# and the public# with information to assure that a
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19 ! thorough review of the environmental impacts of the purposed
20 , federal action is included in the decision making process.
21 The CF Mining Corporation draft EIS was prepared
22 using the so-called third-party EIS process. Under this
23 ! arrangement, EPA and CF Mining Corporation entered into a
24 third-party agreement for CF to retain a consultant to prepare
25 ' the EIS under EPA's direction.
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Environmental Science and Engineering, Incorporated
of Gainesville was approved by EPA as the third-party consultant |
to prepare the EIS. However, EPA retains ultimate
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responsibility for the EIS.
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To comply with the goals of NEPA, the EIS must do the j
following: I
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Oner provide a thorough description of the
environmental background and setting*
Two, evaluate all responsible alternatives which meet !
project objectives, as well as the no action alternative.
Three* assess the environmental impacts of the
alternatives.
And four# identify all potential adverse impacts and
evaluate means to mitigate these impacts.
I would now like to introduce Mr. Ronald Ratliff, who
is with Environmental Science and Engineering. Nr. Ratliff has '
worked on the EIS since its beginning many years ago, and he
will describe how the CF Mining Corporation Eis was prepared to
satisfy the requirements of NEPA.
At the conclusion of Mr. Ratliffs remarks, I will :
summarize the discussion of the EIS and NEPA process,-mentioning ;
the NEPA related permit conditions that are contained in the
back of the NPDES permit.
MR. RATLIFF: Thank you, Maryann.
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T h*ve a prepared statement.
MCCLELLAN COURT REPORTING SERVICE
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Good evening. My name is Ronald Ratliff, and I nave
served as the project manager for the preparation of the
Environmental Impact Statement for the CF project.
This evening I would like to briefly describe how we
have coordinated with EPA in the preparation of the EIS document
and to discuss the contents of the EIS for the CP project.
As some of you probably recall, this process began
seven years ago with a scoping meeting being held in Wauchula,
Florida on July 13th» 1981.
Following that scoping meeting, a final plan of study
was prepared for EIS. This plan of study incorporated all
regulatory agency and public comments received as a result of
the scoping meeting and public advertisement process.
The resultant data collection and EIS preparation was
then completed in accordance with a joint memorandum of
understanding between EPA and the Corps of Engineers, in this
agreementf EPA served as the lead agency for compliance with
NEPA. And all data collection, analysis and report preparation
activities were coordinated with the Corps of Engineers and the
Florida Department of Environmental Regulations.
The basic component of the draft EIS is the
description of alternatives which meet the project and NEPA
goals. These alternatives include CF Mining Corporation's
purposed action and the no action alternative. Also included is
a description of the existing environment of tne raining site.- -
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description of the impact of the various alternatives on that
environment.
The alternative analysis is designed to identify tne
least damaging or most environmentally suitable method for
achieving project goals,
CP Mining Corporation's objective is to produce two
million tons of phosphate rock per year during the first phase
of mining. Phase two begins about seven years from the
initiation of mining and lasts through the total
twenty-seven—year lifetime of the project.
During phase two, CP's objective is to produce four
million tons of phosphate rock per year with the use of two
draglines. The mined ore would be processed in the
beneficiation facility to be constructed onsite.
The site contains fourteen thousand, nine hundred and
ninety-four acres and is located south of State Road 62 and west
of wauchula in northwestern Hardee County.
Major phases of the purposed construction and
operation of the facility arei
One, clearing and preparing the site for operations
and constructing the processing plant, initial settling areas,
well fields, water and wastewater control structures and
recirculation systems.
Two, extracting the pnospnate rock bearing matri:: oy
electrical powered draglines.
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Three, transporting the matrix to the central
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j processing plant.
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Pour, physically separating tno pnosphate rock from
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| sand and clay wastes.
Fiver disposing of the sand and clay in settling
areas.
Six, shipping the phosphate rock from the facility by
rail.
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| And seven, reclaiming or restoring the disturbed
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i areas.
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The purposed facility has received-three key
regulatory permits needed for implementation: A consumptive use
permit from the Southwest Florida Water Management District; an
approval—an approved development order from Hardee County based
on an application for Development Approval/Development of
Regional Impact; a Mineral Extraction Permit and zoning variance
' approval from Hardee County.
In addition, tne Florida Department of Natural
: Resources has accepted and approved the conceptual reclamation
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I plan for the facility.
The EI5 and its supplemental information document
include information about the environmental data collected and
analyses performed, data from CF Mining Corporation's
environmental monitoring at its existing mine sites in
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Hardee County. Data. included are for air resources,
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geotechnical resources# radiation, ground water# surface water,
aquatic ecology# terrestrial ecology, socioeconomics.
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; During mining# all of the rock mined from the project
i site will be shipped to fertilizer plants for conversion to
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finished fertilizer# with one hundred percent of the tonnage
going to CP's existing phosphate fertilizer manufacturing
facilities in Plant City and Bartow.
To accomplish these operational objectives# CF
purposes to mine approximately fourteen thousand# six hundred
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i and forty-seven acres, or ninety-nine percent of the site.
A beneficiation plant and temporary rock storage
facility would also be constructed onsite.
The initial phase of the proposed action includes
land clearing and open burning in advance of the mine. This
cleared acreage in front of the mining operation will average
| approximately eighty acres.
¦ The mining operation will employee a single
fifty—five-cuDic—yard dragline supplemented, oeginnina in mine
: year eight# with a second similar dragline.
The mined matrix will be slurrifiea and transported
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' via pipeline to the beneficiation for rock—for washing. This
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would separate pebble product# clay and fines and facilitate
' additional product recovery via floation.
The wet rock will be stored temporarily at the plant
: site. CP plans to construct an access railway spur linking tne
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1 the plane with the CSX Railroad that presently bisects the
2 ; property. CP will rail ship the wet rock product to the
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3 receiving phosphate fertilizer plants.
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4 The waste disposal method purposed by CP is sand/clay
5 ' mixing. Sand/clay mixing refers to the process in which sand
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6 I and clay components separated during mining and beneficiation
7 | are recombined into a suitable mix for disposal in previously
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8 i mined areas.
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9 In the proposed CF process, the waste clay generated
10 from the beneficiation processes is routed to a containment area
11 for interim storage and subsequent consolidation to higher
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12 percent solids. The sand/clay mixture is then pumped from the
13 mix tank to a designated disposal site.
14 Disposal areas are designed to receive sand/clay mix
15 over mined lands and finally fill all elevations that
16 | consolidate to within approximately two to three feet above tne
17 i average pre-mining evaluations by the end of the reclamation
18 period.
19 To complete this waste disposal cycle an aboveground
20 i settling area is necessary to receive diluted clay slurries for
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21 I storage and consolidation to use in sand/clay mixing.
22 To satisfy this requirement# CP plans one aboveground
23 settling area subdivided into tnree compartments. During the
24 last three years of mining, this aboveground settling area will
25 also be mined and reclaimed.
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Water is important in CP's purposed phospnate mining
| operation. Water is used as a medium to transport ore from the
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| mining site to the plant, to transport tne feeds and product
j through the plant, to process the product and to transport the
waste products away from the plant to disposal sites. These
processes require large quantities of water, in the proposed
project, the plant will be utilizing ninety-three point five
million gallons per day, more than ninety percent of which will !
be—will be provided and supplied from a recirculation system,
! an average seven point eight, five million gallons a day
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will come from ground water sources.
The mine water recirculation system consists of
settling areas, beneficiation plant, active and mined-out pits,
active sand/clay mix storage areas and water return ditches.
The settling area, tailings storage areas and return
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j water ditches act as a water clarification system, returning
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1 decanted water to the beneficiation plant.
Recycled water returns to tne recirculation syster.
several times to be reused, while a portion is continually oeing
I lost by entrainment in sand and clay and being replenished in
some degree by rainfall. However, since rainfall varies
; seasonally and is approximately equal to evaporation, some
! outside source of water will be required.
Also due to the seasonal variables, an alternate
source of water, i.e., ground water, must be available riurtn?
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periods of water deficits for operation of the floation process,
: as a makeup water during the dry season. Conversely, discharges
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the system is exceeded.
In the purposed project, the water discharge would be
to surface waters, Doe Branch and/or Shirttail Branch, directly,
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or as required to Payne Creek via sheetflow through adjacent
wetlands.
t The purposed reclamation plan is based upon the use -
of the waste sand/clay mix material as backfill over most of the
mined area. The purposed plan is designed to return the site to
a land form and use compatible with the surrounding area, which
is primarily agricultural. j
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The reclaimed site will consist primarily of improved \
pasture, forested uplands, restored marshes, lakes and areas to
! be perserved by CF. With reclamation the acreage of improved
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, pasture, forested uplands, freshwater marsh, fresnwater swamp
and lakes will increase. The acreage of palmetto prairie, field
and row crops and citrus will decrease.
Of tne total site acreage of fourteen thousand, nine
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: hundred, ninety-four acres, fourteen thousand, six hundred,
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' forty-seven is purposed for mining by CF. Sixty acres will be
required for the plant site. Two hundred and eighteen acres
will be required for road and buffer zones. And sixty-nine
i acres of contiguous wetlands are purposed by CF to oe perserved.
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EPA, however, is requiring CF Mining Corporation to
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preserve all Category I wetlands onsite from mining activities.
CF Mining Corporation must produce and maintain documentation
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I wetlands can be re-established onsite prior to EPA
recategorization of these Category I wetland areas.
An objective of the reclamation plan is to restore
the land's surface to the original grade as much as possible.
All of the site is planned to be reclaimed to within two to
three feet of the original grade, with the exception of two
thousand# three hundred and ninety-nine acres of mined areas
which will be reclaimed as lakes.
The socioeconomic impact results include generation
of jobs with compartively high incomes for Hardee County; the
addition of ad valorem and sales tax revenues for the county,
the increase in severance tax revenue for the State, the Land
Reclamation Trust Fund and the Florida Institute of Phospnate
Researcn.
There will be some population increase in Hardee with
additional d.Mnd for services out increased revenues will
provide soae increased capaBility to provid. these services.
During th» prepsration process, several proj.ct
alternatives were thoroughly evaluated. As a result o£ this
analysis, EPA'spreferred alternatives for each of the project
components is as follows:
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Mining; EPA preferred alternative# dragline mining.
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| Matrix transport; slurry matrix transport.
I Matrix processing; conventional matrix processing.
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! Waste sand and clay disposal; sand/clay mixing.
| Process water source; ground water withdrawal.
! water management plan; discharge to surface waters.
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Reclamation; CP's proposed reclamation plan. j
Wetlands preservation; preservation of Category I !
; wetlands.
As indicated, EPA*s preferred alternatives for the
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! various project components are in agreement with CP's proposed
action* with the exception of mining in Category I-C or I-D
wetlands* !
EPA's preferred project action involves the 1
perservation of all Category I-C and I-D wetlands. CP will not
be allowed to mine Category I-C or I-D wetlands until such time
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1 they can provide documented evidence to EPA*s satisfaction that
these forested wetlands can be successfully restored.
( Implementation of recommended mitigation measures
i descrioed in the Environmental Impact Statement are proposed as
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; conditions of the NPDES permit for the project.
A summary table with comparisons of the environmental
: impacts of the project alternative is available here tonight at
the table# and was also included in the initial pages of the
EIS.
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Thank you very ouch.
MS. GERBERj Thank you, Mr. Ratiiff.
EPA's recommendations and proposed agency action are
embodied in the draft NPDES permit which is contained in the
draft EIS.
Several measures which would mitigate the !
environmental impacts of CF Mining proposed project were {
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identified during preparation of the draft EIS# as Mr. Ratliff
mentioned. These measures were made conditions of the draft
NPDES permit and are contained in pages "A" thirty-two and "A"
thirty-three of the draft EIS.
The final EIS will be published after the close of ;
the draft EIS comment period. The final EIS will consist of the |
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agency statement of findings, tentative permit decision# j
substantive comments on the draft EIS, and any responses to the
comments, the transcript of this hearing and any additional
evaluations performed. A copy of the draft EIS should be
retained if a complete evaluation of the project is desirec.
Thank you.
MR. SMITH: I would now ask Steve Richardson of EPA,
Region IV, to discuss the proposed NPDES permit.
MR. RICHARDSON: Thank you, Mr. Smith.
Good evening. My name is Steve Richardson and I am
an environmental engineer with the Permits Section of EPA,
Region IV, in Atlanta.
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It has been my responsibility to prepare tne draft
i NPDES permit for the new CF facility.
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In July of 1986, CP Mining Corporation applied for an
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' NPDES permit for their new phosphate mine and beneficiation
plant, known as the Hardee Phosphate Complex II, to be located
just south of the existing CP Hardee Complex near wauchula,
Plorida.
A draft permit and fact sheet describing the
| rationale for the effluent limits, and other permit conditions,
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were prepared by EPA in February of 1987. Copies of these
; documents were then sent to CF and DER for review.
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I In June of 1988, a revised draft permit was prepared
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and sent to CF for review. This revised draft included
additional permit conditions recommended by the draft EIS to
minimize the environmental impact of the proposed project. At
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j that time DER was requested to provide state certification of
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' the draft permit in accordance with section four, 0, one of the
Clean Water Act. In addition, on June 20th, 1988, public notice
of EPA's proposed issuance of an NPDES permit to CP was
publisned and distributed.
At this time I would like to discuss the more
significant permit conditions. You may wish to refer to the
draft permit in the back of the EIS as I proceed.
The purposed draft permit would autnorize three
discnarae points for mine dewatering and process generated
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wastewater from the mining and beneficiation of phosphate rocK.
Outfall number 0, 0, one would discharge to
Shirttail Branch at latitude twenty-seven degrees, thirty-five
minutes# three seconds and longitude eighty-one degrees,
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fifty-six minutes, fifty-nine seconds.
Outfall number 0, 0, two would discharge to j
Doe Branch at latitude twenty-seven degrees, thirty-four minutes j
and fifty-one seconds and longitude eighty-one degrees,
fifty-five minutes, fifty-two seconds.
And outfall 0, 0, three would discharge to
Payne Creek at latitude twenty-seven degrees, thirty-six
minutes, twelve seconds and longitude eighty-one degrees,
fifty-five minutes and twenty-nine seconds. I
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All three of the receiving streams are tributaries to !
the Peace River and are classified by the State of Florida as
class three surface water for recreation and propagation and
management of fish and wildlife.
The effluent limitation and monitoring requirements
for each outfall contained in part one -A- of the draft permit
were derived from:
One, EPA New Source Performance Standard for the
Mineral Mining and Processing Point Source Category, Phosphate
rock Subcategory contained at Title Forty, Part Four,
Thirty-six, Subpart -R' of the fOrif qf FrtCMl RMUUUMg.
Two, State of Florid Phosphate .'lining waste and
mcclellan coort reporting service
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Treatment Requirements of chapter seventeen* six of the
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i Plorida Administrative Code.
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I And three, State of Florida Water Quality Standards
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! for Class III Surface Water.
| This is in accordance with the Clean water Act whicn
requires that permitted discharges meet EPA technology-based 1
limits# as well as any more stringent conditions required by j
statutes or regulations,
j Based on the aoove-mentioned CPA and State
: regulations, permit limits and/or monitoring requirements were
! developed for the following parameters: Flow; total
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non-volatile; non-filterable residue; total non-filterable
residue; total phosphorus; fluorides; gross alpha particle j
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activity; combined radium two* twenty-six and two, twenty-eight; !
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specific conductance; unionized ammonia; dissolved oxygen; total |
| kjeldahl nitrogen; total sulfate; pH; and biological integrity.
1 The basis for each of the permit requirements is discussed in
the permit fact sneet.
In addition to the requirements just mentioned, the
| purposed permit also requires CF to develop and implement a best
| management practices plan, or BMP plan. The purpose of the BMP
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: plan is to prevent, or minimize, tne potential for release of
! toxic or hazardous substances to surface waters.
Finally, the proposed permit contains specific
i requirements nan*-! on BPA's preferred mining and management
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alternatives, and mitigation measures recommended in the draft
EIS, to minimize the environmental impacts of the CF project.
These permit conditioner which are found in part three "C" of
the draft permit* require CF to comply with the preferred
alternatives listed in the draft EZS. The proposed requirements
have been incorporated into the draft permit in accordance with
forty CFR one* twenty-two point four, four, mDm, nine.
Tonight I have briefly discussed the principle
requirements of the proposed NPOES permit. EPA believes that
the proposed permit conditions will ensure compliance with the
requirements of the Clean Water Act.
Thank you.
NR. SMITHi One thing that I overlooked, and I want
to do that now, 1 want the record to show, and also anyone here
that is from the county government# I want to extend EPA's# and i
I know DER's, greatful thanks for allowing us to use this
beautiful facility in this place at this time so that we can
reach out and touch tne public. We tnank you very raucn. : nope
you will extend that thanks to the people responsible for this.
Have 1 got now from you all the cards of tnose that
wish to make any kind of a statement? Is there anybody holding
a card that hasn't brought it up?
And those of you that did fill out the registration
cards, did you make sure and check whether or not you wanted to
c.«i». or to a. put on th. Mil in? lilt for tl-i. «.»<•? I! ym,
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neglected to do that, before you leave, reshuffle the cards and
make sure the record shows you did want to receive. Because the <
only signal we have as to what you're interested in is what you
check for us here.
Having said that, now it's time to open this meeting
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here up to the public for comments. That is exactly what I '
intend to do. And I would like to call first on |
Dr. Karl U. Smith with the Plorida Bipartisans from Lake Wales,
Florida.
Dr. Smith.
KARL U. SMITH: My name is Karl U. Smith. I'm an
ex-teacher from the University of Wisconsin. My qualifications
to speak here as a environmentalist scientist rests on the fact
that I started the tradition of experimental environmental
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science in Plorida some forty-five years ago and I have been i
interested in Florida environmental matters every since.
I don't want to come here sounding like I am trying
to put tne blankets on CF Mining's operation in tne area. But I
would like to first make a statement of a semi scientific nature
for the benefit of the people of Central Florida, particularly
Hardee County. That statement is that they haven't really been
informed through this impact statement that this fourteen
thousand acre mining operation is going to turn about a tentn of
their county into a desert, and that this desert is going to
ruin the lives of the families living in tne area, amounting to
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some forty some families apparently, that the economic impact of ;
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this is going to be on their shoulders, them, their children, !
their children's children's and their children's children's and
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their children's children's and from then on. Because what is j
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purposed here in this permitting process is to turn about a j
tenth of Hardee County into a waterless desert in which the
sponge area of the land is permanently destroyed, the surface
area and wildlife are eliminated and the beautiful and richly
endowed land on which the psychology of the people in this area !
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depend, and the whole party of Hardee County and Central Florida ;
is going to be destroyed in a process not unlike committing j
suicide. What we're talking about here is environmental suicide
of about a third or a tenth of Hardee County.
The people of Wauchula and Zolfo Springs, and the
people of the Peace River system generally, should note that
this permit, if granted, is like stabbing them in the back for
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all future time.
I am giving you that as a scientific statement of the
tpug impact of bench mining upon the water resources, ground and <
surface, upon the wildlife, upon the plant life of the area.
It is taken over a million years for this land to be
formed here. It's richly endowed with wildlife that will be
destroyed and it will never be .returned by the falsely described !
mitigation process that the EPA and the mining corporation
itself presents as an engineering fantasy of tne worst sort.
* i
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Let me say in conclusion of this statement that I, as |
a scientist, consider the impact statements o£ this mining
operation to be a series of falsehoods designed to mislead the
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public in Central Florida about the true impact of the mining.
!
Now, I, as I represent here Florida Bipartisans—
Florida Bipartisans is a civic organization of Central Florida,
both on and beyond the Ridge.
I am also representing here, in a carrier capacity,
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Ridge Audubon. Ridge Audubon, through its conservation I
chairman, Ken Morrison, has submitted a statement in opposition
to this mining operation.
I won't go over his statements since it in some way
duplicates the statements submitted for the benefit of |
Florida Bipartisans. !
Let me say in general that Florida Bipartisans and {
Ridge Audubon together represent broadly a good part of Central
Florida in environmental matters. Let me say also that both of
these organizations, by their statement, are adamantly opposed
to extending the area of this mining operation to include this
richly endowed wildlife area of northern Hardee County. |
Now, I don't want to repeat myself here. Since the
letter presented for Florida Bipartisans apparently also has
already been incorporated into the record. However, I want to
make two or three points at this public hearing that leaves no
question about the basis of our opposition both scientifically
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and technically.
First of all, this impact statement does not address
the fundamental legal questions presented by this mining
operation under the laws of the State of Florida. The
Constitution of the State of Florida states explicitly in
Article X, Section XI that government authorization of a private i
i
use of sovereign land# in this case Payne Creek and Horse Creek,
shall under—shall be permitted only under the condition that it
is not contrary to the public interest.
I think that's a safe rendering of the constitutional
article that X referred to.
Now, it is our opinion that Florida Bipartisans and
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Ridge Audubon represent a significant knowledgeable j
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cross-section of public interest in the authorization of the !
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private use of Payne Creek and Horse Creek, and we oppose that
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authorization under any circumstances and for any period into
the future.
we oppose it for several reasons. First of all, tne
Payne Creek and Horse Creek should be considered as integral
parts of the total Peace River system. Any private use of the
Peace River system to date, beyond the rape of that system by
the mining corporation already, will further endanger the fresh
drinking water resources of over a half a million people south
of the Polk County line.
Under no circumstances, in our opinion, should
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Payne Creek be submitted, or Horse Creek be submitted, or the
Peace River system be submitted to further effluent for mining
operations, particularly the diesel fuel effluent and the slim
pits, and from beneficiation plants that, under past experience,
have never been controlled by the regulatory agencies and county
commissions of this state.
Working along the same regulatory legal lines,
Florida's laws prohibit explicitly, or rules, regulatory rules,
any capturing or harassment or habitat destruction of the
following endangered animals in the area in the instance case.
This is particularly indigo snakes, gopher-type tortoises, wood
storks and cockade woodpeckers.
Zt is my belief, and it is our point of view, that
none of the regulatory agencies in the State of Plorida have
permitted in the past any permits to set aside the laws
governing capturing or harassment or habitat destruction of
these endangered animals.
Accordingly, we believe that any violations of these
rules and laws by executives or workers, CP Mining, in
harrassing or interferring with the lives of indigo snakes, wood
storks, cockade woodpeckers, or any other endangered animal in
this area under Plorida's legal protection, should be assigned
criminal charges in full and effectively, at least more
effectively than these laws have been applied in the past to
mining corporation operators.
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The other main point that I want to make before
closing here, beyond the points I just made and along the lines
of the Plorida Bipartisans letter, is that the whole permitting
process in this operation is foggy and is possibly illegal under
Florida's lav. Because the people of the Charlotte Harbor area,
Sanibel Island, port Myers, and so forth# whose drinking water
is being affected by the very heavy drainage and threatened
cause of depression of the water table in this area in relation
to the Peace River system—
My point, going back to my main point, is that until
the people in the Charlotte Harbor area and Port Myers and
Sanibel Island are fully appraised of the implications of this
mining operation on it in a public hearing, and timely notice of
that hearing, we will consider that, as Florida Bipartisans and
also Ridge Audubon, we will consider the hearing process
Incomplete and not fully related to the needs of the people
tfhose lives are going to be affected by this mining operation.
Thank you.
MR. SMITH: Thank you, Dr. Smith.
The next noticed speaker is Mrs. Faye Dobbs of the
i
loncerned Citizens League.
FAYE DOBBS* I am Faye Dobbs, representative of the
loncerned Citizens League of America, Incorporated.
We are— Our sole onus to property in
lardee County—
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MR. RATLIFP: Speak up, OA*Am.
MR. SMITH: Ma'am, would you tilt that mike down just
a little. Thank you.
PAYE DOBBSt And we are very much concerned with the
water table and the flow of the water that comes down
Payne Creek and Peace River. We canoe often in the river. And
many times the phosphate companies have already destroyed the
water in Payne—in Peace River north of Bowling Green. And if
it wasn't for Payne Creek# we wouldn't have any water to canoe !
I
down the river.
I
And I just want to say that we support Dr. Smith and j
would like for his statements to represent us.
Thank you.
MR. SMITHx As I said earlier, I only have those two
speakers on the record.
Is there anyone else at large that wishes to make any
kind of comment? !
I want the record to reflect that CF, you have an
opportunity, if you wish, to make a comment of equal time. j
Or any other citizen representing any other group? j
We will, if not— I think it's fair to say X am j
receiving no response.
I wish to thank all of you for your attendance and i
participation in this evening's hearing. The comments which we
heve received t-onight, ootft oral and written, will be carefully
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considered and evaluated as we make our determinations.
As previously mentioned, the record of this hearing !
I
|
will remain open through the close of business on August the 5th I
nineteen hundred and eighty-eight. This will allow anyone j
wishing to submit additional comments sufficient time to do just I
that.
i
Further submissions must be in writing to be included
in the official record and should be sent to the attention of
Maryann Gerber, Environmental Assessment Branch, EPA, Region IV,
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three, four, five Courtland Street Northeast, Atlanta, Georgia, j
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three, 0, three, six, five. j
i
A final EIS will be published after the close of the
public comment period. It will consist of a summary of the
draft EZS, the agency's tentative decision on this project,
responses to comments received on the draft EZS, the transcript
of the public hearing, and any other comments submitted between j
i
now and the close of the comment period, and any other relevant ¦
information or evaluations developed after publication of the
draft EZS. A copy of the draft EZS should be retained, if a
complete evaluation of the project is desired.
»
After consideration of all the comments and the
i
requirements and policies of the Clean Water Act and appropriate
regulations, the EPA administrator will make the final
determination regarding the permit issuance. Zf the
determinations are substantially unchanged, EPA will so notify
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all parsons asking statements tonight and all persons submitting
written comments.
And I add those that have checked that you want those
comments.
However# if the determinations are substantially
changed, EPA will issue a public notice indicating the revised
determinations.
The notice that we will issue will be o£ a similar
nature as the one received of this meeting I assume.
Is that correct?
i
MS. POTTER: Uh huh. (Affirmative response.)
NR. SMITHi Okay. Within thirty days of receipt of
the final determination or the date of the public notice, any
Interested party may request an evidentiary hearing on the
determination. Requests for such a hearing should be addressed
to the EPA regional clerk. The procedures for filing hearing j
requests are set out in Title Forty, Code of Federal !
Regulations. Part one, twenty-four, Subpart Please note
that any issues posed by an evidentiary hearing request must
have been previously raised by the requestor during the public
comment period or at the public hearing.
Also in accordance with Porty CPR one, twenty-six j
point sixty-one, no final permit will be issued un^il at least
thirty days after issuance of the final EIS.
Unless a request for an evidentiary hearing is j
1
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granted, our determination will be the final action of the
Environmental Protection Agency, in the event that auch a
request is granted, the issued permit will be stayed until final
agency action has been taken on the hearing request.
Thank each and every one of you for your attention at
this place.
This hearing is adjourned.
(Thereupon the proceedings were concluded.)
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CERTIFICATE OF REPORTER
STATE OP FLORIDA
COUNTY OF HIGHLANDS
I, PAMELA K. COLDING, Deputy Official Court Reporter,
hereby certify that I was authorized to and did report the
foregoing proceedings, and that the above and foregoing pages,
numbered 1 through 35 inclusive, represent a true and correct
transcription of my stenographic notes taken at that time.
DATED at Sebring, Highlands County, Plorida this 27th day
of July, 1988.
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PUBLIC PARTICIPATION
3.4 Responses
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3.4 RESPONSES TO TRANSCRIPT COMMENTS
See Section 3.3 for the original hearing transcript and complete comment
language.
Dr. Smith
T-l
"[The proposed mining will] turn about a tenth of Hardee County Into
a waterless desert In which the sponge area of the land 1s
permanently destroyed, the surface area and wildlife eliminated..."
The mining and reclamation plan is designed to assure that mining
will have no unacceptable land use or wildlife habitat impacts.
Reclamation will result In much less impact than other types of
development or uses would have created. The regulatory agency
Dermittina process 1s designed to assure that mining will not
adversely affect off-site areas. The proposed EPA NPDES permit and
the FDER permits are designed to ensure that surface water discharges
do not unacceptably impact the watercourses and water resources of
Hardee and surrounding counties. The surface water system required
for approval of surface water quality and quantity permits is
deslaned to assure acceptable water quality off site. The surface
water system provides for recirculation and recycling of the majority
of water stored 1n the system so that treated process water will
normally be discharged off site only during wet season rain events.
The orooosed NPDES Permit will require compliance with state water
aualltv standards 1n the receiving waters. Section 2.6.3 of the
Environmental Impact Statement provides a detailed description of
the wastewater discharge system and Its environmental protection
features.
Surface water runoff characteristics from lands reclaimed under
Florida Department of Natural Resources reclamation procedures 1s
exoected to be similar to premlning characteristics. Land contours
and elevations will be similar to premlning conditions. A
retirement for surface water permits 1s that postdevelopment surface
water flows be similar to predevelopment runoff characteristics.
T-2 'wildlife that will be destroyed and 1t will never be returned by
the ... mitigation process..."
snades are not expected to be extirpated from the site as long as
a/Haeont suitable habitats are maintained around the cleared areas.
Population levels will be lowered during the mining period, but since
onlv small areas of the property will be mined at any given time,
and mined tracts will be continuously restored, resident species are
exoected to persist on site. Population levels should rise after
the entire site 1s restored and habitat availability of resources
Increases.
3.4-1
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T-3 "Constitution of ... Florida states explicitly ... that government
authorization of a private use of sovereign land ... Payne Creek
and Horse Creek ... shall be permitted only [In] ... the public
Interest."
Article X, Section 11 of the Florida Constitution concerns title to
sovereignty lands and private uses of such lands. The section states
that "The title to lands under navigable waters, within the
boundaries of the state, which have not been alienated, including
beaches below mean high water lines, 1s held by the state, by virtue
of its sovereignty, in trust for all the people. Sale of such lands
may be authorized by law, but only when in the public interest."
"Private use of portions of such lands may be authorized by law,
but only when not contrary to the public Interest." Such private
uses may be authorized by administrative agencies such as FDER,
operating within statutory authority. Legislative policy for surface
water permitting is that water quality be protected by providing
"that no wastes be discharged into any waters of the state without
first being given the degree of treatment necessary to protect the
beneficial uses of such water." Section 403.021(2) F.S. Wastewater
discharge permits issued by technically qualified administrative
agencies such as FDER is the method selected by the Florida
Legislature to assure that discharges to public watercourses are "not
contrary to the public interest."
T-4 "Any private use of the Peace River system ... will further endanger
the fresh water drinking resources of ... people south of ... Polk
County"
The proposed EPA NPDES permit and the FDER permits are designed to
ensure that surface water discharges do not significantly Impact the
watercourses and water resources of Hardee and surrounding counties.
The surface water system required for approval of surface water
quality and quantity permits is designed to assure acceptable water
quality off site. The surface water system provides for
recirculation and recycling of the majority of water stored in the
system so that treated process water will normally be discharged off
site only during wet season rain events. The proposed NPDES Permit
will require compliance with state water quality standards 1n
the receiving waters. Section 2.6.3 of the Environmental Impact
Statement provides a detailed description of the wastewater discharge
system and Its environmental protection features.
Surface water runoff characteristics from lands reclaimed under
Florida Department of Natural Resources reclamation procedures 1s
expected to be similar to premlnlng characteristics. Land contours
and elevations will be similar to premlnlng conditions. A
requirement for surface water permits 1s that postdevelopment surface
water flows be similar to predevelopment runoff characteristics.
3.4-2
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T-5 "Florida's laws ... [or rules] prohibit explicitly any capturing or
harassment or habitat destruction of ... endangered animals..."
The Wildlife Code of the State of Florida, Chapter 39, Florida
Administrative Code, lists specific prohibitions applicable to all
wildlife, including regulations on hunting, molesting, capturing,
selling, transporting, and taking of nests or eggs. The Florida
Endangered and Threatened Species Act of 1977, Section 372.072,
Florida Statutes, provides recommendations for the management of
protected species, but lists no specific prohibitions regarding
endangered species. The Florid Panther Protection Act, Section
372.671, Florida Statutes, prohibits the killing of the Florida
panther, but does not set aside panther habitat in Florida.
None of the above-referenced State of Florida laws establish
regulations against habitat alteration, rather, these laws deal with
direct physical Impacts to protected species. CF will strive to
avoid harm to protected species encountered during mining of the
property. An agency-approved program will provide for reduction of
mining Impacts on the Indigo snake. The unavoidable, temporary
Impacts to wildlife habitat will be mitigated to the fullest extent
possible after mining of each area 1s completed. Current Florida
laws governing wildlife protection do not specifically require the
preservation of endangered species habitat. Since the long-term
plans for the property are complete restoration, mining will not
cause the permanent removal of wildlife habitat. Therefore, the
proposed mine/reclamation plan 1s consistent with Florida laws
prohibiting the capturing or harassment of endangered animals.
T-6 "drinking water 1s being affected by the very heavy drainage and
threatened cones of depression of the water table..."
A cone of depression results when pumping water from an aquifer.
The cone ceases to exist within a relatively short time after pumping
stops. Wells will be used only for process makeup water because the
majority of water 1s supplied by recycling of water 1n the system.
A consumptive use permit has been approved by the Southwest Florida
Water Management District (SWFWMD). A primary criterion of the
permit 1s that proposed withdrawal not Interfere with existing legal
uses of water and 1s consistent with the public Interest (see Section
373.223 FS). The effect of drawdown within the well on surrounding
water uses 1s evaluated 1n the permitting process.
T-7 "until the people In the Charlotte Harbor area and Fort Myers and
Sanlbel Island are fully appraised ... we will consider the hearing
process Incomplete..."
All required EPA hearings on the NPDES permit application of CF
Mining Corporation have been noticed as required by law. This
Included extensive mall out of Individual notices to known Interested
persons and those requesting notice. This Included both media and
3.4-3
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individual notices designed to insure that all interested parties
and persons were aware of the permitting process. EPA Region IV
maintains in its records the mailing lists used for required
hearings.
Fave Dobbs
T-8 "we are very much concerned with the water table and the flow of
water that comes down Payne Creek and the Peace River."
A cone of depression results when pumping water from an aquifer.
The cone ceases to exist within a relatively short time after pumping
stops. Wells will be used only for process makeup water because the
majority of water 1s supplied by recycling of water 1n the system.
A consumptive use permit has been approved by the Southwest Florida
Water Management District (SWFWMD). A primary criterion of the
permit 1s that proposed withdrawal not Interfere with existing legal
uses of water and 1s consistent with the public Interest (see Section
373.223 FS). The effect of drawdown within the well on surrounding
water uses 1s evaluated 1n the permitting process. •
The proposed EPA NPDES permit and the FDER permits are designed to
ensure that surface water discharges do not unacceptably impact the
watercourses and water resources of Hardee and surrounding counties.
The surface water system required for approval of surface water
quality and quantity permits 1s designed to assure acceptable water
quality off site. The surface water system provides for
recirculation and recycling of the majority of water stored in the
system so that treated process water will normally be discharged off
site only during wet season rain events. The proposed NPDES Permit
will require compliance with state water quality standards in the
receiving waters. Section 2.6.3 of the Environmental Impact
Statement provides a detailed description of the wastewater discharge
system and its environmental protection features.
3.4-4
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COORDINATION LIST
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4.0 COORDINATION T.TST
4.1 FINAL ENVIRONMENTAL IMPACT STATEMENT COORDINATION LIST
The following federal, state, and local agencies; public officials;
organizations; and interest groups have been requested to comment on this
impact statement.
4.1.1 FEDERAL AgEBCIES
o Bureau of Outdoor Recreation
o Bureau of Mines
o Coast Guard
o Corps of Engineers
o Council on Environmental Quality
o Department of Agriculture
o Department of Commerce
o Department of Education
o Department of the Interior
o Department of Transportation
o Department of Health and Human
Services
o Department of Housing and Urban
Development
o Department of Energy
o Federal Highway Administration
o Fish and Wildlife Service
o Food and Drug Administration
o Forest Service
o Geological Survey
o National Park Service
o Economic Development
Administration
o Public Health Service
4.1.2 MEMBERS OF CONGRESS
o Honorable Lawton Chiles
United States Senate
o Honorable D. Robert Graham
United States Senate
o Honorable Andy P. Ireland
U.S. House of Representatives
4.1.3 STATE
o Honorable Robert Martinez, o Environmental Regulation
Governor Commission
o Toby Holland, State Representative o Department of State
o Marlene Woodson, State Senator
o Coastal Coordinating Council
o Department of Natural Resources
4-1
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o Department of Agriculture and
Consumer Services
o Department of Community Affairs
o Geological Survey
o Game and Freshwater Fish Commis
o Department of Administration
o Department of Commerce
o Department of Health and
Rehabilitative Services
o Bureau of Intergovernmental
Relations
o Department of Environmental
Regulation
o Department of Transportation
4.1.4 LOCAL AND REGIONAL
o Hillsborough County Commission
o Polk County Commission
o Manatee County Commission
o DeSoto County Commission
o Hardee County Commission
o Hardee County Building and Zoning
Department
o Tampa Bay Regional Planning
Council
o Central Florida Regional
Planning Council
o Southwest Florida Water
Management District
4.1.5 INTEREST GROUPS
o The Fertilizer Institute
o Florida Phosphate Council
o Florida Audubon Society
o Florida Sierra Club
o Manasota 88
o Florida Defenders of the
Environment
o Izaak Walton League of
America
o Florida Wildlife Federation
4.2 PUBLIC PARTICIPATION AND SCOPING
On May 29, 1981, EPA published a Notice of Intent to prepare an EIS for the
proposed project which at that time included plans for a chemical fertilizer
plant. A scoping meeting for the project was held by EPA in Wauchula,
Florida, on July 13, 1981. It should be noted that among the issues discussed
at the scoping meeting were CF's initial plans for a chemical fertilizer plant
on the project site. Such plans for the chemical plant have now been
abandoned.
4-2
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As a result of these efforts to foster public participation, conments
regarding the project have been solicited and received by EPA during the
intervening period leading to the publication of this Final EIS.
4.3 CONSULTATION WITH THE U.S. DEPARTMENT OF INTERIOR
EPA has performed all consultation procedures in accordance with the
requirements of Section 7 of the endangered Species Act of 1973, as amended.
On February 19, 1982, EPA requested the Fish and Wildlife Service (FWS) to
provide a list of threatened and endangered species that may be present on
site. On February 25, 1982, FWS provided a list of species that could occur
in the area of CF's proposed new mine. On December 3, 1986, FWS was provided
a biological assessment of the proposed construction, operations, and
associated activities; the impacts of such actions on listed species and their
habitats; and the proposed efforts to be taken to eliminate, reduce, or
mitigate any adverse effects. On December 11, 1986, FWS commented that this
information -adequately addresses endangered species concerns." EPA
determined that the issuance of an NPDES permit for the proposed project may
affect certain listed species and on March 4, 1987, officially requested that
Section 7 consultation procedures with FWS be implemented. On March 26, 1987,
FWS responded to this request by providing a Biological Opinion regarding the
effects of the proposed project on threatened and endangered specie. (FWS,
1987).
FWS stated that, in their opinion, "the endangered and threatened species
occurring on the CF site are the wood stork and the eastern indigo snake...No
direct harm to wood storks is expected from the mining operations, but wood
storks will be temporarily displaced during mining. Extensive areas of
feeding habitat will be temporarily lost during mining and in the initial
stages of reclamation...Based on our review of the reclamation plan suitable
feeding habitat will be created and available for wood stork feeding.-
FWS did find, however, that a "long-term i-pact of the proposed project will
4 1-ki. •astern indigo snake habitat. This permanent loss
be a reduction in available eastern i ,
_-f.-ntial for complete recolonitation of the site
of habitat will reduce the potential w
, „ mna1eM. ^ acceptable relocation program for snakes could
by eastern indigo snako». • *
eliminate some of these problems..."
4-3
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Based on FVS's review of the project, their Biological Opinion stated that
"this project is not likely to jeopardize the continued existence of the
eastern indigo snake or wood stork." FWS did recommend, however, that EPA
require an acceptable relocation program for eastern indigo snakes. This
program is presented as a project mitigation measure in Section 2.11.5.2. FWS
also recommended that all relocation activities conducted as part of this
mitigation program be coordinated with the Florida Game and Fresh Water Fish
Commission and should follow an accepted and approved eastern indigo snake
relocation protocol.
4.4 CONSULTATION WITH THE STATE HISTORIC PRESERVATION OFFICER
EPA has conducted all the consultation requirements established by Section 106
of the National Historic Preservation Act of 1966. In 1976, the State
Historic Preservation Officer (SHPO) of the Florida Department of State,
Division of Historic Resources (DHR) (formerly, the Division of Archives,
History and Records Management) was provided a description of the proposed
project and a research report entitled "An Archaeological and Historical
Survey of the CF Mining Corporation Property in Northwestern Hardee County,
Florida." This report was submitted pursuant to the procedures for
consultation and comment promulgated by the Advisory Council on Historic
Preservation in 35 CFR 800. DHR (1986) determined that the'survey established
the location of all regionally significant sites. DHR recommended that
regionally significant sites be subjected to systematic testing by a
professional archaeologist prior to the onset of any mining activities in the
immediate vicinities of the sites if mining could not be avoided. CF Mining
should retain a professional archaeologist to perform salvage excavation on
the regionally significant sites with enough lead time that the field work and
results could be reviewed by SHPO and the conclusions accepted prior to mining
within the immediate vicinity of these sites.
4.5 COORDINATION WITH THE U.S. ARMY CORPS OF ENGINEERS
Some of the wetlands on the CF site fall under the regulatory jurisdiction of
the U.S. Army Corps of Engineers (COE) by Section 404, Federal Water Pollution
Control Act (FWPCA). For CF to accomplish the proposed action in those
wetland areas on site, a Section 404 permit would be required.
4-4
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In 1981, EPA, COE, and CF Mining executed a joint Memorandum of Understanding
which established EPA as the lead agency and COE as a cooperating agency in
the preparation of this EIS. COE was provided the opportunity for review and
comment on the Plan of Study and on all work performed by the third-party
consultant, including the Preliminary Draft EIS.
4.6 REFERENCES
U.S. Fish and Wildlife Service. 1987. Correspondence from David J. Wesley
to Patricia A. Brooks dated March 26, 1987.
Division of Historic Resources, Florida Department of State. 1986.
Correspondence from George Percy, Chief, Bureau of Historic
Preservation, to Richard Zwolak, dated October 23, 1986.
4-5
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LIST OF PREPARERS
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5.0 UST OF PREPARERS
This Final EIS for the proposed CF Mining Corporation, Hardee Complex II,
phosphate mining and beneficiation project was prepared for EPA by Hunter
Services, Incorporated [formerly Environmental Science and Engineering, Inc.
(ESE-Tanrpa and Gainesville, Florida) and Reynolds, Smith and Hills (RS&H-
Jacksonville and Tampa, Florida)] using the Third Party EIS preparation
method. The names and qualifications of the Hunter staff responsible for
the preparation of this EIS are presented in Table 5-1. An independent
evaluation of all information presented in this EIS was also performed by
the following EPA officials:
Heinz J. Mueller/Robert B. Howard
Name
Responsibility
Chief, Environmental Policy
Section
Cory Berish/Maryann Gerber/
A. Jean Tolman/Patricia A. Brooks
Steve Richardson/Andrea E. Zimmer
Louis Nagler
Doyle T. Brittain
Richard Boone
Gail 0. Mitchell
H. Richard Payne
Andrea E. Zimmer
John T. Marlar
William L. Kruczynski
Delbert B. Hicka
EIS Project Officer
NPDES Permit Coordinator
Air Quality/Noise
Air Quality/Noise
Geology and Ground Water
Geology and Ground Water
Radiation
Surface Water
Surface Water
Terrestrial Ecology
Aquatic Ecology
For information on the material presented in
Howard at (404) 347-3776 (FTS/257-3776).
this Final EIS, contact Robert B.
5-1
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Table 5-1. Names, Qualifications and Responsibilities of Persons who are
Primarily Responsible for Preparing the CF Mining Corporation
Final Environmental Impact Statement
Name
Responsibility
Qualifications
J. Ronald Ratliff
Project Manager
Bruce M. Parker
Assistant Project
Manager
Clay A. Adams
Project Coordinator
David A. Buff
Air, Meteorology
Michael J. Geden
Geology
M.S. Planning; Vice President,
Hunter Services, Inc. and
Reynolds, Smith and Hills,
Inc.; 16 years experience in
the direction and management
of interdisciplinary
environmental studies and
permit compliance programs.
J.D. Law; Director of Environ-
mental Planning, Hunter
Services, Inc., nine years
experience in environmental
regulation and admini-
stration, design and conduct
of environmental plans and
programs.
M.S. Ecology/Zoology;
Associate-Vice President,
Environmental Science and
Engineering, Inc.; 15 years
experience in biological
studies and management of
interdisciplinary projects,
including permit applications.
M.E. Environmental
Engineering, Environmental
Science and Engineering,
Inc.*; 15 years experience in
environmental studies,
including meteorology, air
quality, and impact studies.
B.S. Earth Science; Sice
Geologist, Environmental
Science and Engineering, Inc.;
five years experience in
geophysical investigation,
geologic structure and
process, geonorphology, and
field sampling
5-2
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Table 5-1. Names, Qualifications and Responsibilities of Persons who are
Primarily Responsible for Preparing the CF Mining Corporation
Final Environmental Impact Statement (Continued, Page 2 of 3)
Name
Responsibility
Qualifications
Robert G. Gregory
Ground Water
Gregory Gensheimer
Radiation
M.S. Geology; Project
Geologist, Environmental
Science and Engineering, Inc.;
eight years experience in
hydrology, geohydrology, and
impact studies.
Ph.D. Soil Science; Soil
Scientist, Environmental
Science and Engineering, Inc.;
six years experience in soil
contamination studies and risk
assessments.
Gary H. Tourtellotte Aquatic Ecology
Anthony N. Arcuri
Terrestrial Ecology
Warren Pandorf
Surface Water
Ecologist, Environmental
Science and Engineering, Inc.;
seven years experience in the
assessment of mining impacts
on aquatic communities.
M.S. Botany; Head, Department
of Ecological Services; eight
years experience in field
surveys, wetland and wildlife
impact statements, and
biological systems evaluations
for permit applications.
Department Head, Water
Resources Engineering;
Environmental Science and
Engineering, Inc.; seven years
experience in conducting
surface and ground water
baseline monitoring studies
for environmental studies.
5-3
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Table 5-1. Names, Qualifications and Responsibilities of Persons who are
Primarily Responsible for Preparing the CF Mining Corporation
Final Environmental Impact Statement (Continued, Page 3 of 3)
Name
Responsibility
Qualifications
Richard A. Zwolak
Socioeconomics
M.A. Geography; Head,
Environmental Planning
Department; Reynolds, Smith
and Hills, Inc.; eight years
experience in assessing
impacts on transportation,
housing, labor/employment,
recreation, and public
services and government
finances.
Annette Ball
Editor
BFA Communications; Manager,
Document Production, Reynolds,
Smith and Hills, Inc.; five
years experience in
coordination and editing
documentation for
environmental studies.
*Mr. Buff is currently employed at KBN Engineering and Applied Science, Inc.,
Gainesville, Florida.
5-4
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APPENDIX
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appendix a
DRAFT NPDES PERMIT FOR THE CF MINING CORPORATION, HARDEE COMPLEX II,
HARDEE COUNTY, FLORIDA, PROJECT
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
REGION IV
349 COURT LAND STREET
ATLANTA. GEORGIA 303CS
Permit No: FL0040177
A! 7TH0RIZ ATION TO DISCHARGE UNDER THE
NATIONAL POLLUTANT DISCHARGE ELIMINATION SYSTEM
In compliance with the provisions of the Clean Water Act, as amended
(33 u.S.C. 1251 et. seq; the "Act"),
C. F. Mining Corporation
Post Office Box 1549
Wauchula, Florida 33873
is authorized to discharge from a facility located at
Hardee Phosphate Complex II
Section 20, 29, and 30;
Township 33 South, Range 24 East
Hardee County, Florida
to receiving waters named
Outfall 001 - Shirttail Branch
Outfall 002 - Doe Branch
Outfall 003 - Payne Creek
in accordance with effluent Imitations, "onitoring ^irements and other
conditions set forth in Parts I, II, III, and IV toreof. The pemit
of this cover sheet, Part I II pag«> Part " s' J™. —
pages. Part IV _2_ pages, Table 1 _J_ psg«- and TaDle 2 _6_ pages.
This permit shall become effective on
This permit and the authorization to discharge shall expire at midnight
Date Signed
Bruce R. Barrett, Director
Water Management Division
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I'£»|e l-I
Ieriod beginning on the ertective (late ot this i>eniiit and lasting through the term
of this permit, the permittee is autliorized to discharge irom outtall(s) serial number(s) 001,
process generated and mine dewateriny discharges trim the minmj and beneticiation ot phospliate
rock.
Such discharges shall be limited and monitored by the permittee as specified below:
LFFLUENT CHARACTERISTIC
D1MCIIAHGI-; LIMITATIONS
MONITORING RBQUIRFMKNTS
kg/day (1hs/day)
Daily Avy Uaily Max
Other Units (b{article
activity including
radium 226, but excluding
radon and uranium
Combined radiun 22b
ami 228 (b)
Specific Conductance (c) —
Amnonia (unionized) (c)(d) —
Dissolved Oxygen (c)
12 ihj/1
30 my/1
2b mj/1
60 my/1
10 mj/1
15 jCi/1
S [/Ci/l
127b micrcmtios
cm
b.ll my/I (min.)
Measurement Saiiple
Frequency Type
(During Discharge)
Continuous Recorder
J/V»eek 24-Hr. C mosite
1/toeek 24-Hr. Cjujiosite
1/Week 24—lit. Ccugosite
1/Vieek 24-Hr. Cauposite
1/Month 24-Hr. Cumosite
1/Month 24-Hr. t.'uiposite
1/Week 24-Hr. (.'«iii[osite
i/Week Grab
1/Week Grab
(Continued on next (.aye)
-------
Part l.A. continued, Outfall 001:
Page 1-2
Permit No. FL0040177
EFHJUEWT CHARACTERISTIC
DISCHARGE LIMITATIONS
kg/day (lbs/day) Other Units (specify)
Uaily Avij iJoily Max teily Avq Daily Max
MONITORING REQUIREMENTS
Measurement Sample
Frequency Type
Ititi 1 e
conducted in accordance with the provisions ot Ctiapter 17-3.121(7) and acceptable biological field
investigation practices. The plan ot study shall also include a sampling program tor pertinent chemical
parameters, to include ammonia-nitrogen, specific conductance, alkalinity, and temperature at a minimum.
4. There shall be no discharge ot floating solids or visible foam in otlier than trace amounts.
5>. Samples taken in oon^>liance with the monitoring requirements specified above shall be taken at the
following location(s): nearest accessible point after final treatment but prior to actual discharge or
mixing with the receiving streams.
6. Any requirements specified in the attached state certification sujiersede any less stringent requirements
listed above. Other conditions of tlie certif ication requiring si il miss ion of data or documents, not
identified in Part I of this |>erniit, shall also be conditions ot this permit and subject to the rejiorting
scfiedule ot Part III A.
Notes:
a. Total phns[>horus shall I*? tor monitoring and rejxirting only, except as provided in Part Ill-It.
U".ontinued an next
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Page 1-3
Permit No. FL0040177
Part I.A., continued; Outfall 001;
Notes, continued
b. Monitoring for combined radium 226 and 228 is required only if the value
for gross alpha particle activity, including radium 226 but excluding
radon and uranium, is greater than 15 pCi/1.
c. Monitoring for specific conductance, unionized anvronia, and dissolved
oxygen shall be discontinued after fifteen (15) months of sampling,
unless the results of monitoring demonstrate that monitoring for some
or all of these parameters should be continued and EPA notifies the
permittee of such in writing. However/ after nine (9) months of sairpling,
the permittee may request that monitoring for scire or all of these
parameters be discontinued. If the monitoring results to that date
clearly demonstrate compliance, then monitoring for the corresponding
parameters(s) may be discontinued upon receipt of written approval fran
CPA.
d. The maximum concentration of unionized amnonia in the effluent shall not
exceed the value listed in Table 1 (attached) for the appropriate pH
and temperature.
The effluent limitation for unionized amnonia shall be calculated as
follows:
Grab samples for pH and tenperature shall be taken simultaneously with
the amnonia saitple. Unionized ammonia shall be calculated in accordance
with Table 2 (attached). The calculated concentration of unionized
amnonia in the effluent shall not exceed the value listed in Table 1
tor the appropriate pH and tenperature. The measured values for pH,
temperature, ana amnonia; the calculated unionized aimonia concentration
from Table 1; ana, the appropriate effluent limitation from Table 2
shall all be reported in the monthly discharge monitoring report (OMR).
e. Monitoring and reporting for total kjeldahl nitrogen and total sulfate
will be continued for a period of one year.
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Page 1-4
Hermit No. HAJ040177
PANT 1
a. »:i-iuiitavrr limitations and muniim-ini; rh.)Iiiri*iints
I. During the |>ericxl lieginnmj i I y Avg ] ia ij y Max
How, ~ 3/cJay (MUD)
¦|»ital r. jn-volatile,
rim--1 i lt«?rablsphonjs
(as I') (a)
l luoi itles
Cross alpha j*irticle
activity including
radium 226, but excluding
radon and uranium
Combined rati inn 22»>
ami 228 (b)
<<-i I ic Conductance (c)'
Aimioriia (unionized) (c)(d)
Dissolved Oxygen (<:)
(>ther Units (Sj^x:ily)
laily Avy Daily Max
12 mj/1
30 mj/1
2b n»j/l
foO mj/l
HI mj/l
lb iCi/i
MONITORING REQUIREMENTS
Measurement Sample
Frequency Type
(Durinj Uischatye)
Continuous Recorder
1/toeek
1/Week
1/Week
1/Week
1/Month
b |<"i/1 1/Month
127b micrxmhos 1/Week
on
1/Week
5.0 mj/l (miri.) M/Week
24-hr. C|josite
24-Ur. composite
24-llr. Composite
24-llr. Cantos ite
24-llr. t:aii|x)site
24-llr. cnnjosile
24-l»r. Cim|<«ite
Grab
Grab
(Continued ixi next page)
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page 1-5
Permit No. FL0040177
Bart I.A. continued, Outfall 002;
Total Kjeldahl Nitroyen(eT
Dotal Sulfate (e)
EFFLUENT CHARACTERISTIC
DISCHARGE LIMITATIONS
kg/day (lbs/day) Other llnits (Specity)
Daily Avy Daily Max Daily Avy Daily Max
MONITORING RBQUlhFMENTS
Measurement Sanple
Frequency Type
1/Week 24-Hr. C(iii))Qsite
1/Viteek 24-Hr. t'antjosite
2. The pli shall not be less than 6.0 standard units nor greater than 9.0 standard units and shall hi; Monitored
1/Vweek during discharge with a grab sample.
3. Hie llioloyical Integrity Standard, Chapter 17-3.121(7), Florida Artninistrative Code, shall not I>l> violated
by the facility's discharge ot wastewater. Within sixty (60) days after the effective date of tnu (
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Page 1-6
Permit No. FL0040177
Part I.A. continued, Outfall 002:
Notes, continued
b. Monitoring for combined radiun 226 and 228 is required only if the value
for gross alpha particle activity, including radium 226 but excluding
radon and uranium, is greater than 15 pCi/1.
c. Monitoring for specific conductance, unionized anmonia, and dissolved
oxygen shall be discontinued after fifteen (15) months of sampling,
unless the results of monitoring demonstrate that monitoring for sane
or all of these parameters should be continued and EPA notifies the
permittee of such in writing. However, after nine (9) months of sampling,
the permittee may request that monitoring for sane or all of these
parameters be discontinued. If the monitoring results to that date
clearly demonstrate ccmpliance, then monitoring for the corresponding
parameters(s) may be discontinued upon receipt of written approval frcm.
EPA.
d. The maximum concentration of unionized anmonia in the effluent shall not
exceed the value listed in Table 1 (attached) for the appropriate pH
and temperature.
The effluent limitation for unionized anmonia shall be calculated as
follows:
Grab samples for pH and temperature shall be taken simultaneously with
the anmonia sample. Unionized anmonia shall be calculated in accordance
with Table 2 (attached). The calculated concentration of unionized
ammonia in the effluent shall not exceed the value listed in Table 1
for the appropriate pH and temperature. The measured values for pH,
temperature, and anmonia; the calculated unionized anmonia concentration
frcrrv Table 1; and, the appropriate effluent limitation frcm Taole 2
shall all be reported in the monthly discharge monitoring report (D4R).
e. Monitoring and reporting for total kjeldahl nitrogen and total sulfate
will be continued for a period of one year.
A-8
-------
I'age 1-7
Hermit No. FL0040177
I'AKT I
A. fcttlilUNT L1MITA1ICJNS AM) WJNllUfclNl. KLUII1 KLMtNlS
I. During the |icri(xl lieyinninj on ttm otltictive date ot this |ss generated and wine dewatormj discharges troit the mining and heneticiation ot phosphate
rock.
Such discharges shall tie limit i*l a rut monitored liy tin; ijcnnittou as specitied below:
m-IAJtOT CHARACTERISTIC l>ISCIIAl«;i-: LIMITATIONS
kg/day (I tis/lia |iarticle
activity including
ludiuh 22t>, tut excluding
ttMfcjri and uraniim
('(Mhined tad it an 2tt>
ami 22H (h)
S|«>cilic Conductance (c)
Anmuriia (unionized) (c)(d)
Dissolved uxytjen (c)
Other Units (Sijecity)
Daily Avy Daily Max
MCM1TUR1NG RbQUIKEMfcMS
Measurement Sample
Frequency TyiH nij/l
Id n»|/l
l'j jrf'i/l 1/Month
1» |Ci/l l/Month
I27'_> inicKinlios 1/Week
tin
1/Keek
b.D mj/l (min.) 1/V»eek
24-1 Ir. ivmijosite
24-lir. » uino.'ii Lu
24-hr. Omjosite
24-Ur. ("Jim
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Page 1-8
Permit No. FL0040177
Part I.A. continued, Uuttall 0»3:
FKKLUfcNT CHARACTERISTIC
UlSCHAHtiE LIMITATIONS
kg/day (Ths/day) Other Units (Specify)
Laily Avg 13ai ly Max Daily Avq Daily Max
MONITORING RBUUIRFMWIS
Measurement Sample
Frequency Tyjie
Total Kjeldahl Nitrnjen(e)
Total Sulfate (e)
1/Vieek 24-llr. Ccmi
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Page 1-9
Permit no. FL0040177
Part I.A. continued, Outfall 003:
Notes, continued
b. Monitoring for combined radian 226 and 228 is required only if the value
for gross alpha particle activity, including radiun 226 but excluding
radon and uraniun, is greater than 15 pCi/1.
c. Monitoring for specific conductance, unionized amnonia, and dissolved
oxygen shall be discontinued after fifteen (15) months of sampling,
unless the results of monitoring demonstrate that monitoring for sane
or all of these parameters should be continued and .EPA notifies the
permittee of such in writing. However, after nine (9) months of sampling,
the permittee may request that monitoring for seme or all of these
parameters be discontinued. If the monitoring results to that date
clearly demonstrate compliance, then monitoring for the corresponding
parameters(s) may be discontinued upon receipt of written approval from
EPA.
d. The maximum concentration of unionized ammonia in the effluent shall not
exceed the value listed in Table 1 (attached) for the appropriate pH
and temperature.
The effluent limitation for unionized amnonia shall be calculated as
follows:
e. Monitoring and reporting for total kjeldahl nitrogen and total sulfate
will be continued for a period of one year.
A-ll
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Part l
Page 1-10
Permit No. FL0040177
DEFINITIONS
A. For Nine Discharges
(a) The term "mine dewatering" shall mean any water that is inpounded or that collects
in the mine and is pumped, drained, or otherwise removed from the mine through the
efforts of the mine operator. However, if a mine is also used for the treatment of
process generated wastewater, discharges of commingled water from the mine shall be
deemed discharges of process generated wastewater.
(b) The term "mine" shall mean an area of land, surface or underground, actively used
for or resulting from the extraction of a mineral from natural deposits.
(c) The term "process generated wastewater" shall mean any wastewater used in the
slurry transport of mined material, air emissions control, or processing exclusive
of mining. The term shall also include any other water which becomes comningled
with such wastewater in a pit, pond, lagoon, mine, or other facility used for
settling or treatment of such wastewater.
(d) The term "total non-filterable residue (total suspended solids)" shall mean those
solids which are retained by an approved filter and dried to a constant weight at
103° to 105° C as described at page 94 of the 14th edition of Standard Methods
for the Examination of Water and Wastewater.
(e) Hie term "non-filterable, non-volatile residue (fixed solids)" shall mean those
solids which represent the difference between the total non-filterable residue and
tlie total volatile residue deter Mined in accordance with the test methods specified
at page 95 of the 14th edition of Standard Methods for the Examination of Water and
Wastewater.
(f) Hie term "total phosphorus" shall mean the total phosphorus in ah unfiltered sample
measured in milligrams per liter using the manual or automated ascorbic acid method
following persultate digestion as referenced at pages 476, 481, and 624 of the 14th
edition of Standard Methods for the Examination of Water and Wastewater or measured
in accordance with a comparable analytical method approved by EPA and DER.
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Part I
Page 1-11
Permit No. FL0040177
B. SCHEDULE OF COMPLIANCE
i. The permittee shall achieve compliance with the effluent limitations
specified for discharges in accordance with the following schedule:
Operational Level Attained Effective Date of the Permit
2. No later than 14 calendar days following a date identified in the
above schedule of compliance, the permittee shall submit either a
report of progress or, in the case of specific actions being required
by identified dates, a written notice of compliance or
noncompliance. In the latter case, the notice shall include the
cause of noncompliance, any remedial actions taken, ano the
probability of meeting the next scheduled requirement.
P-13
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Part ZZ
Pag* II-l
PART ZZ
STANDARD CONDITIONS FOR NPDZS PERMITS
SECTION A. GENERAL CDKDITZOK5
1. Duty to Ooaply
The permittee aust comply with all conditions of this permit. Any permit
noncompliance eonstltutaa a violation of the Clean Water Act and is grounds
for enforcement action; for permit termination, revocation and reissuance, or
Modification} or for denial of a permit renewal application.
2. Penalties for Violations of Permit Conditions
Any person who violates a permit condition is subjeet to a civil penalty not
to exceed 110*000 per day of such violation. Any person vfao willfully or
negligently violatea permit conditions is subject to a fine of not less than
S2,500 nor more than $25#000 per day of violation, or by Imprisonment for not
more than 1 year, or both.
3. Duty to Mitioate
Ac permittee shall take all reasonable steps to minimise or prevent any
discharge in violation of this permit whleh has a reasonable likelihood of
adversely affecting human health or the environment.
4. Permit Modification
After notice and opportunity for • bearing, this permit may be modified,
terminated or revoked for cause (¦» described in 40 cm 122.62 et seq)
including, but not limited to, the following:
a. Violaticr. of any terms or conditions of this permit;
b. Obtaini:., this permit by misrepresentation or failure to dlaclose
fully all relevant facts;
c. A ehange In any conditions that requires either temporary
interruption or elimination of the permitted discharge; or
d. Information newly acquired by the Agency indicating the discharge
poses a tnreat to human health or welfare.
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Part ZZ
Page XI-2
Zf the permittee believes that any paat or planned activity would be cause for
modification or revocation and reissuance under 40 CTR 122.62, the permittee
Bust report such information to the Permit Issuing Authority. tbe submittal
of a new application may be required of the peraittee. The filing of a
request by the peraittee for a permit modification, revocation and reissuance,
or termination, or a notification of planned changes or anticipated
noncompliance, does not stay any permit condition.
5. Ibxic Pollutants
notwithstanding Paragraph A-4, above, if a toxic effluent standard or
prohibition (including any schedule of compliance specified in such effluent
standard or prohibition) is established under Section 307(a) of the Act for a
toxic pollutant whieh is present In the discharge and such standard or
prohibition is more stringent than any limitation for such pollutant in this
permit, this permit shall be modified or revoked and reissued to conform to
the toxic effluent standard or prohibition and the permittee so notified.
B»e permittee shall comply with effluent standards or prohibitions established
under Section 307(a) of the Clean water Act for toxic pollutants within the
time provided in the regulatlona that establish those standards or
prohibitions, even if the permit has not yet been modified to Incorporate the
requirement.
6. Civil and Criminal Liability
Accept as provided in permit conditions on "Bypassing" Seetion B, Paraqraph
B-3, nothing in this permit shall be construed to relieve the permittee from
civil or criminal penalties for noncompliance.
7. Oil and Hazardous Substance Liability
Nothing in this permit shall be construed to preclude the institution of any
legal action or relieve the permittee from any responsibilities, liabilities,
or penalties to which the permittee is or may be subject under Seetion 311 of
the Act.
8. State Laws
Nothing in this permit shall be construed to preclude the institution of any
legal action or relieve the permittee from any responsibilities# liabilities,
or penalties established pursuant to any applicable State law or regulation
under authority preserved by Seetion 510 of the Aet.
9. Property Rights
The is*uanc« this permit does not convey any property rights of any sort,
or any exclusive privileges, nor does it authorise any injury to private
property or any invasion of personal rights, nor any infringement of federal,
State or local laws or regulatlona.
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Part XI
Pag* zx-3
10. Onshore or Offshore Construction
nils perait docs net authorise or approve the construction of any onshore or
offshore physical atructurea or facilities or the undertaking of any work in
any waters of the Ohlted States.
11. Severability
the provisions of this perait sre severable, and if any provision of this
perait, or the application of any proviaion of this perait to any
circus*tance, is held invalid, the application of such provision to other
clreuaataneea, and the reaalnder of this perait, shall not be affected thereby.
12. Putv to Provide Inforaatlon
Th« paraittee shall furnish to the Perait Issuing Authority, within a
reasonable tiae, any lnforaation which the Perait Issuing Authority aay
request to deteraine whether cause exists for aodlfylng, revoking and
reissuing, or terainating this perait or to deteraine compliance with this
perait. n>e perait tee shall also furnish to the Perait Zssuing Authority upon
request, copies of records required to be kept by this perait.
SECT 10W B. OPERATION AKD MADTTgHANCE OP TOL1PTTON QDWTftQIS
1. Proper Operation and Maintenance
Tbe permittee shall at all tlaes properly operate and aa in tain all facilities
and systeas of treataent and control (and related appurtenanees) which are
Installed or used by the peraittee to achieve eoapliance with the conditions
of this perait. Proper operation and aalntananee also Includes adequate
laboratory controla and appropriate quality assurance procedures. this
provision requires the operation of baek-up or auxiliary facilities or siailar
systeas which are Installed by a peraittee only when the operation is
necessary to achieve eoapliance with the conditions of the perait.
2. Meed to Halt or Weduce not a Defense
It shsll not be a defense for a peraittee In an enforceaent action that it
would have been necessary to halt or reduce the peraltted activity in order to
aaintain eoapliance with the condition of this perait.
3. ^pass of Treataent Pscllltles
a. Definitions
(1) "Bypass" Mans the intentional diversion of waste atreaoa from
any portion of a treataent facility, which Is not s designed or
established operstlng aode for the facility.
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Part II
Page XI-4
(2) "Severe property damage" Beans substantial physical damage to
property« damage to the treatment facilities which causes then
to become inoperable, or substantial and permanent loss of
natural resources which can reasonably be expected to oceur in
the absence of a bypass. Severe property damage does not mean
economic loas caused by delays in production.
b. Bypass not exceeding limitations.
The permittee may allow any bypass to oceur which does not cause
effluent limitations to be exceeded, but only if it also is for
essential maintenance to assure efficient operation. These bypasses
are not subject to the provisions of Paragraphs c. and d. of this
section.
c. Natice
(1) Anticipated bypass. If the permittee knows in advance of the
need for a bypass, it shall submit prior notice, if possible at
least ten days before the date of the bypass) Including an
evaluation of the anticipated quality and effect of the bypass.
(2) Chanticipated bypass. The permittee shall submit notice of an
unanticipated bypaaa as required in Section D, Paragraph D-8
(24-hour notice).
d. Prohibition of bypass.
(1) Bypass is prohibited and the Permit Issuing Authority may take
enforcement action against a permittee for bypass, unless:
(a) Bypass was unavoidable to prevent loss of life, personal
injury, or severe property damage?
(b) There were no feasible alternatives to the bypass, such as
the use of auxiliary treatment facilities, retention of
untreated wastes, or maintenance during normal perioda of
•quipment downtime. This condition is not satisfied if
sdequste back-up equipment should have been Installed in
the exercise of reasonable engineering judgment to prevent
a bypass which occurred during normal periods of equlpaent
downtime or preventive maintenance! and
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Part II
Page I1-5
4. Ogsets
¦Upset" scans an exceptional incident In which there is unintentional and
temporary noncoapllance with technology baaed permit affluent limitations
because of factors beyond the reasonable control of tbe permittee. V>
upset does not include noncompliance to the extent caused by operational
error, improperly designed treatment facilities, inadequate treauent
facilities, lack of preventive maintenance, or careless or improper
operation. An upset constitutes an affirmative defense to an action
brought for non-ccapl lance with sueh technology based permit limitation if
the requirements of 40 CTR 122.41 (n) (3) are ait.
5. Removed Substances
nils perait does not authorise discharge of solids, sludge, filter baekwash,
or other pollutants removed in the course of treatment or control of
wastewaters to waters of the Chited States unless specifically Halted in Part
1.
SBCTSK C. MONITORING AMD RSCDRPS
1. Bepresentatlve Sampling
Saaples and aeasureaent* taken as required herein shall be representative of
the voluae and nature of the aonitored discharge. All saaples shall be taken
at tbe aonltoring points specified in this perait and, unless otherwise
specified, before the effluent joins or is diluted by any other wastestresa,
body of water, or substance. Monitoring points shall not be changed without
notification to and the approval of the Perait Issuing Authority.
2. Flow Measurements
Appropriate flow aeasureaent devices and aethods consistent with accepted
scientific practices shall be selected and used to insure the accuracy and
reliability of measurements of the volume of aonitored discharges. The
devices shall be installed, calibrated and maintained to insure that the
accuracy of the aeasureaents are consistent with the accepted capability of
that type of device. Devices selected shall be capable of aeasuring flows
with a maximum deviation of lass than ~ 10% froa the true discharge rates
throughout the range of expectsd discharge voluaes. Onoe-through condenser
cooling water flow which is aonitored by puap logs, or puap hour asters as
specified In Part Z of this perait sad based on the aanufacturer's puap curves
shall not be subject to this requirement. Guidance in selection,
installation, calibration and operation of acceptable flow aeasureaent devices
ean be obtained froa the following referencesi
1. *A Guide of Methods and Standards for the Measurement of Mater Plow",
U.S. Department ef Commerce, Ihtlonal Bureau of Standards, IBS
*P»eial PuMJeatlon 421, May 1975, 97 pp. (Available froa the U.S.
(fevernaent Printing Office, Washington, D.C. 20402. Order by SO
catalog (to. C13.10i421.)
2. "Hater Measursaent Manual', U.J. Qspartasnt of later lor, Bureau of
ftselaaatlon. Second Bdltlon, Revised Reprint, 1974, 327 pp.
(Available froa ths U.S. GDvernaent Printing Office, Washington,
D.C 20402. Order by estalog Mo. 127.19/2tW29/2, Stock Mo. S/H
24003-0027.)
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Part ZZ
Page II-6
(3) "flow Meaaureaent in Open Channels and Closed Conduits , D.S.
Department of Cbaoerce, national Bureau of Standards, .IBS Special
Publication 484, October 1977, 982 pp. (Available in paper copy or
¦icrofiehe from Itetional Technical Inforaation Service (WTIS),
Springfield, VX 22151. Order ty KTXS Ho. PB-273 53S/5S7.)
(4) "OTOES Compliance Flaw Measurement Manual", O.S. Bttvironaental
Protection feency, Office of Mater Biforceaent, Publication MCD-77,
Septeaber 1981, 135 pp. (Available froa the General Services
Mainistration (8BRC), Centralised Mailing Lists Services, Building
41, Denver Federal Center, Denver, 03 80225.)
3. Monitoring Procedures
Monitoring aust be conducted according to test procedures approved under 40
CPS Part 136, unless other test procedures have been specified in this permit.
4. Penalties for Tampering
tt>e Clean Mater Act provides that any person who falsifies, taapers with, or
knowingly rwders inaccurate, any monitoring device or method required to be
maintained under this perait shall# upon conviction, be punished nv * #<«• a£
5. Retention of Records
by the Perait Issuing Authority at any tiae.
6. Record Contents
Records of aonitoring information shall Include»
a. »e date, exact pUce, and tiae of stapling or i
b. the individual(s) vho perforaed the sailing or
c. the date(s) analyses were perforaed;
of Measurements;
measurements;
d. The Individual(s) who performed the analyses»
e. me analytical technique* or Methods used; and
f. ftte results of such analyaes.
A-2C
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Part XI
Pag* I1-7
'* Inspection and Pitrv
**>e permittee shall allow the Permit Issuing Authority, or an authority
representative, upon the presentation of credentials and othar docuBM»« >.
¦¦Y be required by law, to: —as
». fetter upon the permittee'® preaiaea where a regulated facility or
activity ia located or conducted, or vhere records must be kept und*r
the condition* of this perait;
b. Have access to and copy, at reasonable times, any records that aust
be kept under the conditions of this permit;
c. Inspect at reasonable tlae any facilities, equipment (including
monitoring and control equipment), practices, or operations regulated
or required under this perait; and
d. Saapl* or aonitor at reasonable times, for the purposes of assuring
perait eospllance or as otherwise authorised by the Clean tfcter Act
any substances or paraaeters at any location. '
1?CTPm T). KZPORTIWS KBDPMEH1S
** Q>enoa in Discharge
Permittee shall give notice to the Permit Issuing Aithorlty as soon as
y°*«lble of any planned physical alterations or additions to the permitted
'•eiiity. lbtice is required only when:
a.
. .4,14 tian to a permitted facility may meet one of
S.* • *•»"»» " ••—< «
lner.... th. of .uej.« n.lth.r to .fflwnt
irSuJien" iTti* oor «. not!tie."on
Section 0, Paragraph D-lO(a)*
** Anticipated Nonooaplltnce
If* Permittee shall «iwe advance notice to the Perait Issuing ftithorlty of any
Jl*»ned change in tte permitted facility or activity which asy result in
I^OBPlianca with permit requirements. Any maintenance of facilities, which
It"*•wmiut. r." ld»l. i»t.rwtlon of op.r.tlcn md d.Sr.d.tlon of
'*luent quality 6» scheduled during rion«-ritisrl later quality periods
^ t, . ^ W »• UKia>
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Part IX
Pag* II—8
3. Transfer ef Ownership or Control
A permit say be automatically transferred to another party if:
a. The permittee notifies the Permit Issuing Authority of the proposed
transfer at least 30 days in advance of the proposed transfer date;
b. The notice includes a written agreement between the existing and new
permittees containing a specific date for transfer of permit
responsibility* coverage, and liability between themi and
c. The Perait Issuing Authority does not notify the existing permittee
of his or her intent to modify or revoke and reissue the permit. If
this notice is not received, the transfer is effective on the date
specified in the agreement mentioned in paragraph b.
4. Monitoring Reports
See Part III of this permit.
5. Additional Manltorlng by the Permittee
If the permittee monitors any pollutant more frequently than required by this
permit, using test procedures approved under 40 CTR 136 or as specified in
this permit, the results of this monitoring shall be included in the
calculation and reporting of the data submitted in the Discharge Monitoring
Report (QUO• flbch increased frequency shall also be indicated.
6. Averaging of Measurements
Calculations for limitations which require averaging of measurements shall
utilise an arithmetic mean unless otherwise specified by the Permit Issuing
Jfcithority in the permit.
7. Cbmpi lance Schedules
Reports of compliance or noncompliance with, or any progress reports on,
Interim and final requirements contained in any compliance schedule of this
permit shall be submitted no later than 14 days following each schedule date.
Any reports of noncompliance shall include the cause of noncompliance, any
remedial aetions taken, and the probability of meeting the next scheduled
requirement.
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Part ZZ
Fig* ZZ-9
6. Twentv-fcur Hour Reporting
The peraittee shall orally report any noncospliance which may endanger health
or the envlrcnaent# within 24 hours from the tlae tha peraittee btooaii aware
of tha clreuaatancea. A written aubaission shall also ba provided within 5
days of tha tiac tha permittee beooaes aware of tha clrcuastances. me
writtan aubalaalon shall contain a daaeription of tha noncoapliance and its
causa, tha period of nonooapllanee# Including exact datas and tlaea; and if
tha noncoapl ianca baa not baan cor r act ad# tha anticipatad tlae it is expected
to continue# and staps takan or planned to reduce, eliminate, and prevent
reoccurrence of tha noncoaplianca. Die Perait Zaauing Authority aay verbally
waive the writtan report* on a caae-fcy-eaee basis, whan tha oral report ia
Bade.
The following violations shall ba included In tha 24 hour report whan they
aight endanger health or tha envirenaent:
a. An unanticipated bypaaa which azceeda any affluent liaitation in the
perait.
b. Any upsat which exceeds any affluent liaitation in the perait.
J. Other Noncompliance
The permittee shall report in narrative for*, all Instances of nonooaplianee
not previously reported under Section D, Paragraphs D-2, 0-4, D-7, and D-8 at
the tiae aonltoring reports are subaitted. »e reports shall contain the
information listed In Paragraph D-8.
10. Qiances in Diacharoea of lbxlc ftibstances
She perait tee shall notify the Perait Issuing Authority as soon as it knows or
has reason to believe:
a. Ihst any activity has occurred or will occur which would result in
the discbarge, on a routine or fraquent basis, of any toxic
substance(s) (listed st 40 CPU 122, Appendix D, ttble ZZ and ZZZ)
which is net Halted in the perait, if that discharge will exceed the
highest of the foliating •notification levels"t
(1) Cne hundred alcrograas per liter (100 ug/1)t
(2) two hundred alcrograas per liter (200 ug/1) for acrolein and
acrylonltriles five hundred aierograas per liter (500 ug/1) for
2,4-dinltrophenol and for 24ethyl-4,€«41nltrophenols and one
ailligraa per liter (1 ag/1) for antiaony* or
(3) Plve (S) tlaes the aaxlaua concentration value reported tor that
pollutant (s) In the perait Application.
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Part II
Page 11-10
b. That any activity baa occurred or will occur which would result in
any discharge, on a non-routine or Infrequent basis, of a toxic
pollutant (listed at 40 C7R 122, Appendix 0. Table II and XII) which
is not Halted in the perait, If that discharge will exceed the
highest of the following "notification levels":
(1) Five hundred aicrograas per liter (500 ug/1) *
(2) Che ailligraa per liter a ag/l) for antimony* or
(3) 2fcn (10) tiaes the aaxiaua concentration value reported for that
pollutant (s) in the perait application.
11. Duty to Kaapolv
If the peralttee wishes to continue an activity regulated by this perait after
the expiration date of this permit, the peralttee aust apply for and obtain a
new perait. the application should be subaltted at least 180 days before the
expiration date of this perait. Ac Perait Issuing Authority aay grant
peraisslon to cobalt an application less than 180 days in advance but not
later than the perait aspiration date.
Mbere EPA is the Perait Issuing Authority, the teras and conditions of this
perait are autoaatleally continued In accordance with 40 C7H 122.6, only where
the peralttee has anbaitted a tlaely and sufficient application for a renewal
perait and the Perait Issuing Authority is unable through no fault of the
peralttee to issue a new perait before the expiration date*
12. Slgiatorv Requirements
Ml applications* reports, or information submitted to the Perait Issuing
Jhithorlty shall be slgped and certified.
a. All perait applications ah all be signed as follows:
(1) For a corporationt by a responsible corporate officer. For
the purpose of this Section, a responsible corporate officer
aeana: (1) a president, secretary, treasurer or vice president
of the corporation in charge^ of a principal business function,
or any other person who performs slailar policy - or
decisionmaking functions for the corporation, or (2) the
aanager of one or aore aanufacturing production or operating
facilities employing aore than 250 persons or having gross
annual sales or expenditures exceeding 25 Billion (in second
quarter 1980 dollars), if authority to sign documents has been
assigned or delegated to the manager is accordance with
corporate procedures.
(2) Ibr a partnership or sole proprietorship: by a general partner
or the proprietor, respectively! or
(3) ibr s municipality, State, federal, or other public agency: by
•Ithtr • principal aMC^iTs officsr or ranking dieted official.
b. All reports required by the perait and other information requested by
the Permit Issuing Authority shall be signed by a person described
above or ty a duly authorised representative of that person. A
person is a duly authorised representative only if:
A-2f
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Part XI
Page 11-11
(1) Ibt authorisation Is made in writing by a person described above;
(2) The authorisation specifies either an individual or a position
having responsibility for the overall operation of the regulated
facility or activity, such as the position of plant manager,
operator of a well or a well field, superintendent, position of
equivalent responsibility, or an Individual or position having
overall responsibility for environmental Batters for the
oospeny. (A duly authorised representative may thus be either a
named individual or any individual occupying a named position.);
and
(3) the written authorisation is submitted to the Permit Issuing
Authority.
c. Certification. Any person signing a document under paragraphs (a) or
(b) of this section shall make the following certification!
"I certify under penalty of law that this document and all
attachments were prepared under the direction or supervision in
accordance with a system designed to assure that qualified
personnel properly gather and evaluate the information
submitted. Based on my inquiry of the person or persons who
manage the systsm, or those persons directly responsible for
gathering the information, the information submitted is, to the
best of my knowledge end belief, true, aeeurate, and complete.
Z am aware that there are significant penalties for submitting
false information, including the possibility of fine and
imprlsoiment for knowing violations.¦
13. Availability of Ksoorts
•*cept for data determined to be confidential under 40 CTR Part 2, all reports
Prepared in accordance with the terms of this permit shall be available for
Public inspection at the offices of the Permit Issuing Authority. As required
by the Jtet, permit spplleatlcns, permits and effluent data shall not be
°bnsldered confidential.
Penalties for Falsification of Reports
Clean Niter Jtet provides that any person who tncwingly makes any false
statement, representation, or certification in any record or other document
*Ubmltted or required to bs maintained under this permit, including monitoring
'•ports or reports of compliance or noncompliance shall, upon conviction, be
tanlshed by a fine of not more than 110,000 per violation, or by Imprisonment
'or not more than C months per violation, or by both.
&CT3PH E. DglMITlPie
Peril*. Issuing »ithorlty
Regional Administrator of SPA Region IV or his d«sign«tf unless at soot
time in ths future ths tuts rsctives authority to adainistsr the mob
Program and assumes jurisdiction over tbs permit) st which time, the Director
the State program receiving authorisation becomes the issuing suthorlty.
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Part XI
Page 11-12
2. Jtet
"Jtet" scans the Clean Hater Jtet (foraerly referred to aa the Federal Water
Pollution Control Jtet) Public Lav 92-500, as aaended by Public law 95-217 and
Public Uv 95-576, 33 O.S.C. 1251 et seg.
3. Mass/Psy Measureaents
a. The "average Monthly discharge" is defined as the total Bass of all
daily discbarges saapled and/or aeasured during a calendar aonth on
which daily discharges are saapled and aeasured, divided by the
nutter of dally discharges saapled and/or aeasured during such
aonth. Xt is therefore, an arithaetic Bean found by adding, the
weights of the pollutant found each day of the aonth and then
dividing this sua by the nuaber of days the teats were reported. The
liaitaticn is identified as "Daily Average" or "Monthly Average" in
Part Z of the perait and the average aonthly discharge value is
reported in the " Average" coluan under "Quantity" cn the Discharge
Monitoring Report (OMR).
b. The "average weekly discharge" is defined as the total asss of all
daily discharges saapled and/or aeasured during the calendar week on
which dally discharges are saapled and aeasured, divided by the
nuaber of dally discharges saapled and/or aeasured during such week.
Zt is, therefore, an arithaetic aean found by adding the weights of
pollutants found each day of the week and than dividing this sua by
the nuaber of days the tests were reported. Ibis limitation is
identified as "Weekly Average" in Part Z of the perait and the
average weekly discharge value is reported in the Maxiaua" colum
under "Quantity" on the MR.
c. Ike ^aaxlaua daily discharge" is the total aass (weight) of a
pollutant dlsdiarged during a calendar day. If only one Maple is
taken during any calendar day the weight of pollutant calculated froa
it is the "aaxiaua dally discharge". This limitation is identified
as "Daily Maxlaua", in Part Z of the perait and the highest such
value recorded during the reporting period is reported in the
Aaxiaua" colon under "Quantity" on the EMR.
d. the "average annual discharge" la defined aa the total aaas of all
daily discharges sailed and/or aeasured during the cal«dar year on
which daily dlschargea are saapled and aeasured, divided by the
nuaber of dally discharges saapled and/or aeasured during such year.
Zt is, therefore, an arithaetic aean found by adding the weights of
pollutants found eaeh day of the year and then dividing this sua by
the nuaber of days the tests were reported. ibis Hal tat ion is
defined as "Annual Average" in ?srt I ef tbz persift and tfc# averaae
annual discharge value is reported in the "Average" coluai under
"Qiantity" on the IXR. Tht okr for this report shall toe su&aitted in
January for the previous reporting calendar year.
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Part II
Page 11-13
Concentration Measurements
a. ttie "average aonthly concentration', other than for fecal oolifora
bacteria* i* **>• sua of the concentrations of all dally discharges
sampled and/or aeasured during a calendar aonth on which daily
dlsdiarges are saapled and aeaaured, divided by the nuaber of daily
discharges sampled and/or asasured during such aonth (arithaetic aean
of the dally concentration values), the dally concentration value is
equal to the concentration of a composite ssaple or In the caae of
crab aaapie* la tha arithaetic aean (weighted by flow value) of all
the saaples collected during that calendar day. The average aonthly
count for fecsl colifora baeteria la the fwa trie aean of the counts
for aaaples collected during a calendar aonth. «his limitation is
Identified as Monthly Average* or "Daily Average" under "Other
Uaits" in Part X of the peralt and the average aontbly concentration
value la reported under the "Average" ooluan under "Quality" on the
SMIL
»e "average weekly concentration", other than for feeal colifora
bacteria Is the eua of the ecncentratlona of all dally discharges
easel ed 'and/or ¦tasured during a calendar week cn which daily
dia^iarges are asapled and aeasured divided by the nuaber of daily
discharges sampled and/or aeasured during such week (arithaetic aean
of the daily concentration values). The dally concentration value is
•aual to the concentration of a composite sample or In the case of
crab ssanies la the arithaetic aean (weighted by flow value) of all
Lie aaaples collected during that calendar day. fhe average weekly
count for fecal colifora bacteria is the geoaetric aean of the counts
for sanies collected during a calendar week, ttis limitation is
identified as "Weekly Average" wder "Other Uaits" In fart 2 of the
**• average weekly concentration value is reported under
9he -ma*iwa dally concentration" la the concentration of a pollutant
diIe*;«. d«ino a calendar day. It la identified as "Bally Namlaua"
under "Other Limits' In * of th# P*riit *nd the highest such
£& mecM dttttm «• U ""°"d
¦Maxiaua" eoluan wder ffiality on the «R.
mnoil concentration", other than for fecal colifora
?« Che sua of the concentrations of all daily discharges
Italia '¦nd/oraeasured during a calendar year cn which daily
saapled end/or aa ftnd Hliar(d divided by the number of daily
sMded and/or aeasured during such year (arithaetic aean
Of «ncentration values), fhe daily concentration value Is
-uaT S Cancan tratien of a sample or in the case of
«ab s2dU? is the arithaetic aean (weighted by flow value) of all
S s^ srtl.tt«< ^' that calendar d*. fhe .vera,, yearly
S!nt"^e£ «ollfofi U the geoaetrlc aean of the counts
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Part ZZ
Page 11-14
for samples collected during a calendar year. This liaitation is identified
as "Jtanual Average" under "Other Limits' in Part Z of the permit and the
average annual concentration value ia reported under the •Average' coluan
under "Quality' on the EMR. The DKR for this report shall be submitted in
January for the previous reporting year.
5. Other Measurements
a. The effluent flow expressed as M3/day (MGD) is the 24 hour average
flow averaged monthly. Zt is the arithmetic mean of the total daily
flows recorded during the calendar month. Where monitoring
requirements for flow are specified in Part I of the permit the flow
rate values are reported in the "Average" col urn under "Quantity" on
the EMR.
b. An "instantaneous flow messurement" is a measure of flow taken at the
time of sampling* when both the sample and flow will be
representative of the total diacharge.
c. Where monitoring requirements for pB, dissolved oxygen or fecal
eollfora bacteria are specified In Part Z of the permit, the values
are generally reported In the "frailty or Concentration" colum on
the EMR.
6. TVpea of Samples
a. Cbmposite Sample: A "coapoaite sample" Is a combination of not less
than 8 influent or effluent portions, of at leaat 100 ml, collected
over the full time period specified In Part X.A. Bit composite
sample must be flow proportioned by either time interval between each
aliquot or by volume aa it relates to effluent flow at the time of
sampling or total flow since collection of the previous aliquot.
Allquots may be collected manually or automatically.
b. Crab Sample: A "gr«b sample" is a single Influent or effluent
portion which is not a composite sai^le. lh« sample(s) shall be
collected at the period(a) moat representative of the total discharge.
7. Calculation of Means
AiittKtie *.«it arithaatie »«•" of any aat of ».lu.. i, th.
•untloo of th. indi.ldu.l ..1»m dWld.d oy u,. of
individual values.
?*°**trlc **.¦" of ,ny Of viIum ia tk« Xth
root of tha ptoduet of th. indl.ldu.l nluM vh.r. a la aru.l to u.
"! l.r Lr LmJtrlf . , o< »• Individual
,,o-ttie —- «i»"
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Fart ZX
Pig* 11-15
C ifeiahted by Flow Valuet lighted by flow value Mans the sunation
of each concentration tiaes its respective flow divided by the
•siMBUtlon of the respective flows.
•• O^endar Pay
A ealamUr dav is defined as the period fro* midnight of on# day until
•idnigbt of tte ne*t day. "wwk, for purposes of this permit, any
consecutive 24-bour period that raaaonably represents the calendar day say be
*>«d for sa*pl ing.
'• la«ardoM« *»fa«tance
, . ^ —*n« any substance designated under 40 CTR Part 116
» huirdou. ^ ,„ttI Kt.
Pursuant to faction 311 of «>• L-L*
texic Pollutant
* toxic pollutant is any
Clean Mater Act.
pollutant listed as toxic
under Section 307(a)(1) of
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part :::
Page m-i
Permit Nc. FL0040177
PART III
OTHER REQUIREMENTS
A. Reporting of Monitoring Results
Monitorina results obtained each calendar month must be summarized for
that month and reported on a Discharge Monitoring Report Form (EPA Mo.
3320-1) postmarked no later than the 28th day of the month following the
completed calender month. (For example, data for January shall be
submitted by February 28.) Duplicate signed copies of these, and all
other reports required by Section D of Part II, Reporting Requirements,
shall be cUDir.itted to the Perr.it Issuing Authority at the following
addresses:
Environmental protection Agency
Region IV
Facilities performance -ranc..
Water Management Division
3^5 courtlanc Street, N.E.
Atlanta, Georgia 30365
T4j m„m.orina data show total phosphorus levels exceed 3 mg/1 montnly
for?£re San one 30-day period pec calenoar year, the
discharaer upon written notification by EPA or the Florida Department or
? = ^^eaulation (DER)/ shall prepare and file within 120 days
fCnleSTthe time is extendea by the requesting agency) a stucv consisting
of the following: (1> a chronology of at least one year's discharge
data. f?) an assessment of tne cause anc origin or the phosphorus
ta, U> an riischarae; (3) a description of the discharger's
constituent of operation anc ranagement practices cirectly relatec
Of Fhosphorus: (41 ar. evaluation of the environnerxai
to t... c-nt.ci . nhospnorus levels; anc Izj an identity of reascnacie
^;hi^Carrnce.£fte ' to the extent practicable, the influx of phosphorus
metnoas to aoatc, receipt of the report the requesting agency may
into the ciscnar . . pujtuish a public notice in a newspaper of
require cr.e fPP1* . ^ tj.e affected area which states that the report
general circulatio it is avaiiable for public inspection. The
was received and wn evaluate the report and may amend the
requesting agency^ ^ ^ cfp n2^2 or 122#63) to reflect
discharger's perm- ip . _ecc t0 administrative anc judicial review
additional reguir«ne of COst-effective management practices or
including the reduce or eliminate the phosphorus in tne
technolccical advances wru~' _raeticabie
discharge to the maximum extent practicaole.
Florica Dept. of Environmental Regulation
Southwest District
4520 Live Cak Fair Boulevard
Tampa, Florica 33610-7347
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Part III
Page II1-2
Permit No. FL0040177
C. National Environmental Policy Act (NEPA) Requirements
The site specific Environmental Impact Statement tor the CF Industries,
Inc. Hardee Phosphate Complex II lists specific mining and management
alternatives. The EPA selected preferred alternatives to minimize the
impact on the environment. As a condition for the NPDES permit
application, CF shall ccmply with the preferred alternatives listed in
the EIS and the EIS shall became a technical reference for the issued
NPDES permit.
The below listed requirements, conditions and limitations were recatmended
in the CF Industries, inc. Hardee Phosphate Complex II Environmental
Impact Statement, and are hereby incorporated into National Pollutant
Discharge Elimination System Permit No. FL0040177 in accordance with 40
CFR 122.44 (d)(9).
1. CF shall pile overburden such that the volume available for below-
ground waste disposal is maximized.
2. CF shall use "toe spoiling" to reduce the radioactivity of reclaimed
surface soils.
3. CF shall restrict mining along the preserved portion of Horse Creek
to only one side of the stream channel at a given time.
4. CF shall protect upstream wetland areas and use as a seed source
to recolonize the disturbed downstream unit after mining ot a stream
segment is complete and restoration begins.
5. CF shall use the best available scientific information to reestablish
the desired surficial zone in restoration areas and habitat-specific
topsoil and root mass to the extent feasible.
6. CF shall design a productive littoral zone in newly created laxe
systems to enhance habitat values and water quality.
7. CF shall implement a program prior to ccrrmencement of mining and
approved by both the Florida Game and Fresh Water Fish Commission
and the US Fish and Wildlife Service to reduce impact on the
eastern indigo snake, a threatened species which occurs on the
site. A copy of the approved program shall be sent to EPA.
8. CF shall control fugitive emissions by reducing premine land
clearing during the dry season and by utilization of approved
dust control techniques on internal access roadways.
9. CF shall develop and implement a program, acceptable to the SHPO,
to minimize loss of cultural/hi-t&i-ical artifacts and sites.
10. CF shall assure the quality of the surficial aquifer in the
vicinity of the sand-clay mix disposal areas and CF shall
monitor both the surface and ground water quality to assess
A-32
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Part ill
Page II1-3
Permit No. FL0040177
the impacts of mining and reclamation bv ,¦
pennit conditions of the Florida r^r»r^ c^npliance with specific
(FDNR) (reclamation plan approval) ^FLoridl nf Natural ^sources
mental Regulation (FDER) (groundwater nnfj Apartment of Environ-
Wo
these monitoring requirements shall be results of
annually. 1 06 Surarnari2e^ and sent to EPA
11. CF shall minimize the potential adverse /•
loss, radiation, drainage changes) and as!X™ *" habitat
use of restored areas through strict r_n..„i^ ^successful, viable
reclamation plan update/approval process^ The6 W1^ FDNR'S annual
to restore water bodies, Stlands^S^n^f** °f plan
and upland habitats to the extent feasible. drainage basins,
12. CF shall preserve all Category I wetland .
activities. CF must monitor the effectivenesstefnan mining
to minimize any adverse effects of adiar^t ff design controls
mine on only one side at a time, and assu«
buffers are established to protect the wetlaSt r sufficient
CF must produce and maintain documentation rW. dewatering.
satisfaction that equally functional wetlands^In 2tXng to EPA'S
onsite prior to EPVs conside„tion
13. CF shall restore all Category II wetlands.
14. CF shall prepare and submit annually to epa a
of compliance with NPDES pennit condition nimbeS? ^ status
1, 2, 3, 4, 5, 6, 8, 11,. 12 and 13.
-------
Figure 1.1.1-1
GENERAL LOCATION OF CENTRAL FLORIDA PHOSPHATE
OISTRICT AND THE CF INDUSTRIES EXISTING MINE
AND PLANNED MINE EXPANSION
U.S. Environmental Protection Agency, Region IV
Draft Environmental Impact Statement
CF INDUSTRIES
Hardee Phosphate Complex II
-------
f
GUM SWAMP
BRANCH
o ° Xi /V
r^V/ C* .»•
\
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REEK / C\> ^ O
t \
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qnW •
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-s '
j i>« •^D-.
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Vy^ ^ • CREEK
rv<
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^ CBEER
o^AV.Q t? - •<> 'vA o>
H 30
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M
2! M
O I
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-------
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(^X*'bay
^ ^-^PRANCH
W ; V:
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t> aar, fl
PLUNDER
|70> y •
troubIcso^e^
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\ BRANCH X*"! r J • n • \
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S >*¦> *—/rv r\
/troublesome cheek \
/ \
UT
•Hiw* rM»aowr»:
Hllll C«rf ~>mTI- MOICCICO
I I CAKOOWI ¦ - *Mt I MIlOMf WtUAMDS
¦ CAICOOftT ¦ - MMC «MTN NO MESIOIWtNM
lO WEIL AMOS
i-r-n is-HMnoaon«MOF
liil MAINSKM STRCAM
HTtHMHOGIC COMNECIICN
DMHtME MSM aoUNOMV
»i_r.r
' ™" l"f' ¦ 1
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-J
WfllANOS OClM€ATION MAP - EASTERN PORTION
> cm. mm *m» • mm. mt
U.S. Emifownwiiul Prottcno* Ayencv, Rtfon IV
Oi«ft liwitnnimiim Impact Sttle
-------
Page III-7
Permit No. FLQ040177
LOCATION MAP
Prom 0. 8. Geological Surray Map, 1935
Bard** County« Florida
CF INDUSTRIES
Hardee Phosphate Complex II
-------
E&rt iv
age iv-1
Permit No. FL0040177
PART IV
BEST MANAGEMENT PRACTICES CONDITIONS
SECTION A GENERAL CONDITIONS
1. BMP Plan
For ourooses of this part, the teems "pollutant" or "pollutants" refer to
anv substance listed as toxic under Section 307(a)(1) of the Clean water
oil as defined in Section 311(a)(1) of the Act, and any substance
listed as hazardous under Section 311 of the Act. The permittee shall
develop and implement a Best Management Etactices (BMP) plan which
nrevents or minimizes the potential for, the release of pollutants from
ancillary activities, including material storage areas; plant site runoff;
in-olant transfer, process and material handling areas; loading and
unloading operations, and sludge and waste disposal areas, to the waters
of the United States through plant site runoff; spillage or leaks; sludge
or waste disposal; or drainage from raw material storage.
2. Implementation
the dan shall be developed within six months after the effective date of
nermit ^ shall be implemented as soon as practicable but not later
fcu-f io»i*nrhs after the effective date of this permit condition unless a
"y M»etor.
3. General Reg"*cements
The BMP plan shall:
a Be documented in narrative form, and shall include any necessary plot
plans, drawings or maps.
b Establish specific objectives for the control of pollutants.
m Each facility component or system shall be examined for its
potential for causing a release of significant amounts of
nollutants to waters of the United States due to equipment
failure, inproper operation, natural phenomena such as rain or
snowfall/ etc.
... uh«re experience indicates a reasonable potential for-equipment
u' f,.Mnre (e.g.# a tank overflow or leakage), natural condition
(e a. precipitation), or other circumstances to result in
significant amounts of pollutants reaching surface waters, the
San should include a prediction of the direction, rate of flow,
and total quantity of pollutants which could be discharged from
the facility as a result of each condition or circumstance.
Af39
-------
arc iv
E&ge IV-2
Permit No. FL0040177
c. Establish specific best management practices to meet the objectives
identified under paragraph b of this section, addressing each
component or system capable of causing a release of significant
amounts of pollutants to the waters of the United States, and
identifying specific preventative or remedial measures to be
implemented.
d. Include any special conditions established in Section B of this part.
e. Be reviewed by plant engineering staff and the plant manager.
4. Documentation
The permittee shall maintain the BMP plan at the facility and shall make
the plan available to the permit issuing authority upon request.
5. BMP Plan Modification
The permittee shall amend the BMP plan whenever there is a change in the
facility or change in the operation of the facility which materially
increases the potential for the ancillary activities to result in a
discharge of significant amounts of pollutants.
6. Modification for Ineffectiveness
If the BMP plan proves to be ineffective in achieving the general
objective of preventing the release of significant amounts of pollutants
to surface waters and the specific objectives and requirements under
paragraphs b and c of Section 3, the permit shall be subject to
modification pursuant to 40 CFR 122.62 or 122.63 to incorporate revised
BMP requirements. Any such permit modification shall be subject to review
in accordance with the procedures for evidentiary hearings set forth in 40
CFR fert 124.
SECTION B. SPECIAL CONDITIONS
NONE.
-------
TABLE I
UNIOUIZIJi JUtUNIA (iny/1 NHjj
pll
0 C
6.50
0.0007
6.75
0.0012
7.00
0.0021
7.25
0.0037
7.50
0.0066
7.75
0.0109
8.00
0.0126
8.25
0.0126
8.50
0.0126
8.75
0.0126
9.00
0.0126
r
It
5 C
10 C
0.0009
0.0013
0.0017
0.0023
0.0029
0.0042
0.0052
0.0074
0.0093
0.0132
0.0153
0.02
0.0177
0.02
0.0177
0.02
0.0177
0.02
0.0177
0.02
0.0177
0.02
15 C
20 C
0.00L9
0.0026
0.0033
0.0047
0.0059
0.0083
0.0105
0.0148
0.0186
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
25 C
30 C
0.0026
0.0026
0.0047
0.0047
U.0083
0.0083
0.0148
0.0148
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
0.02
-------
Tabic 2
Percent Un-1oMr»a IHj 1n Aqueous Anwonie Solutions
For 0-30C end pH 6-10
pH 0.0 0.S
6.0 .00827 .00862
6.1 .0104 .0109
6.2 .0131 .0137
6.3 .0165 .0122
6.4 .0208 .0217
6.5 .0261 .0273
6.6 .0329 .0343
6.7 .0414 .0432
6.8 .0521 .0544
6.9 .0656 .0685
7.0 .0826 .0862
7.1 .104 .108
7.2 .131 .136
7.3 .165 .172
7.4 .207 .216
7.5 .261 .272
7.*6 .328 .342
7.7 .413 .430
7.8 .519 .541
7.9 .652 .680
8.0 .820 .855
8.1 1.03 1.07
8.2 1.29 1.35
8.3 1.62 1.69
8.4 2.03 2.12
8.5 2.55 2.65
8.6 3.19 3.32
8.7 3.SS 4.14
8.8 4.56 5.16
8.9 6.16 6.41
9.0 7.64 7.94
9.T 5.«3 9.79
9.2 *.!•« 12.0
9.3 U.: 14.7
9.4 17.: 17.8
9.5 20.7 21.4
«.5 :a.f 25.6
9.7 29.3 3C.2
9.8 34.; 35.2
9.9 39.6 40.7
.0.0 45.3 46.3
ToMperatui
1.0 1.5 2.0
.00899 .00937 .00977
.0113 .0118 .0123
.0143 .0149 .0155
.0179 .0187 .0195
.0226 .0235 .0245
.0284 .0296 .0309
.0358 .0373 .0389
.0451 .0470 .0490
.0567 .0591 .0616
.0714 .0744 .0776
.0898 .0937 .0977
.113 .118 .123
.142 .148 .155
.179 .187 .195
.225 .235 .245
.284 .296 .308
.357 .372 .388
.449 .468 .488
.564 .588 .613
.709 .739 .770
.891 .929 .968
1.12 1.17 1.22
1.41 1.46 1.53
1.76 1.84 1.91
2.21 2.30 2.40
2.77 2.88 3.00
3.46 3.60 3.75
4.31 4.49 4.67
5.37 5.59 S.81
6.67 6.93 7.20
8.25 8.57 e.90
;c.2 10.6 '.1.0
12.5 12.9 13.4
15.2 15.8 16.3
18.4 19.1 19.7
22.1 22.9 23.5
25.4 27.2 28.3
31.1 32.C 32.9
36.2 37.2 36.1
41.7 42.7 43.7
IT.3 48.4 49.4
. *C
2.5
3.0
3.5
.0102
.0106
.0111
.0128
.0134
.0139
.0161
.0168
.0175
.0203
.0212
.0221
.0256
.0267
.0278
.0322
.0336
.0350
.0405
.0422
.0440
.0510
.0532
.0554
.0642
.0669
.0697
.0808
.0843
.0878
.102
.106
.110
.128
.133
.139
.161
.168
.175
.203
.211
.220
.255
.266
.277
.321
.335
.349
.404
.421
.438
.508
.529
.551
.639
.665
.693
.803
.836
.871
1.01
1.05
1.09
1.27
1.32
1.37
1.59
1.65
1.72
1.99
2.07
2.16
2.49
2.60
2.70
3.12
3.25
3.38
3.90
4.C6
4.22
4.86
5.35
5.25
6.C4
6.28
6.52
7.49
7.78
8.08
9.24
9.60
9.96
11.4
11.8
12.2
13.9
14.4
14.9
16.9
17.5
18.1
20.4
21.1
21.7
24.4
25.1
25.9
28.9
29.7
30.6
33.8
34.7
35.7
39.1
40.1
41.1
44.7
45.8
46.8
50.5
51.5
52.5
4.0
' 5
5.0
.0115
.0120
.0125
.0145
.0151
.0157
.0183
.0190
.0198
.0230
.0239
.0249
.0289
.0301
.0314
.0384
.0379
.0395
.0459
.0478
.0497
.0577
.0801
.0626
.0727
.0757
.0788
.0915
.0953
.0992
.115
.120
.125
.145
.151
.157
.182
.190
.198
.229
.239
.249
.289
.301
.313
.363
.378
.394
.457
.476
.495
.574
.598
.623
.722
.752
.783
.907
.944
V3
1.14
1.19
1.23
1.43
1.49
1.S5
1.79
1.17
1.94
2.25
2.34
2.43
2.81
2.93
3.04
3.52
3.66
3.80
4.39
4.56
4.74
5.46
5.67
5.90
6.78
7.04
7.31
8.39
8.70
9.03
10.3
10.7
11.1
12.7
13.1
13.6
15.4
16.0
16.5
18.7
19.3
20.0
22.4
23.2
23.9
28.7
27.5
28.3
31.4
32.3
33.2
36.6
37.6
38.5
42.1
43.1
44.1
47.8
48.8
49.8
53.5
54.6
55.6
(continued)
-------
(Table 2. conrnuto)
«
Pcretnt lto-1on1ztd nm3 In Aqueous /SmenU Solutions
pH
Twocrtturc, *C
5,5 (.0 6.5 7.0 7.5 8.0 8.5 9.0 9.5 10.0
* o 0130 .0136 .0141 .0147 .01S3 .0159 .0166 .0172 .0179 .0186
\i 0164 .0171 .0178 .0185 .0192 .0200 .0208 .0217 .0225 .0235
M *0206 .0215 .0224 .0233 .0242 .0252 .0262 .0273 .0284 .0295
0260 .0270 .0282 .0293 .0305 .0317 .0330 .0344 .0357 .0372
H *0327 .0340 .0354 .0369 .0384 .0400 .0416 .0432 .0450 .0468
{5 '.0412 «M29 .0446 .0464 .0483 .0503 .0823 .0544 .0566 .0589
QS1S .9539 .0562 .0585 .0608 .0833 .0659 .0685 .0713 .0741
6-8 •5g 0679 .0707 .0736 .0766 .0797 .0829 .0862 .0897 .0933
H *0821 .0855 .0890 .0926 .0964 .100 J04 .109 .113 .117
5*2 *103 108 .112 ."7 .121 .126 .131 .137 .142 .148
7*0 J30 Il35 .141 .147 .153 .159 .165 .172 .179 .186
ISA .170 .177 .115 - .192 .200 .208 .216 .225 .234
H 'jM .214 .223 .232 .242 .252 .262 .272 .283 .294
.z]! i*J4
I'l »« 270 .281 .292 .304 .316 .329 .342 .356 .370
M *81 339 .353 .368 .383 .318 .414 .431 .4*8 .466
M *410 *27 .462 .481 .501 .521 .5*2 .563 .586
*339 .353 .368 .383 .398 .414 .431 .448 .466
;*27 1*44 .462 .481 .501 .521 .542 .563 .586
.« £37 .559 .582 .605 .629 .655 .681 .708 .736
7-* -111 *175 *702 .731 .760 . 791 .823 .856 .890 . 925
7'7 '!?! 148 I»3 .919 . 955 . 994 1.03 1.07 1.12 1,16
7'8 ,*2i5 i 07 1J1 1.15 1.20 1.2S 1.30 1.35 1.40 f.46
1:S i.m us ¦
1 tt 1.75 1.82 1.89 1.96 2.04 2.12 2.21 2.29
l.M 1%. ... • d* 9 M 9 UL 9 M 9 IT
7.5
- I* % Q7 l_ll I t 19 l|«V 1 U#« «•«*« »•"
7.9 j-g 1*39 MS 1.51 1.57 1.63 1.69 1.76 1.83
8-1 I'S 5*10 2J 9 2.28 2.37 2.46 2.56 2.66 2.76 2.87
5*8 53 l!74 2.85 2.96 3.38 3.20 3.32 3.45 3.58
8-3 5* 8 3 42 3.56 3.70 3.84 3.99 4.15 4.31 4.47
• J 1.17 3.Z9 ;*?. a »i 1 ?0 i n Ml «_tt S it
»•* MI 1*11 4.27 4^44 4.61 4.79 4.97 5.16 5.36 5.56
j#5 3.95
. <« i 32 5.53 5.74 5.96 6.18 6.42 6.66 6.91
4*93 ! 1*61 6.86 7.12 7.39 7.66 7.95 8.24 8.54
1*18 848 8.80 9.12 9.46 9.80 10.2 10.5
7>S9 I'S Ifll 10 5 10 8 11.2 11.6 12.0 12.5 12.9
M7 1?.*9 lill 12-« 13.3 13.7 14.2 14.7 15.2 15.7
« li 1 15.6 18.1 U.7 17*2 U'B 18-4 ,9-3
*'1 1*3 18 9 19.5 20.1 20.8 21.4 22.1 22.8
9.2 .7.1 1J-J l\'i 22 7 23.4 24.1 24.8 25.6 26.3 27.1
9 3 20.6 21.3 22.0 «•' |7 y 2| t 2M J0 2 3U0 „ f
!•• «• 2«.4 28.2 « u . «, ,, ,
2IJ ||;o 30*.9 31*7 32.6 33.5 34.4 35.3 36.2 37.1
9,5 2'* \ - fl 36 9 37.8 38.8 39.7 *0.7 41.6 42.6
9 6 34.1 35.1 i«.J jJ'J 4J.4 u.t 45.3 46.3 47.3 4J.3
•*; 3# 5 *0.5 2*1 4®! 1 s:.l 51.1 52.1 53.1 54.3
96 81 5*8 S5.8 56.8 57.8 58.7 59.7
s0-8 !}' «* 60-8 i1,A " 43,3 64 2
IC.fi 5i»s
UontmwM)
A-*3
-------
(T«b1« 2, continues)
Percent Un-ionizeo 'in^ in Aqueous Ammonia Solutions
Ttnptraturc, *C
pH 10.5 11.0
6.0 .0194 .0201
6.1 .0244 .0254
6.2 .0307 .0319
6.3 .0366 .0402
6.4 .0487 .0S06
6.5 .0612 .0637
6.6 .0771 .0801
6.7 .0970 .101
6.8 .122 .127
6.9 .154 .160
7.0 .193 .201
7.1 .243 .253
7.2 .306 .318
7.3 .385 .400
7.4 .484 .504
7.5 .609 .633
7.6 .766 .796
7.7 .962 1.00
7.8 1.21 1.26
7.9 1.52 1.58
8.0 1.90 1.97
8.1 2.38 2.47
8.2 2.98 3.09
8.3 3.72 3.86
8.4 4.64 4.82
8.5 5.77 5.99
8.6 7.16 7.42
8.7 8.85 9.17
8.8 10.9 11.3
8.9 13.3 13.8
9.0 16.2 16.S
9.1 19.6 23.2
9.2 23.5 2-.2
9.3 27.9 25.7
9.4 32.7 33.6
9.5 38.0 3F.5
3.6 43.5 44.5
i.* i?.3
S.£ £5.0
3.5 50.6 ei.:
3.5 £6.0 it.:
11.5
12.0
12.5
13.0
13.5
14.0
14.5
15.0
.0209
.0218
.0226
.0235
.0244
.0254
.0264
.0274
.0264
.0274
.0285
.0296
.0307
.0319
.0332
.0345
.0332
.0345
.0358
.0373
.0387
.0402
.0418
.0434
.0418
.0434
.0451
.0469
.0487
.0506
.0526
.0546
.0526
.0547
.0568
.0590
.0613
.0637
.0662
.0687
.0662
.0688
.0715
.0743
.0772
.0802
.0833
.0865
.0833
.0866
.0900
.0935
.0972
.101
.105
.109
.105
.109
.113
.118
.122
.127
.132
.137
.132
.137
.143
.148
.154
.160
.166
.172
.166
.173
.179
.186
.194
.201
.209
.217
.209
.217
.226
.235
.244
.253
.263
.273
.263
.273
.284
.295
.307
.319
.331
.344
.331
.344
.357
.371
.386
.401
.416
.432
.416
.433
.449
.467
.485
.504
.523
.543
.523
.544
.565
.587
.610
.633
.658
.683
.658
.684
.710
.738
.767
.796
.827
.859
.827
.859
.893
.927
.953
1.00
1.04
1.08
1.04
1.08
1.12
1.16
1.21
1.26
1.30
1.35
1.30
1.36
Ml
1.46
1.52
1.58
1.64
1.70
1.64
1.70
1.77
1.83
1.90
1.98
2.05
2.13
2.05
2.13
2.21
2.30
2.38
2.48
2.57
2.67
2.57
2.67
2.77
2.87
2.98
3.10
3.21
3.33
3.21
3.34
3.46
3.59
3.73
3.87
4.01
4.16
4.01
4.16
4.32
4.48
4.65
4.82
5.00
5.18
5.00
5.19
5.38
5.58
5.78
5.99
6.21
6.44
6.21
6.44
6.68
6.92
7.17
7.43
7.70
7.97
7.70
7.98
8.26
9.56
8.86
9.18
9.£0
9.83
9.50
9.84
10.2
12.5
10.9
11.3
11.7
12.1
11.7
12.1
12.5
12.9
13.4
13.8
14.3
U.7
14.3
14.7
15.2
15.7
16.3
16.8
17.3
17.9
17.3
17.9
18.5
19.3
19.6
2C.2
23.S
21.5
2C.9
21.5
22.2
22.8
23.5
24.2
24.3
25.6
24.9
25.7
26.4
27.1
27.9
28.7
29.5
30.3
29.5
30.3
31.1
31.9
32.6
33.6
34.J
35.3
34.5
35.-
36.2
37.1
38.0
18.9
39.S
43.8
39.5
-Z.i
41.7
42.6
43.6
44.5
45.5
<6.4
45.5
-6.-
4'.4
44.3
49.3
50.3
£1.2
52.2
51.2
s:.:
£3.1
54/
£5.0
£6.0
« :
• • ~ 7
57.8
£6.9
*? '
• * •
58.1
£5 *
6C.7
61.6
ti t
» • • •
63.3
52.5
c3»»
6i. 3
6£ j
66.0
66.8
67.:
65.5
ei.5
69.3
"C.2
71.0
71.7
"2.5
73.3
.ta)
-------
(Tabic 2, eont1nu«fi)
P»rc»nt On-Honix«tf !iHj in Aqueous kmonit Solutions
Tfnptrtturt, *C
pH 15.5 16.0 16*5 17,0 17,5 ,1,0 18,5 19,0 19*5 20,0
< a m*i 0295 .0306 .3318 .0330 .0343 .0356 .0369 .0383 .0397
S*? *£« 0372 I03M .0401 .0416 .0*31 .0448 . 0465 .0482 .0500
H *221? MM 0«6 .0504 .0523 .0543 .0564 .0585 .0607 .0629
H *0519 0611 .0635 .0659 .0684 .0709 .0736 .0763 .0792
H *°|?I •SfJl 0769 .0799 .0829 .0860 .0893 .0926 .0961 .0997
S:S :du :»» ¦«** •"« -,!1 -m
. . m 122 .127 .131 .136 .141 .147 .152 .158
H * H iii 53 .15» .172 .178 .185 .192 .199
H * M I 93 .200 .208 .216 .224 .232 .241 .250
S*! 'III 534 243 .252 .262 .272 .282 .292 .303 .315
7*.0 '.III *.Iw ^06 -317 *329 'M2 *358 ,3W *M1 '3U
t7fl 384 .399 . 414 . 430 .446 .463 .480 .498
M *?5I *22 *483 . 502 .521 .540 .561 .582 . 603 .626
• •"! '2 *$ 631 .655 .679 .70S .731 .758 .786
J'J -W S *?5 .793 .823 .814 .886 .919 .953 .988
m !i5i iS 1,03 1,07 1,11 1,18 1,20 UM
... ,5i 1.25 1.30 1.35 1.40 1.45 1.50 1.56
J*! !*!? 'If *51 1.17 1.63 1.19 1.75 1.82 1.88 1.95
I'7 M1 MS M 1.97 2.04 2.12 2.20 2.28 2.36 2.44
7.8 1.76 1.83 J.g ? 2.56 2.65 2.75 2.85 2.95 3.06
J.J |.g |.g |:J? 3l08 3.20 3.31 3.44 3.56 3.69 3.82
* . , r, 3 85 3.99 4.14 4.29 4.44 4.60 4.76
8.1 3.46 3.58 3.72 4H jjS 5.34 5.53 s.72 5.92
8.2 4.31 4.47 «•« !»5 j.18 6.40 6.63 6.86 7.10 7.34
8.3 5.37 5.56 5.76 2*J0 7 66 7.93 8.20 8.49 8.77 9.07
8.4 6.57 6.91 7.15 /.Jf ^ ]QJ 1Q>5 10<8 11<2
8.5 8.25 8.54 8.84 f."
a 112 11.6 12.0 12.4 12.8 13.2 13.7
8.6 10.2 10.5 I*: U2 '<.7 U.l IS-*
8.7 12.5 12.9 3.3 H 172 17.8 18.3 18.9 19.5 20.0
8.8 15.2 15.7 15*; {Jj 21.4 22.0 22.7 23.3 24.0
8.9 18.4 19.0 "-J g'f S3 25.5 26.2 27.0 27.7 28.4
9.0 22.1 22.8 23.5 »•••
« 6 29.4 30.1 30.9 31.7 32.5 33.3
9.1 26.4 27.1 27.f «.| g J 2 3| , 3fi>9 37#a 3S J
U 31.1 31.9 "-J ".5 3J § 41#5 A2i tJ3 ^
».3 36.2 37.1 38.0 44,5 47.2 48.1 49.0 49.9
».4 41.7 42.6 *3.5 51 , 52.0 52.9 53.9 54.8 55.7
'.5 47.3 4H.3 49,2 su,<
ll} <(( 57.7 58.6 59.5 60.4 61.3
4.6 «3.1 £i.C 55.C *23 63.2 6*»1 ®8,7 M,S
».» ill «:• «•« ¦{ ».2 »;•» ;«•' "•«
l.s H.2 !!.l JJ.J S'l 72.1 »).l H.) '».} JJ-
'2:5 Sic ;i:i '•
(CO»»»l«y*Cs
A—115
-------
(T*bl« 2, continued)
Percent Un-lonized NHj in Aqueous Annenl* Solutions
T«nptraturt, *C
PH
20.5
21.0
21.5
22.0
22.5
23.0
23.5
24.0
24.5
25.0
6.0
0412
.0427
.0443
.0459
.0476
.0493
.0511
.0530
.0549
.0569
6.1
0518
.0538
.0557
.0578
.0599
.0621
.0644
.0667
.0691
.0716
6.2
0653
.0677
.0702
.0727
.0754
.0782
.0810
.0839
.0870
.0901
6.3
0821
.0852
.0883
.0916
.0949
.0984
.102
.106
.109
.113
6.4
103
.107
.111
.115
.119
.124
.128
.133
.138
.143
6.5
130
.135
.140
.145
.150
.156
.162
.167
.173
.180
6.6
164
.170
.178
.183
.189
.198
.203
.211
.218
.226
6.7
206
.214
.222
.230
.238
.247
.256
.265
.275
.284
6.B
259
.269
.279
.289
.300
.310
.322
.333
.345
.358
6.9
326
.338
.351
.364
.377
.390
.405
.419
.434
.450
7.0
410
.425
.441
.457
.47*
.491
.509
.527
.546
.566
7.1
516
.535
.555
.575
.596
.617
.640
.663
.687
.711
7.2
649
.673
.697
.723
.749
.776
.804
.833
.863
.894
7.3
815
.845
.876
.908
.Ml
.975
1.01
1.05
1.38
1.12
7.4
1
02
1.06
1.10
1.14
1.18
1.22
1.27
1.31
1.36
1.41
7.5
1
29
1.33
1.38
1.43
1.48
1.54
1.59
1.65
1.71
1.77
7.6
1
61
1.67
1.73
1.80
1.86
1.93
2.00
2.07
2.14
2.22
7.7
2
02
2.10
2.17
2.75,
2.33
2.41
2.50
2.59
2.68
2.77
7.8
2
S3
2.63
2.72
-nst
2.92
3.02
3.13
3.24
3.35
3.47
7.9
3
17
3.28
3.40
3.52
3.64
3.77
3.90
4.04
4.18
4.33
8.0
3
96
4.10
4.24
4.39
4.55
4.70
4.87
5.03
5.21
5.38
8.1
4
93
5.10
5.28
5.47
5.66
5.85
6.05
6.26
6.47
6.69
8.2
6
13
6.34
6.56
6.79
7.02
7.25
7.50
7.75
8.01
8.27
8.3
7
60
7.86
8.12
8.39
8.68
8.96
9.26
9.56
9.88
10.2
8.4
9
38
9.69
10.0
10.3
10.7
11.0
11.4
11.7
12.1
12.5
8.5
11
5
11.9
12.3
12.7
13.1
13.5
13.9
14.4
14.8
15.3
8.6
14
1
14.5
15.0
15.5
15.9
16.4
16.9
17.4
17.9
18.5
8.7
17
1
17.6
18.2
18.7
19.3
19.8
20.4
21.0
21.6
22.2
8.8
20
6
21.2
21.8
22.5
23.1
23.7
24.4
25.1
25.7
26.4
8.9
24
7
25.3
26.0
26.7
27.4
28.2
28.9
29.6
30.4
31.1
9.0
29
2
29.9
30.7
31.5
32.3
33.0
33.8
34.6
35.5
36.3
9.1
34
2
35.0
35.8
36.6
37.5
38.3
39.2
40.0
40. S
<1.7
9.2
39
5
40.4
41.2
42.1
43.0
43.9
44.8
45.7
46.5
47.4
9.3
45
«
t
46.0
46.9
47.8
48.7
49.6
50.5
51.4
52.3
53.2
9.4
50
9
51.8
52.7
53.6
54.5
55.4
56.2
57.1
58.:
ss.s
9.5
56
6
57.5
58.3
59.2
60.1
60.9
61.8
62.6
63.5
64.3
9.6
62
1
63.0
63.8
64.6
65.5
66.3
67.1
(7.8
68.6
£9.4
9.7
67
•
68.2
68.9
69.7
7C.5
71.2
71.9
72.7
?3.i
:«.c
9.8
72
2
72.9
73.7
74.3
75.0
75.7
76.3
77.0
77.£
"8.2
9.9
7t
6
77.2
77.9
78.4
79.1
79.7
80.3
80.8
81.•
31.9
10.0
80
5
81.0
81.6
82.1
82.6
83.2
83.6
84.1
84.5
£5.1
i II"
A-46
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(T4bl« 2, contmu«a)
Prrcent lln-iomrea nh^ in Aqueous Armani* Solutions
Toapcrature, *C
PH 25.5 26.0 265 27*° 27,5 28*° 28,5 25,0 VA 3°*°
.... o6i0 .0632 .065* .0678 .0701 .0726 .0752 .0778 .0805
!*? *2|?I 0768 .0796 .0824 .0853 .0883 .091* .09*6 .0979 .01
M *88 0967 100 .104 .107 .111 .115 .119 . 23 . 28
6.2 .0933 .0967 m ^ # „ jjq
H 'III ' 53 .159 .164 .170 .176 .182 .189 .195 .202
6*5 *186 "!w •200 *207 *214 *221 *229 *
»12 .251 .260 .269 .279 .289 .299 .309 .320
H '\\i *305 ^316 .327 .339 .351 .363 .376 .389 .402
6,7 '1$ M4 .397 .411 .426 .441 .456 .472 .*89 . 506
fi,a ,3!1 'SI 500 .517 .536 .554 .57* .594 .615 .636
7'.l '.£86 itS Ml .651 .674 . 697 . 722 .747 . 772 . 799
790 .818 .846 .876 .907 .938 .970 1.00
7J *2! <& 992 1.03 1.06 1.10 1.14 1,18 1.22 1.26
7*2 • 926 .'In 1 25 U29 1.33 1.38 1.43 1.4# 1.53 1.58
7.3 1.16 .20 .» g M7 K73 K79 1.85 1.92 1.98
7*5 I'm IiS 2'®3 2,10 2*17 2,25 2,32 2,40
« 2 46 2.54 2.63 2.72 2.81 2.91 3.01 3.11
7.6 2.29 2.37 2.»# j. ^ y„ 3 „ 3B8
7.7 2.87 2.9J 3-OJ >' 4 JQ 4>24 4<38 4#H 4#68 4.g4
7'8 3'5! K1 4 78 4 9« 5.11 5.28 5.46 5.64 5.82 6.01
7.9 4.47 4.63 £ ]S 6 n 6>M 6.78 7<0fl 7#22 7.4i,
8.0 5.57 5.75 5«»
, 7 37 7.62 7.87 8.12 8.38 8.65 8.92 9.21
8-1 8*91 I'll 9 11 9 40 9.70 10.0 10.3 10.7 11.0 1.3
8.2 8.54 3.82 9.11 . 12<3 ,3>(J 13#4 ,33
8.3 10.5 0.9 J'2 \\'} u.6 15.0 15.* 15.9 16.4 16.8
e.4 -,2.9 13.3 3.7 n ia^2 1g#7 19>2 1fti 20.3
£.5 15.7 1«.* 16,7
,« 1 ?0 7 21.3 21.8 22.4 23.0 23.7 24.3
6.6 19.0 '9.6 20.1 §4*7 25.4 26.0 26.7 27.4 28.1 28.8
f.7 22.8 23.< 24.1 Z*.£ fl 3fl 7 3M 32>2 32.9 33.7
1.1 27.: 27.8 28.5 |J-| jjSj'J 35.g 3fi.# 37.4 38.2 39.0
8.9 31.9 32.? \l'j 39*6 40.4 *5.2 <2.1 42.9 *3.8 44.6
4 a 17 1 37.9
, 48 2 46.1 46.9 47.8 *8.6 49.5 M.4
9.1 >2.6 *3.5 {J'j 50*9 51.8 52.7 53.1 54.4 55.2 56.1
9.2 *8.3 49.2 50.1 50. ^ jj,] §9.2 60.0 60.8 61.6
9.3 !*.3 54.9 55.8 | « J3 fl H 8 54.5 55.4 6*,2 66.9
9.4 6C.5 fil.« |f;S 68.2 68.9 69.7 70.4 71.1 71.8
a t •£ *!.S \°A IS'! 3*.3 34.8 35.2 35.7 86.V £6.5
5.i «•> \l'< fJ:S 37:i S7.5 37.9 88.3 86.6 89.0
1* * :i £ it.? ^
*0. a. auimi—11 Printing Qffio® l»Ui S3J-37S/4M70
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